Street Address: Mailing Address:

Lazarus Gov. CenterTELE: (614) 644-3020 FAX: (614) 644-2329

Lazarus Gov. Center

122 S. Front Street P.O. Box 1049

State of Ohio Environmental Protection Agency

RE: FINAL PERMIT TO INSTALL MODIFICATION CERTIFIED MAIL

CUYAHOGA COUNTY

Application No: 13-03302

DATE: 3/22/2001

Buschman Corporation

Sekar Venkataraman

4100 Payne Avenue 

Cleveland, OH 44103

Enclosed Please find a modification to the Ohio EPA Permit To Install referenced above which will modify the terms and

conditions.

You are hereby notified that this action by the Director is final and may be appealed to the Ohio Environmental Review

Appeals Commission pursuant to Chapter 3745.04 of the Ohio Revised Code. The appeal must be in writing and set forth

the action complained of and the grounds upon which the appeal is based. It must be filed within thirty (30) days after the

notice of the Directors action. A copy of the appeal must be served on the Director of the Ohio Environmental Protection

Agency within three (3) days of filing with the Commission. An appeal may be filed with the Environmental Review

Appeals Commission at the following address:

Environmental Review Appeals Commission

236 East Town Street, Room 300

Columbus, Ohio 43215

Very truly yours,

Thomas G. Rigo, Manager

Field Operations and Permit Section

Division of Air Pollution Control

cc: USEPA CBAPC
 STATE OF OHIO ENVIRONMENTAL PROTECTION AGENCY

Permit To Install Issue Date: 3/22/2001

Terms and Conditions Effective Date: 3/22/2001

FINAL ADMINISTRATIVE MODIFICATION OF PERMIT TO INSTALL 13-03302

Application Number: 13-03302

APS Premise Number: 1318007874

Permit Fee: $0

Name of Facility: Buschman Corporation

Person to Contact: Sekar Venkataraman

Address: 4100 Payne Avenue 

Cleveland, OH 44103

Location of proposed air contaminant source(s) [emissions unit(s)]:

4100 Payne Avenue

Cleveland, Ohio

Description of proposed emissions unit(s):

Hard Chrome Plating Line

The above named entity is hereby granted a modification to the permit to install described above pursuant to Chapter 3745-

31 of the Ohio Administrative Code. Issuance of this modification does not constitute expressed or implied approval or 

agreement that, if constructed or modified in accordance with the plans included in the application, the above described 

source(s) of environmental pollutants will operate in compliance with applicable State and Federal laws and regulations, and 

does not constitute expressed or implied assurance that if constructed or modified in accordance with those plans included in 

the application, the above described source(s) of pollutants will be granted the necessary operating permits.

This permit is granted subject to the conditions attached hereto.

Ohio Environmental Protection Agency

Director
Buschman Corporation Facility ID: 1318007874

PTI Application: 13-03302

Issued: 3/22/2001

3

Part I - GENERAL TERMS AND CONDITIONS

A. Permit to Install General Terms and Conditions

1. Compliance Requirements

The emissions unit(s) identified in this Permit to Install shall remain in full compliance with all

applicable State laws and regulations and the terms and conditions of this permit.

2. Reporting Requirements Related to Monitoring and Recordkeeping Requirements

The permittee shall submit required reports in the following manner:

a. Reports of any required monitoring and/or recordkeeping information shall be submitted

to the appropriate Ohio EPA District Office or local air agency.

b. Except as otherwise may be provided in the terms and conditions for a specific emissions

unit, quarterly written reports of (a) any deviations (excursions) from emission limitations,

operational restrictions, and control device operating parameter limitations that have been

detected by the testing, monitoring, and recordkeeping requirements specified in this

permit, (b) the probable cause of such deviations, and (c) any corrective actions or

preventive measures which have been or will be taken, shall be submitted to the

appropriate Ohio EPA District Office or local air agency. If no deviations occurred during

a calendar quarter, the permittee shall submit a quarterly report, which states that no

deviations occurred during that quarter. The reports shall be submitted quarterly, i.e., by

January 31, April 30, July 31, and October 31 of each year and shall cover the previous

calendar quarters. (These quarterly reports shall exclude deviations resulting from

malfunctions reported in accordance with OAC rule 3745-15-06.)

3. Records Retention Requirements

Each record of any monitoring data, testing data, and support information required pursuant to

this permit shall be retained for a period of five years from the date the record was created.

Support information shall include, but not be limited to, all calibration and maintenance records

and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all

reports required by this permit. Such records may be maintained in computerized form.

