STATIONARY SOURCE PERMIT TO CONSTRUCT AND OPERATE 

This permit includes designated equipment subject to 

National Emission Standards for Hazardous Air Pollutants.

 In compliance with the Federal Clean Air Act and the Commonwealth of Virginia Regulations for 

the Control and Abatement of Air Pollution, 

 Trident 

 12000 Vance Davis Drive 

 Charlotte, North Carolina 28269 

 Registration No.: 52175 

 

is authorized to modify and operate 

 a hard chromium electroplating facility 

located at 

 833 Liberty Way 

 Chester, Virginia 23836 

in accordance with the Conditions of this permit. 

Approved on October 8, 2009.

_____________________________________ 

James E. Kyle, P.E.

Air Permit Manager

Permit consists of 9 pages. 

Permit Conditions 1 to 28. 
Trident 

Registration Number: 52175 

October 8, 2009 

Page 2 

INTRODUCTION

This permit approval is based on the permit application dated January 4, 2007, including amendment 

information dated February 15, 2007, February 28, 2007 and October 2, 2009. Any changes in the permit 

application specifications or any existing facilities which alter the impact of the facility on air quality may 

require a permit. Failure to obtain such a permit prior to construction may result in enforcement action. 

Words or terms used in this permit shall have meanings as provided in 9 VAC 5-10-10 of the State Air 

Pollution Control Board Regulations for the Control and Abatement of Air Pollution. The regulatory 

reference or authority for each condition is listed in parentheses () after each condition. 

Annual requirements to fulfill legal obligations to maintain current stationary source emissions data will 

necessitate a prompt response by the permittee to requests by the DEQ or the Board for information to 

include, as appropriate: process and production data; changes in control equipment; and operating 

schedules. Such requests for information from the DEQ will either be in writing or by personal contact. 

The availability of information submitted to the DEQ or the Board will be governed by applicable 

provisions of the Freedom of Information Act, §§ 2.2-3700 through 2.2-3714 of the Code of Virginia, § 

10.1-1314 (addressing information provided to the Board) of the Code of Virginia, and 9 VAC 5-170-60 of 

the State Air Pollution Control Board Regulations. Information provided to federal officials is subject to 

appropriate federal law and regulations governing confidentiality of such information. 

PROCESS REQUIREMENTS

1. Equipment List - Equipment at this facility consists of the following: 

Equipment to be Constructed 

Reference No. Equipment Description Rated Capacity Federal Requirements

Chromium Electroplating Process: 

P001-Tank 1 Chromium plating tank #1 (2002) 336 gallons MACT, Subpart N 

(area source) 

Dechroming Operations: 

DC-1 Dechroming tank #1 238 gallons 

DC-2 Dechroming tank #2 238 gallons 

Equipment Exempt from Permitting 

Reference No. Equipment Description Rated Capacity Exemption Citation 

Alkali Copper Plating Process: 

ALP-1 Alkali plating bath tank #1 159 gallons 9 VAC 5-80-1320 C.1 

Acid Copper Plating Process: 

ACP-1 Acid copper plating tank #1 312 gallons 9 VAC 5-80-1320 C.1 

ACP-2 Acid copper plating tank #2 312 gallons 9 VAC 5-80-1320 C.1 

ACP-3 Acid copper plating tank #3 312 gallons 9 VAC 5-80-1320 C.1 

ACP-4 Acid copper plating tank #4 312 gallons 9 VAC 5-80-1320 C.1 

Proofing Operations: 

PP-1 & PP-2 Two low-volume single rotation 

proofing presses 

4.7 lbs VOC/hr 

combined 

9 VAC 5-80-1320 C.1 
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Registration Number: 52175 

October 8, 2009 

Page 3 

Wastewater Evaporators: 

WE-1 Wastewater evaporator (natural gas) 0.6 MMBtu/hr 9 VAC 5-80-1320 B.1.d 

WE-2 Wastewater evaporator (natural gas) 0.6 MMBtu/hr 9 VAC 5-80-1320 B.1.d 

Miscellaneous: 

