October 2, 2008 

Mr. Keith E. Litz 

Co-Owner 

Electro Finishing, Inc. 

6817 W. Lee Highway 

Rural Retreat, Virginia 24368 

Location: Wythe County, VA 

Registration No. 11200 

Facility ID No. 51-197-00077 

Dear Mr. Litz: 

 Attached is a permit to modify and operate a chrome electroplating facility in 

accordance with the provisions of the Commonwealth of Virginia State Air Pollution Control 

Board Regulations for the Control and Abatement of Air Pollution. This permit supersedes 

your permit dated July 23, 2008. 

 This permit contains legally enforceable conditions. Failure to comply may result in a 

Notice of Violation and civil charges. Please read all permit conditions carefully. 

 In the course of evaluating the application and arriving at a final decision to approve the 

project, the Department of Environmental Quality (DEQ) deemed the application complete on 

October 2, 2008. 

 This approval to modify and operate shall not relieve Electro Finishing, Inc. of the 

responsibility to comply with all other local, state, and federal permit regulations. 

 The Board's Regulations as contained in Title 9 of the Virginia Administrative Code 

5-170-200 provide that you may request a formal hearing from this case decision by filing a 

petition with the Board within 30 days after this case decision notice was mailed or delivered 

to you. 9 VAC 5-170-200 provides that you may request direct consideration of the decision 

by the Board if the Director of the DEQ made the decision. Please consult the relevant 

regulations for additional requirements for such requests. 
Mr. Keith E. Litz 

October 2, 2008 

Page 2

 As provided by Rule 2A:2 of the Supreme Court of Virginia, you have 30 days from the 

date of service of this decision (the date you actually received this decision or the date on 

which it was mailed to you, whichever occurred first), within which to initiate an appeal of this 

decision by filing a Notice of Appeal with: 

 David K. Paylor, Director 

 Department of Environmental Quality 

 P. O. Box 1105 

 Richmond, VA 23218 

In the event that this decision is served on you by mail, three days are added to the period in 

which to file an appeal. Please refer to Part Two A of the Rules of the Supreme Court of 

Virginia for information on the required content of the Notice of Appeal and for additional 

requirements governing appeals from decisions of administrative agencies. 

 If you have any questions concerning this permit, please call the regional office at 

(276) 676-4800. 

 Sincerely, 

Dallas R. Sizemore 

Regional Director 

DRS/TMD/P-11200-08B.doc 

Attachments: Permit amendment 

 

c. Director, OAPP (electronic file submission) 

Manager, Data Analysis (electronic file submission) 
STATIONARY SOURCE PERMIT TO MODIFY AND OPERATE 

This permit supersedes your permit dated July 23, 2008.

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

Regulations for the Control and Abatement of Air Pollution, 

Electro Finishing, Inc. 

6817 West Lee highway 

Rural Retreat, VA 24368 

Registration No. 11200 

Facility ID No. 51-197-00077 

is authorized to modify and operate 

a chrome electroplating facility 

located at 

6817 West Lee Highway, at Rural Retreat 

in Smyth County, Virginia 

in accordance with the Conditions of this permit. 

 Approved on October 2, 2008. 

Dallas R. Sizemore 

Regional Director 

Permit consists of 9 pages. 

Permit Conditions 1 to 25.
Electro Finishing, Inc. 

Registration Number 11200 

October 2, 2008 

Page 2 

INTRODUCTION

This permit approval is based on the permit applications dated August 4, 2008, April 24, 

2008, July 5, 2006, March 29, 2005, September 6, 2002, March 21, 2001, November 22, 

2000, January 12, 1998, March 3, 1997, June 15, 1996, and October 16, 1995, the permit 

application letter dated May 23, 2005, amendment information dated October 2, 2008, 

September 18, 2008, September 6, 2006, May 27, 2005, April 8, 2005, October 16, 2002, 

May 31, 2001, April 2, 2001, December 4, 7, 11, 2000, and January 11, 2001, and addendum 

information received July 17 and June 17, 2008, October 28 and 22, 2002, and July 18, 1996. 