4. Inspections and Information Requests

The Director of the Ohio EPA, or an authorized representative of the Director, may, subject to

the safety requirements of the permittee and without undue delay, enter upon the premises of this

source at any reasonable time for purposes of making inspections, conducting tests, examining

records or reports pertaining to any emission of air contaminants, and determining compliance

with any applicable State air pollution laws and regulations and the terms and conditions of this

permit. The permittee shall furnish to the Director of the Ohio EPA, or an authorized
Buschman Corporation Facility ID: 1318007874

PTI Application: 13-03302

Issued: 3/22/2001

4

representative of the Director, upon receipt of a written request and within a reasonable time, any

information that may be requested to determine whether cause exists for modifying, reopening or

revoking this permit or to determine compliance with this permit. Upon verbal or written request,

the permittee shall also furnish to the Director of the Ohio EPA, or an authorized representative

of the Director, copies of records required to be kept by this permit.

5. Scheduled Maintenance/Malfunction Reporting

Any scheduled maintenance of air pollution control equipment shall be performed in accordance

with paragraph (A) of OAC rule 3745-15-06. The malfunction of any emissions units or any

associated air pollution control system(s) shall be reported to the appropriate Ohio EPA District

Office or local air agency in accordance with paragraph (B) of OAC rule 3745-15-06. Except as

provided in that rule, any scheduled maintenance or malfunction necessitating the shutdown or

bypassing of any air pollution control system(s) shall be accompanied by the shutdown of the

emissions unit(s) that is (are) served by such control system(s).

6. Permit Transfers

Any transferee of this permit shall assume the responsibilities of the prior permit holder. The

appropriate Ohio EPA District Office or local air agency must be notified in writing of any

transfer of this permit.

7. Air Pollution Nuisance

The air contaminants emitted by the emissions units covered by this permit shall not cause a public

nuisance, in violation of OAC rule 3745-15-07.

8. Termination of Permit to Install

This Permit to Install shall terminate within eighteen months of the effective date of the Permit to

Install if the owner or operator has not undertaken a continuing program of installation or

modification or has not entered into a binding contractual obligation to undertake and complete

within a reasonable time a continuing program of installation or modification. This deadline may

be extended by up to 12 months if application is made to the Director within a reasonable time

before the termination date and the party shows good cause for any such extension.

9. Construction of New Sources(s)

The proposed emissions unit(s) shall be constructed in strict accordance with the plans and

application submitted for this permit to the Director of the Ohio Environmental Protection

Agency. There may be no deviation from the approved plans without the express, written

approval of the Agency. Any deviations from the approved plans or the above conditions may

lead to such sanctions and penalties as provided under Ohio law. Approval of these plans does

not constitute an assurance that the proposed facilities will operate in compliance with all Ohio

laws and regulations. Additional facilities shall be installed upon orders of the Ohio
Buschman Corporation Facility ID: 1318007874

PTI Application: 13-03302

Issued: 3/22/2001

5

Environmental Protection Agency if the proposed sources cannot meet the requirements of this

permit or cannot meet applicable standards.

If the construction of the proposed emissions unit(s) has already begun or has been completed

prior to the date the Director of the Environmental Protection Agency approves the permit

application and plans, the approval does not constitute expressed or implied assurance that the

proposed facility has been constructed in accordance with the approved plans. The action of

beginning and/or completing construction prior to obtaining the Director's approval constitutes a

violation of OAC rule 3745-31-02. Furthermore, issuance of the Permit to Install does not

constitute an assurance that the proposed source will operate in compliance with all Ohio laws

and regulations. Approval of the plans in any case is not to be construed as an approval of the

facility as constructed and/or completed. Moreover, issuance of the Permit to Install is not to be

construed as a waiver of any rights that the Ohio Environmental Protection Agency (or other

persons) may have against the applicant for starting construction prior to the effective date of the

permit. Additional facilities shall be installed upon orders of the Ohio Environmental Protection

Agency if the proposed facilities cannot meet the requirements of this permit or cannot meet

applicable standards.

10. Public Disclosure

The facility is hereby notified that this permit, and all agency records concerning the operation of

this permitted source, are subject to public disclosure in accordance with OAC rule 3745-49-03.

11. Applicability

This Permit to Install is applicable only to the emissions unit(s) identified in the Permit to Install.

Separate application must be made to the Director for the installation or modification of any other

emissions unit(s).

12. Best Available Technology

As specified in OAC Rule 3745-31-05, all new sources must employ Best Available Technology

(BAT). Compliance with the terms and conditions of this permit will fulfill this requirement.

13. Source Operation and Operating Permit Requirements After Completion of Construction

a. If the permittee is required to apply for a Title V permit pursuant to OAC Chapter

3745-77, the permittee shall submit a complete Title V permit application or a complete

Title V permit modification application within twelve (12) months after commencing

operation of the emissions units covered by this permit. However, if the proposed new or
Buschman Corporation Facility ID: 1318007874

PTI Application: 13-03302

Issued: 3/22/2001

6

modified source(s) would be prohibited by the terms and conditions of an existing Title V 

permit, a Title V permit modification must be obtained before the operation of such new 

or modified source(s) pursuant to OAC rule 3745-77-04(D) and OAC rule 

3745-77-08(C)(3)(d).

b. If the permittee is required to apply for permit(s) pursuant to OAC Chapter 3745-35, the 

source(s) identified in this Permit To Install is (are) permitted to operate for a period of up 

to one year from the date the source(s) commenced operation. Permission to operate is 

granted only if the facility complies with all requirements contained in this permit and all 

applicable air pollution laws, regulations, and policies. Pursuant to OAC Chapter 3745-35, 

the permittee shall submit a complete operating permit application within thirty (30) days 

after commencing operation of the source(s) covered by this permit.

