217/782-2113

TITLE V - CLEAN AIR ACT PERMIT PROGRAM (CAAPP) PERMIT

and

TITLE I PERMIT1

PERMITTEE

En-Chro Plating, Ltd.

Attn: Joe Villareal

2755 West Lake Street

Melrose Park, Illinois 60160

Application No.: 95120121 I.D. No.: 031186AGQ

Applicant’s Designation: Date Received: December 7, 1995

Operation of: Chromium Electroplating Tanks

Date Issued: June 6, 2000 Expiration Date2: June 6, 2005

Source Location: 2755 West Lake Street, Melrose Park, Cook County

Responsible Official: Milan Pecharich, President

This permit is hereby granted to the above-designated Permittee to operate a

hard chromium electroplating source, pursuant to the above referenced permit

application. This permit is subject to the conditions contained herein.

If you have any questions concerning this permit, please contact Jonathan

Sperry at 217/782-2113.

Donald E. Sutton, P.E.

Manager, Permit Section

Division of Air Pollution Control

DES:JS:psj

cc: Illinois EPA, FOS, Region 1

USEPA

1

This permit may contain terms and conditions which address the applicability, and

compliance if determined applicable, of Title I of the CAA and regulations

promulgated thereunder, including 40 CFR 52.21 – federal PSD and 35 IAC Part 203 –

Major Stationary Sources Construction and Modification. Any such terms and

conditions are identified within this permit.

2

Except as provided in Condition 8.7 of this permit.
2

TABLE OF CONTENTS

PAGE

1.0 SOURCE IDENTIFICATION 4

1.1 Source

1.2 Owner/Parent Company

1.3 Operator

1.4 General Source Description

2.0 LIST OF ABBREVIATIONS/ACRONYMS USED IN THIS PERMIT 5

3.0 INSIGNIFICANT ACTIVITIES 7

3.1 Identification of Insignificant Activities

3.2 Compliance with Applicable Requirements

3.3 Addition of Insignificant Activities

4.0 SIGNIFICANT EMISSION UNITS AT THIS SOURCE 9

5.0 OVERALL SOURCE CONDITIONS 10

5.1 Source Description

5.2 Applicable Regulations

5.3 Non-Applicability of Regulations of Concern

5.4 Source-Wide Operational and Production Limits and Work

Practices

5.5 Source-Wide Emission Limitations

5.6 General Recordkeeping Requirements

5.7 General Reporting Requirements

5.8 General Operational Flexibility/Anticipated Operating

Scenarios

5.9 General Compliance Procedures

6.0 EMISSIONS REDUCTION MARKET SYSTEM (ERMS) 16

6.1 Description of ERMS

6.2 Applicability

6.3 Recordkeeping and Reporting

6.4 Federal Enforceability

7.0 UNIT SPECIFIC CONDITIONS 18

7.1 Unit – Hard Chromium Electroplating Tanks

Control – Composite Mesh Pad Systems
3

PAGE

8.0 GENERAL PERMIT CONDITIONS 31

8.1 Permit Shield

8.2 Applicability of Title IV Requirements

8.3 Emissions Trading Programs

8.4 Operational Flexibility/Anticipated Operating Scenarios

8.5 Testing Procedures

8.6 Reporting Requirements

8.7 Obligation to Comply with Title I Requirements

9.0 STANDARD PERMIT CONDITIONS 36

9.1 Effect of Permit

9.2 General Obligations of Permittee

9.3 Obligation to Allow Illinois EPA Surveillance

9.4 Obligation to Comply with Other Requirements

9.5 Liability

9.6 Recordkeeping

9.7 Annual Emissions Report

9.8 Requirements for Compliance Certification

9.9 Certification

9.10 Defense to Enforcement Actions

9.11 Permanent Shutdown

9.12 Reopening And Reissuing Permit For Cause

9.13 Severability Clause

9.14 Permit Expiration and Renewal

10.0 ATTACHMENTS

10.1 Attachment 1 - Particulate Matter Emissions from Process

Emission Units

1-1

10.2 Attachment 2 - Example Certification by a Responsible

Official

2-1
4

1.0 SOURCE IDENTIFICATION

1.1 Source

En-Chro Plating, Ltd.

2755 West Lake Street

Melrose Park, Illinois 60160

708/450-1250

I.D. No.: 031186AGQ

Standard Industrial Classification: 3471, Plating and Polishing

1.2 Owner/Parent Company

Milan M. Pecharich

18-236 71st Street

Westmont, Illinois 60559

1.3 Operator

En-Chro Plating, Ltd.

2755 West Lake Street

Melrose Park, Illinois 60160

Joe Villareal

708/450-1250

1.4 General Source Description

En-Chro Plating, Ltd., is located at 2755 West Lake Street in

Melrose Park, Illinois. The source performs hard chrome plating

of hydraulic shafting-rolls-cylinders, steel components, and

assemblies, molds and dies. In addition, the source polishes items

and performs electroless nickel plating as required.
5

2.0 LIST OF ABBREVIATIONS/ACRONYMS USED IN THIS PERMIT

ACMA Alternative Compliance Market Account

Act Illinois Environmental Protection Act [415 ILCS 5/1 et

seq.]

ATU Allotment Trading Unit

amp-hr ampere-hour

AP-42 Compilation of Air Pollutant Emission Factors, Volume 1,

Stationary Point and Other Sources (and Supplements A

through F), USEPA, Office of Air Quality Planning and

Standards, Research Triangle Park, NC 27711

Btu British thermal unit

CAA Clean Air Act [42 U.S.C. Section 7401 et seq.]

CAAPP Clean Air Act Permit Program

CFR Code of Federal Regulations

CMP composite mesh pad

dscm dry standard cubic meter

ERMS Emissions Reduction Market System

HAP Hazardous Air Pollutant

hr hour

IAC Illinois Administrative Code

I.D. No. Identification Number of Source, assigned by Illinois

EPA

ILCS Illinois Compiled Statutes

Illinois EPA Illinois Environmental Protection Agency

kg kilogram

kW kilowatts

lb pound

mg milligram

mmBtu Million British thermal units

NESHAP National Emission Standards for Hazardous Air Pollutants

NOx Nitrogen Oxides

NSPS New Source Performance Standards

O & M Operation and Maintenance

OSHA Occupational Safety and Health Administration

PM Particulate Matter

PM10 Particulate matter with an aerodynamic diameter less

than or equal to a nominal 10 microns as measured by

applicable test or monitoring methods

ppm parts per million

PSD Prevention of Significant Deterioration

RMP Risk Management Plan

SO2 Sulfur Dioxide

SOP Standard Operating Procedure

T1 Title I – identifies Title I conditions that have been

carried over from an existing permit

T1N Title I New – identifies Title I conditions that are

being established in this permit
6

T1R Title I Revised – identifies Title I conditions that

have been carried over from an existing permit and

subsequently revised in this permit

USEPA United States Environmental Protection Agency

VOM Volatile Organic Material

yr year
7

3.0 INSIGNIFICANT ACTIVITIES

3.1 Identification of Insignificant Activities

The following activities at the source constitute insignificant

activities as specified in 35 IAC 201.210:

3.1.1 Activities determined by the Illinois EPA to be

insignificant activities, pursuant to 35 IAC 201.210(a)(1)

and 201.211, as follows:

None

3.1.2 Activities that are insignificant activities based upon

maximum emissions, pursuant to 35 IAC 201.210(a)(2) or

(a)(3), as follows:

Electroless Nickel Plating Tanks

3.1.3 Activities that are insignificant activities based upon

their type or character, pursuant to 35 IAC 201.210(a)(4)

through (18), as follows:

Direct combustion units designed and used for comfort

heating purposes and fuel combustion emission units

as follows: (A) Units with a rated heat input

capacity of less than 2.5 mmBtu/hr that fire only

natural gas, propane, or liquefied petroleum gas; (B)

Units with a rated heat input capacity of less than

1.0 mmBtu/hr that fire only oil or oil in combination

with only natural gas, propane, or liquefied

petroleum gas; and (C) Units with a rated heat input

capacity of less than 200,000 Btu/hr which never burn

refuse, or treated or chemically contaminated wood

[35 IAC 201.210(a)(4)].

3.1.4 Activities that are considered insignificant activities

pursuant to 35 IAC 201.210(b).

3.2 Compliance with Applicable Requirements

Insignificant activities are subject to applicable requirements

notwithstanding status as insignificant activities. In

particular, in addition to regulations of general applicability,

such as 35 IAC 212.301 and 212.123 (Condition 5.2.2), the

Permittee shall comply with the following requirements, as

applicable:

3.2.1 For each cold cleaning degreaser, the Permittee shall

comply with the applicable equipment and operating

requirements of 35 IAC 215.182, 218.182, or 219.182.
8

3.2.2 For each particulate matter process emission unit, the

Permittee shall comply with the applicable particulate

matter emission limit of 35 IAC 212.321 or 212.322. For

example, the particulate matter emissions from a process

emission unit shall not exceed 0.55 pounds per hour if the

emission unit’s process weight rate is 100 pounds per hour

or less, pursuant to 35 IAC 266.110.

