MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

June 4, 2004

NEW SOURCE REVIEW PERMIT TO INSTALL

No. 213-01B

ISSUED TO

Perfection Industries, Inc.

LOCATED AT

18571 Weaver Street

Detroit, Michigan 48228

IN THE COUNTY OF

Wayne

STATE REGISTRATION NUMBER

N0305

The Air Quality Division has approved this Permit to Install, pursuant to the delegation of authority 

from the Michigan Department of Environmental Quality. This permit is hereby issued in

accordance with and subject to Part 5505(1) of Article II, Chapter I, Part 55 (Air Pollution Control) 

of P.A. 451 of 1994. Pursuant to Air Pollution Control Rule 336.1201(1), this permit constitutes 

the permittee’s authority to install the identified emission unit(s) in accordance with all 

administrative rules of the Department and the attached conditions. Operation of the emission 

unit(s) identified in this Permit to Install is allowed pursuant to Rule 336.1201(6).

DATE OF RECEIPT OF ALL INFORMATION REQUIRED BY RULE 203:

5/21/2004

DATE PERMIT TO INSTALL APPROVED:

6/4/2004

SIGNATURE:

DATE PERMIT VOIDED: SIGNATURE:

DATE PERMIT REVOKED: SIGNATURE:
Perfection Industries, Inc. June 4, 2004

Permit No. 213-01B Page 1 of 7

PERMIT TO INSTALL

Table of Contents

Section Page

Alphabetical Listing of Common Abbreviations / Acronyms...........................................................................2

General Conditions.......................................................................................................................................3

Emission Unit Identification..........................................................................................................................5

Flexible Group Identification ........................................................................................................................5

Flexible Group Special Conditions ................................................................................................................5
Perfection Industries, Inc. June 4, 2004

Permit No. 213-01B Page 2 of 7

Common Abbreviations / Acronyms

Common Acronyms Pollutant/Measurement Abbreviations

AQD Air Quality Division Btu British Thermal Unit

ANSI American National Standards Institute °C Degrees Celsius

BACT Best Available Control Technology CO Carbon Monoxide

CAA Clean Air Act dscf Dry standard cubic foot

CEM Continuous Emission Monitoring dscm Dry standard cubic meter

CFR Code of Federal Regulations °F Degrees Fahrenheit

COM Continuous Opacity Monitoring gr Grains

EPA Environmental Protection Agency Hg Mercury 

EU Emission Unit hr Hour 

FG Flexible Group H2S Hydrogen Sulfide

GACS Gallon of Applied Coating Solids hp Horsepower 

GC General Condition lb Pound

HAP Hazardous Air Pollutant m Meter

HVLP High Volume Low Pressure * mg Milligram 

ID Identification mm Millimeter

LAER Lowest Achievable Emission Rate MM Million

MACT Maximum Achievable Control Technology MW Megawatts

MAERS Michigan Air Emissions Reporting System NOx Oxides of Nitrogen 

MAP Malfunction Abatement Plan PM Particulate Matter 

MDEQ Michigan Department of Environmental Quality PM-10 Particulate Matter less than 10 microns diameter

MIOSHA Michigan Occupational Safety & Health 

Administration

pph Pound per hour

MSDS Material Safety Data Sheet ppm Parts per million

NESHAP National Emission Standard for Hazardous Air 

Pollutants

ppmv Parts per million by volume 

NSPS New Source Performance Standards ppmw Parts per million by weight 

NSR New Source Review psia Pounds per square inch absolute

PS Performance Specification psig Pounds per square inch gauge 

PSD Prevention of Significant Deterioration scf Standard cubic feet

PTE Permanent Total Enclosure sec Seconds 

PTI Permit to Install SO2 Sulfur Dioxide 

RACT Reasonable Available Control Technology THC Total Hydrocarbons

ROP Renewable Operating Permit tpy Tons per year

SC Special Condition Number μg Microgram 

SCR Selective Catalytic Reduction VOC Volatile Organic Compounds 

SRN State Registration Number yr Year 

TAC Toxic Air Contaminant

VE Visible Emissions

* For High Volume Low Pressure (HVLP) applicators, the pressure measured at the HVLP gun air cap shall not exceed ten 

(10) pounds per square inch gauge (psig). 
Perfection Industries, Inc. June 4, 2004

Permit No. 213-01B Page 3 of 7

GENERAL CONDITIONS

1. The process or process equipment covered by this permit shall not be reconstructed, relocated, or 

modified, unless a Permit to Install authorizing such action is issued by the Department, except to the 

extent such action is exempt from the Permit to Install requirements by any applicable rule. 

