NEW SOURCE CONSTRUCTION PERMIT

and MINOR SOURCE OPERATING PERMIT

OFFICE OF AIR MANAGEMENT

H.V. Roll Center, Incorporated

1079 W. State Road 149

Chesterton, IN 46304

(herein known as the Permittee) is hereby authorized to construct and operate subject to the

conditions contained herein, the emission units described in Section A (Source Summary) of this

permit. 

This permit is issued to the above mentioned company under the provisions of 326 IAC 2-1.1,

326 IAC 2-5.1 if new source, 326 IAC 2-6.1 and 40 CFR 52.780, with conditions listed on the

attached pages.

Operation Permit No.: MSOP 127-11519-00091

Issued by: 

Paul Dubenetzky, Branch Chief

Office of Air Management

Issuance Date:
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-

11519-00091

Permit Reviewer: PR/EVP

Page 2 of 26

TABLE OF CONTENTS

A SOURCE SUMMARY .......................................................... 3

A.1 General Information [326 IAC 2-5.1-3(c)] [326 IAC 2-6.1-4(a)]

A.2 Emission Units and Pollution Control Equipment Summary 

A.3 Part 70 Permit Applicability [326 IAC 2-7-2]

B GENERAL CONSTRUCTION CONDITIONS ....................................... 5

B.1 Permit No Defense [IC 13]

B.2 Definitions

B.3 Effective Date of the Permit [IC13-15-5-3]

B.4 Revocation of Permits [326 IAC 2-1.1-9(5)]

B.5 Modification to Permit [326 IAC 2]

B.6 Minor Source Operating Permit [326 IAC 2-6.1]

C SOURCE OPERATION CONDITIONS ............................................ 7

C.1 PSD Minor Source Status [326 IAC 2-2] [40 CFR 52.21] 

C.2 Preventive Maintenance Plan [326 IAC 1-6-3]

C.3 Permit Revision [326 IAC 2-5.1-3(e)(3)] [326 IAC 2-6.1-6]

C.4 Inspection and Entry [326 IAC 2-7-6(2)]

C.5 Transfer of Ownership or Operation [326 IAC 2-6.1-6(d)(3)]

C.6 Permit Revocation [326 IAC 2-1-9]

C.7 Opacity [326 IAC 5-1]

Testing Requirements

C.8 Performance Testing [326 IAC 3-6][326 IAC 2-1.1-11]

Compliance Monitoring Requirements 

C.9 Compliance Monitoring [326 IAC 2-1.1-11]

C.10 Monitoring Methods [326 IAC 3]

Record Keeping and Reporting Requirements

C.11 Malfunctions Report [326 IAC 1-6-2]

C.12 Annual Emission Statement [326 IAC 2-6]

C.13 Monitoring Data Availability [326 IAC 2-6.1-2] [IC 13-14-1-13]

C.14 General Record Keeping Requirements [326 IAC 2-6.1-2]

C.15 General Reporting Requirements [326 IAC 2-1.1-11] [326 IAC 2-6.1-2] [IC 13-14-1-13] 

C.16 Annual Notification [326 IAC 2-6.1-5(a)(5)]

D.1 EMISSIONS UNIT OPERATION CONDITIONS - Hard Chrome Tanks ................. 15

Emission Limitations and Standards 

D.1.1 General Provisions Relating to HAPs [326 IAC 20-1-1] [40 CFR Part 63, Subpart A]

D.1.2 Chromium Electroplating NESHAP [326 IAC 20-8-1] [40 CFR Part 63, Subpart N]

D.1.3 Preventive Maintenance Plan [326 IAC 1-6-3]

D.1.4 Operation and Maintenance Plan [40 CFR 63.342(f)(3)]

Compliance Determination Requirements

D.1.5 Performance Testing [40 CFR 63.343, 63.344, and 63.7]

Compliance Monitoring Requirements

D.1.6 Monitoring to Demonstrate Continuous Compliance [40 CFR 63.343(c)(1)]
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-

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Permit Reviewer: PR/EVP

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Record Keeping and Reporting Requirements [326 IAC 2-5.1-3(e)(2)] [326 IAC 2- 6.1-