3.2.3 For each organic material emission unit that uses organic

material, e.g., a mixer or printing line, the Permittee

shall comply with the applicable VOM emission limit of 35

IAC 215.301, 218.301, or 219.301, which requires that

organic material emissions not exceed 8.0 pounds per hour

or do not qualify as photochemically reactive material as

defined in 35 IAC 211.4690.

3.3 Addition of Insignificant Activities

3.3.1 The Permittee is not required to notify the Illinois EPA

of additional insignificant activities present at the

source of a type that is identified in Condition 3.1,

until the renewal application for this permit is

submitted, pursuant to 35 IAC 201.212(a).

3.3.2 The Permittee must notify the Illinois EPA of any proposed

addition of a new insignificant activity of a type

addressed by 35 IAC 201.210(a) and 201.211 other than

those identified in Condition 3.1, pursuant to Section

39.5(12)(b) of the Act.

3.3.3 The Permittee is not required to notify the Illinois EPA

of additional insignificant activities present at the

source of a type identified in 35 IAC 201.210(b).
9

4.0 SIGNIFICANT EMISSION UNITS AT THIS SOURCE

Emission

Unit Description

Date

Constructed

Emission Control

Equipment

01 Hard Chromium

Electroplating Tank #1

1991 Composite Mesh Pad

System

02 Hard Chromium

Electroplating Tank #2

5/1994 Composite Mesh Pad

System

03 Hard Chromium

Electroplating Tank #3

1991 Composite Mesh Pad

System

04 Hard Chromium

Electroplating Tank #4

1991 Composite Mesh Pad

System

05 Hard Chromium

Electroplating Tank #5

1991 Composite Mesh Pad

System

06 Hard Chromium

Electroplating Tank #6

1991 Composite Mesh Pad

System

07 Hard Chromium

Electroplating Tank #7

7/1995 Composite Mesh Pad

System

08 Hard Chromium

Electroplating Tank #8

7/1995 Composite Mesh Pad

System
10

5.0 OVERALL SOURCE CONDITIONS

5.1 Source Description

5.1.1 This permit is issued based on the source requiring a

CAAPP permit as a major source of HAP emissions.

5.2 Applicable Regulations

5.2.1 Specific emission units at this source are subject to

particular regulations as set forth in Section 7 (UnitSpecific Conditions) of this permit.

5.2.2 In addition, emission units at this source are subject to

the following regulations of general applicability:

a. No person shall cause or allow the emission of

fugitive particulate matter from any process,

including any material handling or storage activity,

that is visible by an observer looking generally

overhead at a point beyond the property line of the

source unless the wind speed is greater than 40.2

kilometers per hour (25 miles per hour), pursuant to

35 IAC 212.301 and 212.314.

Compliance with this requirement is considered to be

assured by the inherent nature of operations at this

source, as demonstrated by historical operation.

b. i. This source shall be operated under the

provisions of an operating program prepared by

the Permittee and submitted to the Illinois

EPA for its review. Such operating program

shall be designed to significantly reduce

fugitive particulate matter emissions [35 IAC

212.309(a)].

ii. The operating program shall be amended from

time to time by the Permittee so that the

operating program is current. Such amendments

shall be consistent with the requirements set

forth by this Condition and shall be submitted

to the Illinois EPA [35 IAC 212.312].

iii. All normal traffic pattern roads and parking

facilities located at this source shall be

paved or treated with water, oils, or chemical

dust suppressants. All paved areas shall be

cleaned on a regular basis. All areas treated

with water, oils, or chemical dust

suppressants shall have the treatment applied
11

on a regular basis, as needed, in accordance

with the operating program [35 IAC 212.306].

c. No person shall cause or allow the emission of smoke

or other particulate matter, with an opacity greater

than 30 percent, into the atmosphere from any

emission unit other than those emission units subject

to the requirements of 35 IAC 212.122, pursuant to 35

IAC 212.123(a), except as allowed by 35 IAC

212.123(b) and 212.124.

5.2.3 The Permittee shall comply with the standards for

recycling and emissions reduction of ozone depleting

substances pursuant to 40 CFR Part 82, Subpart F, except

as provided for motor vehicle air conditioners in Subpart

B of 40 CFR Part 82:

a. Persons opening appliances for maintenance, service,

repair, or disposal must comply with the required

practices pursuant to 40 CFR 82.156.

b. Equipment used during the maintenance, service,

repair, or disposal of appliances must comply with

the standards for recycling and recovery equipment

pursuant to 40 CFR 82.158.

c. Persons performing maintenance, service, repair, or

disposal of appliances must be certified by an

approved technician certification program pursuant to

40 CFR 82.161.

5.2.4 Risk Management Plan

Should this stationary source, as defined in 40 CFR

Section 68.3, become subject to the Accidental Release

Prevention regulations in 40 CFR Part 68, then the owner

or operator shall submit [40 CFR 68.215(a)(2)(i) and

(ii)]:

a. A compliance schedule for meeting the requirements of

40 CFR Part 68 by the date provided in 40 CFR

68.10(a); or

b. A certification statement that the source is in

compliance with all requirements of 40 CFR Part 68,

including the registration and submission of the Risk

Management Plan (RMP), as part of the annual

compliance certification required by 40 CFR Part 70

or 71.
12

5.2.5 a. Should this stationary source become subject to a

regulation under 40 CFR Parts 60, 61, or 63, or 35

IAC after the date issued of this permit, then the

owner or operator shall, in accordance with the

applicable regulation(s), comply with the applicable

requirements by the date(s) specified and shall

certify compliance with the applicable requirements

of such regulation(s) as part of the annual

compliance certification, as required by 40 CFR Part

70 or 71.

b. No later than upon the submittal for renewal of this

permit, the owner or operator shall submit, as part

of an application, the necessary information to

address either the non-applicability of, or

demonstrate compliance with all applicable

requirements of any potentially applicable regulation

which was promulgated after the date issued of this

permit.

5.2.6 Episode Action Plan

a. If the source is required to have an episode action

plan pursuant to 35 IAC 244.142, the Permittee shall

maintain at the source and have on file with the

Illinois EPA a written episode action plan (plan) for

reducing the levels of emissions during yellow

alerts, red alerts, and emergencies, consistent with

safe operating procedures. The plan shall contain

the information specified in 35 IAC 244.144.

b. The Permittee shall immediately implement the

appropriate steps described in this plan should an

air pollution alert or emergency be declared.

c. If a change occurs at the source which requires a

revision of the plan (e.g., operational change,

change in the source contact person), a copy of the

revised plan shall be submitted to the Illinois EPA

for review within 30 days of the change. Such plans

shall be further revised if disapproved by the

Illinois EPA.

d. For sources required to have a plan pursuant to 35

IAC 244.142, a copy of the original plan and any

subsequent revisions shall be sent to:
13

i. Illinois EPA, Compliance Section; and

ii. For sources located in Cook County and outside

of the city of Chicago: Cook County

Department of Environmental Control; or

iii. For sources located within the city of

Chicago: Chicago Department of Environmental

Control.

5.3 Non-Applicability of Regulations of Concern

None

5.4 Source-Wide Operational and Production Limits and Work Practices

In addition to the source-wide requirements in the Standard Permit

Conditions in Section 9, the Permittee shall fulfill the following

source-wide operational and production limitations and/or work

practice requirements:

5.4.1 General Operation and Maintenance Requirements

The Permittee shall maintain and operate each emission

unit or group of emission units at this source that is

regulated by relevant standards or requirements pursuant

to 40 CFR Part 63, National Emission Standards for

Hazardous Air Pollutants for Source Categories, in

accordance with “Operation and Maintenance Requirements”

in 40 CFR 63.6(e). The emission units at this source that

are subject to these requirements include hard chromium

electroplating tanks, as addressed in Section 7.1 of this

permit.

5.5 Source-Wide Emission Limitations

5.5.1 Permitted Emissions for Fees

The annual emissions from the source, not considering

insignificant activities as addressed by Section 3.0 of

this permit, shall not exceed the following limitations.

The overall source emissions shall be determined by adding

emissions from all emission units. Compliance with these

limits shall be determined on a calendar year basis.