14. Construction Compliance Certification

The applicant shall provide Ohio EPA with a written certification (see enclosed form) that the 

facility has been constructed in accordance with the Permit to Install application and the terms and 

conditions of the Permit to Install. The certification shall be provided to Ohio EPA upon 

completion of construction but prior to startup of the source.

15. Fees

The permittee shall pay fees to the Director of the Ohio EPA in accordance with ORC section 

3745.11 and OAC Chapter 3745-78. The permittee shall pay all applicable Permit to Install fees 

within 30 days after the issuance of this Permit to Install.

B. Permit to Install Summary of Allowable Emissions

The following information summarizes the total allowable emissions, by pollutant, based on the individual 

allowable emissions of each air contaminant source identified in this permit. 

SUMMARY (for informational purposes only) 

TOTAL PERMIT TO INSTALL ALLOWABLE EMISSIONS

Pollutant Tons Per Year

Chromium 

(as TSP mist)

0.0015
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PART II - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)

A. Applicable Emissions Limitations and/or Control Requirements

1. The specific operations(s), property, and/or equipment which constitute this emissions unit are 

listed in the following table along with the applicable rules and/or requirements and with the 

applicable emissions limitations and/or control measures. Emissions from this unit shall not 

exceed the listed limitations, and the listed control measures shall be specified in narrative form 

following the table.

Operations, Property, 

and/or Equipment

P002 - Electroplating hard chrome

system number 2 (Administrative

Modification - 1)

Applicable Rules/Requirements

OAC rule 3745-31-05(A)(3)

40 CFR 63 Subpart N

Applicable Emissions

Limitations/Control Measures

2.96 pounds of Chromium/year

0.0015tpy

0.015 mg of Chromium/dscm

2. Additional Terms and Conditions

2.a The permittee shall not allow the concentration of total chromium in the exhaust gases

discharged to the atmosphere to exceed 0.015 mg/dscm.

B. Operational Restrictions

1. At all times, including periods of startup, shutdown, and malfunction, the permittee shall operate

and maintain any chromium electroplating or anodizing tank, including associated air pollution control

devices and monitoring equipment, in a manner consistent with the operation and maintenance plan

required by these Additional Special Terms and Conditions.

2. Malfunctions shall be corrected as soon as practicable after occurrence in accordance with the

operation and maintenance plan.

3. Determination of whether acceptable operation and maintenance procedures are being used will

be based on information available to the appropriate Ohio EPA District Office or Local air agency, which

may include, but is not limited to, monitoring results; review of the operation and maintenance plan,
Buschman Corporation Facility ID: 1318007874

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procedures, and records; and inspection of the emission unit. Based on this information, the appropriate

Ohio EPA District Office or Local air agency Control may require that the permittee make changes to the

operation and maintenance plan if that plan:

a. does not address a malfunction that has occurred;

b. fails to provide for the operation of the emission units, the air pollution control techniques,

or the control techniques, or the control system and process monitoring equipment during

a malfunction in a manner consistent with good air pollution practices; or,

c. does not provide adequate procedures for correction malfunctioning process equipment,

air pollution control techniques, or monitoring equipment as quickly as practicable.

4. The permittee shall prepare an operation and maintenance plan to be implemented no later than

May 1998. The plan shall include the following elements:

a. the plan shall specify the operation and maintenance criteria for the affected source, the

add-on air pollution control device (if such a device is used to comply with the emissions

limits), and the process and control system monitoring equipment, and shall include a

standardized checklist to document the operation and maintenance of the equipment.

b. The Operation/Maintenance plan shall incorporate the following work practice standards:

i. visually inspect the device at least once per quarter to insure there is proper

drainage, no chronic acid buildup on the pads, and no evidence of chemical attack

on the structural integrity of the device;

ii. visually inspect at least once per quarter the back portion of the mesh pad closest

to the fan to ensure there is no breakthrough of the chromic acid mist;

iii. visually inspect at least once per quarter the duct work from the tank to the control

device to ensure there are no leaks; and,

iv. perform washdown of the composite mesh-pads in accordance with manufacturer's

recommendations;

c. the plan shall specify procedures to be followed to ensure that equipment or process

malfunctions due to poor maintenance or other preventable conditions do not occur;

d. the plan shall include a systematic procedure for identifying malfunctions of process

equipment, add-on air pollution control devices, and process and control system
Buschman Corporation Facility ID: 1318007874

