State of IIlil10is 

ENVIRONMENTAL PROTECTION AGENCY 

Mary A. Cade, Director P. O. Box 19506, Springfield,IL 62794-9506 

217/182-2113 

OPERATING PERMIT FOR HARD CHROME ELECTRO?LATING OPERATION 

NESHAP SOURCE 

PERMITTEE 

Economy Plating. Inc . 

Attn : Victor J . Koerner 

2350 No r th Elston 

Chicago , Illinois 60614 

Application No.: 73031926 I.D. No.: 03160QCVM 

Apnlicant ' s Designation : Date Rec ei.ved : Janua ry 29 , 1998 

Subjec t: Chrome Electroplating 

Date Issued : March 31 , 1998 

Location: 2350 North Elston, Chicago 

Expiration Date : March 31, 2003 

Pe~t is hereby granted to the above-designated PeDmittee to OPERATE 

emission unit(s) and/or air pollution control equipment consisting of 

c hrome plating tanks Ul and #4, each controlled by a single stage 

comp o site mesh pad (CI>lP) system with mist eliminator, and hard chrome 

p lating tanks U5 and #6, both controlled by a 4-stage CHP system as 

d escribed i n the above-referenced application . This Permit is subject 

standard condition s attached hereto and the following special 

condition (s) : 

hard 

lao Air pollution control equipment associated with a hard chrome 

electroplating tank(s) shall be operated at all times during the 

operation of the tank . 

to 

b . Hard chrome electroplating tank(s) controlled by a common add- on air 

pollution control device shall not e xceed the following limits: 

Eq uipment 

Existing Hard Chrome Electrop lating Tanks 

Ch r omium 

Emissions 

!mg/dscml 

0 . 03 

This limit is the National Emissions Standard for Hard Chromium 

Electroplating Tanks, 40 CFR Part 63 Subpart N and is based on the 

actual annual cumulative rectifier capacity of the hard chrome 

electroplating tanks being less than 60 million amp-hrs/yea r. An 

electroplating tank(s) installed before December 16, 1993, is 

considered as existing tank(s). compliance with the limit shall be 

determined from initial performance testing and ongoing compliance 

monitoring requirements . as required by conditions in this permit. 

c. Failure to ope r ate in accordance with operating parameter value, 

determined during initial performance testing shall be considered a 

violation of the above limit, pursuant to 40 CrR 63 Subpart N. 

d . The Permittee shall be in compliance wi th 40 CFR 63 Subpa rt N -

National Emission Standard for hard chrome tan :(s) on o r before 

January 25, 1997 . 

;' 

I 
Page 2 

2. The operation and maintenance practices required by 40 CFR 63.342(f) 

shall be implemented for control systems used on hard chrome plating 

tanks. 

The following operation and maintenance procedures for the composite 

mesh pad control systems; pursuant to 40 CFR 63.342(f) (3) (i) (B): 

a. A quarterly visual inspection of composite mesh pad (CMP) 

system to ensure there is proper drainage, no chromic acid 

buildup on the pads, and no evidence of chemical attack on the 

structural integrity of the devices. 

b. A quarterly visual inspection of the back portion of the mesh 

pad closest to the fan to ensure there is no breakthrough of 

chromic acid mist. 

c. A quarterly visual inspection of duct work from the tank(s) to 

the control device to ensure there are no leaks. 

d. Perform wash-down of the composite mesh-pads in accordance 

with manufacturer's recommendations. 

3a. The Permittee shall develop and implement an operation and 

maintenance (0 & M) plan for hard chrome plating tanks which shall 

include at least the following, pursuant to 40 CFR 6~.342(f) (3): 

i. Description of the operation and maintenance criteria for the 

control devices and monitoring equipment in use. 

ii. A checklist to document the operation and maintenance of the 

equipment. 

iii. Required operation and maintenance procedures, pursuant to 40 

CFR 63.342(f) (Condition 2). 

iv. Procedure to follow to ensure that equipment or process 

malfunctions due to poor maintenance or other preventable 

conditions do not occur. 

v. Procedure for identifying malfunctions and for implementing 

corrective actions. 

b. The Permittee may use any Standard Operating Procedure (SOP) 

manuals, Occupational Safety and Health Administration (OSHA) plans 

or other existing plans as part of the operation and maintenance 

plan, as long as they meet all the criteria of Condition 3(a). 