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: 

Ref. 

No. Equipment Description Rated Capacity Federal Requirements 

Original 

Permit Date 

Equipment to be added as part of the facility modification:

7 One 1100 gallon hard chrome 

electroplating tank 

6000 amp 

max rectifier cap

40 CFR 63, 

Subpart N 7/22/2008 

8 One 750 gallon hard chrome 

electroplating tank 

2 × 4000 amp 

max rectifier cap

40 CFR 63, 

Subpart N 7/22/2008 

9 One 500 gallon hard chrome 

electroplating tank 

4000 amp 

max rectifier cap

40 CFR 63, 

Subpart N 7/22/2008 

10 One 500 gallon hard chrome activation 

electroplating tank 

3000 amp 

max rectifier cap

40 CFR 63, 

Subpart N 7/22/2008 

11 One adhesive coating dip tank 50 gal capacity - 10/03/2008
Electro Finishing, Inc. 

Registration Number 11200 

October 2, 2008 

Page 3 

Ref. 

No. Equipment Description Rated Capacity Federal Requirements 

Original 

Permit Date 

Equipment to be modified:

6 One DeVilbiss JGA 510 spray gun 18.75 gal/hr - 9/19/2006 

Previously permitted equipment:

1 One decorative chrome electroplating tank 1000 amp 

rectifier 

(shared) 

40 CFR 63, 

Subpart N 

2 One hard chrome electroplating tank 40 CFR 63, 

Subpart N 

3 One hard chrome electroplating tank 500 amp 

max rectifier cap

40 CFR 63, 

Subpart N 

4 One hard chrome electroplating tank 300 gal 40 CFR 63, 

Subpart N 

- One 2000 ampere rectifier - 

6A One metal dip tank 750 inserts/hr - 

6B One metal dip tank 500 inserts/hr - 

Registered Equipment:

12 One 500 gallon hard chrome 

electroplating tank 

4000 amp 

max rectifier cap

40 CFR 63, 

Subpart N n/a 

Specifications included in the permit under this condition are for informational purposes 

only and do not form enforceable terms or conditions of the permit. 

(9 VAC 5-80-1180 D.3) 

2. Emission Controls - Particulate emissions from the permitted hard chrome 

electroplating tanks shall be controlled by packed bed/composite mesh pad (CMP) 

scrubbers, or equivalent. The scrubbers shall be provided with adequate access for 

inspection. 

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

3. Emission Controls - Particulate emissions from the decorative chrome electroplating 

tank shall be controlled by the use of a wetting agent type fume suppressant in the 

plating bath while maintaining the bath surface tension at a level not to exceed 45 

dynes per centimeter, or equivalent control device. 

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

4. Emission Controls - Particulate emissions from the DeVilbiss spray gun shall be 

controlled by a Grainger paint filter system, or equivalent. The Grainger paint filter 

system shall be provided with adequate access for inspection. 

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

5. Testing/Monitoring Ports - The permitted facility shall be constructed so as to allow 

for emissions testing and monitoring upon reasonable notice at any time, using 

appropriate methods. Test ports shall be provided when requested at the appropriate 
Electro Finishing, Inc. 

Registration Number 11200 

October 2, 2008 

Page 4 

locations or in accordance with the applicable performance specification (reference 

40 CFR Part 60, Appendix B). 

(9 VAC 5-50-30 F) 

OPERATING/EMISSION LIMITATIONS

6. Throughput - The throughput of the following coating materials (or their equivalents) to 

the DeVilbiss spray gun shall not exceed the specified limits, calculated monthly as the 

sum of each consecutive 12-month period: 

Chemlok 233 Adhesive 2.25 gal/hr 2500 gal/yr 

Toluene solution 2.25 gal/hr 2500 gal/yr 

The DeVilbiss spray gun is limited to an hourly rate of 4.5 gallons/hr, calculated monthly 

by dividing the total gallons of Chemlok adhesive and thinner mixture sprayed for the 

month by the total number of hours spraying time for that month. 