[R336.1201(1)]

2. If the installation, construction, reconstruction, relocation, or modification of the equipment for which 

this permit has been approved has not commenced within 18 months, or has been interrupted for 18 

months, this permit shall become void unless otherwise authorized by the Department. Furthermore, the 

permittee or the designated authorized agent shall notify the Department via the Supervisor, Permit 

Section, Air Quality Division, Michigan Department of Environmental Quality, P.O. Box 30260,

Lansing, Michigan 48909, if it is decided not to pursue the installation, construction, reconstruction, 

relocation, or modification of the equipment allowed by this Permit to Install. [R336.1201(4)]

3. If this Permit to Install is issued for a process or process equipment located at a stationary source that is 

not subject to the Renewable Operating Permit program requirements pursuant to R336.1210, operation 

of the process or process equipment is allowed by this permit if the equipment performs in accordance 

with the terms and conditions of this Permit to Install. [R336.1201(6)(b)]

4. The Department may, after notice and opportunity for a hearing, revoke this Permit to Install if evidence 

indicates the process or process equipment is not performing in accordance with the terms and

conditions of this permit or is violating the Department’s rules or the Clean Air Act. [R336.1201(8), 

Section 5510 of Act 451, PA 1994]

5. The terms and conditions of this Permit to Install shall apply to any person or legal entity that now or 

hereafter owns or operates the process or process equipment at the location authorized by this Permit to 

Install. If the new owner or operator submits a written request to the Department pursuant to R336.1219 

and the Department approves the request, this permit will be amended to reflect the change of

ownership or operational control. The request must include all of the information required by subrules 

(1)(a), (b), and (c) of R336.1219. The written request shall be sent to the District Supervisor, Air 

Quality Division, Michigan Department of Environmental Quality. [R336.1219]

6. Operation of this equipment shall not result in the emission of an air contaminant which causes injurious 

effects to human health or safety, animal life, plant life of significant economic value, or property, or 

which causes unreasonable interference with the comfortable enjoyment of life and property. 

[R336.1901]

7. The permittee shall provide notice of an abnormal condition, start-up, shutdown, or malfunction that 

results in emissions of a hazardous or toxic air pollutant which continue for more than one hour in 

excess of any applicable standard or limitation, or emissions of any air contaminant continuing for more 

than two hours in excess of an applicable standard or limitation, as required in Rule 912, to the 

Department. The notice shall be provided not later than two business days after start-up, shutdown, or 

discovery of the abnormal condition or malfunction. Written reports, if required, must be filed with the 

Department within 10 days after the start-up or shutdown occurred, within 10 days after the abnormal 

conditions or malfunction has been corrected, or within 30 days of discovery of the abnormal condition 

or malfunction, whichever is first. The written reports shall include all of the information required in 

Rule 912(5). [R336.1912]

8. Approval of this permit does not exempt the permittee from complying with any future applicable 

requirements which may be promulgated under Part 55 of 1994 PA 451, as amended or the Federal 

Clean Air Act.
Perfection Industries, Inc. June 4, 2004

Permit No. 213-01B Page 4 of 7

9. Approval of this permit does not obviate the necessity of obtaining such permits or approvals from other 

units of government as required by law.

10. Operation of this equipment may be subject to other requirements of Part 55 of 1994 PA 451, as 

amended and the rules promulgated thereunder. 