-- Four mechanical engravers -- 9 VAC 5-80-1320 C.1 

-- One fiber laser for copper engraving -- 9 VAC 5-80-1320 C.1 

-- Two milling machines -- 9 VAC 5-80-1320 C.1 

-- One lathing machine -- 9 VAC 5-80-1320 C.1 

(9 VAC 80-1180 D 3) 

2. Emission Controls – Particulate and chromium emissions from the chromium plating tank (Ref. No. 

P001-Tank 1) shall be controlled by a mesh pad mist eliminator/scrubber in series with a HEPA filter 

(Ref. No. CD001). The eliminator/scrubber shall be provided with adequate access for inspection and 

shall be in operation when the chromium plating tank is operating. 

(9 VAC 5-80-1180 and 9 VAC 5-50-260) 

3. Emission Controls – Particulate and chromium emissions from the two (2) dechroming tanks (Ref. 

Nos. DC-1 and DC-2) shall be controlled by a mesh pad mist eliminator in series with a HEPA filter 

(Ref. No. CD002). The eliminator shall maintain a control efficiency for particulates and chromium of 

no less than 99.0 percent. The eliminator shall be provided with adequate access for inspection and 

shall be in operation when the two (2) dechroming tanks are operating. 

(9 VAC 5-80-1180 and 9 VAC 5-50-260) 

4. Monitoring Devices - The mesh pad mist eliminator/scrubber (Ref. Nos. CD001) shall be equipped 

with devices to continuously measure the scrubber liquid flow rate and differential pressure across the 

scrubber and mesh pad mist eliminator. Each monitoring device shall be installed, maintained, 

calibrated and operated in accordance with approved procedures which shall include, as a minimum, 

the manufacturer's written requirements or recommendations. Each monitoring device shall be 

provided with adequate access for inspection and shall be in operation when the scrubber and mesh 

pad mist eliminator is operating. 

(9 VAC 5-80-1180 D) 

5. Monitoring Device Observation – To ensure good performance, the process/control monitoring 

device used to continuously measure the scrubber liquid flow rate and differential pressure across the 

scrubber and mesh pad mist eliminator shall be observed by the permittee with a frequency of not 

less than once per day. The permittee shall keep a log of the observations from the process/control 

monitoring device. The system shall be operated within ± 2 inches of water column of the pressure 

drop value established during the initial performance test or within the range established during the 

most recent performance test which demonstrated compliance with the emission limit in Condition 9. 

(9 VAC 5-80-1180 D and 40 CFR 63.343(c)(1)(ii)) 

OPERATING LIMITATIONS

6. Throughput - The maximum chromium plating current for the chroming plating tank (Ref. No. P001-

Tank 1) shall not exceed 4,000 amps. 

(9 VAC 5-80-1180) 

7. Throughput - The maximum dechroming plating current for the dechroming tanks (Ref. Nos. DC-1 

and DC-2) shall not exceed 100 amps each. 

(9 VAC 5-80-1180) 
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Registration Number: 52175 

October 8, 2009 

Page 4 

8. Requirements by Reference - Except where this permit is more restrictive than the applicable 

requirement, the MACT equipment as described in Condition 1 shall be operated in compliance with 

the requirements of 40 CFR 63, Subpart N. 

(9 VAC 5-80-1180, 9 VAC 5-60-90, and 9 VAC 5-60-100) 

EMISSION LIMITS

9. Process Emission Limits - Emissions from the operation of the chromium electroplating process 

(Ref. Nos. P001-Tank 1) as exhausted from the mesh pad mist eliminator/scrubber (Ref. No. CD001) 

shall not exceed the limits specified below: 

Chromium Compounds 0.015 mg/dscm 

These emissions are derived from the estimated overall emission contribution from operating limits. 

Exceedance of the operating limits may be considered credible evidence of the exceedance of 

emission limits. Compliance with these emission limits may be determined as stated in Conditions 2 

and 6. 

(9 VAC 5-80-1180 and 40 CFR 63.342(c)(2)(i)) 

10. Visible Emission Limit - Visible emissions from the mesh pad mist eliminator/scrubber exhaust (Ref. 

No. CD001) shall not exceed 5 percent opacity as determined by the EPA Method 9 (reference 40 

CFR 60, Appendix A). 