These limitations (Condition 5.5.1) are set for the

purpose of establishing fees and are not federally

enforceable.
14

Permitted Emissions of Regulated Pollutants

Pollutant Tons/Year

Volatile Organic Material (VOM) --

Sulfur Dioxide (SO2) --

Particulate Matter (PM) 9.42

Nitrogen Oxides (NOx) --

HAP, not included in VOM or PM 9.42

TOTAL 18.84

5.5.2 Emissions of Hazardous Air Pollutants

Source-wide emission limitations for HAPs as listed in

Section 112(b) of the CAA are not set. This source is

considered to be a major source of HAPs.

5.5.3 Other Source-Wide Emission Limitations

Other source-wide emission limitations are not set for

this source pursuant to either the federal rules for

Prevention of Significant Deterioration (PSD), 40 CFR

52.21, Illinois EPA rules for Major Stationary Sources

Construction and Modification, 35 IAC Part 203, or Section

502(b)(10) of the CAA. However, there may be unit

specific emission limitations set forth in Section 7 of

this permit pursuant to these rules.

5.6 General Recordkeeping Requirements

5.6.1 Emission Records

The Permittee shall maintain records of the following

items for the source to demonstrate compliance with

Condition 5.5.1, pursuant to Section 39.5(7)(b) of the

Act:

Total annual emissions on a calendar year basis for

the emission units covered by Section 7 (Unit

Specific Conditions) of this permit.

5.6.2 Records for Operating Scenarios

N/A

5.6.3 Retention and Availability of Records

a. All records and logs required by this permit shall be

retained for at least five years from the date of

entry (unless a longer retention period is specified

by the particular recordkeeping provision herein),

shall be kept at a location at the source that is
15

readily accessible to the Illinois EPA or USEPA, and

shall be made available for inspection and copying by

the Illinois EPA or USEPA upon request.

b. The Permittee shall retrieve and print, on paper

during normal source office hours, any records

retained in an electronic format (e.g., computer) in

response to an Illinois EPA or USEPA request for

records during the course of a source inspection.

5.7 General Reporting Requirements

5.7.1 General Source-Wide Reporting Requirements

The Permittee shall promptly notify the Illinois EPA,

Compliance Section of noncompliance with the permit

requirements as follows, pursuant to Section

39.5(7)(f)(ii) of the Act. Reports shall describe the

probable cause of such deviations, and any corrective

actions or preventive measures taken.

5.7.2 Annual Emissions Report

The annual emissions report required pursuant to Condition

9.7 shall contain emissions information for the previous

calendar year.

5.8 General Operational Flexibility/Anticipated Operating Scenarios

N/A

5.9 General Compliance Procedures

5.9.1 General Procedures for Calculating Emissions

Compliance with the source-wide emission limits specified

in Condition 5.5 shall be based on the recordkeeping and

reporting requirements of Conditions 5.6 and 5.7, and

Compliance Procedures in Section 7 (Unit Specific

Conditions) of this permit.
16

6.0 EMISSIONS REDUCTION MARKET SYSTEM (ERMS)

6.1 Description of ERMS

The ERMS is a “cap and trade” market system for major stationary

sources located in the Chicago ozone nonattainment area. It is

designed to reduce VOM emissions from stationary sources to

contribute to reasonable further progress toward attainment, as

required by Section 182(c) of the CAA.

The ERMS addresses VOM emissions during a seasonal allotment

period from May 1 through September 30. Participating sources

must hold "allotment trading units" (ATUs) for their actual

seasonal VOM emissions. Each year participating sources are

issued ATUs based on allotments set in the sources’ CAAPP permits.

These allotments are established from historical VOM emissions or

“baseline emissions” lowered to provide the emissions reductions

from stationary sources required for reasonable further progress.

By December 31 of each year, the end of the reconciliation period

following the seasonal allotment period, each source should have

sufficient ATUs in its transaction account to cover its actual VOM

emissions during the preceding season. A transaction account’s

balance as of December 31 will include any valid ATU transfer

agreements entered into as of December 31 of the given year,

provided such agreements are promptly submitted to the Illinois

EPA for entry into the transaction account database. The Illinois

EPA will then retire ATUs in sources’ transaction accounts in

amounts equivalent to their seasonal emissions. When a source

does not appear to have sufficient ATUs in its transaction

account, the Illinois EPA will issue a notice to the source to

begin the process for Emissions Excursion Compensation.

In addition to receiving ATUs pursuant to their allotments,

participating sources may also obtain ATUs from the market,

including ATUs bought from other participating sources and general

participants in the ERMS that hold ATUs (35 IAC 205.630) and ATUs

issued by the Illinois EPA as a consequence of VOM emissions

reductions from an Emissions Reduction Generator or an Intersector

Transaction (35 IAC 205.500 and 35 IAC 205.510). During the

reconciliation period, sources may also buy ATUs from a secondary

reserve of ATUs managed by the Illinois EPA, the “Alternative

Compliance Market Account” (ACMA) (35 IAC 205.710). Sources may

also transfer or sell the ATUs that they hold to other sources or

participants (35 IAC 205.630).

6.2 Applicability

This permit is issued based on this source not being a

participating source in the Emissions Reduction Market System

(ERMS), 35 IAC Part 205, pursuant to 35 IAC 205.200. This is
17

based on the source’s actual VOM emissions during the seasonal

allotment period from May 1 through September 30 of each year

being less than 10 tons and the source’s baseline emissions also

being less than 10 tons.

6.3 Recordkeeping and Reporting

a. The Permittee shall maintain the following records to

allow the confirmation of actual VOM emissions during the

seasonal allotment period:

i. Records of operating data and other information for

each individual emission unit or group of related

emission units at the source, as specified in

Sections 5 and 7 of this permit, as appropriate, to

determine actual VOM emissions during the seasonal

allotment period;

ii. Records of the VOM emissions, in tons, during the

seasonal allotment period, with supporting

calculations, for each individual emission unit or

group of related emission units at the source,

determined in accordance with the procedures

specified in Sections 5 and 7 of this permit; and

iii. Total VOM emissions from the source, in tons, during

each seasonal allotment period, which shall be

compiled by November 30 of each year.

b. In the event that the source’s VOM emissions during the

seasonal allotment period equal or exceed 10 tons, the

source shall become a participating source in the ERMS and

beginning with the following seasonal allotment period,

shall comply with 35 IAC Part 205, by holding allotment

trading units (ATUs) for its VOM emissions during each

seasonal allotment period, unless the source obtains

exemption from the ERMS by operating with seasonal VOM

emissions of no more than 15 tons pursuant to a limitation

applied for and established in its CAAPP permit.

6.4 Federal Enforceability

Section 6.0 becomes federally enforceable upon approval of the

ERMS by USEPA as part of Illinois’ State Implementation Plan.
18

7.0 UNIT SPECIFIC CONDITIONS

7.1 Unit - Hard Chromium Electroplating Tanks

Control – Composite Mesh Pad Systems

7.1.1 Description

The electroplating tanks perform hard chrome plating of

hydraulic equipment, steel components and assemblies,

molds and dies. The chrome plating process generates

hydrogen gas that has entrained droplets of chromic acid

in it, which creates a mist. The ventilation system

carries the mist through a mesh pad control system to

remove chromic acid droplets by inertial impaction.

This source is a large, hard chromium electroplating

facility because the maximum cumulative rectifier capacity

is greater than or equal to 60 million ampere-hours per

year.

7.1.2 List of Emission Units and Pollution Control Equipment

Emission

Unit Description

Emission

Control

Equipment

01 Hard Chromium Electroplating

Tank #1

Composite Mesh

Pad System

02 Hard Chromium Electroplating

Tank #2

Composite Mesh

Pad System

03 Hard Chromium Electroplating

Tank #3

Composite Mesh

Pad System

04 Hard Chromium Electroplating

Tank #4

Composite Mesh

Pad System

05 Hard Chromium Electroplating

Tank #5

Composite Mesh

Pad System

06 Hard Chromium Electroplating

Tank #6

Composite Mesh

Pad System

07 Hard Chromium Electroplating

Tank #7

Composite Mesh

Pad System

08 Hard Chromium Electroplating

Tank #8

Composite Mesh

Pad System

7.1.3 Applicability Provisions and Applicable Regulations

a. An “affected chrome plating tank” for the purpose of

these unit-specific conditions, is a hard chromium

electroplating tank specified in Condition 7.1.2.

b. The affected chrome plating tanks are subject to the

National Emission Standards for Hazardous Air
19

Pollutants (NESHAP) for Chromium Emissions From Hard

and Decorative Chromium Electroplating and Chromium

Anodizing Tanks, 40 CFR 63, Subparts A and N. The

Illinois EPA is administering NESHAP in Illinois on

behalf of the United States EPA under a delegation

agreement.

c. The affected chrome plating tanks are subject to 35

IAC 212.321, which provides that:

No person shall cause or allow the emission of

particulate matter into the atmosphere in any one

hour period from any new process emission unit,

either alone or in combination with the emission of

particulate matter from all other similar process

emission units for which construction or modification

commenced on or after April 14, 1972, at a source or

premises, exceeds the allowable emission rates

specified in subsection (c) of 35 IAC 212.321 (See

also Attachment 1) [35 IAC 212.321(a)].