11. Except as provided in subrules (2) and (3) or unless the special conditions of the Permit to Install 

include an alternate opacity limit established pursuant to subrule (4) of R336.1301, the permittee shall 

not cause or permit to be discharged into the outer air from a process or process equipment a visible 

emission of density greater than the most stringent of the following. The grading of visible emissions 

shall be determined in accordance with R336.1303. [R336.1301] 

a) A six-minute average of 20 percent opacity, except for one six-minute average per hour of not 

more than 27 percent opacity.

b) A visible emission limit specified by an applicable federal new source performance standard.

c) A visible emission limit specified as a condition of this permit to install.

12. Collected air contaminants shall be removed as necessary to maintain the equipment at the required 

operating efficiency. The collection and disposal of air contaminants shall be performed in a manner so 

as to minimize the introduction of contaminants to the outer air. Transport of collected air contaminants 

in Priority I and II areas requires the use of material handling methods specified in R336.1370(2). 

[R336.1370]

13. The Department may require the permittee to conduct acceptable performance tests, at the permittee’s 

expense, in accordance with R336.2001 and R336.2003, under any of the conditions listed in

R336.2001. [R336.2001]
Perfection Industries, Inc. June 4, 2004

Permit No. 213-01B Page 5 of 7

SPECIAL CONDITIONS

Emission Unit Identification

Emission Unit ID Emission Unit Description Stack Identification

EUCHROME2 Hard chrome electroplating tank with a composite mesh 

pad system for control which is shared with the other 

four hard chrome electroplating tanks.

SVCHROME1

EUCHROME3 Hard chrome electroplating tank with a composite mesh 

pad system for control which is shared with the other 

four hard chrome electroplating tanks. 

SVCHROME1

EUCHROME4 Hard chrome electroplating tank with a composite mesh 

pad system for control which is shared with the other 

four hard chrome electroplating tanks. 

SVCHROME1

EUCHROME5 Hard chrome electroplating tank with a composite mesh 

pad system for control which is shared with the other 

four hard chrome electroplating tanks. 

SVCHROME1

EUCHROME6 Hard chrome electroplating tank with a composite mesh 

pad system for control which is shared with the other 

four hard chrome electroplating tanks. 

SVCHROME1

Changes to the equipment described in this table are subject to the requirements of R336.1201, except as 

allowed by R336.1278 to R336.1290.

Flexible Group Identification

Flexible Group ID Emission Units Included in Flexible Group Stack Identification

FGCHROME1 EUCHROME2, EUCHROME3, EUCHROME4, 

EUCHROME5 and EUCHROME6

SVCHROME1

The following conditions apply to: FGCHROME1

Emission Limits

Pollutant Equipment Limit Time 

Period

Testing/

Monitoring 

Method

Applicable 

Requirements

1.1a Total 

chromium

FGCHROME1 0.006 milligram per 

dry standard cubic 

meter, corrected to 

70°F and 29.92 

inches Hg

Test 

Method

SC 1.5, 

SC 1.7, 

SC 1.8,

SC 1.9

R336.1225, 

R336.1941

40 CFR Part 63 

Subpart N 

1.1b Total 

chromium

FGCHROME1 4.0 * 10-4 pph Test 

Method

SC 1.5, 

SC 1.7, 

SC 1.8,

SC 1.9

R336.1225, 

R336.1941

40 CFR Part 63 

Subpart N

Equipment

1.2 The permittee shall not operate FGCHROME1 unless the composite mesh pad system is installed,

maintained, and operated in a satisfactory manner. [R336.1225, R336.1941, 40 CFR Part 63 Subpart N]
Perfection Industries, Inc. June 4, 2004

Permit No. 213-01B Page 6 of 7

1.3 The permittee shall equip and maintain the composite mesh pad system with a differential pressure 

monitoring device. [R336.1225, R336.1910, R336.1941, 40 CFR 63.343(c)]

Process/Operational Limits

1.4 Within 30 calendar days after compliance testing, the permittee shall submit to the AQD District 

Supervisor, a new approvable operation and maintenance plan only if the pressure drop value is different 

than the pressure drop value determined during the previous compliance test. The plan shall contain all 

information required by 40 CFR 63.342(f)(3)(i), which includes the following: [R336.1225, R336.1941, 

40 CFR Part 63 Subpart N]

a) Operation and maintenance criteria for FGCHROME1, add-on control device(s), and for the 

process and control device(s) monitoring equipment as well as a standardized checklist to 

document the operation and maintenance of the equipment;

b) The work practice standards for the add-on control device(s) and monitoring equipment;

c) Procedures to be followed to ensure that equipment or process malfunctions due to poor 

maintenance or other preventable conditions do not occur; and 

d) A systematic procedure for identifying process equipment, add-on control device(s) and 

monitoring equipment malfunctions and for implementing corrective actions to address such 

malfunctions.

