217/782-2113

FEDERALLY ENFORCEABLE STATE OPERATING PERMIT

NESHAP SOURCE -- RENEWAL

PERMITTEE

Nova Chrome, Inc.

Attn: Lynn Knoth

3200 North Wolf Road

Franklin Park, Illinois 60131

Application No.: 72100963 I.D. No.: 031096AIF

Applicant's Designation: IEPA-APR-011 Date Received: October 19, 2001

Subject: Hard Chrome Plating

Date Issued: April 18, 2003 Expiration Date: April 18, 2008

Location: 3200 North Wolf Road, Franklin Park

This permit is hereby granted to the above-designated Permittee to OPERATE 

emission unit(s) and/or air pollution control equipment consisting of 5 hard 

chrome plating tanks controlled by composite mesh pad/packed bed scrubber 

systems, oil dipping tank, solvent cleaning station, hydrogen embrittlement 

oven, and acid stripping tank controlled by scrubber pursuant to the 

above-referenced application. This Permit is subject to standard conditions 

attached hereto and the following special condition(s):

1. This federally enforceable state operating permit is issued to limit 

the actual cumulative rectifier capacity from the hard chrome 

electroplating operation to less than 60 million Amp-hours per rolling 

12 months. As a result the source is excluded from the requirement to 

obtain a Clean Air Act Permit Program (CAAPP) permit. The maximum 

emissions of this source, as limited by the conditions of this permit, 

are described in Attachment A.

2. The 5 Hard Chrome Plating Tanks controlled by composite mesh pad/packed 

bed scrubber systems are subject to 40 CFR Part 63, Subpart N –

National Emission Standards for Chromium Emissions From Hard and 

Decorative Chromium Electroplating and Chromium Anodizing Tanks. The 

Illinois EPA is administering this regulation in Illinois on behalf of 

the United States EPA under a delegation agreement.

3a. Air pollution control equipment associated with a hard chrome 

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

operation, including periods of startup and shutdown.

 b. Hard chrome electroplating tank(s) shall not exceed the following 

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

Chromium Emissions

Hard Chromium Electroplating Tanks (mg/dscm)

5 Existing Small Hard Chromium 

Electroplating Facility Tanks 0.03
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This limit is the National Emission Standards for Chromium Emissions 

from Hard Chromium Electroplating Tanks, 40 CFR Part 63, Subpart N and 

is based on the maximum cumulative actual rectifier capacity of the 

hard chrome electroplating tanks being LESS than 60 million amperehours per year. An electroplating tank(s) installed before December 

16, 1993, is considered as existing tank(s). Compliance with this 

limit shall be determined from initial performance testing and ongoing 

compliance monitoring requirements.

 c. Failure to operate in accordance with the operating parameter value(s), 

determined during initial performance testing, shall be considered a 

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

4. Emissions and operation of the solvent cleaning shall not exceed the 

following limits:

VOM Usage VOM Emissions

Material (Lb/Mo) (Lb/Yr) (Lb/Mo) (Tons/Yr)

Clean-Up Solvent 88 880 88 0.44

These limits are based on complete volatilization of the VOM and HAP 

contents of the materials, material VOM usage = material usage x 

material VOM content, and the information provided in the permit 

application. Compliance with annual limits shall be determined from a 

running total of 12 months of data.

5. This permit is issued based on negligible emissions of particulate 

matter (PM) from the acid stripping tank with scrubber and hydrogen 

embrittlement oven. For this purpose emissions from each emission 

source, shall not exceed nominal emission rates of 0.1 lb/hour and 0.44 

tons/year.

6. This permit is issued based on negligible emissions of volatile organic 

material (VOM) from the oil dip tank. For this purpose, emissions 

shall not exceed nominal emission rates of 0.1 lb/hour and 0.44 

ton/year.

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

shall be implemented for control systems used on hard chrome 

electroplating tanks, including:

a. 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 devices.

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

to the control device(s) to ensure there are no leaks.

d. Perform washdown of the composite mesh-pads in accordance with 

manufacturer's recommendations.

8a. The Permittee shall develop and implement an operation and maintenance 

(O & M) plan for hard chrome electroplating 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 2).

iv. Procedure to follow to ensure that equipment or process 

malfunctions due to poor maintenance or other preventable 

conditions do not occur.

v. Procedure for identifying malfunctions and for implementing 

corrective actions.

 b. The Permittee may use 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 this Condition.

9a. Within 60 days of a written request from the Illinois EPA, the chromium 

emissions of the hard chrome electroplating tank(s) shall be tested 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.