7.1.4 Non-Applicability of Regulations of Concern

None

7.1.5 Operational Limits and Work Practice Standards

a. Air pollution control equipment associated with an

affected chrome plating tank shall be operated at all

times during tank operation, including periods of

startup and shutdown.

b. Pursuant to 40 CFR 63.342(f)(1), the Permittee is

subject to these work practice standards.

i. At all times, including periods of startup,

shutdown, and malfunction, the Permittee shall

operate and maintain any affected source,

including associated air pollution control

devices and monitoring equipment, in a manner

consistent with good air pollution control

practices, consistent with the operation and

maintenance plan required by Condition

7.1.5(c).

ii. Malfunctions shall be corrected as soon as

practicable after their occurrence in

accordance with the operation and maintenance

plan required by Condition 7.1.5(c).
20

iii. Operation and maintenance requirements

established pursuant to Section 112 of the CAA

are enforceable independent of emissions

limitations or other requirements in relevant

standards.

c. The Permittee shall develop and implement an

operation and maintenance (O & M) plan for the

affected chrome plating tanks which shall include at

least the following, pursuant to 40 CFR 63.342(f)(3):

i. Description of the operation and maintenance

criteria for the control device(s) and

monitoring equipment.

ii. A checklist to document the operation and

maintenance of the equipment.

iii. Required work practice standards, pursuant to

40 CFR 63.342(f) (Condition 7.1.8).

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.

d. If the operation and maintenance plan fails to

address or inadequately addresses an event that meets

the characteristics of a malfunction at the time the

plan is initially developed, the Permittee shall

revise the operation and maintenance plan within 45

days after such an event occurs. The revised plan

shall include procedures for operating and

maintaining the process equipment, add-on air

pollution control device, or monitoring equipment

during similar malfunction events, and a program for

corrective action for such events.

e. The Permittee may use applicable Standard Operating

Procedure (SOP) manuals, Occupational Safety and

Health Administration (OSHA) plans or other existing

plans as part of the operation and maintenance plan,

provided the alternative plans meet the requirements

of Condition 7.1.5(c).

f. The standards in Condition 7.1.6 that apply to

chromic acid baths shall not be met by using a
21

reducing agent to change the form of chromium from

hexavalent to trivalent.

7.1.6 Emission Limitations

In addition to Condition 5.2.2 and the source wide

emission limitations in Condition 5.5, the affected chrome

plating tanks are subject to the following:

a. The concentration of total chromium in each exhaust

gas stream discharged to the atmosphere from the

affected chrome plating tanks shall not exceed the

following limits, pursuant to 40 CFR 63.342(c)(1):

Equipment

Chromium

Emissions

(mg/dscm)

New and Existing Tanks at a Large Hard

Chromium Electroplating Facility

0.015

This limit is based on the maximum cumulative

potential rectifier capacity of all hard chrome

electroplating tanks at his source being greater than

60 million ampere-hours per year. An electroplating

tank installed before December 16, 1993, is

considered as existing tank.

Compliance with this limit shall be determined from

initial performance testing and ongoing compliance

monitoring requirements, as required by this permit.

7.1.7 Testing Requirements

a. Within 180 days of initial startup, the chromium

emissions of the affected chrome plating tank shall

be tested in accordance with 40 CFR 63, Subpart N to

demonstrate compliance, pursuant to 40 CFR 63.343(b).

b. The following test methods and procedures shall be

used for performance testing, pursuant to 40 CFR

63.344(c). Refer to 40 CFR 63, Appendix A, for USEPA

test methods. Alternate test methods may be used as

specified in 40 CFR 63.344(c)(2) and (4).

Location of Sample Points USEPA Method 1

Gas Flow and Velocity USEPA Method 2

Chromium USEPA Method 306 or 306A

c. During initial performance testing, the site specific

“operating parameter value”, i.e., range of pressure
22

drop data across the composite mesh pad systems shall

be established to demonstrate continuous compliance,

pursuant to 40 CFR 63.343(c). Pressure drop range

can be established from the highest and lowest value

during multiple performance testing or + 1 inch of

H2O column about the average pressure drop measured

during the three compliant test runs of one

performance test.

d. The Permittee shall follow the procedures of 40 CFR

63.344(d) to establish site-specific operating

parameter values and to install monitoring equipment.

7.1.8 Inspection and Monitoring Requirements

a. The operation and maintenance practices required by

40 CFR 63.342(f) (See Condition 7.1.5(b) and (c))

shall be implemented for control systems used on the

affected chrome plating tanks, including the

following work practice standards for the composite

mesh pad control system(s):

i. A quarterly visual inspection of the 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 device.

ii. A quarterly visual inspection of the back

portion of the mesh pad closest to the fan to

ensure that there is no breakthrough of

chromic acid mist.

iii. A quarterly visual inspection of the duct work

from the tank(s) to the composite mesh pad

scrubber(s) to ensure there are no leaks.

iv. Perform washdown of the composite mesh-pads in

accordance with manufacturer’s

recommendations.

b. On and after the date on which the initial

performance test required to be completed (see

Condition 7.1.7), the Permittee shall monitor and

record the pressure drop across the composite meshpad system once each day that the affected chrome

plating tank is operating.
23

7.1.9 Recordkeeping Requirements

In addition to the records required by Condition 5.6, the

Permittee shall maintain records of the following items

for the affected chrome plating tanks to demonstrate

compliance with Conditions 5.5.1, 7.1.5, and 7.1.8,

pursuant to Section 39.5(7)(b) of the Act:

a. The Permittee shall keep the records required by 40

CFR 63.346(b) to demonstrate compliance with 40 CFR

63, Subpart N, including the following:

i. 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.

ii. Records of all maintenance performed on the

affected chrome plating tanks, as related to

emissions, the associated control system, and

monitoring equipment.

iii. Records of the occurrence, duration, and cause

(if known) of each malfunction of the affected

chrome plating tanks, associated control

system, and monitoring equipment.

iv. Records of actions taken during periods of

malfunction when such actions are inconsistent

with the operation and maintenance plan

required by 40 CFR 63.342(f)(3), pursuant to

40 CFR 63.342(f)(3)(iv).

v. Records, which may take the form of

checklists, necessary to demonstrate

consistency with the provisions of the

operation and maintenance plan required by 40

CFR 63.342(f)(3).

vi. 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
24

special compliance procedures of 40 CFR

63.344(e).

vii. Records of monitoring data required by 40 CFR

63.343(c) (See Condition 7.1.8) that are used

to demonstrate compliance with the standard

including the date and time the data are

collected.

viii. 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.

ix. 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 affected chrome

plating tanks and associated control device or

monitoring equipment.

x. Records for the total process operating time

of the affected chrome plating tanks during

the reporting period.

xi. Records demonstrating the maximum cumulative

potential rectifier capacity, if hard chrome

electroplating is less than 60 million amperehours 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 semiannually.

xii. Copies of the notifications and reports

required by 40 CFR Parts 63.9, 63.10, and

63.347 (Condition 7.1.10), with supporting

documentation.

xiii. All records shall be retained for a period of

five years, pursuant to 40 CFR 63.10(b)(1).

b. The Permittee shall keep the written operation and

maintenance plan (See Condition 7.1.5) on record

after it is developed to be made available for

inspection, upon request, by the Illinois EPA and/or

USEPA for the life of the affected chrome plating
25

tanks or until the chrome plating tanks are no longer

subject to the provisions of 40 CFR 63 Subpart N. In

addition, if the operation and maintenance plan is

revised, the Permittee shall keep previous (i.e.,

superseded) versions of the operation and maintenance

plan on record to be made available for inspection,

upon request, by the Illinois EPA and/or USEPA for a

period of 5 years after each revision to the plan.

