October 22, 2009

Mr. Bob Kantor

Hard Chrome, Inc. 

2631 Second Street Northeast

Minneapolis, MN 55418

RE: Notice of Compliance for the August 12, 2009, Performance Test on the Hard Chromium Plating Emission 

Units (EU004, EU005/CE001) Pursuant to Air Emission Permit No. 05300247-001 (Permit), Test Plan 

Approval dated August 4, 2009, and MPCA letter dated May 5, 2009 

Dear Mr. Kantor:

The Minnesota Pollution Control Agency (MPCA) staff has reviewed the final test report for the test conducted 

on the emission unit(s) referenced above at the Hard Chrome, Inc. (Company) facility located in Minneapolis, 

Minnesota. The test report was received September 24, 2009, and the microfiche/compact disc copy of the test 

report was received September 29, 2009.

The MPCA staff has determined that the test results demonstrate the following under test conditions: 

SUMMARY OF PERFORMANCE TEST RESULTS

Emission Unit 

Tested

Limitation 

Basis

Pollutant and 

Emission Limit Test Result Compliance Status

Chromium Plating 

Emission Units

EU004, EU005

SV001, CE001

40 CFR 

§ 63.342(c)(1)(i)

Chromium:

≤ 0.015 mg/dscm

Chromium:

0.0015 mg/dscm

Compliant

The test was conducted while operating with an average total amperage of 10,092. The mist eliminator inlet had 

an average pressure drop of 1.5 inches of water column. These parameters are within the ranges defined in the 

approved test plan. Operating limits based on these conditions are defined in Item 1 of this letter.

In addition, please be advised of the following:

1. The following operating limit applies pursuant to Minn. R. 7017.2025, subp. 3. This limit applies in addition 

to any operating limit or requirement that already exists, and it does not serve to relax any limit or requirement 

except where prior authorization has been given by the MPCA staff. Note: Your facility has a Title V (Part 70) 

Permit; therefore your permit will be re-opened (under Minn. R. 7007.1600, 

subp. 1(D)) in order to add the new operating limit. This letter serves as your 30-day notice of the MPCA's 

intent to amend your permit. The new operating limit is now effective and any operational changes shall be 

made upon receipt of this letter. 
Emission 

Unit Production Limit Averaging Method

Mist 

Eliminator

(CE001)

Pressure Drop:

Not to exhibit less than 0.5 inches 

of water column (≥ 0.5 in w.c.)

Not to exhibit greater than 3.5 in 

w.c. (≤ 3.5w.c.)

Instantaneous Reading taken once Daily

Based on the average pressure drop reading 

observed during the most recent performance test. 

Record pressure drop at inlet of Mist Eliminator 

(CE001) at least once each day of operation. 

The Company may not operate a control equipment unit at a less stringent rate than that listed in the 

table above unless it conducts a performance test at an alternate rate and the MPCA staff determines 

compliance at that rate for the emission unit.

2. If an operating/production limit is exceeded, it must be reported in accordance with the deviation reporting 

requirements of Minn. R. 7007.0800, subp. 6(A).

3. The operating conditions met the worst-case operating condition as defined in the approved test plan. 

However, please be aware that should operating practices change such that the current definition of worstcase becomes outdated, the MPCA may require a performance test at the new worst-case condition.

4. The Emission Inventory rule, Minn. R. 7019.3000 to 7019.3100, requires the calculation of emissions based 

on an established hierarchy. In the absence of Continuous Emission Monitor data meeting the requirements 

of Minn. R. 7019.3040, the next method of calculation, a performance test, must be used. When a 

performance test for particulate matter, particulate matter with an aerodynamic diameter less than or equal to 

a nominal ten micrometers, carbon monoxide, nitrogen oxides, sulfur oxides, volatile organic compounds or 

lead is conducted and meets the requirements of Minn. 

R. 7017.2001 to 7017.2060, the results must be used to calculate emissions, unless specified otherwise by 

Minn. R. 7019.3000 to 7019.3100. It is the Company’s responsibility to ensure the results of performance 

tests are accounted for in their annual emission inventory submittal. Note that the final decision to approve 

the emission factor for any given inventory year will be made by the Emission Inventory Coordinator.

If you have questions or comments regarding the content of this letter, please contact me at 651-757-2359.

Your continued cooperation is appreciated.

Sincerely,

Shanda L. Fisher

Pollution Control Specialist

Compliance and Enforcement Section

Industrial Division

SLF:rrh

cc: Brent Rohne, MPCA St. Paul

Kelsey Suddard, MPCA St. Paul

AQ Correspondence File No. 1687