Location of Sample Points USEPA Method 1

Gas Flow and Velocity USEPA Method 2

Chromium USEPA Method 306 or 306A

 c. At least thirty (30) days prior to the actual date of testing, a 

written test plan shall be submitted to the Illinois EPA for review, 

pursuant to 40 CFR 63.344(a). This plan shall describe the specific 

procedures for testing, including as a minimum:

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

their experience and qualifications with similar tests.
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ii. The specific conditions under which testing will be performed, 

including a discussion of why these conditions will be 

representative of the maximum emissions, the levels of operating 

parameters at or within which compliance is intended to be shown, 

if applicable, and the means by which the operating parameters 

for the process and any control equipment will be determined.

iii. The specific determination of emissions and operations which are 

intended to be made, including sampling and monitoring locations.

iv. The test method(s) which will be used, with the specific analysis 

method, if the method can be used with different analysis 

methods. The specific sampling, analytical, and quality control 

procedures which will be used, with an identification of the 

standard method upon which they are based.

v. Any minor changes in standard methodology proposed to accommodate 

the specific circumstances of testing, with justification.

vi. Any proposed use of an alternative test method, with detailed 

justification.

vii. The format and content of the Source Test Report.

viii. A statement that the performance testing will be performed by a 

qualified independent testing service.

 d. Prior to carrying out these tests, the Illinois EPA shall be notified 

in writing a minimum of thirty (30) 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).

If the scheduled date for the test 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.

 e. The Permittee shall follow the procedures of 40 CFR 63.344(d) to 

establish site-specific operating parameter values.

 f. 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). 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.
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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:

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:

1. Pressure drop range across the system 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.

10. The Permittee shall keep the records required by 40 CFR 63.346(b) to 

demonstrate compliance, including the following:

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

i. Pressure drop across the composite mesh-pad system, 

determined daily.

b. Inspection records for the control device and monitoring 

equipment, to document that the inspection and maintenance 

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

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

should identify the device inspected, the date of inspection, a 

brief description of the working condition of the device during 

the inspection, and any actions taken to correct deficiencies 

found during the inspection.
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c. Records of all maintenance performed on the hard chrome 

electroplating tanks, as related to emissions, the associated 

control system, and monitoring equipment.

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

malfunction of the hard chrome electroplating process, associated 

control system, and monitoring equipment.

e. Records of actions taken during periods of malfunction when such 

actions are inconsistent with the operation and maintenance plan 

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

63.342(f)(3)(iv).

f. 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).

g. Copies of test reports documenting results of all performance 

tests and all measurements as may be necessary to determine the 

conditions of performance tests, including measurements necessary 

to determine compliance with the special compliance procedures of 

40 CFR 63.344(e).

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

used to demonstrate compliance with the standard including the 

date and time the data are collected.

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

commencement and completion) of each period of excess emissions, 

as indicated by monitoring data. Records of excess emissions 

that occurs during malfunction of the process, control, or 

monitoring equipment.

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

commencement and completion) of each period of excess emissions, 

as indicated by monitoring data. Records of excess emissions 

that occurs during periods other than malfunction of the hard 

chrome electroplating tanks and associated control device or 

monitoring equipment.

k. Records for the total process operating time of the hard chrome 

electroplating tank(s) during the reporting period.

l. Records demonstrating the maximum cumulative potential rectifier 

capacity, if hard chrome electroplating is less than 60 million 

ampere-hours 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.
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m. Copies of the notifications and reports required by 40 CFR Parts 

63.9, 63.10, and 63.347 (Conditions 9, 10, and 11), with 

supporting documentation.

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

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

11. The Permittee shall also maintain the following records:

a. Name, Usage (gal/mo and gal/yr), VOM and HAP content (lb/gal or 

%wt), and VOM and HAP Emissions for the following materials:

i. Clean-up Solvents; and 

ii. dip oil.

b. Name and amount of Acid Used in the stripping tank (gal/mo and 

gal/yr).

12. The Permittee shall comply with the compliance reporting requirements 

of 40 CFR 63.347(e), including the following:

a. A notification of compliance status, signed by the responsible 

official who shall certify its accuracy, attesting to whether the 

hard chrome electroplating tank(s) has complied with Subpart N, 

pursuant to 40 CFR 63.347(e)(2). The notification 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 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.
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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.