7.1.10 Reporting Requirements

a. Prior to carrying out the tests required by Condition

7.1.7, the Illinois EPA shall be notified in writing

a minimum of sixty (60) calendar days prior to the

scheduled date of these tests with the exact date,

time, and place of these tests, to enable the

Illinois EPA to observe these tests, pursuant to 40

CFR 63.347(d)(1).

b. If the scheduled date for the test required by

Condition 7.1.7 is changed for unforeseen reasons,

the Permittee shall inform the Illinois EPA within

five (5) working days of the originally scheduled

test date and must specify the date of the

rescheduled test. Observation of the performance

test by the Illinois EPA is optional.

c. Three (3) copies of the Final Report(s) for

performance tests and compliance status shall be

submitted to the Illinois EPA within 90 calendar days

after the performance test, pursuant to 40 CFR

63.347(f)(2) and 63.347(e)(3). If testing is not

required, the report of compliance status shall be

submitted no later than 30 days after initial

startup. The Final Report shall include, pursuant to

40 CFR 63.344(a):

i. General information, i.e., date of test,

testing personnel and observers, if any.

ii. A summary of test results and compliance

status.

iii. Description of test method(s), including

description of sampling points, sampling

train, analysis equipment, and test schedule.

iv. Detailed description of test conditions,

including:
26

A. Process information, i.e., mode(s) of

operation, process weight rate, e.g. raw

material consumption, rectifier operating

rate.

B. Sampling and analytical procedures and any

modifications to standard procedures.

C. Control equipment record of pressure drop

range across the composite mesh pad

systems to demonstrate continuous

compliance.

D. A discussion of any preparatory actions

taken, i.e., standard preparation,

inspections, maintenance, and repair.

E. A discussion of calibration procedures.

v. Data and calculations, including copies of all

raw data sheets and records of laboratory

analyses, sample calculations, and data on

equipment calibration.

vi. An explanation of any discrepancies among

individual tests or anomalous data.

vii. Quality assurance procedures and results.

viii. Any additional information required by the

test method.

d. The Permittee shall comply with the compliance

reporting requirements of 40 CFR 63.347(e), including

the following:

A notification of compliance status, signed by the

responsible official who shall certify its accuracy,

attesting to whether the affected chrome plating tank

has complied with 40 CFR 63 Subpart N, pursuant to 40

CFR 63.347(e)(2). The notification shall be

submitted no later than 90 days following completion

of the initial performance test required by Condition

7.1.7 and shall list the following:

i. The applicable emission limitation and the

methods that were used to determine compliance

with this limitation.

ii. The performance test report documenting the

results of the performance test, which
27

contains the elements required by 40 CFR

63.344(a), including measurements and

calculations to support the special compliance

provisions of 40 CFR 63.344(e) if these are

being followed, pursuant to 40 CFR

63.344(e)(5).

iii. The type and quantity of hazardous air

pollutants emitted by the source reported in

mg/dscm or mg/hr if the source is using the

special provisions of 40 CFR 63.344(e) to

comply with the standards.

iv. The specific operating parameter value, or

range of values, that corresponds to

compliance with the applicable emission limit,

pursuant to 40 CFR 63.343(c).

v. The methods that will be used to determine

continuous compliance.

vi. A description of the air pollution control

technique for each emission point.

vii. A statement that the Permittee has completed

and has on file the operation and maintenance

plan as required by the work practice

standards of 40 CFR 63.342(f).

viii. If the Permittee is determining facility size

based on actual cumulative rectifier capacity

in accordance with 40 CFR 63.342(c)(2),

records to support that the facility is small.

For existing sources, records from any 12-

month period preceding the compliance date

shall be used or a description of how

operations will change to meet a small

designation shall be provided.

ix. A statement by the Permittee as to whether the

affected chrome plating tank has complied with

the provisions of 40 CFR Part 63, Subpart N.

e. The Permittee shall submit ongoing compliance status

reports documenting the ongoing compliance status to

the Illinois EPA every six months, pursuant to 40 CFR

63.347(g). If the Permittee exceeds the emission

limits as indicated during monitoring, ongoing

compliance status reports shall be submitted once

every quarter. To reduce the frequency of ongoing
28

compliance status reports, the procedures in 40 CFR

63.347(g)(2) shall be followed.

f. The Permittee shall report the results from 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 Permittee shall

report the results from each monitoring device for

the relevant compliance period.

g. The ongoing compliance status report shall contain

the following:

i. The company name and address of the source

performing hard chrome electroplating.

ii. An identification of the operating

parameter(s) that is monitored for compliance

determination, as required by 40 CFR

63.343(c).

iii. The relevant emission limitation for the

affected chrome plating tanks, 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, as required

by 40 CFR 63.347(e)(2).

iv. The beginning and ending dates of the

reporting period.

v. A description of the type of process performed

in the affected chrome plating tanks.

vi. The total operating time of the affected

chrome plating tanks during the reporting

period.

vii. The actual cumulative rectifier capacity

expended during the reporting period, on a

month-by-month basis, if the Permittee limits

the maximum cumulative potential 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
29

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 of 40 CFR

63.342(f) were followed in accordance with the

operation and maintenance plan for the source.

x. If the operation and maintenance plan required

by 40 CFR 63.342(f)(3) was not followed, an

explanation of the reasons for not following

the provisions, an assessment of whether any

excess emission and/or parameter monitoring

exceedances are believed to have occurred, and

a copy of the report(s) required by 40 CFR

63.342(f)(3)(iv) 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.

h. If actions taken by the Permittee during periods of

malfunction are inconsistent with the procedures

specified in the operation and maintenance plan

required by Condition 7.1.5, the Permittee shall

record the actions taken for that event and shall

report by phone such actions within 2 working days

after commencing actions inconsistent with the plan.

This report shall be followed by a letter within 7

working days after the end of the event, unless the

Permittee makes alternative reporting arrangements,

in advance, with the Illinois EPA and/or USEPA.

7.1.11 Operational Flexibility/Anticipated Operating Scenarios

N/A
30

7.1.12 Compliance Procedures

a. Compliance with the particulate matter emission limit

in Condition 7.1.3(c) is assured by proper operation

of the affected chrome plating tanks and associated

control equipment, as required by work practice

standards in Condition 7.1.5.

b. Compliance with the chromium emission limit in

Condition 7.1.6 shall be determined by the monitoring

required by Condition 7.1.8. To be in compliance,

the composite mesh-pad system(s) shall be operated

within + 1 inch of water column of the pressure drop

established during the initial performance test, or

shall be operated within the range of compliant

valves for pressure drop established during multiple

performance tests. Failure to operate in accordance

with the operating parameter value(s), determined

during initial performance testing, shall be

considered a violation of the limit in Condition

7.1.3, pursuant to 40 CFR 63, Subpart N.
31

8.0 GENERAL PERMIT CONDITIONS

8.1 Permit Shield

Pursuant to Section 39.5(7)(j) of the Act, the Permittee has

requested and has been granted a permit shield. This permit

shield provides that compliance with the conditions of this permit

shall be deemed compliance with applicable requirements which were

applicable as of the date the proposed permit for this source was

issued, provided that either the applicable requirements are

specifically identified within this permit, or the Illinois EPA,

in acting on this permit application, has determined that other

requirements specifically identified are not applicable to this

source and this determination (or a concise summary thereof) is

included in this permit.

This permit shield does not extend to applicable requirements

which are promulgated after April 19, 2000 (the date of issuance

of the draft permit) unless this permit has been modified to

reflect such new requirements.

8.2 Applicability of Title IV Requirements (Acid Deposition Control)

This source is not an affected source under Title IV of the CAA

and is not subject to requirements pursuant to Title IV of the

CAA.

8.3 Emissions Trading Programs

No permit revision shall be required for increases in emissions

allowed under any USEPA approved economic incentives, marketable

permits, emissions trading, and other similar programs or

processes for changes that are provided for elsewhere in this

permit and that are authorized by the applicable requirement

[Section 39.5(7)(o)(vii) of the Act].

As of the date of issuance of this permit, there are no such

economic incentive, marketable permit or emission trading programs

that have been approved by USEPA.

8.4 Operational Flexibility/Anticipated Operating Scenarios

8.4.1 Changes Specifically Addressed by Permit

Physical or operational changes specifically addressed by

the Conditions of this permit that have been identified as

not requiring Illinois EPA notification may be implemented

without prior notice to the Illinois EPA.
32

8.4.2 Changes Requiring Prior Notification

The Permittee is authorized to make physical or

operational changes that contravene express permit terms

without applying for or obtaining an amendment to this

permit, provided that [Section 39.5(12)(a)(i) of the

Act]:

a. The changes do not violate applicable requirements;

b. The changes do not contravene federally enforceable

permit terms or conditions that are monitoring

(including test methods), recordkeeping, reporting, or

compliance certification requirements;

c. The changes do not constitute a modification under

Title I of the CAA;

d. Emissions will not exceed the emissions allowed under

this permit following implementation of the physical

or operational change; and

e. The Permittee provides written notice to the Illinois

EPA, Division of Air Pollution Control, Permit

Section, at least 7 days before commencement of the

change. This notice shall:

i. Describe the physical or operational change;

ii. Identify the schedule for implementing the

physical or operational change;

iii. Provide a statement of whether or not any New

Source Performance Standard (NSPS) is

applicable to the physical or operational

change and the reason why the NSPS does or

does not apply;

iv. Provide emission calculations which

demonstrate that the physical or operational

change will not result in a modification; and

v. Provide a certification that the physical or

operational change will not result in

emissions greater than authorized under the

Conditions of this permit.