4. The Permittee shall maintain records required by 40 CFR 63.346(b) 

for all chrome electroplating tanks to demonstrate compliance, 

including the following: 

a. Records of monitoring data required by 40 CFR 63.343(c). 

i. Pressure drop across each CMP system, determined daily. 
\ , 

Page 3 

b. Inspection records for the control device and monitoring 

equipment, to document that the inspection and maintenance 

required by the work practice standards of 40 CFR 63.342(f) 

have taken place. The record can take the form of a checklist 

and should identify the device inspected, the date of 

inspection, a brief description of the working condition of 

the device during the inspection, and any actions taken to 

correct deficiencies found during the inspection. 

c. Records of all maintenance performed on the chrome plating 

tanks, as related to emissions, the associated control system 

and monitoring equipment. 

d. Records of the occurrence, duration, and cause (if known) of 

each malfunction of the chrome plating process, associated 

control system and monitoring equipment. 

e. Records of actions taken during periods of malfunction when 

such actions are inconsistent with the operation and 

maintenance plan. 

f. Records, which may take the form of checklists, necessary to 

demonstrate consistency with the operation and maintenance 

plan required by 40 CFR 63.342(f) (3). 

g. Copies of test reports documenting results of all performance 

tests and all measurements as may be necessary to determine 

the conditions of performance tests, including measurements 

necessary to determine compliance with the special compliance 

procedures of 40 CFR 63.344(e). 

h. Records of monitoring data required by 40 CFR 63.343(c) that 

are used to demonstrate compliance with the standard including 

the date and time the data is collected. 

i. The specific identification (i.e~, the date and time of 

commencement and completion) of each period of excess 

emissions, as indicated by monitoring data. Records of excess 

emissions that occurs during malfunction of the process, 

control, or monitoring equipment. 

j. The specific identification (i.e., the date and time of 

commencement and completion) of each period of excess 

emissions, as indicated by monitoring data. Records of excess 

emissions that occurs during periods other than malfunction of 

the subject chrome plating tanks and associated control 

devices. 

k. Records for the total process operating time of the affected 

chrome plating tank(s) during the reporting period. 

1. Copies of the notifications and reports required by 40 CFR 

Part 63.9, 63.10, and 63.347 with supporting documentation. 
Page 4 

m. Records demonstrating the maximum cumulative rectifier 

capacity, if hard chrome plating is less than 60 million 

amp-hrs per year, or of the actual cumulative rectifier 

capacity of hard chromium electroplating tank(s) at a facility 

expended during each month and the total capacity expended 

during each reporting period. 

n. All records shall be retained for a period of five years, 

pursuant to 40 eFR 63.10(b) (1). 

5. The Permittee shall comply with the compliance reporting 

requirements of 40 eFR 63.347 including the following: 

A notification of compliance status, signed by the responsible 

official who shall certify its accuracy" attesting to whether the 

affected source has complied with Subpart N, pursuant to 40 eFR 

63.347(e). The notification shall be submitted within 90 days of, 

the completion of the compliance demonstration required by 40 eFR 

63.343(b) and construction permit 97040058. The notification shall 

list the following: 

a. The applicable emission limitation and the methods that were 

used to determine compliance with this limitation. 

b. The performance test report documenting the results of the 

performance test, which contains the elements required by 40 

eFR 63.344(a), including measurements and calculations to 

support the special compliance provisions of 40 eFR 63.344(e) 

if these are being followed. 

c. If the Permittee had previously submitted emission estimates, 

the Permittee shall state that this report corrects or 

verifies the previous estimate. 

d. The specific operating parameter value, or range of values, 

that corresponds to compliance with the applicable emission 

limit. 

e. The methods that will be used to determine continuous 

compliance. 

f. A description of the air pollution control technique for each 

emission point. 

g. A statement that the owner or operator has completed and has 

on file the operation and maintenance plan as required by the 

work practice standards of 40 eFR 63.342(f). 

h. If the Permittee is determining facility size based on actual 

cumulative rectifier capacity in accordance with 40 eFR 

63.342(c) (2), records to support that the facility is small. 

i. A statement as to whether the source has complied with the 

provisions of 40 eFR 63, Subpart N. 