(9 VAC 5-80-1180) 

7. Throughput - The consumption of adhesive materials (or their equivalents) in the 

adhesive dip tank shall not exceed the specified limits, calculated monthly as the sum 

of each consecutive 12-month period: 

Chemlok 5150 Adhesive 1.13 gal/hr 50 gal/yr 

Denatured Alcohol (Ethanol SIS A1) 3.38 gal/hr 150 gal/yr 

(9 VAC 5-80-1180) 

8. Throughput – The total combined throughput for the clear cement and black cement 

dipping processes shall not exceed 2,500,000 inserts per year, calculated monthly as 

the sum of each consecutive 12 month period. 

(9 VAC 5-80-1180) 

9. Emission Limits – Emissions from the clear cement and the black cement dipping 

processes shall not exceed the following: 

Volatile Organic Compounds (VOC) 3.56 lb/hr 5.59 tons/yr 

These emissions are derived from the estimated overall emission contribution from 

operating limits. Exceedance of the operating limits shall be considered credible 

evidence of the exceedance of emission limits. Compliance with these emission limits 

may be determined as stated in Condition 8. 

(9 VAC 5-80-1180) 

10. Emission Limits – The emissions from the application of adhesives in the DeVilbiss 

spray gun shall not exceed the following: 

Volatile Organic Compounds (VOC) 30.02 lb/hr 16.68 tons/yr 

These emissions are derived from the estimated overall emission contribution from 

operating limits. Exceedance of the operating limits shall be considered credible 
Electro Finishing, Inc. 

Registration Number 11200 

October 2, 2008 

Page 5 

evidence of the exceedance of emission limits. Compliance with these emission limits 

may be determined as stated in Condition 6. 

(9 VAC 5-80-1180) 

11. Emission Limits – The emissions from the application of adhesives in the adhesive 

dip tank shall not exceed the following: 

Volatile Organic Compounds (VOC) 30.03 lb/hr 0.67 tons/yr 

These emissions are derived from the estimated overall emission contribution from 

operating limits. Exceedance of the operating limits shall be considered credible 

evidence of the exceedance of emission limits. Compliance with these emission limits 

may be determined as stated in Condition 7. 

(9 VAC 5-80-1180) 

12. Visible Emission Limit - Visible emissions from the Grainger paint filter exhaust shall 

not exceed five percent (5%) opacity as determined by EPA Method 9 (reference 40 

CFR 60, Appendix A). This condition applies at all times except during startup, 

shutdown and malfunction. 

(9 VAC 5-50-260) 

13. Visible Emission Limit - Visible emissions from all packed bed/composite mesh pad 

scrubber exhausts shall not exceed five percent (5%) opacity as determined by EPA 

Method 9 (reference 40 CFR 60, Appendix A). This condition applies at all times 

except during startup, shutdown and malfunction. 

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

RECORDS

14. 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, Southwest 

Regional Office. These records shall include, but are not limited to: 

a. The combined total number of hours of operation of the seven (7) hard chrome 

electroplating tanks (Reference No’s. 2, 3, 4, 7, 8, 9, and 10), calculated monthly 

as the sum of each consecutive 12-month period. 

b. The combined total yearly amp-hours for the seven (7) hard chrome electroplating 

tanks (Reference No’s. 2, 3, 4, 7, 8, 9, and 10) calculated monthly as the sum of 

each consecutive 12-month period. 

c. Monthly and annual throughput (in gallons) of Chemlok 5150 adhesive and 

denatured alcohol mixture in the adhesive dip tank. Annual throughput shall be 

calculated monthly as the sum of each consecutive 12-month period. 

d. Monthly and annual throughput (in gallons) of Chemlok 233 adhesive and toluene 

mixture to the DeVilbiss spray gun. Annual throughput shall be calculated monthly 

as the sum of each consecutive 12-month period. The hourly throughput shall be 
Electro Finishing, Inc. 

Registration Number 11200 

October 2, 2008 

Page 6 

determined by dividing the total gallons of Chemlok 233 adhesive mixture sprayed 

for the month by the total number of hours spraying time for that month. 

e. Total annual combined throughput of inserts from the dipping processes, calculated 

monthly as the sum of each consecutive 12 month period. 

f. MSDS records for the clear cement and black cement, or their equivalents, used in 

the dipping processes. 

g. MSDS records for all adhesive dip tank and DeVilbiss spray coatings, adhesives, 

and thinners. 