5(a)(2)]

D.1.7 Record Keeping Requirements [40 CFR 63.346]

D.1.8 Reporting Requirements [40 CFR 63.345 & 63.347]

Annual Notification ................................................................ 21

Malfunction Report ................................................................ 22

Ongoing Compliance Status Report .................................................. 24
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-

11519-00091

Permit Reviewer: PR/EVP

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SECTION A SOURCE SUMMARY

This permit is based on information requested by the Indiana Department of Environmental Management

(IDEM), Office of Air Management (OAM). The information describing the source contained in conditions

A.1 through A.3 is descriptive information and does not constitute enforceable conditions. However, the

Permittee should be aware that a physical change or a change in the method of operation that may

render this descriptive information obsolete or inaccurate may trigger requirements for the Permittee to

obtain additional permits or seek modification of this permit pursuant to 326 IAC 2, or change other

applicable requirements presented in the permit application.

A.1 General Information [326 IAC 2-5.1-3(c)] [326 IAC 2-6.1-4(a)] 

The Permittee owns and operates a stationary source, hard chromium electroplating operation for

reconditioning mill rolls.

Authorized Individual: Don Lippelt

Source Address: 1079 W. State Road 149, Chesterton, IN 46304

Mailing Address: P.O. Box M 828 Gary, IN 46401

Phone Number: 219-886-7655

SIC Code: 3471

County Location: Porter

County Status: Attainment for all criteria pollutants 

Source Status: Minor Source Operating Permit

Minor Source, under PSD Rules; 

Minor Source, Section 112 of the Clean Air Act

A.2 Emissions units and Pollution Control Equipment Summary 

This stationary source is approved to construct and operate the following emissions units and

pollution control devices:

(a) Two (2) hard chromium electroplating operations, identified as P-1 and P-2, using a

composite mesh-pad system for control, each having a rectifier with a maximum

potential capacity of 12,500 amps, exhausting to one (1) stack identified as S-1.

A.3 Part 70 Permit Applicability [326 IAC 2-7-2]

This stationary source is not required to have a Part 70 permit by 326 IAC 2-7-2 (Applicability)

because:

(a) It is a minor source, as defined in 326 IAC 2-7-1(22);

(b) It is not an affected source under Title IV (Acid Deposition Control) of the Clean Air Act,

as defined in 326 IAC 2-7-1(3);

(c) It is not in a source in a source category designated by the United States Environmental

Protection Agency (U.S. EPA) under 40 CFR 70.3 (Part 70 - Applicability).
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-

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Permit Reviewer: PR/EVP

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SECTION B GENERAL CONSTRUCTION CONDITIONS

THIS SECTION OF THE PERMIT IS BEING ISSUED UNDER THE PROVISIONS OF 326 IAC 2-1.1 AND

40 CFR 52.780, WITH CONDITIONS LISTED BELOW.

B.1 Permit No Defense [IC 13]

This permit to construct does not relieve the Permittee of the responsibility to comply with the

provisions of the Indiana Environmental Management Law (IC 13-11 through 13-20; 13-22

through 13-25; and 13-30), the Air Pollution Control Law (IC 13-17) and the rules promulgated

thereunder, as well as other applicable local, state, and federal requirements.

B.2 Definitions

Terms in this permit shall have the definition assigned to such terms in the referenced

regulation. In the absence of definitions in the referenced regulation, any applicable definitions

found in IC 13-11, 326 IAC 1-2, and 326 IAC 2-1.1-1 shall prevail.

B.3 Effective Date of the Permit [IC13-15-5-3]

Pursuant to IC 13-15-5-3, this permit becomes effective upon its issuance.

B.4 Revocation of Permits [326 IAC 2-1.1-9(5)]

Pursuant to 326 IAC 2-1.1-9(5)(Revocation of Permits), the Commissioner may revoke this

permit if construction is not commenced within eighteen (18) months after receipt of this

approval or if construction is suspended for a continuous period of one (1) year or more.