8.5 Testing Procedures

Tests conducted to measure composition of materials, efficiency of

pollution control devices, emissions from process or control
33

equipment, or other parameters shall be conducted using standard

test methods. Documentation of the test date, conditions,

methodologies, calculations, and test results shall be retained

pursuant to the recordkeeping procedures of this permit. Reports

of any tests conducted as required by this permit or as the result

of a request by the Illinois EPA shall be submitted as specified

in Condition 8.6.

8.6 Reporting Requirements

8.6.1 Monitoring Reports

If monitoring is required by any applicable requirements

or conditions of this permit, a report summarizing the

required monitoring results, as specified in the

conditions of this permit, shall be submitted to the Air

Compliance Section of the Illinois EPA every six months as

follows [Section 39.5(7)(f) of the Act]:

Monitoring Period Report Due Date

January - June September 1

July - December March 1

All instances of deviations from permit requirements must

be clearly identified in such reports. All such reports

shall be certified in accordance with Condition 9.9.

8.6.2 Test Notifications

Unless otherwise specified elsewhere in this permit, a

written test plan for any test required by this permit

shall be submitted to the Illinois EPA for review at least

60 days prior to the testing pursuant to Section

39.5(7)(a) of the Act. The notification shall include at

a minimum:

a. The name and identification of the affected unit(s);

b. The person(s) who will be performing sampling and

analysis and their experience with similar tests;

c. The specific conditions under which testing will be

performed, including a discussion of why these

conditions will be representative of maximum

emissions and the means by which the operating

parameters for the source and any control equipment

will be determined;
34

d. The specific determination of emissions and operation

which are intended to be made, including sampling and

monitoring locations;

e. The test method(s) which will be used, with the

specific analysis method, if the method can be used

with different analysis methods;

f. Any minor changes in standard methodology proposed to

accommodate the specific circumstances of testing,

with justification; and

g. Any proposed use of an alternative test method, with

detailed justification.

8.6.3 Test Reports

Unless otherwise specified elsewhere in this permit, the

results of any test required by this permit shall be

submitted to the Illinois EPA within 60 days of completion

of the testing. The test report shall include at a

minimum [Section 39.5(7)(e)(i) of the Act]:

a. The name and identification of the affected unit(s);

b. The date and time of the sampling or measurements;

c. The date any analyses were performed;

d. The name of the company that performed the tests

and/or analyses;

e. The test and analytical methodologies used;

f. The results of the tests including raw data, and/or

analyses including sample calculations;

g. The operating conditions at the time of the sampling

or measurements; and

h. The name of any relevant observers present including

the testing company’s representatives, any Illinois

EPA or USEPA representatives, and the representatives

of the source.

8.6.4 Reporting Addresses

a. The following addresses should be utilized for the

submittal of reports, notifications, and renewals:
35

i. Illinois EPA - Air Compliance Section

Illinois Environmental Protection Agency

Bureau of Air

Compliance Section (MC 40)

P.O. Box 19276

Springfield, Illinois 62794-9276

ii. Illinois EPA - Air Regional Field Office

Illinois Environmental Protection Agency

Division of Air Pollution Control

Eisenhower Tower

1701 South First Avenue

Maywood, Illinois 60153

iii. Illinois EPA - Air Permit Section (MC 11)

Illinois Environmental Protection Agency

Division of Air Pollution Control

Permit Section

P.O. Box 19506

Springfield, Illinois 62794-9506

iv. USEPA Region 5 - Air Branch

USEPA (AR - 17J)

Air & Radiation Division

77 West Jackson Boulevard

Chicago, Illinois 60604

b. Unless otherwise specified in the particular

provision of this permit, reports shall be sent to

the Illinois EPA - Air Compliance Section with a copy

sent to the Illinois EPA - Air Regional Field Office.

8.7 Obligation to Comply with Title I Requirements

Any term, condition, or requirement identified in this permit by

T1, T1R, or T1N is established or revised pursuant to 35 IAC Part

203 or 40 CFR 52.21 (“Title I provisions”) and incorporated into

this permit pursuant to both Section 39.5 and Title I provisions.

Notwithstanding the expiration date on the first page of this

permit, the Title I conditions remain in effect pursuant to Title

I provisions until the Illinois EPA deletes or revises them in

accordance with Title I procedures.
36

9.0 STANDARD PERMIT CONDITIONS

9.1 Effect of Permit

9.1.1 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 applicable

ordinances, except as specifically stated in this permit

and as allowed by law and rule [Section 39.5(7)(j)(iv) of

the Act].

9.1.2 In particular, this permit does not alter or affect the

following:

a. The provisions of Section 303 (emergency powers) of

the CAA, including USEPA's authority under that

Section;

b. The liability of an owner or operator of a source for

any violation of applicable requirements prior to or

at the time of permit issuance;

c. The applicable requirements of the acid rain program

consistent with Section 408(a) of the CAA; and

d. The ability of USEPA to obtain information from a

source pursuant to Section 114 (inspections,

monitoring, and entry) of the CAA.

9.1.3 Notwithstanding the conditions of this permit specifying

compliance practices for applicable requirements, any

person (including the Permittee) may also use other

credible evidence to establish compliance or noncompliance

with applicable requirements.

9.2 General Obligations of Permittee

9.2.1 Duty to Comply

The Permittee must comply with all terms and conditions of

this permit. Any permit noncompliance constitutes a

violation of the CAA and the Act, and is grounds for any

or all of the following: enforcement action, permit

termination, revocation and reissuance, modification, or

denial of a permit renewal application [Section

39.5(7)(o)(i) of the Act].

The Permittee shall meet applicable requirements that

become effective during the permit term in a timely manner
37

unless an alternate schedule for compliance with the

applicable requirement is established.

9.2.2 Duty to Maintain Equipment

The Permittee shall maintain all equipment covered under

this permit in such a manner that the performance or

operation of such equipment shall not cause a violation of

applicable requirements.

9.2.3 Duty to Cease Operation

No person shall cause, threaten or allow the continued

operation of any emission unit during malfunction or

breakdown of the emission unit or related air pollution

control equipment if such operation would cause a

violation of an applicable emission standard, regulatory

requirement, ambient air quality standard or permit

limitation unless such malfunction or breakdown is allowed

by a permit condition [Section 39.5(6)(c) of the Act].

9.2.4 Disposal Operations

The source shall be operated in such a manner that the

disposal of air contaminants collected by the equipment

operations, or activities shall not cause a violation of

the Act or regulations promulgated thereunder.

9.2.5 Duty to Pay Fees

The Permittee must pay fees to the Illinois EPA consistent

with the fee schedule approved pursuant to Section

39.5(18) of the Act, and submit any information relevant

thereto [Section 39.5(7)(o)(vi) of the Act]. The check

should be payable to "Treasurer, State of Illinois" and

sent to: Fiscal Services Section, Illinois Environmental

Protection Agency, P.O. Box 19276, Springfield, Illinois

62794-9276.

9.3 Obligation to Allow Illinois EPA Surveillance

Upon presentation of proper credentials and other documents, the

Permittee shall allow the Illinois EPA, or an authorized

representative to perform the following [Section 39.5(7)(a) and

(p)(ii) of the Act and 415 ILCS 5/4]:

a. Enter upon the Permittee's premises where an actual or

potential emission unit is located; where any regulated

equipment, operation, or activity is located or where

records must be kept under the conditions of this permit;
38

b. Have access to and copy, at reasonable times, any records

that must be kept under the conditions of this permit;

c. Inspect during hours of operation any sources, equipment

(including monitoring and air pollution control

equipment), practices, or operations regulated or required

under this permit;

d. Sample or monitor any substances or parameters at any

location:

i. At reasonable times, for the purposes of assuring

permit compliance; or

ii. As otherwise authorized by the CAA, or the Act.

e. Obtain and remove samples of any discharge or emission of

pollutants authorized by this permit; and

f. Enter and utilize any photographic, recording, testing,

monitoring, or other equipment for the purposes of

preserving, testing, monitoring, or recording any

activity, discharge or emission at the source authorized

by this permit.

9.4 Obligation to Comply With Other Requirements

The issuance of this permit does not release the Permittee from

applicable State and Federal laws and regulations, and applicable

local ordinances addressing subjects other than air pollution

control.

9.5 Liability

9.5.1 Title

This permit shall not be considered as in any manner

affecting the title of the premises upon which the

permitted source is located.

9.5.2 Liability of Permittee

This permit 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 sources.
39

9.5.3 Structural Stability

This permit does not take into consideration or attest to

the structural stability of any unit or part of the

source.