(9 VAC 5-80-1180 and 9 VAC 5-50-260) 

11. Visible Emission Limit - Visible emissions from mist eliminator exhaust (Ref. No. CD002) shall not 

exceed 5 percent opacity as determined by the EPA Method 9 (reference 40 CFR 60, Appendix A). 

(9 VAC 5-80-1180 and 9 VAC 5-50-260) 

INITIAL COMPLIANCE DETERMINATION

12. Stack Test - Initial performance tests shall be conducted for chromium emissions from the mesh pad 

mist eliminator/scrubber (Ref. No. CD001) using Reference Method 306 or 306A to determine 

compliance with the emission limit contained in Condition 9. The permittee shall establish the 

pressure drop across the system as a site-specific operating parameter, setting the value that 

corresponds to compliance with the emission limit contained in Condition 9. The tests shall be 

performed and demonstrate compliance within 60 days after achieving the maximum production rate 

at which the facility will be operated but in no event later than 180 days after start-up of the permitted 

facility. Tests shall be conducted and reported and data reduced as set forth in 9 VAC 5-50-30 and 9 

VAC 5-60-30, and the test methods and procedures contained in each applicable section or subpart 

listed in 9 VAC 5-50-410 and 9 VAC 5-60-70. The details of the tests are to be arranged with the 

Director, Piedmont Region. The permittee shall submit a test protocol at least 30 days prior to 

testing. One copy of the test results shall be submitted to the Director, Piedmont Region within 45 

days after test completion and shall conform to the test report format enclosed with this permit. 

(9 VAC 5-50-30, 9 VAC 5-80-1200, and 40 CFR 63.344(c)(1)) 

13. Stack Test - Initial performance tests shall be conducted for chromium emissions from the mesh pad 

mist eliminator (Ref. No. CD002) to determine compliance with the control efficiency requirements 

contained in Condition 3. The tests shall be performed and demonstrate compliance within 60 days 

after achieving the maximum production rate at which the facility will be operated but in no event later 

than 180 days after start-up of the permitted facility. Tests shall be conducted and reported and data 

reduced as set forth in 9 VAC 5-50-30 and 9 VAC 5-60-30, and the test methods and procedures 

contained in each applicable section or subpart listed in 9 VAC 5-50-410 and 9 VAC 5-60-70. The 

details of the tests are to be arranged with the Director, Piedmont Region. The permittee shall submit 
Trident 

Registration Number: 52175 

October 8, 2009 

Page 5 

a test protocol at least 30 days prior to testing. One copy of the test results shall be submitted to the 

Director, Piedmont Region within 45 days after test completion and shall conform to the test report 

format enclosed with this permit. 

(9 VAC 5-50-30 and 9 VAC 5-80-1200) 

14. Visible Emissions Evaluation - Visible Emission Evaluations (VEE) in accordance with 40 CFR Part 

60, Appendix A, Method 9, shall also be conducted by the permittee on the mesh pad mist 

eliminator/scrubber (Ref. No. CD001) and the mesh pad mist eliminator (Ref. No. CD002). Each test 

shall consist of 30 sets of 24 consecutive observations (at 15 second intervals) to yield a six minute 

average. The details of the tests are to be arranged with the Director, Piedmont Region. The 

permittee shall submit a test protocol at least 30 days prior to testing. The evaluation shall be 

performed and demonstrate compliance within 60 days after achieving the maximum production rate 

at which the facility will be operated but in no event later than 180 days after start-up of the permitted 

facility. Should conditions prevent concurrent opacity observations, the Director, Piedmont Region 

shall be notified in writing, within seven days, and visible emissions testing shall be rescheduled 

within 30 days. Rescheduled testing shall be conducted under the same conditions (as possible) as 

the initial performance tests. One copy of the test result shall be submitted to the Director, Piedmont 

Region within 45 days after test completion and shall conform to the test report format enclosed with 

this permit. 