,J 
Page 5 

6a. The Per.mittee shall prepare an ongoing compliance status report 

every year and retain the report on site, and make the report 

available to the Illinois EPA upon request, pursuant to 40 CFR 

63.347(h). However, if both of the following conditions are met, 

semiannual reports shall be prepared and submitted to the Illinois 

EPA: 

i. The total duration of excess emissions (as indicated by the 

monitoring data) is 1 percent or greater of the total 

operating time for the reporting period; and 

ii. The total duration of malfunctions of the add-on air pollution 

control device and monitoring equipment is 5 percent or 

greater of the total operating time. 

b. The ongoing compliance report shall contain the following: 

i. The company name and address of the source perfor.ming hard 

chrome plating operations. 

ii. An identification of the operating parameter(s) that are 

monitored for compliance deter.mination. 

iii. The relevant emission limitation for the source, and the 

operating parameter value, or range of values, that correspond 

to compliance with this emission limitation as specified in 

the notification of compliance status. 

iv. The beginning and ending dates of the reporting period. 

v. A description of the type of process performed in the source. 

vi. The total operating time of the source during the reporting 

period. 

vii. The actual cumUlative rectifier capacity expended during the 

reporting period, on a month-by-month basis, if the Per.mittee 

limits the maximum cumulative rectifier capacity less than 60 

million amp-hr/yr. 

viii. A summary of operating parameter values, including the total 

duration of excess emissions during the reporting period as 

indicated by those values, the total duration of excess 

emissions expressed as a percent of the total source operating 

time during that reporting period, and a breakdown of the 

total duration of excess emissions during the reporting period 

into those that are due to process upsets, control equipment 

malfunctions, other known causes, and unknown causes. 

ix. A certification by a responsible official that the work 

practice standards are followed in accordance with the 

operation and maintenance plan for the source. 

x. If the operation and maintenance plan was not followed, an 

explanation of the reasons for not following the provisions, 

an assessment of whether any excess emission and/or parameter 
Page 6 

monitoring exceedances are believed to have occurred, and a 

copy of the report(s) documenting that the operation and 

maintenance plan was not followed. 

xi. A description of any changes in monitoring processes, or 

controls since the last reporting period. 

xii. The name, title, and signature of the responsible official who 

is certifying the accuracy of the report. 

xiii. The date of the ,report. 

c. The Permittee shall report the results for each monitoring device. 

However, when one monitoring device is used as a backup for the 

primary monitoring device, the Permittee shall only report the 

results from the monitoring device used to meet the monitoring 

requirements. If both devices are used to meet these requirements, 

then the owner or operator shall report the results from each 

monitoring device for the relevant compliance period. 

7. Two (2) copies of required reports and notifications concerning 

equipment operation or repairs, performance testing or a continuous 

monitoring system shall be sent to: 

Illinois EPA 

Bureau of Air 

Compliance section (#40) 

P.o. Box 19276 

Springfield, Illinois 62794-9276 

and one (1) copy shall be sent to the Illinois EPA's regional office 

at the following address unless otherwise indicated: 

Illinois EPA 

Division of Air Pollution Control 

Eisenhower Tower 

1701 South First Avenue 

Maywood, Illinois 60153 

It should be noted that this permit has been revised to no longer include 

operation of a natural gas-fired boiler, a polishing lathe, and a glass 

bead blasting operation controlled by a baghouse. Based on information 

submitted to the Illinois EPA at this time, operation of such equipment 

does not require a permit pursuant to 35 Ill. Adm. Code 201.146 (d), (aa), 

and (jj). 

If you have any questions on this, please call Jonathan Sperry at 

217/782-2113. 

, 

.~ 

Donald E. Sutton, P.E. 

Manager, Permit Section 

Division of Air Pollution Control 

DES: JS: jar.::J;l 

cc: Re~1 

copy 

Original Signed by E 

Oona'rt ltj ~nt.ton. P. . 
July 1, 1985 

STATE OF ILLINOIS 

ENVIRONMENTAL PROTECTION AGENCY 

DIVISION OF AIR POLLUTION CONTROL 

2200 CHURCHILL ROAD 

SPRINGFIELD. ILLINOIS 62706 

STANDARD CONDITIONS 

FOR 

OPERATING PERMITS 

The Illinois Environmental Protection Act (Illinois Revised Statutes, Chapter 111.1/2, Section 1039) grants the 

Environmental Protection Agency authority to impose conditions on permits which it issues. 