B.5 Modification to Permit [326 IAC 2]

Notwithstanding the Section B condition entitled “Minor Source Operating Permit”, all

requirements and conditions of this construction permit shall remain in effect unless modified in

a manner consistent with procedures established for modifications of construction permits

pursuant to 326 IAC 2 (Permit Review Rules).

B.6 Minor Source Operating Permit [326 IAC 2-6.1]

This document shall also become a minor source operating permit pursuant to 326 IAC 2-6.1 

when, prior to start of operation, the following requirements are met:

(a) The attached Affidavit of Construction shall be submitted to the Office of Air

Management (OAM), Permit Administration & Development Section.

(1) If the Affidavit of Construction verifies that the facilities covered in this

Construction Permit were constructed as proposed in the application, then the

facilities may begin operating on the date the Affidavit of Construction is

postmarked or hand delivered to IDEM.

(2) If the Affidavit of Construction does not verify that the facilities covered in this

Construction Permit were constructed as proposed in the application, then the

Permittee shall receive an Operation Permit Validation Letter from the Chief of

the Permit Administration & Development Section prior to beginning operation of

the facilities.

(b) If construction is completed in phases; i.e., the entire construction is not done

continuously, a separate affidavit must be submitted for each phase of construction. 

Any permit conditions associated with operation start up dates such as stack testing for

New Source Performance Standards (NSPS) shall be applicable to each individual

phase. 

(c) Upon receipt of the Operation Permit Validation Letter from the Chief of the Permit

Administration & Development Section, the Permittee shall attach it to this document.
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(d) The operation permit will be subject to annual operating permit fees pursuant to 326 IAC

2-1.1-7(Fees).

(e) Pursuant to 326 IAC 2-6.1-7, the Permittee shall apply for an operation permit renewal at

least ninety (90) days prior to the expiration date established in the validation letter. If

IDEM, OAM, upon receiving a timely and complete permit application, fails to issue or

deny the permit renewal prior to the expiration date of this permit, this existing permit

shall not expire and all terms and conditions shall continue in effect until the renewal

permit has been issued or denied. The operation permit issued shall contain as a

minimum the conditions in Section C and Section D of this permit.
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-

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Permit Reviewer: PR/EVP

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SECTION C SOURCE OPERATION CONDITIONS

Entire Source

C.1 PSD Minor Source Status [326 IAC 2-2] [40 CFR 52.21] 

(a) The total source potential to emit of all criteria pollutants is less than 250 tons per year. 

Therefore the requirements of 326 IAC 2-2 (Prevention of Significant Deterioration) and

40 CFR 52.21 will not apply.

(b) Any change or modification which may increase potential to emit to 250 tons per year

from this source, shall cause this source to be considered a major source under PSD,

326 IAC 2-2 and 40 CFR 52.21, and shall require approval from IDEM, OAM prior to

making the change.

(c) Any change or modification which may increase potential to emit to 10 tons per year of

any single hazardous air pollutant, twenty-five tons per year of any combination of

hazardous air pollutants, or 100 tons per year of any other regulated pollutant from this

source, shall cause this source to be considered a major source under Part 70 Permit

Program, 326 IAC 2-7, and shall require approval from IDEM, OAM prior to making the

change.

C.2 Preventive Maintenance Plan [326 IAC 1-6-3]

(a) If required by specific condition(s) in Section D of this permit, the Permittee shall prepare

and maintain Preventive Maintenance Plans (PMP) after issuance of this permit, including

the following information on each emissions unit:

(1) Identification of the individual(s) responsible for inspecting, maintaining, and

repairing emission control devices;

(2) A description of the items or conditions that will be inspected and the inspection

schedule for said items or conditions; 

(3) Identification and quantification of the replacement parts that will be maintained in

inventory for quick replacement.

(b) The Permittee shall implement the Preventive Maintenance Plans as necessary to

ensure that failure to implement the Preventive Maintenance Plan does not cause or

contribute to a violation of any limitation on emissions or potential to emit.