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monitoring equipment, and for implementing corrective actions to address such

malfunctions;

e. if the operation and maintenance plan fails to address or inadequately addresses an event

that meets the characteristics of a malfunction at the time the plan is initially developed,

the permittee shall revise the operation and maintenance plan within 45 days after such an

event occurs;

f. If actions taken by the permittee during periods of malfunction are inconsistent with the

procedures specified in the operation and maintenance plan, the permittee shall record the

actions taken for that event and shall report such actions within 2 working days after

commencing actions inconsistent with the plan. This report shall be followed by a letter

within 7 working days after the end of the event, unless the permittee makes alternative

reporting arrangements, in advance, with the appropriate Ohio EPA District Office or

local air agency;

g. The permittee shall keep the written operation and maintenance plan on record after it is

developed to be made available for inspection, upon request, by the appropriate Ohio EPA

District Office or local air agency for the life of the emission unit. If the operation and

maintenance plan is revised, the permittee shall keep previous versions of the plan on

record to be made available for inspection, upon request, by the appropriate Ohio EPA

District Office or local air agency for a period of five years after each revision to the plan;

and,

h. The permittee may use applicable standard operating procedure (SOP) manuals,

Occupational Safety and Health Administration (OSHA) plans, or other existing plans to

meet the operation and maintenance plan requirements as long as the alternative plans

meet the requirements.

C. Monitoring and/or Recordkeeping Requirements

1. Packed-bed scrubber/composite mesh-pad system monitoring requirements to demonstrate

continuous compliance

a. During the initial performance test, the permittee shall determine the outlet chromium

concentration using the methods as described in the "Testing Requirements" section of this

permit to comply with the emission limitation through the use of a packed-bed scrubber

and composite mesh-pad system. The permittee shall establish as a site-specific operating

parameter the pressure drop across the system, setting the value that corresponds to
Buschman Corporation Facility ID: 1318007874

PTI Application: 13-03302

Issued: 3/22/2001

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compliance with the applicable emission limitation, using the procedures in the "Testing

Requirements" section of this permit.

b. The permittee may conduct multiple performance tests to establish a range of compliant

pressure drop values, or may set as the compliance value the average pressure drop

measured over the three test runs of one performance test and accept ±1 inch of water

column from this value as the compliant range.

c. On and after the date on which the initial performance test is required to be completed

under §63.7 of 40 CFR Part 63, Subpart A, the permittee shall monitor and record the

pressure drop across the composite mesh-pad system once each day that the emission unit

is operating. To
Buschman Corporation Facility ID: 1318007874

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be in compliance, the composite mesh-pad system shall be operated within ±1 inch of

water column of the pressure drop value established during the initial performance test, or

shall be operated within the range of compliant values for pressure drop established during

multiple performance tests.

2. The permittee shall fulfill all recordkeeping requirements in the General Provisions to 40 CFR Part

63, according to the applicability of subpart A.

3. The permittee also shall maintain the following records:

a. Inspection records for the add-on air pollution control device, if such a device is used, and

monitoring equipment, to document that the inspection and maintenance required by the

work practice standards of this permit 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.

b. Records of all maintenance performed on the emissions unit, add-on air pollution control

device, and monitoring equipment;

c. Records of the occurrence, duration, and cause (if known) of each malfunction of process,

add-on air pollution control device, and monitoring equipment;

d. Records of actions taken during periods of malfunction when such actions are inconsistent

with the operation and maintenance plan;

e. Other records, which may take the form of checklists, necessary to demonstrate

consistence with the provisions of the operation and maintenance plan;

f. Test reports documenting results of all performance tests;

g. All measurements as may be necessary to determine the conditions of performance tests;

h. Records of monitoring data 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, that occurs during

malfunction of the process, add-on air pollution control device, or monitoring equipment;
Buschman Corporation Facility ID: 1318007874

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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, that occurs during

periods other than malfunction of the process, add-on air pollution control device, or

monitoring equipment;

k. The total process operating time of the emission unit during the reporting period; and,

l. All documentation supporting the notifications and reports as outlined in the Reporting

Requirements of this permit and §63.9 and §63.10 of 40 CFR Part 63, subpart A.

4. All records shall be maintained for a period of five years.

D. Reporting Requirements

1. Records of projected rectifier capacity for the first 12-month period of tank operation shall submit

to:

Ohio Environmental Protection Agency

1800 WaterMark Drive

Columbus, OH 43215-1099

Attn: MACT Coordinator

and also send a copy of this report to:

Cleveland Bureau of Air Pollution Control (CBAPC)

1925 St. Clair Ave.

Cleveland, Ohio 44114

Attn: Chief, Bureau of Engineering Services

2. The permittee shall fulfill all reporting requirement as outlined in 40 CFR part 63 subpart A.

These reports shall be made to the appropriate Ohio EPA District Office or local air agency and

shall be sent by U.S. mail, fax or by another courier.

a. Submittals sent by U.S. mail shall be postmarked on or before the specified date.

b. Submittals sent by other methods shall be received by the appropriate Ohio EPA District

Office or local air agency on or before the specified date.