The following conditions are applicable unless superseded by special permit condition(s). 

1. The issuance of this permit does not release the permittee from compliance with state and federal regulations 

which are part of the Illinois State Implementation Plan, as well as with other applicable statutes and regulations 

of the United States or the State of Illinois or with applicable local laws, ordinances and regulations. 

2. The Agency has issued this permit based upon the information submitted by the permittee in the permit 

. application. Any misinformation, false statement or mispresentation in the application shall be grounds for 

revocation under 35111. Adm. Code 201.207. 

3. a. The permittee shall not authorize, cause, direct or allow any modification, as defined in 35 Ill. Adm. Code 

201.102, of equipment, operations or practices which are reflected in the permit application as submitted 

unless a new application or request for revision of the existing permit is filed with the Agency and unless a 

new permit or revision of the existing permit(s) is issued for such modification. 

b. This permit only covers emission sources and control equipment while physically present at the indicated 

plant location(s). Unless the permit specifically provides for equipment relocation, this permit is void for an 

item of equipment on the day it is removed from the permitted location(s) or if all equipment is removed, 

notwithstanding the expiration date specified on the permit. 

4. The permittee shall allow any duly authorized agent of the Agency, upon the presentation of credentials, at 

reasonable times: 

a. to enter the permittee's property where actual or potential effluent, emission or noise sources are located or 

where any activity is to be conducted pursuant to this permit, 

b. to have access to and to copy any records required to be kept under the terms and conditions of this permit, 

c. to inspect, including during any hours of operation of equipment constructed or operated under this permit, 

such equipment and any equipment required to be kept, used, operated, calibrated and maintained under this 

permit, . 

d. to obtain and remove samples of any discharge or emission of pollutants, and 

e. to enter and utilize any photographic, recording, testing, monitoring or other equipment for the purpose of 

preserving, testing, monitoring or recording any activity, discharge or emission authorized by this permit. 

5. The issuance of this permit: 

a. shall not be considered as in any manner affecting the title of the premises upon which the permitted 

facilities are located, 

b. does not release the permittee from any liability for damage to person or property caused by or resulting from 

the construction, maintenance, or operation of the facilities, 

lL ~3~·0224 Printed on Recycled Paper 

090-006 

APe 161 Fell. 11".-93 
C:ll culation Sheet 

Facility: Ecolllony Plating, Inc . yt Analysis Engineer: Jonathan Spe .., 

Review Engineer: 

Contact: Victor 1. Koemer (773-486·0960) 

Coullty: Cook, Region I (ozone 1I 01l-attainlllent area) 

imroduclioll 

Dale: 3/31 /98 

Dale: 

ID: 031600CVM 

P.N.: 73031926 

Date Received: 1129198 

Application to renew an operating pennit for chrome electroplating and to incorporate control equipment 

from construction penn it 97040058. 

Flags 

Toxic Flag: toxic screening not required (JMS) 

No other nags (Legal, FOS, or NSPS/NESHAP) 

Analysis 

The equipment at this facility includes 4 chrome electroplating tanks (#1, 4, 5, and 6). In a phone call on 

3/30/98, V. Koemer indicated that tank 112 has been completely shut down and tank #7 is being replaced 

(construction penuit 97040058). The chrome electroplaling tanks arc controlled by 3 composite mesh pad 

systems. From initial notificmion, dated 7(21 /95, all tanks have stanup dates prior to 12/ 16/93 (i.e., 

existing tanks). TIle facility has tested the three chrome electroplating systems. 

Based on maximum rectifier capacity, this is a large facility according to 40 CFR 63.341. However, the 

facility has submitted information from 1997 data to indicate that actual usage is less than 60 million amphr/yr. Therefore, this is considered a small facility as long as records continue to show this (40 CFR 

63.342(c)(2». The allowable emissions for each group of tanks with a common add-on air pollution 

control device is 0.03 mgldscm (13. 11.1006 grfdscf). Note that when the replacemcnt for tank #7 begins 

operation (with the appropriate notification and testing), the appropriate emissionlimitalion for tanks #5, 6, 

and 7 will be found using the procedure in 40 CFR 63.344(e)(4). 