(c) PMP’s shall be submitted to IDEM, OAM, upon request and shall be subject to review

and approval by IDEM, OAM. IDEM, OAM, may require the Permittee to revise its

Preventive Maintenance Plan whenever lack of proper maintenance causes or

contributes to any violation.

C.3 Permit Revision [326 IAC 2-5.1-3(e)(3)] [326 IAC 2-6.1-6]

(a) The Permittee must comply with the requirements of 326 IAC 2-6.1-6 whenever the

Permittee seeks to amend or modify this permit. 

(b) Any application requesting an amendment or modification of this permit shall be

submitted to:
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Indiana Department of Environmental Management

Permits Branch, Office of Air Management

100 North Senate Avenue, P.O. Box 6015 

Indianapolis, Indiana 46206-6015

Any such application should be certified by the “authorized individual” as defined by 

326 IAC 2-1.1-1. 

(c) The Permittee shall notify the OAM within thirty (30) calendar days of implementing a

notice-only change. [326 IAC 2-6.1-6(d)]

C.4 Inspection and Entry [326 IAC 2-7-6(2)]

Upon presentation of proper identification cards, credentials, and other documents as may be

required by law, and subject to the Permittee’s right under all applicable laws and regulations to

assert that the information collected by the agency is confidential and entitled to be treated as

such, the Permittee shall allow IDEM, OAM, U.S. EPA, or an authorized representative to

perform the following:

(a) Enter upon the Permittee's premises where a permitted source is located, or

emissions related activity is conducted, or where records must be kept under the

conditions of this permit;

(b) Have access to and copy, at reasonable times, any records that must be kept under this

title or the conditions of this permit or any operating permit revisions;

(c) Inspect, at reasonable times, any processes, emissions units (including monitoring and air

pollution control equipment), practices, or operations regulated or required under this

permit or any operating permit revisions; 

(d) Sample or monitor, at reasonable times, substances or parameters for the purpose of

assuring compliance with this permit or applicable requirements; and

(e) Utilize any photographic, recording, testing, monitoring, or other equipment for the

purpose of assuring compliance with this permit or applicable requirements.

C.5 Transfer of Ownership or Operation [326 IAC 2-6.1-6(d)(3)]

Pursuant to [326 IAC 2-6.1-6(d)(3)] :

(a) In the event that ownership of this source is changed, the Permittee shall notify IDEM,

OAM, Permits Branch, within thirty (30) days of the change. 

(b) The written notification shall be sufficient to transfer the permit to the new owner by an

notice-only change pursuant to 326 IAC 2-6.1-6(d)(3). 

(c) IDEM, OAM, shall issue a revised permit.

The notification which shall be submitted by the Permittee does require the certification by the

“authorized individual” as defined by 326 IAC 2-1.1-1.

C.6 Permit Revocation [326 IAC 2-1-9]

Pursuant to 326 IAC 2-1-9(a)(Revocation of Permits), this permit to construct and operate may

be revoked for any of the following causes:

(a) Violation of any conditions of this permit.
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Chesterton, Indiana MSOP127-

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(b) Failure to disclose all the relevant facts, or misrepresentation in obtaining this permit.

(c) Changes in regulatory requirements that mandate either a temporary or permanent

reduction of discharge of contaminants. However, the amendment of appropriate

sections of this permit shall not require revocation of this permit.

(d) Noncompliance with orders issued pursuant to 326 IAC 1-5 (Episode Alert Levels) to

reduce emissions during an air pollution episode.

(e) For any cause which establishes in the judgment of IDEM , the fact that continuance of

this permit is not consistent with purposes of this article.

C.7 Opacity [326 IAC 5-1]

Pursuant to 326 IAC 5-1-2 (Opacity Limitations), except as provided in 326 IAC 5-1-3

(Temporary Alternative Opacity Limitations), opacity shall meet the following, unless otherwise

stated in this permit:

(a) Opacity shall not exceed an average of forty percent (40%) in any one (1) six (6) minute

averaging period as determined in 326 IAC 5-1-4. 