(9 VAC 5-50-30 and 9 VAC 5-80-1200) 

RECORDS

15. On Site Records - The permittee shall maintain records of emission data and operating parameters 

as necessary to demonstrate compliance with this permit. The content and format of such records 

shall be arranged with the Director, Piedmont Region. These records shall include, but are not limited 

to: 

a. Annual amp-hours of the chromium electroplating process, calculated monthly as the sum of each 

consecutive 12-month period. Compliance for the consecutive 12-month period shall be 

demonstrated monthly by adding the total for the most recently completed calendar month to the 

individual monthly totals for the preceding 11 months. 

b. The maximum chromium plating current for the chromium electroplating tank (Ref. Nos. P001-

Tank 1). 

c. The maximum dechroming plating current for the dechroming tanks (Ref. Nos. DC-1 and DC-2). 

d. Material Safety Data Sheets (MSDS) other vendor information as approved by DEQ showing 

VOC content, toxic compound content, and HAP content for each ink and solvent used. 

e. The results of the control device monitoring observations (log) required by Condition 5, any 

corrective actions taken for abnormal observation readings, and any documentation certifying 

compliant control device operating conditions during periods of abnormal observation readings. 

f. Inspection records for the mesh pad mist eliminator/scrubber (Ref. No. CD001) and the 

process/control monitoring equipment to document that the inspection and maintenance required 

in 40 CFR 63.342(f) have taken place. The record can be a checklist to include 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. 

g. Results of all stack tests, visible emission evaluations and performance evaluations. 

h. Scheduled and unscheduled maintenance and operator training. 
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Registration Number: 52175 

October 8, 2009 

Page 6 

These records shall be available for inspection by the DEQ and shall be current for the most recent 

five years. 

(9 VAC 5-80-1180, 9 VAC 5-50-50, and 40 CFR 63.346(b)) 

16. Operation and Maintenance Plan - The permittee shall prepare an operation and maintenance plan 

for the chromium plating tank (Ref. No. P001-Tank 1) which shall include: 

a. Specify the operation and maintenance criteria for the tank, the mesh pad mist 

eliminator/scrubber (Ref. No. CD001), and the process/control monitoring equipment, and shall 

include a standardized checklist to document the operation and maintenance of this equipment; 

b. The work practice standards for the mesh pad mist eliminator/scrubber (Ref. No. CD001) and the 

process/control monitoring equipment, as listed below: 

i. Visually inspect device to ensure there is proper drainage, no chronic acid buildup on the 

pads, and no evidence of chemical attack on the structural integrity of the device 1/quarter. 

ii. Visually inspect back portion of the mesh pad closest to the fan to ensure there is no 

breakthrough of chromic acid mist 1/quarter. 

iii. Visually inspect ductwork from tank to the control device to ensure there are no leaks 

1/quarter. 

iv. Perform wash-down of the composite mesh pads in accordance with manufacturers 

recommendations per manufacturer. 

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 malfunctions of the tank, the mesh pad mist 

eliminator/scrubber (Ref. No. CD001), and the process/control monitoring equipment and for 

implementing corrective actions to address such malfunctions. 

The permittee shall keep the written operation and maintenance plan on record and these records 

shall be available for inspection by the DEQ and shall be current for the most recent five years. 

(9 VAC 5-80-1180, 9 VAC 5-50-50, and 40 CFR 63.342(f)(3)) 

17. Emissions Testing - The facility shall be constructed/modified/installed so as to allow for emissions 

testing upon reasonable notice at any time, using appropriate methods. This includes constructing the 

facility/equipment such that volumetric flow rates and pollutant emission rates can be accurately 

determined by applicable test methods and providing a stack or duct that is free from cyclonic flow. 

Sampling ports shall be provided when requested at the appropriate locations and safe sampling 

platforms and access shall be provided. 