A. 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.

13a. The Permittee shall prepare an ongoing compliance status report every 

year and retain the report on site, and make the report available to 

the Illinois EPA upon request, pursuant to 40 CFR 63.347(h). However, 

if both of the following conditions are met, semiannual reports shall 

be prepared and submitted to the Illinois EPA:

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

monitoring data) is 1 percent or greater of the total operating 

time for the reporting period; and 

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

control device and monitoring equipment is 5 percent or greater 

of the total operating time.

 b. The ongoing compliance 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 hard chrome 

electroplating tank(s), 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 hard chrome 

electroplating tank(s).

vi. The total operating time of the hard chrome electroplating 

tank(s) during the reporting period.
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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 

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.

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

readily accessible location at the source for at least three years from 

the date of entry and shall be made available for inspection and 

copying by the Illinois EPA or USEPA upon request. Any records 

retained in an electronic format (e.g., computer) shall be capable of 

being retrieved and printed on paper during normal source office hours 

so as to be able to respond to an Illinois EPA or USEPA request for 

records during the course of a source inspection.

15. If there is an exceedance of the requirements of this permit as 

determined by the records required by this permit, the Permittee shall 

submit a report to the Illinois EPA's Compliance Section in 

Springfield, Illinois within 30 days after the exceedance. The report 

shall include the emissions released in accordance with the 

recordkeeping requirements, a copy of the relevant records, and a 

description of the exceedance or violation and efforts to reduce 

emissions and future occurrences.
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16. Two (2) copies of required reports and notifications concerning 

equipment operation or repairs, performance testing or a continuous 

monitoring system shall be sent to:

Illinois Environmental Protection Agency

Division of Air Pollution Control

Compliance Section (#40)

P.O. Box 19276

Springfield, Illinois 62794-9276

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

the following address unless otherwise indicated:

Illinois Environmental Protection Agency

Division of Air Pollution Control

9511 West Harrison

Des Plaines, Illinois 60016

17. The Permittee shall submit the following additional information with 

the Annual Emissions Report, due May 1st of each year:

a. Actual cumulative rectifier capacity for the previous 12 months 

(amp-hours).

It should be noted that the 2 heaters, buffing/polishing machine with 

cyclone, and glass bead blasting cabinet are exempt from state permitting 

pursuant to 35 Ill. Adm. Code 201.146(d), (aa), and (jj), respectively.

If you have any questions on this, please call Eric Jones at 217/782-2113.

Donald E. Sutton, P.E.

Manager, Permit Section

Division of Air Pollution Control

DES:EEJ:psj

cc: Illinois EPA, FOS Region 1

Illinois EPA, Compliance Section

Lotus Notes
Attachment A - Emission Summary

This attachment provides a summary of the emission limitations for the hard 

chrome plating facility operating in compliance with the requirements of this 

federally enforceable permit. In preparing this summary, the Illinois EPA 

used the annual operating scenario which results in maximum emissions from 

such a plant. Actual emissions from this source will be less than predicted 

in this summary to the extent that chromium emissions is less than that 

required in this permit.

1. Hard chrome electroplating tank(s) shall not exceed the following 

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

Chromium Emissions

Hard Chromium Electroplating Tanks (mg/dscm)

5 Existing Small Hard Chromium 

Electroplating Facility Tanks 0.03

This limit is the National Emission Standards for Chromium Emissions 

from Hard Chromium Electroplating Tanks, 40 CFR Part 63, Subpart N and 

is based on the maximum cumulative actual rectifier capacity of the

hard chrome electroplating tanks being LESS than 60 million amperehours per year. An electroplating tank(s) installed before December 

16, 1993, is considered as existing tank(s). Compliance with this 

limit shall be determined from initial performance testing and ongoing 

compliance monitoring requirements.

2. Emissions and operation of the solvent cleaning shall not exceed the 

following limits:

VOM Usage VOM Emissions

Material (Lb/Mo) (Lb/Yr) (Lb/Mo) (Tons/Yr)

Clean-Up Solvent 88 880 88 0.44

These limits are based on complete volatilization of the VOM and HAP 

contents of the materials, material VOM usage = material usage x 

material VOM content, and the information provided in the permit 

application. Compliance with annual limits shall be determined from a 

running total of 12 months of data.

3. This permit is issued based on negligible emissions of particulate 

matter (PM) from the acid stripping tank with scrubber and hydrogen 

embrittlement oven. For this purpose emissions from each emission

source, shall not exceed nominal emission rates of 0.1 lb/hour and 0.44 

tons/year.

4. This permit is issued based on negligible emissions of volatile organic 

material (VOM) from the oil dip tank. For this purpose, emissions shall 

not exceed nominal emission rates of 0.1 lb/hour and 0.44 ton/year.

EEJ:psj