9.5.4 Illinois EPA Liability

This permit in no manner implies or suggests that the

Illinois EPA (or its officers, agents or employees)

assumes any liability, directly or indirectly, for any

loss due to damage, installation, maintenance, or

operation of the source.

9.5.5 Property Rights

This permit does not convey any property rights of any

sort, or any exclusive privilege [Section 39.5(7)(o)(iv)

of the Act].

9.6 Recordkeeping

9.6.1 Control Equipment Maintenance Records

A maintenance record shall be kept on the premises for

each item of air pollution control equipment. As a

minimum, this record shall show the dates of performance

and nature of preventative maintenance activities.

9.6.2 Records of Changes in Operation

A record shall be kept describing changes made at the

source that result in emissions of a regulated air

pollutant subject to an applicable requirement, but not

otherwise regulated under this permit, and the emissions

resulting from those changes [Section 39.5(12)(b)(iv) of

the Act].

9.6.3 Retention of Records

a. Records of all monitoring data and support

information shall be retained for a period of at

least 5 years from the date of the monitoring sample,

measurement, report, or application. Support

information includes all calibration and maintenance

records, original strip-chart recordings for

continuous monitoring instrumentation, and copies of

all reports required by this permit [Section

39.5(7)(e)(ii) of the Act].
40

b. Other records required by this permit shall be

retained for a period of at least 5 years from the

date of entry unless a longer period is specified by

a particular permit provision.

9.7 Annual Emissions Report

The Permittee shall submit an annual emissions report to the

Illinois EPA, Compliance Section no later than May 1 of the

following year, as required by 35 IAC Part 254.

9.8 Requirements for Compliance Certification

Pursuant to Section 39.5(7)(p)(v) of the Act, the Permittee shall

submit annual compliance certifications. The compliance

certifications shall be submitted no later than May 1 or more

frequently as specified in the applicable requirements or by

permit condition. The compliance certifications shall be

submitted to the Air Compliance Section, Air Regional Field

Office, and USEPA Region 5 – Air Branch. The addresses for the

submittal of the compliance certifications are provided in

Condition 8.6.4 of this permit.

a. The certification shall include the identification of each

term or condition of this permit that is the basis of the

certification; the compliance status; whether compliance

was continuous or intermittent; the method(s) used for

determining the compliance status of the source, both

currently and over the reporting period consistent with

the conditions of this permit.

b. All compliance certifications shall be submitted to USEPA

Region 5 in Chicago as well as to the Illinois EPA.

c. All compliance reports required to be submitted shall

include a certification in accordance with Condition 9.9.

9.9 Certification

Any document (including reports) required to be submitted by this

permit shall contain a certification by a responsible official of

the Permittee that meets the requirements of Section 39.5(5) of

the Act [Section 39.5(7)(p)(i) of the Act]. An example

Certification by a Responsible Official is included as an

attachment to this permit.
41

9.10 Defense to Enforcement Actions

9.10.1 Need to Halt or Reduce Activity Not a Defense

It shall not be a defense for the Permittee in an

enforcement action that it would have been necessary to

halt or reduce the permitted activity in order to maintain

compliance with the conditions of this permit [Section

39.5(7)(o)(ii) of the Act].

9.10.2 Emergency Provision

a. An emergency shall be an affirmative defense to an

action brought for noncompliance with the technologybased emission limitations under this permit if the

following conditions are met through properly signed,

contemporaneous operating logs, or other relevant

evidence:

i. An emergency occurred as provided in Section

39.5(7)(k) of the Act and the Permittee can

identify the cause(s) of the emergency.

Normally, an act of God such as lightning or

flood is considered an emergency;

ii. The permitted source was at the time being

properly operated;

iii. The Permittee submitted notice of the

emergency to the Illinois EPA within two

working days of the time when emission

limitations were exceeded due to the

emergency. This notice must contain a

detailed description of the emergency, any

steps taken to mitigate emissions, and

corrective actions taken; and

iv. During the period of the emergency the

Permittee took all reasonable steps to

minimize levels of emissions that exceeded the

emission limitations, standards, or

regulations in this permit.

b. This provision is in addition to any emergency or

upset provision contained in any applicable

requirement. This provision does not relieve a

Permittee of any reporting obligations under existing

federal or state laws or regulations.
42

9.11 Permanent Shutdown

This permit only covers emission units and control equipment while

physically present at the indicated source location(s). Unless

this permit specifically provides for equipment relocation, this

permit is void for the operation or activity of any item of

equipment on the date it is removed from the permitted location(s)

or permanently shut down. This permit expires if all equipment is

removed from the permitted location(s), notwithstanding the

expiration date specified on this permit.

9.12 Reopening and Reissuing Permit for Cause

9.12.1 Permit Actions

This permit may be modified, reopened, and reissued, for

cause pursuant to Section 39.5(15) of the Act. The filing

of a request by the Permittee for a permit modification,

revocation, and reissuance, or of a notification of

planned changes or anticipated noncompliance does not stay

any permit condition [Section 39.5(7)(o)(iii) of the

Act].

9.12.2 Reopening and Revision

This permit must be reopened and revised if any of the

following occur [Section 39.5(15)(a) of the Act]:

a. Additional requirements become applicable to the

equipment covered by this permit and three or more

years remain before expiration of this permit;

b. Additional requirements become applicable to an

affected source for acid deposition under the acid

rain program;

c. The Illinois EPA or USEPA determines that this permit

contains a material mistake or inaccurate statement

when establishing the emission standards or

limitations, or other terms or conditions of this

permit; and

d. The Illinois EPA or USEPA determines that this permit

must be revised to ensure compliance with the

applicable requirements of the Act.

9.12.3 Inaccurate Application

The Illinois EPA has issued this permit based upon the

information submitted by the Permittee in the permit

application. Any misinformation, false statement or
43

misrepresentation in the application shall be grounds for

revocation under Section 39.5(15)(b) of the Act.

9.12.4 Duty to Provide Information

The Permittee shall furnish to the Illinois EPA, within a

reasonable time specified by the Illinois EPA any

information that the Illinois EPA may request in writing

to determine whether cause exists for modifying, revoking

and reissuing, or terminating this permit, or to determine

compliance with this permit. Upon request, the Permittee

shall also furnish to the Illinois EPA copies of records

required to be kept by this permit, or for information

claimed to be confidential, the Permittee may furnish such

records directly to USEPA along with a claim of

confidentiality [Section 39.5(7)(o)(v) of the Act].

9.13 Severability Clause

The provisions of this permit are severable, and should any one or

more be determined to be illegal or unenforceable, the validity of

the other provisions shall not be affected. The rights and

obligations of the Permittee shall be construed and enforced as if

this permit did not contain the particular provisions held to be

invalid and the applicable requirements underlying these

provisions shall remain in force [Section 39.5(7)(i) of the Act].

9.14 Permit Expiration and Renewal

The right to operate terminates on the expiration date unless the

Permittee has submitted a timely and complete renewal application.

For a renewal to be timely it must be submitted no later than 9

and no sooner than 12 months prior to expiration. The equipment

may continue to operate during the renewal period until final

action is taken by the Illinois EPA, in accordance with the

original permit conditions [Section 39.5(5)(l), (n), and (o) of

the Act].
1-1

10.0 ATTACHMENTS

10.1 Attachment 1 Particulate Matter Emissions from Process Emission

Units

10.1.1 Section 212.321 Process Emission Units For Which

Construction or Modification Commenced On or After April

14, 1972

a. Except as further provided in 35 IAC Part 212, no

person shall cause or allow the emission of

particulate matter into the atmosphere in any one

hour period from any new process emission unit which,

either alone or in combination with the emission of

particulate matter from all other similar process

emission units for which construction or modification

commenced on or after April 14, 1972, at a source or

premises, exceeds the allowable emission rates

specified in subsection (c) of this Section.

b. Interpolated and extrapolated values of the data in

subsection (c) of this Section shall be determined by

using the equation:

E = A(P)Β

Where:

P = Process weight rate; and

E = Allowable emission rate; and,

i. Up to process weight rates of 408 Mg/hr (450

Ton/hr):

Metric English

P Mg/hr Ton/hr

E kg/hr lbs/hr

A 1.214 2.54

B 0.534 0.534

ii. For process weight rate greater than or equal

to 408 Mg/hr (450 Ton/hr):

Metric English

P Mg/hr Ton/hr

E kg/hr lbs/hr

A 11.42 24.8

B 0.16 0.16
1-2

c. Limits for Process Emission Units For Which

Construction of Modification Commenced On or After

April 14,1972

Metric English

P E P E

Mg/hr kg/hr Ton/hr lbs/hr

 0.05 0.25 0.05 0.55

 0.1 0.29 0.10 0.77

 0.2 0.42 0.20 1.10

 0.3 0.64 0.30 1.35

 0.4 0.74 0.40 1.58

 0.5 0.84 0.50 1.75

 0.7 1.00 0.75 2.40

 0.9 1.15 1.00 2.60

 1.8 1.66 2.00 3.70

 2.7 2.1 3.00 4.60

 3.6 2.4 4.00 5.35

 4.5 2.7 5.00 6.00

 9. 3.9 10.00 8.70

 13. 4.8 15.00 10.80

 18. 5.7 20.00 12.50

 23. 6.5 25.00 14.00

 27. 7.1 30.00 15.60

 32. 7.7 35.00 17.00

 36. 8.2 40.00 18.20

 41. 8.8 45.00 19.20

 45. 9.3 50.00 20.50

 90. 13.4 100.00 29.50

140. 17.0 150.00 37.00

180. 19.4 200.00 43.00

230. 22. 250.00 48.50

270. 24. 300.00 53.00

320. 26. 350.00 58.00

360. 28. 400.00 62.00

408. 30.1 450.00 66.00

454. 30.4 500.00 67.00

Where:

P = Process weight rate in Mg/hr or Ton/hr, and

E = Allowable emission rate in kg/hr or lbs/hr.