3. The permittee shall submit to the appropriate Ohio EPA District Office or local air agency an

initial notification report no later than July 24, 1995 that contains the following information:
Buschman Corporation Facility ID: 1318007874

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a. The name, title, and address of the owner or operator;

b. The address (i.e., physical location) of the emissions unit;

c. Identification of the applicable emission limitations and compliance date.

d. A statement of whether the affected emissions unit is located at a major source or at an

area source.

e. A brief description of each affected emission unit, including the type of process operation

performed.

f. The maximum potential cumulative potential rectifier capacity

g. A statement of whether the emissions unit is located at a small or a large, hard

chromium facility and whether this will be demonstrated through actual or maximum

potential cumulative rectifier capacity.

h. A statement of whether the permittee will limit the maximum potential cumulative

rectifier capacity such that the hard chromium electroplating facility is considered small.

4. The permittee shall submit a Notification of Performance Test to the appropriate Ohio EPA

District Office or local air agency at least 60 calendar days before the performance test is

scheduled. In the event that the permittee is unable to conduct the performance as scheduled,

the provisions of §63.7(b)(2) of 40 CFR Part 63, subpart A apply

5. The permittee shall submit a Notification of Compliance Status to the appropriate Ohio EPA

District Office or local air agency 90 days after the performance test, is completed signed by the

responsible official who shall certify its accuracy, attesting to whether the affected emissions unit

is in compliance. The notification shall list for each affected emissions unit:

a. The applicable emission limitations and the methods that were used to determine

compliance with this limitation;

b. If a performance test is required, the test report documenting the results of the

performance test, which includes the elements required in the Test Requirements section

of this permit, including measurements and calculations to support special compliance

provisions for multiple emissions units controlled by a common add-on air pollution

control device;
Buschman Corporation Facility ID: 1318007874

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c. The type and quantity of hazardous air pollutants emitted by the emissions unit reported in

mg/dscm or mg/hr if the emissions unit is using the special provisions for multiple

emissions units controlled by a common add-on air pollution control device;

d. For each monitored parameter for which a compliant value was established, the specific

operating parameter value, or range of values, that corresponds to compliance with the

applicable emission limit;

e. The methods that will be used to determine continuous compliance;

f. A description of the air pollution control technique used for each emission point;

g. A statement that the permittee has completed and has on file the operation and

maintenance plan as required by the work practice standards; and,

h. A statement by the owner or operator as to whether the emissions unit is in compliance.

6. The permittee shall report to the appropriate Ohio EPA District Office or local air agency the

results of any performance test conducted. The report shall be submitted no later than 90 days

following the completion of the performance test, and shall be submitted as part of the notification

of compliance status report required by this section.

7. The permittee shall prepare an ongoing compliance status report annually (unless a request to

reduce frequency of ongoing compliance status reports has been approved) to the appropriate

Ohio EPA District Office or local air agency to document the ongoing compliance status of the

emissions unit. This report shall include the following:

a. The company name and address of the emissions unit;

b. An identification of the operating parameter that is monitored for compliance

determination;

c. The relevant emission limitation for the emissions unit, 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 required by this section;

d. The beginning and ending dates of the reporting period;

e. The total operating time of the emissions unit during the reporting period;
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f. 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 emissions unit 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;

g. A certification by a responsible official that the work practice standards in this permit were

followed in accordance with the operation and maintenance plan for the emissions unit;

h. If the operation and maintenance plan required by this permit 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 reports required by the work practices in this permit;

i. A description of any changes in monitoring, processes, or controls since the last reporting

period;

j. The name, title, and signature of the responsible official who is certifying the accuracy of

the report;

k. The date of the report; and,

l. The report shall be completed annually and retained on site, and made available to the

appropriate Ohio EPA District Office or Local Air Pollution Control Agency upon

request.

8. The permittee shall submit semiannual reports if the following conditions are met:

a. the total duration of excess emissions is one percent or greater of the total operating time

for the reporting period; and

b. 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.

9. Once the permittee reports an exceedance, ongoing compliance status reports shall be submitted

semiannually until a request to reduce reporting frequency is approved.

10. The appropriate Ohio EPA District Office or local air agency may determine on a case-by-case

basis that the summary report shall be completed more frequently and submitted, or that the
Buschman Corporation Facility ID: 1318007874

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annual report shall be submitted instead of being retained on site, if these measures are necessary

to accurately assess the compliance status of the emissions unit.