(b) Opacity shall not exceed sixty percent (60%) for more than a cumulative total of fifteen

(15) minutes (sixty (60) readings) as measured according to 40 CFR 60, Appendix A,

Method 9 or fifteen (15) one (1) minute nonoverlapping integrated averages for a

continuous opacity monitor in a six (6) hour period.

Testing Requirements

C.8 Performance Testing [326 IAC 3-6][326 IAC 2-1.1-11]

(a) Compliance testing on new emissions units shall be conducted within 60 days after

achieving maximum production rate, but no later than 180 days after initial start-up, if

specified in Section D of this approval. All testing shall be performed according to the

provisions of 326 IAC 3-6 (Source Sampling Procedures), except as provided elsewhere

in this permit, utilizing any applicable procedures and analysis methods specified in 40

CFR 51, 40 CFR 60, 40 CFR 61, 40 CFR 63, 40 CFR 75, or other procedures approved

by IDEM, OAM.

A test protocol, except as provided elsewhere in this permit, shall be submitted to:

Indiana Department of Environmental Management

Compliance Data Section, Office of Air Management

100 North Senate Avenue, P. O. Box 6015

Indianapolis, Indiana 46206-6015

no later than thirty-five (35) days prior to the intended test date. The Permittee shall

submit a notice of the actual test date to the above address so that it is received at least

two weeks prior to the test date.

(b) All test reports must be received by IDEM, OAM within forty-five (45) days after the

completion of the testing. An extension may be granted by the IDEM, OAM, , if the

source submits to IDEM, OAM, a reasonable written explanation within five (5) days prior

to the end of the initial forty-five (45) day period.

The documentation submitted by the Permittee does not require certification by the “authorized
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Chesterton, Indiana MSOP127-

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individual” as defined by 326 IAC 2-1.1-1.

Compliance Monitoring Requirements 

C.9 Compliance Monitoring [326 IAC 2-1.1-11]

Compliance with applicable requirements shall be documented as required by this permit. The

Permittee shall be responsible for installing any necessary equipment and initiating any required

monitoring related to that equipment. All monitoring and record keeping requirements not

already legally required shall be implemented when operation begins.

C.10 Monitoring Methods [326 IAC 3]

Any monitoring or testing required by Section D of this permit shall be performed according to

the provisions of 326 IAC 3, 40 CFR 60, Appendix A, or other approved methods as specified in

this permit.

Record Keeping and Reporting Requirements

C.11 Malfunctions Report [326 IAC 1-6-2] 

Pursuant to 326 IAC 1-6-2 (Records; Notice of Malfunction):

(a) A record of all malfunctions, including startups or shutdowns of any facility or emission

control equipment, which result in violations of applicable air pollution control regulations

or applicable emission limitations shall be kept and retained for a period of three (3)

years and shall be made available to the Indiana Department of Environmental

Management (IDEM), Office of Air Management (OAM) or appointed representative

upon request. 

(b) When a malfunction of any facility or emission control equipment occurs which lasts

more than one (1) hour, said condition shall be reported to OAM, using the Malfunction

Report Forms (2 pages). Notification shall be made by telephone or facsimile, as soon

as practicable, but in no event later than four (4) daytime business hours after the

beginning of said occurrence. 

(c) Failure to report a malfunction of any emission control equipment shall constitute a

violation of 326 IAC 1-6, and any other applicable rules. Information of the scope and

expected duration of the malfunction shall be provided, including the items specified in

326 IAC 1-6-2(a)(1) through (6).

(d) Malfunction is defined as any sudden, unavoidable failure of any air pollution control

equipment, process, or combustion or process equipment to operate in a normal and

usual manner. [326 IAC 1-2-39]

C.12 Annual Emission Statement [326 IAC 2-6]

(a) The Permittee shall submit an annual emission statement certified pursuant to the

requirements of 326 IAC 2-6, that must be received by July 1 of each year and must

comply with the minimum requirements specified in 326 IAC 2-6-4. The annual

emission statement shall meet the following requirements:

(1) Indicate actual emissions of criteria pollutants from the source, in compliance

with 326 IAC 2-6 (Emission Reporting);

(2) Indicate actual emissions of other regulated pollutants from the source, for

purposes of Part 70 fee assessment.
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Chesterton, Indiana MSOP127-