(9 VAC 5-50-30 F and 9 VAC 5-80-1180) 

NOTIFICATIONS

18. Initial Notifications - The permittee shall furnish written notification to the Director, Piedmont Region 

of: 

a. The actual date on which construction of the hard chromium electroplating facility commenced 

within 30 days after such date. 
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Registration Number: 52175 

October 8, 2009 

Page 7 

b. The anticipated start-up date of the hard chromium electroplating facility postmarked not more 

than 60 days nor less than 30 days prior to such date. 

c. The actual start-up date of the hard chromium electroplating facility within 15 days after such 

date. 

d. The anticipated date of stack tests and visible emission evaluations postmarked at least 60 days 

prior to such date. 

e. The date of compliance status to MACT, Subpart N no later than 90 days after the completion of 

the stack test required in Condition 12. This notification shall include all items listed in 40 CFR 

63.347(e)). 

(9 VAC 5-50-50 and 9 VAC 5-80-1180) 

REPORTING

19. Ongoing Compliance Status Reports - The permittee shall prepare a summary report to document 

the ongoing compliance status of the chromium plating tank (Ref. No. P001-Tank 1). The report shall 

contain all items listed in 40 CFR 63.347(g)(3) and shall be completed annually and retained on site. 

The time duration may change if 40 CFR 63.347(h)(2) conditions are met. 

(9 VAC 5-50-50, 9 VAC 5-80-1180, and 40 CFR 63.347(h)) 

GENERAL CONDITIONS

20. Permit Invalidation – This permit to construct the hard chromium electroplating facility shall become 

invalid, unless an extension is granted by the DEQ, if: 

a. A program of continuous construction, reconstruction, or modification is not commenced within 

the latest of the following: 

i. 18 months from the date of this permit; 

ii. Nine months from the date that the last permit or other authorization was issued from any 

other governmental entity; 

iii. Nine months from the date of the last resolution of any litigation concerning any such permits 

or authorization; or 

b. A program of construction, reconstruction, or modification is discontinued for a period of 18 

months or more, or is not completed within a reasonable time, except for a DEQ approved period 

between phases of a phased construction project. 

(9 VAC 5-80-1210) 

21. Permit Suspension/Revocation - This permit may be suspended or revoked if the permittee: 

a. Knowingly makes material misstatements in the permit application or any amendments to it; 

b. Fails to comply with the conditions of this permit; 

c. Fails to comply with any emission standards applicable to a permitted emissions unit, ; 

d. Causes emissions from the stationary source which result in violations of , or interfere with the 

attainment and maintenance of, any ambient air quality standard; or 
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Registration Number: 52175 

October 8, 2009 

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e. Fails to operate in conformance with any applicable control strategy, including any emission 

standards or emission limitations, in the State Implementation Plan in effect at the time an 

application for this permit is submitted. 

(9 VAC 5-80-1210 F) 

22. Right of Entry - The permittee shall allow authorized local, state, and federal representatives, upon 

the presentation of credentials: 

a. To enter upon the permittee's premises on which the facility is located or in which any records are 

required to be kept under the terms and conditions of this permit; 

b. To have access to and copy at reasonable times any records required to be kept under the terms 

and conditions of this permit or the State Air Pollution Control Board Regulations; 

c. To inspect at reasonable times any facility, equipment, or process subject to the terms and 

conditions of this permit or the State Air Pollution Control Board Regulations; and 

d. To sample or test at reasonable times. 

For purposes of this condition, the time for inspection shall be deemed reasonable during regular 

business hours or whenever the facility is in operation. Nothing contained herein shall make an 

inspection time unreasonable during an emergency. 

(9 VAC 5-170-130 and 9 VAC 5-80-1180) 

23. Maintenance/Operating Procedures – At all times, including periods of start-up, shutdown, and 

malfunction, the permittee shall, to the extent practicable, maintain and operate the affected source, 

including associated air pollution control equipment, in a manner consistent with good air pollution 

control practices for minimizing emissions. 

The permittee shall take the following measures in order to minimize the duration and frequency of 

excess emissions, with respect to air pollution control equipment and process equipment which affect 

such emissions: 

a. Develop a maintenance schedule and maintain records of all scheduled and non-scheduled 

maintenance. 

b. Maintain an inventory of spare parts. 

c. Have available written operating procedures for equipment. These procedures shall be based on 

the manufacturer's recommendations, at a minimum. 

d. Train operators in the proper operation of all such equipment and familiarize the operators with 

the written operating procedures, prior to their first operation of such equipment. The permittee 

shall maintain records of the training provided including the names of trainees, the date of training 

and the nature of the training. 