11. The permittee who is required to submit ongoing compliance status reports on a semiannual (or

more frequent) basis, or is required to submit its annual report instead of retaining it on site, may

reduce the frequency of reporting to annual and/or be allowed to maintain the annual report on

site if all of the following conditions are met:

a. For 1 full year (e.g., 2 semiannual or 4 quarterly reporting periods), the ongoing

compliance status reports demonstrate that the affected emissions unit is in compliance

with the relevant emission limit.

b. The permittee continues to comply with all applicable recordkeeping and monitoring

requirements of 40 CFR Part 63, subpart A and this permit.

c. The appropriate Ohio EPA District Office or local air agency does not object to a reduced

reporting frequency. The frequency of submitting ongoing compliance status reports may

be reduced if the following requirements are met:

i. The permittee notifies the appropriate Ohio EPA District Office or local air agency

in writing of its intentions to make such a change. The Ohio EPA District Office

or local air agency may review information concerning the facility’s previous

performance history during the 5-year recordkeeping period prior to the intended

change, or the recordkeeping period since the emission unit’s compliance date,

whichever is shorter. Records subject to review include performance test results,

monitoring data, and evaluations of the permittee’s conformance with emission

limitations and work practice standards. If the permittee’s request is disapproved,

the appropriate Ohio EPA District Office or local air agency will notify the

permittee in writing within 45 days after receiving notice. This notification will

specify the grounds on which the disapproval is based. In the absence of a notice

of disapproval within 45 days, approval is automatically granted.

ii. If monitoring data show that the emissions unit is not in compliance with the

relevant emission limit, the frequency of reporting shall revert to semiannual, and

the permittee shall state this exceedance in the ongoing compliance status report

for the next reporting period. After demonstrating ongoing compliance with the

relevant emission limit for another full year, the permittee may again request

approval to reduce the reporting frequency.

E. Testing Requirements
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1. The permittee shall conduct, or have conducted, performance testing on the air contaminant

source in accordance with procedures approved by the Agency. Two copies of the written report

describing the test procedures followed and the results of such tests shall be submitted and signed

by the person responsible for the test. The Director, or an Ohio EPA representative, shall be

allowed to witness the test, examine testing equipment, and require the acquisition or submission

of data and information necessary to assure that the source operation and testing procedures

provide a valid characterization of the emissions from the source and/or the performance of the

control equipment.

a. A completed Intent to Test form shall be submitted to the appropriate Ohio EPA District

Office or Local Air Pollution Control Agency where the original permit application was

filed. This notice shall be made 30 days in advance and shall specify the source operating

parameters, the proposed test procedures, and the time, date, place and person(s)

conducting such tests; and,

b. Two copies of the test results shall be submitted within 30 days after the completion of the

performance test.

2. Performance test results shall be documented in complete test reports that contain the following

information:

a. a brief process description;

b. sampling location description(s);

c. a description of sampling and analytical procedures and any modifications to standard

procedures;

d. test results;

e. quality assurance procedures and results;

f. records of operating conditions during testing, preparation of standards, and calibration

procedures;

g. raw data sheets for field sampling and field and laboratory analyses;

h. documentation of calculations; and

i. any other information required by the test method.
Buschman Corporation Facility ID: 1318007874

PTI Application: 13-03302

Issued: 3/22/2001

18

Emissions Unit ID: P002

11172.wpd

3. If the permittee conducts performance testing at startup to obtain a permit to install, the results of

such testing may be used to demonstrate compliance if:

a. The test methods and procedures identified in this permit were used during the

performance test;

b. The performance test was conducted under representative operating conditions;

c. The performance test report contains the elements of paragraph 2.a. through 2.i. in this

section; and,

d. The permittee has sufficient data to establish the operating parameter value that

corresponds to compliance as required for continuous compliance monitoring.

4. All monitoring equipment shall be installed such that representative measures of emissions or

process parameters from the affected emission unit are obtained. For monitoring equipment

purchased from a vendor, verification of the operational status of the monitoring equipment shall

include execution of the manufacturer's written specifications or recommendations for installation,

operation, and calibration of the system.

5. The permittee shall measure the pressure drop across the add-on air pollution control device in

accordance with the following guidelines:

a. pressure taps shall be installed at any of the following locations:

i. at the inlet and outlet of the control system. The inlet tap should be installed in the

ductwork just prior to the control device and the corresponding outlet pressure tap

should be installed on the outlet side of the control device prior to the blower or

on the downstream side of the blower;

ii. on each side of the packed bed within the control system of each mesh pad within

the control system; and,

iii. on the front side of the first mesh pad and back side of the last mesh pad within the

control system.

b. pressure taps shall be sited at locations that are:

i. as free from pluggage as possible and away from any flow disturbances such as

cyclonic demisters; and,
Buschman Corporation Facility ID: 1318007874

PTI Application: 13-03302

Issued: 3/22/2001

19

Emissions Unit ID: P002

11172.wpd

ii. situated such that no air infiltration at the measurement site will occur that could

bias the measurement.

c. pressure taps shall be constructed of either polyethylene, polybutylene, or other

non-reactive materials;

d. non-reactive plastic tubing shall be used to connect the pressure taps to the device used to

measure pressure drop;

e. any of the following pressure gauges can be used to monitor pressure drop: a magnehelic

gauge, an included manometer, or a "U"tube manometer; and,

f. prior to connecting any pressure lines to the pressure gauge (s), each gauge shall be

zeroed. No calibration of the pressure gauges is required.