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(b) The annual emission statement covers the twelve (12) consecutive month time period

starting January 1 and ending December 31. The annual emission statement must be

submitted to:

Indiana Department of Environmental Management

Technical Support and Modeling Section, Office of Air Management

100 North Senate Avenue, P. O. Box 6015

Indianapolis, Indiana 46206-6015

(c) The annual emission statement required by this permit shall be considered timely if the

date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the

private shipping receipt, is on or before the date it is due. If the document is submitted by

any other means, it shall be considered timely if received by IDEM, OAM, on or before the

date it is due.

The submittal by the Permittee does require the certification by the “authorized individual” as

defined by 326 IAC 2-1.1-1.

C.13 Monitoring Data Availability [326 IAC 2-6.1-2] [IC 13-14-1-13]

(a) With the exception of performance tests conducted in accordance with Section CPerformance Testing, all observations, sampling, maintenance procedures, and record

keeping, required as a condition of this permit shall be performed at all times the

equipment is operating at normal representative conditions. 

(b) As an alternative to the observations, sampling, maintenance procedures, and record

keeping of subsection (a) above, when the equipment listed in Section D of this permit is

not operating, the Permittee shall either record the fact that the equipment is shut down

or perform the observations, sampling, maintenance procedures, and record keeping

that would otherwise be required by this permit.

(c) If the equipment is operating but abnormal conditions prevail, additional observations

and sampling should be taken with a record made of the nature of the abnormality. 

(d) If for reasons beyond its control, the operator fails to make required observations,

sampling, maintenance procedures, or record keeping, reasons for this must be

recorded. 

(e) At its discretion, IDEM may excuse such failure providing adequate justification is

documented and such failures do not exceed five percent (5%) of the operating time in

any quarter. 

(f) Temporary, unscheduled unavailability of staff qualified to perform the required

observations, sampling, maintenance procedures, or record keeping shall be considered

a valid reason for failure to perform the requirements stated in (a) above.

C.14 General Record Keeping Requirements [326 IAC 2-6.1-2]

(a) Records of all required monitoring data and support information shall be retained for a

period of at least five (5) years from the date of monitoring sample, measurement,

report, or application. These records shall be kept at the source location for a minimum

of three (3) years and available upon the request of an IDEM, OAM, representative. The

records may be stored elsewhere for the remaining two (2) years as long as they are

available upon request. If the Commissioner makes a written request for records to the
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Permittee, the Permittee shall furnish the records to the Commissioner within a

reasonable time.

(b) Records of required monitoring information shall include, where applicable:

(1) The date, place, and time of sampling or measurements;

(2) The dates analyses were performed;

(3) The company or entity performing the analyses;

(4) The analytic techniques or methods used;

(5) The results of such analyses; and 

(6) The operating conditions existing at the time of sampling or measurement.

(c) Support information shall include, where applicable:

(1) Copies of all reports required by this permit;

(2) All original strip chart recordings for continuous monitoring instrumentation; 

(3) All calibration and maintenance records;

(4) Records of preventive maintenance shall be sufficient to demonstrate that

failure to implement the Preventive Maintenance Plan did not cause or

contribute to a violation of any limitation on emissions or potential to emit. To be

relied upon subsequent to any such violation, these records may include, but are

not limited to: work orders, parts inventories, and operator’s standard operating

procedures. Records of response steps taken shall indicate whether the

response steps were performed in accordance with the Compliance Response

Plan required by Section C - Compliance Monitoring Plan - Failure to take

Response Steps, of this permit, and whether a deviation from a permit condition

was reported. All records shall briefly describe what maintenance and response

steps were taken and indicate who performed the tasks.

(d) All record keeping requirements not already legally required shall be implemented when

operation begins.

C.15 General Reporting Requirements [326 IAC 2-1.1-11] [326 IAC 2-6.1-2] [IC 13-14-1-13] 

(a) To affirm that the source has met all the compliance monitoring requirements stated in

this permit the source shall submit a Quarterly Compliance Monitoring Report. Any

deviation from the requirements and the date(s) of each deviation must be reported. 