10.1.2 Section 212.322 Process Emission Units For Which

Construction or Modification Commenced Prior to April 14,

1972.

a. Except as further provided in 35 IAC Part 212, no

person shall cause or allow the emission of

particulate matter into the atmosphere in any one

hour period from any process emission unit for which
1-3

construction or modification commenced prior to April

14,1972, which, either alone or in combination with

the emission of particulate matter from all other

similar process emission units at a source or

premises, exceeds the allowable emission rates

specified in subsection (c) of this Section.

b. Interpolated and extrapolated values of the data in

subsection (c) of this Section shall be determined by

using the equation:

E = C + A(P)Β

Where:

P = process weight rate; and,

E = allowable emission rate; and,

i. For process weight rates up to 27.2 Mg/hr (30

Ton/hr):

Metric English

P Mg/hr Ton/hr

E kg/hr lbs/hr

A 1.985 4.10

B 0.67 0.67

C 0 0

ii. For process weight rates in excess or 27.2

Mg/hr (30 Ton/hr):

Metric English

P Mg/hr Ton/hr

E kg/hr lbs/hr

A 25.21 55.0

B 0.11 0.11

C -18.4 -40.0

c. Limits for Process Emission Units for Which

Construction or Modification Commenced Prior to

April 14, 1972

Metric English

P E P E

Mg/hr kg/hr Ton/hr lbs/hr

 0.05 0.27 0.05 0.55

 0.1 0.42 0.10 0.87

 0.2 0.68 0.20 1.40

 0.3 0.89 0.30 1.83

 0.4 1.07 0.40 2.22

 0.5 1.25 0.50 2.58
1-4

 0.7 1.56 0.75 3.38

 0.9 1.85 1.00 4.10

 1.8 2.9 2.00 6.52

 2.7 3.9 3.00 8.56

 3.6 4.7 4.00 10.40

 4.5 5.4 5.00 12.00

 9. 8.7 10.00 19.20

 13. 11.1 15.00 25.20

 18. 13.8 20.00 30.50

 23. 16.2 25.00 35.40

 27.2 18.15 30.00 40.00

 32.0 18.8 35.00 41.30

 36.0 19.3 40.00 42.50

 41.0 19.8 45.00 43.60

 45.0 20.2 50.00 44.60

 90.0 23.2 100.00 51.20

140.0 25.3 150.00 55.40

180.0 26.5 200.00 58.60

230.0 27.7 250.00 61.00

270.0 28.5 300.00 63.10

320.0 29.4 350.00 64.90

360.0 30.0 400.00 66.20

400.0 30.6 450.00 67.70

454.0 31.3 500.00 69.00

Where:

P = Process weight rate in Mg/hr or Ton/hr, and

E = Allowable emission rate in kg/hr or lbs/hr.
2-1

10.2 Attachment 2 Example Certification by a Responsible Official

I certify under penalty of law that this document and all

attachments were prepared under my direction or supervision in

accordance with a system designed to assure that qualified

personnel properly gather and evaluate the information submitted.

Based on my inquiry of the person or persons directly responsible

for gathering the information, the information submitted is, to

the best of my knowledge and belief, true, accurate, and complete.

I am aware that there are significant penalties for submitting

false information, including the possibility of fine and

imprisonment for knowing violations.

Signature: ______________________________________________

Name: ______________________________________________

Official Title: ______________________________________________

Telephone No.: ______________________________________________

Date Signed: ______________________________________________

JS:psj
I. INTRODUCTION

This source has applied for a Clean Air Act Permit Program (CAAPP)

operating permit for its existing operation. The CAAPP is the program

established in Illinois for the operating permits for significant

stationary sources required by the federal Clean Air Act, as amended in

1990. The conditions in a CAAPP permit are enforceable by both the

Illinois Environmental Protection Agency (Illinois EPA) and the USEPA.

En-Chro Plating, Ltd., is located at 2755 West Lake Street in Melrose

Park, Illinois. The source performs hard chrome plating of hydraulic

shafting-rolls-cylinders, steel components, and assemblies, molds and

dies. In addition, the source polishes items and performs electroless

nickel plating as required.

II. EMISSION UNITS

Significant emission units at this source are as follows:

Emission

Unit Description

Date

Constructed

Emission Control

Equipment

01 Hard Chromium

Electroplating Tank #1

1991 Composite Mesh Pad

System

02 Hard Chromium

Electroplating Tank #2

5/1994 Composite Mesh Pad

System

03 Hard Chromium

Electroplating Tank #3

1991 Composite Mesh Pad

System

04 Hard Chromium

Electroplating Tank #4

1991 Composite Mesh Pad

System

05 Hard Chromium

Electroplating Tank #5

1991 Composite Mesh Pad

System

06 Hard Chromium

Electroplating Tank #6

1991 Composite Mesh Pad

System

07 Hard Chromium

Electroplating Tank #7

7/1995 Composite Mesh Pad

System

08 Hard Chromium

Electroplating Tank #8

7/1995 Composite Mesh Pad

System

III. EMISSIONS

This source is required to have a CAAPP permit since it is a major

source of emissions.

For purposes of fees, the source is allowed the following emissions:
Page 2

 Permitted Emissions of Regulated Pollutants

Pollutant Tons/Year

Volatile Organic Material (VOM) --

Sulfur Dioxide (SO2) --

Particulate Matter (PM) 9.42

Nitrogen Oxides (NOx) --

HAP, not included in VOM or PM 9.42

TOTAL 18.84

IV. APPLICABLE EMISSION STANDARDS

All emission sources in Illinois must comply with the Illinois Pollution

Control Board’s emission standards. The Board's emission standards

represent the basic requirements for sources in Illinois.

All emission sources in Illinois must comply with the federal New Source

Performance Standards (NSPS). The Illinois EPA is administering NSPS in

Illinois on behalf of the United States EPA under a delegation

agreement.

All emission sources in Illinois must comply with the federal National

Emission Standards for Hazardous Air Pollutants (NESHAP). The Illinois

EPA is administering NESHAP in Illinois on behalf of the United States

EPA under a delegation agreement.

V. PROPOSED PERMIT

CAAPP

A CAAPP permit contains all conditions that apply to a source and a

listing of the applicable state and federal air pollution control

regulations that are the origin of the conditions. The permit also

contains emission limits and appropriate compliance procedures. The

appropriate compliance procedures may include inspections, work

practices, monitoring, record keeping, and reporting to show compliance

with these requirements. The Permittee must carry out these procedures

on an on-going basis.

Title I

A combined Title I/CAAPP permit contains terms and conditions

established by the Illinois EPA pursuant to authority found in Title I

provisions, e.g., 40 CFR 52.21 - federal Prevention of Significant

Deterioration (PSD) and 35 IAC Part 203 - Major Stationary Sources

Construction and Modification. Notwithstanding the expiration date on
Page 3

the first page of the permit, the Title I conditions remain in effect

pursuant to Title I provisions until the Illinois EPA deletes or revises

them in accordance with Title I procedures.

VI. REQUEST FOR COMMENTS

It is the Illinois EPA's preliminary determination that this source’s

permit application meets the standards for issuance of a CAAPP permit.

The Illinois EPA is therefore proposing to issue a CAAPP permit, subject

to the conditions proposed in the draft permit.

Comments are requested on this proposed action by the Illinois EPA and

the proposed conditions on the draft permit. If substantial public

interest is shown in this matter, the Illinois EPA will consider holding

a public hearing in accordance with 35 Ill. Adm. Code Part 164.

JS:psj