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

most recent five (5) years. 

(9 VAC 5-50-50) 

NOTIFICATIONS

15. Initial Notifications - The permittee shall furnish written notification to the Director, 

Southwest Regional Office regarding: 

a. The actual date on which facility modification commenced (addition of the four (4) 

hard chrome electroplating tanks (Reference No.’s 7, 8, 9, and 10)) within 30 days 

after such date. 

b. The actual start-up date of the modification (four (4) hard chrome electroplating 

tanks (Reference No.’s 7, 8, 9, and 10) within 15 days after such date. 

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

16. Notification for Control Equipment Maintenance - The permittee shall furnish 

notification to the Director, Southwest Regional Office of the intention to shut down or 

bypass, or both, air pollution control equipment for necessary scheduled maintenance, 

which results in excess emissions for more than one hour, at least 24 hours prior to the 

shutdown. The notification shall include, but is not limited to, the following information: 

a. Identification of the air pollution control equipment to be taken out of service, as 

well as its location, and registration number; 

b. The expected length of time that the air pollution control equipment will be out of 

service; 

c. The nature and quantity of emissions of air pollutants likely to occur during the 

shutdown period; 

d. Measures that will be taken to minimize the length of the shutdown or to negate the 

effect of the outage. 

(9 VAC 5-20-180 B) 
Electro Finishing, Inc. 

Registration Number 11200 

October 2, 2008 

Page 7 

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

furnish notification to the Director, Southwest Regional Office 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 not 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 14 days of the occurrence. When the condition causing the failure 

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

permittee shall notify the Director, Southwest Regional Office in writing. 

(9 VAC 5-20-180 C) 

GENERAL CONDITIONS

18. Permit Invalidation – The provisions of this permit pertaining to the modification of the 

electroplating facility with the addition of the four electroplating tanks (Ref. No.’s 7 - 10) 

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

a. A program of continuous modification is not commenced within the latest of the 

following: 

i. 18 months from July 23, 2008; 

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 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) 

19. Permit Suspension/Revocation - This permit may be suspended or revoked if the 

permittee: 

a. Knowingly makes material misstatements in the application for this permit 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 the equipment listed in 

Condition 1; 

d. Causes emissions from this facility which result in violations of, or interferes with 

the attainment and maintenance of, any ambient air quality standard; 

e. Fails to operate this facility in conformance with any applicable control strategy, 

including any emission standards or emission limitations, in the State 

Implementation Plan in effect on the date that the application for this permit is 

submitted; 
Electro Finishing, Inc. 

Registration Number 11200 

October 2, 2008 

Page 8 

f. Fails to construct, modify, or operate this facility in accordance with the application 

for this permit or any amendments to it; or 

g. Allows the permit to become invalid. 

(9 VAC 5-80-1210) 

20. 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) 

21. Maintenance/Operating Procedures - The permittee shall take the following 

measures in order to minimize the duration and frequency of excess emissions, with 

respect to the air pollution control equipment which affect such emissions: 

a. Develop a maintenance schedule and maintain records of all scheduled and nonscheduled maintenance. These records shall be maintained on site for a period of 

five (5) years and shall be made available to DEQ personnel upon request. 

b. Maintain an inventory of spare parts that are needed to minimize durations of air 

pollution control equipment breakdowns. 

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. 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) 

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

furnish notification to the Director, Southwest Regional Office, of malfunctions of the 
Electro Finishing, Inc. 

Registration Number 11200 

October 2, 2008 

Page 9 

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 not 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, Southwest Regional Office, in writing. 

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

23. 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) 

24. 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, Southwest Regional Office of the change of 

ownership within 30 days of the transfer. 

(9 VAC 5-80-1240) 

25. Permit Copy - The permittee shall keep a copy of this permit on the premises of the 

facility to which it applies. 

(9 VAC 5-170-160)