The Compliance Monitoring Report shall include the certification by the “authorized

individual” as defined by 326 IAC 2-1.1-1(1).

 (b) The report required in (a) of this condition and reports required by conditions in Section

D of this permit shall be submitted to:

Indiana Department of Environmental Management

Compliance Data Section, Office of Air Management

100 North Senate Avenue, P. O. Box 6015
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Indianapolis, Indiana 46206-6015

(c) Unless otherwise specified in this permit, any notice, report, or other submission

required by this permit shall be considered timely if the date postmarked on the envelope

or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or

before the date it is due. If the document is submitted by any other means, it shall be

considered timely if received by IDEM, OAM, on or before the date it is due.

(d) Unless otherwise specified in this permit, any quarterly report shall be submitted within

thirty (30) days of the end of the reporting period. The report does not require the

certification by the “authorized individual” as defined by 326 IAC 2-1.1-1(1).

(e) All instances of deviations must be clearly identified in such reports. A reportable

deviation is an exceedance of a permit limitation or a failure to comply with a

requirement of the permit or a rule. It does not include:

(1) An excursion from compliance monitoring parameters as identified in Section D

of this permit unless tied to an applicable rule or limit; or

(2) A malfunction as described in 326 IAC 1-6-2; or

(3) Failure to implement elements of the Preventive Maintenance Plan unless lack

of maintenance has caused or contributed to a deviation.

(4) Failure to make or record information required by the compliance monitoring

provisions of Section D unless such failure exceeds 5% of the required data in

any calendar quarter.

A Permittee’s failure to take the appropriate response step when an excursion of a

compliance monitoring parameter has occurred or failure to monitor or record the

required compliance monitoring is a deviation.

(f) Any corrective actions or response steps taken as a result of each deviation must be

clearly identified in such reports.

(g) The first report shall cover the period commencing on the date of issuance of this permit

and ending on the last day of the reporting period.

C.16 Annual Notification [326 IAC 2-6.1-5(a)(5)]

(a) Annual notification shall be submitted to the Office of Air Management stating whether or

not the source is in operation and in compliance with the terms and conditions contained

in this permit. 

(b) Noncompliance with any condition must be specifically identified. If there are any permit

conditions or requirements for which the source is not in compliance at any time during

the year, the Permittee must provide a narrative description of how the source did or will

achieve compliance and the date compliance was, or will be, achieved. The notification

must be signed by an authorized individual.
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(c) The annual notice shall cover the time period from January 1 to December 31 of the

previous year, and shall be submitted in the format attached no later than March 1 of

each year to:

Compliance Data Section, Office of Air Management

 Indiana Department of Environmental Management

100 North Senate Avenue, P.O. Box 6015

Indianapolis, IN 46206-6015

(d) The notification shall be considered timely if the date postmarked on the envelope or

certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or

before the date it is due. If the document is submitted by any other means, it shall be

considered timely if received by IDEM, OAM, on or before the date it is due.
H.V. Roll Center, Incorporated

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Page 15 of 26

SECTION D.1 EMISSIONS UNIT OPERATION CONDITIONS

Emissions Unit Description

(a) Two (2) hard chromium electroplating operations, identified as P-1 and P-2, using a

composite mesh-pad system for control, each having a rectifier with a maximum potential

capacity of 12,500 amps, exhausting to one (1) stack identified as S-1.

(The information describing the process contained in this emissions unit description box is descriptive

information and does not constitute enforceable conditions.)

Emission Limitations and Standards

D.1.1 General Provisions Relating to HAPs [326 IAC 20-1-1] [40 CFR Part 63, Subpart A]

The provisions of 40 CFR Part 63, Subpart A - General Provisions, which are incorporated as

326 IAC 20-1-1, apply to the emissions units described in this section except when otherwise

specified in 40 CFR Part 63, Subpart N.