The following paragraphs should only be used if the monitoring requires a velocity pressure value

(i.e., packed bed scrubber).

6. The permittee shall measure the velocity pressure at the inlet to an add-on air pollution control

device to establish the site-specific velocity pressure as follows:

a. locate a velocity traverse port in a section of straight duct that connects the hooding on

the plating tank or tanks with the control device. The port shall be located as close to the

control system as possible, and shall be placed in a minimum of 2 duct diameters

downstream and 0.5 diameter upstream of any flow disturbance such as bend, expansion,

or contraction. If 2.5 diameters of straight duct work does not exist, locate the port 0.8 of

the duct diameter upstream from any flow disturbance; and,

b. a 12-point velocity traverse of the duct to the control device shall be conducted along a

single axis according to Method 2(40 CFR part 60, appendix A) with 12 points. Measure

the velocity pressure (delta p) values for the velocity points and record. Determine the

square root of the individual velocity point delta p values and average. The point with the

square root value that comes closest to the average square root value is the point of

average velocity. The delta p value measured for this point during the performance test

will be used as the reference for future monitoring.

7. The permittee shall use the following test methods to conduct an initial performance test:

a. Method 306 or Method 306A, "Determination of Chromium Emissions From Decorative
Buschman Corporation Facility ID: 1318007874

PTI Application: 13-03302

Issued: 3/22/2001

20

Emissions Unit ID: P002

11172.wpd

and Hard Chromium Electroplating and Anodizing Operations" shall be used to determine

the chromium concentration from hard or decorative chromium electroplating tanks or

chromium anodizing tanks:

i. The sampling time and sample volume for each run of Methods 306 and 306A shall

be at least 120 minutes and 1.7 dscm (60 dscf), respectively.

ii. Methods 306 and 306A allow the measurement of either total chromium or

hexavalent chromium emissions. Emissions units using chromic acid baths can

demonstrate compliance with the emission limits by measuring either the total

chromium or hexavalent chromium concentration. Hence, the hexavalent

chromium concentration measured by these methods is equal to the total chromium

concentration for the affected operations.

b. The California Air Resources Board (CARB) Method 425 may be used to determine the

chromium concentration from hard and decorative chromium electroplating tanks and

chromium anodizing tanks if the following conditions are met:

i. If a colorimetric analysis method is used, the sampling time and volume shall be

sufficient to result in 33-66 micrograms of catch in the sampling train;

ii. If an Atomic Absorption Graphite Furnace (AAGF) or Ion Chromatography (with

a Post-column Reactor (ICPCR) analyses) is used, the sampling time and volume

should be sufficient to result in a sample catch that is 5 to 10 times the minimum

detection limit of the analytical method (i.e., 1.0 microgram per liter of sample for

AAGF and 0.5 microgram per liter of sample for ICPCR);

iii. A minimum of three separate runs must be conducted. The other requirements of 

§63.7 of 40 CFR Part 63, subpart A must also be met; and,

iv. specifications for differential pressure measurement devices used to measure

velocity pressure shall be in accordance with section 2.2 of Method 2 (40 CFR part

60, Appendix A).

F. Miscellaneous Requirements

None
21

Emissions Unit ID: P002

NEW SOURCE REVIEW FORM B

PTI Number: 13-03302 Facility ID: 1318007874

FACILITY NAME Buschman Corporation

FACILITY DESCRIPTION Hard Chrome Plater CITY/TWP Cleveland

11172.wpd

SIC CODE 3471 SCC CODE 3-09-010-01 EMISSIONS UNIT ID P002

EMISSIONS UNIT DESCRIPTION Electroplating hard chrome system number 2

DATE INSTALLED 6-97

EMISSIONS: (Click on bubble help for Air Quality Descriptions)

Pollutants Air Quality Description

Actual Emissions Rate PTI Allowable

Short Term Rate Tons Per Year Short Term 

Rate

Tons Per Year

Particulate Matter

PM10

Sulfur Dioxide

Organic Compounds

Nitrogen Oxides

Carbon Monoxide

Lead

Other: Air Toxics 6.3e

-4 0.0015

APPLICABLE FEDERAL RULES:

NSPS? Subpart T NESHAP? PSD? OFFSET POLICY?

WHAT IS THE BAT DETERMINATION, AND WHAT IS THE BASIS FOR THE DETERMINATION?