operating hours = 24 · 6·52 = 7488 lIr/yr 

total gas now through con trols = 16,000 cflll 

total reclifier capacity (all 4 chrome plating tanks currently in usc) = 18,000 amps 

maximum potenti al rectifier capacity = 18,000 amps" 8400 hr!yr " 0.7 = 105.84 million amp-hr!yr 

actual rectifier usage = IS.8 million amp-hr/yr (based on 1997 data) 

The ca lcu lations below for chromium emissions lise the following cOllversion faclor: 

1 mg/dscm = 6.243· 10'! lb!dscf 

Tanks Tota l Amperage Flow Rate of Control 

efm 

#1 3000 3,000 

#4 3,000 3,000 

5 and 6 12.000 10,000 

Total s 18,000 16,000 

MACT Standard 

grldscm Ib/hr 

0.03 3.37E-04 

Actual Emissions 

grldscm IbIllf 

0.0103 1.16E-04 

0.03 3.37E-04 0.0137 1.S4E-04 

0.03 1.12E-03 0.0083 3.11 E-04 

1.80E-03 S.81E-04 

Other equipment at this facility includes shot blasting, polishing, and a boiler (2.9 mmBtu/hr). This 

equipment is now exempt from pennitting requirements 

similar to APC·268 Sheet I of ~ 

Revised 1/98 
Calculation Sheet - Economy Plating, Inc. 

ID 031600CVM 

App. No. 73031926 

Rules 

• 40 CFR 63, Subpart N: NESHAP for Chrome Electroplating; this is a small, existing facility, so Cr 

emissions are limited to 0.03 mgldscm (63.342(c)(I)(ii»; required to obtain a Title V permit 

(63.340(e», however, the USEPA has deferred for 5 years (up to December 1999) the requirement for 

a Title V permit for this non-major facility; this facility apparently requested a compliance extension, 

but it was received too late according to 63.343(a)(6) 

• Section 201.146: blasting, polishing, and a boiler are exempt from state permitting requirement 

Recommendation/Conclusion 

Grant NESHAP operating permit 

EIS coded (3/30/98) 

similar to APe-268 

Revised ) 198 

Sheet 2 of '2:-
Index to Submission Items 

1. APC Form 200 for exhaust blower # 1 

2. APC Form 200 for exhaust blower # 4 

3. APC Form 200 for exhaust blower # 5 & 6 

4. APC Form 260 for exhaust blower # 1 

5. APC Form 260 for exhaust blower # 4 

6. APC Form 260 for exhaust blower # 5 & 6 

7. APC Form 205 for plating tank # 1 

8. APC Form 205 for plating tank # 4 

9. APC Form 205 for plating tank # 5 

10. APC Form 205 for plating tank # 6 

11. APc Form 205 for polishing lathe 

12. APC Form 205 for boiler 

13. APC Form 205 for sandblaster 

14. APC Form 205 for sandblaster bag house. 

15. APC Form 210 

16. Final Report of Emission Test. 

17. Test Protocol. (prot-I) 

18. Raw test data for 3 tests of# 1 exhaust (test-I) 

19. Traverse pressure and angle calculations for # 1 system. (trav-I) 

20. Raw test data for 3 tests of # 4 exhaust. (test -4) 

21. Traverse pressure and angle calculations for # 4 system. (trav-4) 

22. Raw test data for 3 tests of# 5 & 6 exhaust. (test-5 & 6) 

23. Traverse pressure and angle calculations for # 5 & 6 system. (trav-5) 

24. Lab results from exhaust test for # 1. (Lab- 1) 

25. Lab results from exhaust test for # 4. (Lab-4) 

26. Lab results from exhaust test for # 5 & 6. (Lab-5 & 6) 

27. Copy of Calibration of gas meter and critical orifice use in tests. (Cert-l) 

28. Diagram of test ports for # 1. (port-I) 

29. Diagram of test ports for # 4. (Port-4) 

30. Diagram oftest ports for # 5 & 6. (Port-5 & 6) 

31. Specifications for Composite Mesh Pad system on # 5 & 6. (Spec 5 & 6) 

32. Specifications for Composite Mesh Pad system with mist eliminator for # 1. (Spec-I) 

33. Specifications for Composite Mesh Pad system with mist eliminator for # 4. (Spec-4) 

34. Process diagram. (Process) 

35. Plot Diagram. (plot) 

36. 12 Month rolling amp hour report. (Roll-I)