Monitoring

1.5 The permittee shall perform inspections of the composite mesh pad (CMP) system as follows: 

[R336.1225, R336.1910, R336.1941, 40 CFR Part 63 Subpart N]

a) Determine pressure drop across the CMP system on a daily basis. If the pressure drop across the 

control varies by more than ±1 inch of water column, from the pressure drop determined during 

compliance testing, the variation shall be documented, and the operation and maintenance 

procedures shall be reviewed. Any corrective action shall be documented.

b) Visually inspect the CMP system, on a quarterly basis, to ensure there is proper drainage, no 

chromic acid build up on the pads, and no evidence of chemical attack on the structural integrity 

of the control device.

c) Visually inspect the back portion of the mesh pad closest to the fan, on a quarterly basis, to ensure 

there is no breakthrough of chromic acid mist.

d) Visually inspect ductwork from tanks to the CMP system, on a quarterly basis, to ensure there are 

no leaks.

e) Perform wash-down of composite mesh pads in accordance with manufacturer’s 

recommendations.

1.6 The permittee shall monitor emissions and operating and maintenance information in accordance with the 

National Emission Standards for Hazardous Air Pollutants as specified in 40 CFR Part 63 Subparts A and 

N. [R336.1941, 40 CFR Part 63 Subpart N]
Perfection Industries, Inc. June 4, 2004

Permit No. 213-01B Page 7 of 7

Testing

1.7 By September 30, 2004, verification of chromium emission rates from FGCHROME1, by testing at 

owner's expense, in accordance with 40 CFR Part 63 Subparts A and N, will be required. The permittee 

shall notify the District Supervisor in writing of the intention to conduct a performance test at least 60 

calendar days before the test is scheduled to begin, in accordance with 40 CFR 63.347(d). Stack testing 

procedures and the location of stack testing ports shall be in accordance with the applicable federal

Reference Methods, 40 CFR Part 63 Appendix A. No less than 60 days prior to testing, a complete stack 

test plan shall be submitted to the AQD. The final plan must be approved by the AQD prior to testing. 

Verification of emission rates includes the submittal of a complete report of the test results to the AQD 

District Supervisor within 90 days following the last date of the test. [R336.1225, R336.2001,

R336.2002, R336.2003, 40 CFR Part 63 Subpart N]

Recordkeeping/Reporting/Notification

1.8 The permittee shall maintain records of inspections required to comply with applicable work practice 

standards of 40 CFR 63.342(f). Each inspection record shall identify the device inspected, the date, 

approximate time of inspection, and a brief description of the working condition of the device during the 

inspection. The permittee shall also record any actions taken to correct the deficiencies found during the 

inspection. All records shall be kept on file for a period of at least five years and made available to the 

Department upon request. [R336.1225, R336.1910, R336.1941, 40 CFR Part 63 Subpart N]

1.9 The permittee shall keep records of emission information and operating and maintenance information to 

comply with the National Emission Standards for Hazardous Air Pollutants as specified in 40 CFR Part 63 

Subparts A and N. All source emissions and operating and maintenance information shall be kept on file 

for a period of at least five years and made available to the Department upon request. [R336.1941, 40 

CFR Part 63 Subpart N]

1.10 The permittee shall submit the Ongoing Compliance Status notification to the Department in accordance 

with 40 CFR Part 63.347: [R336.1941, 40 CFR Part 63 Subpart N]

Stack/Vent Restrictions

Stack & Vent ID Maximum Area 

(square inches)

Minimum Height Above

Ground Level (feet)

Applicable 

Requirements

1.11a SVCHROME1 991 26 R336.1225

The exhaust gases shall be discharged unobstructed vertically upwards to the ambient air.