Records of maintenance and training shall be maintained on site for a period of five years and shall 

be made available to DEQ personnel upon request. 

(9 VAC 5-50-20 E and 9 VAC 5-80-1180 D) 

24. Record of Malfunctions – The permittee shall maintain records of the occurrence and duration of 

any bypass, malfunction, shutdown or failure of the facility or its associated air pollution control 

equipment that results in excess emissions for more than one hour. Records shall include the date, 
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Registration Number: 52175 

October 8, 2009 

Page 9 

time, duration, description (emission unit, pollutant affected, cause), corrective action, preventive 

measures taken and name of person generating the record. 

(9VAC 5-20-180 J and 9 VAC 5-80-1180 D) 

25. Notification for Facility or Control Equipment Malfunction - The permittee shall furnish 

notification to the Director, Piedmont Region of malfunctions of the affected facility or related air 

pollution control equipment that may cause excess emissions for more than one hour, by facsimile 

transmission, telephone or telegraph. Such notification shall be made as soon as practicable but no 

later than four daytime business hours after the malfunction is discovered. The permittee shall 

provide a written statement giving all pertinent facts, including the estimated duration of the 

breakdown, within two weeks of discovery of the malfunction. When the condition causing the failure 

or malfunction has been corrected and the equipment is again in operation, the permittee shall notify 

the Director, Piedmont Region. 

(9 VAC 5-20-180 C and 9 VAC 5-80-1180) 

26. Violation of Ambient Air Quality Standard - The permittee shall, upon request of the DEQ, reduce 

the level of operation or shut down a facility, as necessary to avoid violating any primary ambient air 

quality standard and shall not return to normal operation until such time as the ambient air quality 

standard will not be violated. 

(9 VAC 5-20-180 I and 9 VAC 5-80-1180) 

27. Change of Ownership - In the case of a transfer of ownership of a stationary source, the new owner 

shall abide by any current permit issued to the previous owner. The new owner shall notify the 

Director, Piedmont Region of the change of ownership within 30 days of the transfer. 

(9 VAC 5-80-1240) 

28. Permit Copy - The permittee shall keep a copy of this permit on the premises of the facility to which it 

applies. 

(9 VAC 5-80-1180) 
SOURCE TESTING REPORT FORMAT

Report Cover 

1. Plant name and location 

2. Units tested at source (indicate Ref. No. used by source in permit or registration) 

3. Test Dates. 

4. Tester; name, address and report date 

Certification 

1. Signed by team leader/certified observer (include certification date) 

2. Signed by responsible company official 

3. *Signed by reviewer 

Copy of approved test protocol 

Summary 

1. Reason for testing 

2. Test dates 

3. Identification of unit tested & the maximum rated capacity 

4. *For each emission unit, a table showing: 

a. Operating rate 

b. Test Methods 

c. Pollutants tested 

d. Test results for each run and the run average 

e. Pollutant standard or limit 

5. Summarized process and control equipment data for each run and the average, as required by the test 

protocol 

6. A statement that test was conducted in accordance with the test protocol or identification & discussion of 

deviations, including the likely impact on results 

7. Any other important information 

Source Operation 

1. Description of process and control devices 

2. Process and control equipment flow diagram 

3. Sampling port location and dimensioned cross section Attached protocol includes: sketch of stack 

(elevation view) showing sampling port locations, upstream and downstream flow disturbances and their 

distances from ports; and a sketch of stack (plan view) showing sampling ports, ducts entering the stack and 

stack diameter or dimensions 

Test Results 

1. Detailed test results for each run 

2. *Sample calculations 

3. *Description of collected samples, to include audits when applicable 

Appendix 

1. *Raw production data 

2. *Raw field data 

3. *Laboratory reports 

4. *Chain of custody records for lab samples 

5. *Calibration procedures and results 

6. Project participants and titles 

7. Observers’ names (industry and agency) 

8. Related correspondence 

9. Standard procedures 

 _____ 

* Not applicable to visible emission evaluations