Enter Determination

IS THIS SOURCE SUBJECT TO THE AIR TOXICS POLICY? no

OPTIONAL: WHAT IS THE CAPITAL COST OF CONTROL EQUIPMENT? $0

TOXIC AIR CONTAMINANTS

Ohio EPA's air toxics policy applies to contaiminants for which the American Conference of Governmental Industrial Hygienists (ACGIH) 

has a listed threshold limit value.

AIR TOXICS MODELING PERFORMED*? YES x NO

IDENTIFY THE AIR CONTAMINANTS: Chromium
22

Emissions Unit ID: P002

NEW SOURCE REVIEW FORM B

PTI Number: 13-03302 Facility ID: 1318007874

FACILITY NAME Buschman Corporation

FACILITY DESCRIPTION Hard Chrome Plater CITY/TWP Cleveland

11172.wpd

ADMINISTRATIVE MODIFICATION

inter-office communication

to: DAPC, Air Quality Modeling and Planning

from: Cleveland Bureau of Air Pollution Control 

subject: Administrative Modification of Permit To Install

date: February 6, 2001

Choose one:

Initiated by: ☐ Permittee ☒ DO/laa

☐ This modification is the result of an appeal to the Environmental Review Appeals Commission

Please fill out the following:

SUMMARY (for informational purposes only) 

TOTAL PERMIT TO INSTALL ALLOWABLE EMISSIONS

Pollutant Tons Per Year

Chromium (as TSP mist) 0.0015

Please provide a fairly detailed description of the basis for the modification and how the permit is being modified:

1. To strike out obsoleted language from Testing Requirements. Remove requirements for determination of the uncontrolled mass rate of emission. 

Additional comments:
23

Emissions Unit ID: P002

NEW SOURCE REVIEW FORM B

PTI Number: 13-03302 Facility ID: 1318007874

FACILITY NAME Buschman Corporation

FACILITY DESCRIPTION Hard Chrome Plater CITY/TWP Cleveland

11172.wpd

Ohio EPA Permit to Install Information Form 

Please describe below any documentation which is being submitted with 

this recommendation (must be sent the same day). Electronic items should 

be submitted with the e-mail transmitting the PTI terms, and in software 

that CO can utilize. If mailing any hard copy, this section must be printed 

as a cover page. All items must be clearly labeled indicating the PTI name 

and number. Submit hard copy items to Pam McGraner, AQM&P, DAPC, 

Central Office, and electronic files to airpti@epa.state.oh.us

Please fill out the following. If the checkbox 

does not work, replace it with an ‘X’ Electr

onic

Additional 

information File 

Name Convention 

(your PTI # plus 

this letter)

Ha

rd 

Co

py

No

ne

Calculations (required) ☒ 1303302c.wpd ☐

Modeling form/results ☐ 0000000s.wpd ☐ ☐

PTI Application (complete 

or partial)*

☐ 0000000a.wpd ☐ ☐

BAT Study ☐ 0000000b.wpd ☐ ☐

Other/misc. ☐ 0000000t.wpd ☐ ☐

* Mandatory for netting, PSD, nonattainment NSR, 112(g), 

21-07(G)(9)(g) and 21-09(U)(2)(f) - 2 complete copies.

Please complete (see comment bubble to the left for additional 

instructions):

NSR Discussion
24

Emissions Unit ID: P002

NEW SOURCE REVIEW FORM B

PTI Number: 13-03302 Facility ID: 1318007874

FACILITY NAME Buschman Corporation

FACILITY DESCRIPTION Hard Chrome Plater CITY/TWP Cleveland

11172.wpd

NONE

Please complete for these type permits (For PSD/NSR Permit, place mouse 

over this text):

☐ Synthetic Minor Determination and/or ☐ Netting Determination 

Permit To Install ENTER PTI NUMBER HERE

A. Source Description

B. Facility Emissions and Attainment Status

C. Source Emissions

D. Conclusion

PLEASE PROVIDE ADDITIONAL NOTES OR COMMENTS AS 

NECESSARY:

NONE

Please complete:

SUMMARY (for informational purposes only)

TOTAL PERMIT TO INSTALL ALLOWABLE 

EMISSIONS

Pollutant Tons Per Year

Chromium 

(as TSP 

mist)

0.0015
25

Emissions Unit ID: P002

NEW SOURCE REVIEW FORM B

PTI Number: 13-03302 Facility ID: 1318007874

FACILITY NAME Buschman Corporation

FACILITY DESCRIPTION Hard Chrome Plater CITY/TWP Cleveland

11172.wpd
26

Emissions Unit ID: P002

NEW SOURCE REVIEW FORM B

PTI Number: 13-03302 Facility ID: 1318007874

FACILITY NAME Buschman Corporation

FACILITY DESCRIPTION Hard Chrome Plater CITY/TWP Cleveland

11172.wpd