D.1.2 Chromium Electroplating NESHAP [326 IAC 20-8-1] [40 CFR Part 63, Subpart N] 

[326 IAC 2-1.1-11]

These emissions units 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), which is incorporated by reference as 326 IAC 20-8-1. A copy of this rule is

attached. The Permittee shall comply with the requirements in this condition on and after the

startup date.

The emission limitations in this condition apply only during tank operation, and also apply during

periods of startup and shutdown as these are routine occurrences for affected sources subject to

326 IAC 20-8-1. The emission limitations do not apply during periods of malfunction, but the

work practice standards that address operation and maintenance and are required by paragraph

(b) of this condition must be followed during malfunctions.

(a) During tank operation, the Permittee shall control chromium emissions discharged to the

atmosphere from Stack S-1 of P-1 and P-2 by not allowing the concentration of total

chromium in the exhaust gas stream discharged to the atmosphere to exceed 0.015

milligrams of total chromium per dry standard cubic meter (mg/dscm) of ventilation air

(6.6 x 10-6 grains per dry standard cubic foot (gr/dscf)).

(b) The Permittee is subject to the following work practice standards, which address

operation and maintenance practices:

(1) At all times, including periods of startup, shutdown, malfunction, and excess

emissions, the Permittee shall operate and maintain P-1 and P-2, including the

composite mesh-pad system and monitoring equipment, in a manner consistent

with good air pollution control practices, consistent with the Operation and

Maintenance Plan (OMP) required by Condition D.1.4.

(2) Malfunctions and excess emissions shall be corrected as soon as practicable

after their occurrence in accordance with the OMP required by Condition D.1.4.

(3) These operation and maintenance requirements are enforceable independent of

emissions limitations or other requirements in this section.

(4) Determination of whether acceptable operation and maintenance procedures

are being used will be based on information available to IDEM, OAM, which may

include, but is not limited to, monitoring results; review of the OMP, procedures,
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and records; and inspection of the source.

(5) Based on the results of a determination made under paragraph (b)(4) of this

condition, IDEM, OAM may require that the Permittee make changes to the

OMP required by Condition D.1.4. Revisions may be required if IDEM, OAM

finds that the plan:

(A) Does not address a malfunction or period of excess emissions that has

occurred;

(B) Fails to provide for the operation of P-1 and P-2 or the composite meshpad system and process monitoring equipment during a malfunction or

period of excess emissions in a manner consistent with good air

pollution control practices; or

(C) Does not provide adequate procedures for correcting malfunctioning

process equipment, air pollution control techniques, or monitoring

equipment or other causes of excess emissions as quickly as

practicable.

D.1.3 Preventive Maintenance Plan [326 IAC 1-6-3]

A Preventive Maintenance Plan (PMP), in accordance with the Section B condition entitled

“Preventive Maintenance Plans” of this permit is required for P-1 and P-2 and the composite

mesh-pad system.

D.1.4 Operation and Maintenance Plan [40 CFR 63.342(f)(3)] [326 IAC 2-1.1-11]

(a) The Permittee shall prepare an Operation and Maintenance Plan (OMP) to be

implemented no later than the startup date of the emissions units. The plan shall specify

the operation and maintenance criteria for P-1 and P-2, the composite mesh-pad

system, and monitoring equipment, and shall include the following elements:

(1) Quarterly visual inspection of the composite mesh-pad 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 device;

(2) Quarterly visual inspection of the back portion of the mesh-pad closest to the fan

to ensure there is no breakthrough of chromic acid mist;

(3) Quarterly visual inspection of the ductwork from the tanks to the control device

to ensure there are no leaks;

(4) Perform washdown of the composite mesh-pads in accordance with

manufacturer’s recommendations.

(5) A standardized checklist to document the operation and maintenance criteria for

P-1 and P-2, the composite mesh-pad system, and monitoring equipment;

(6) Procedures to be followed to ensure that neither equipment or process

malfunctions due to poor maintenance or other preventable conditions nor

excess emissions as indicated by monitoring data occur;

(7) A systematic procedure for identifying malfunctions of and periods of excess

emissions from P-1 and P-2, the composite mesh-pad system, and monitoring
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equipment; and for implementing corrective actions to address such

malfunctions and periods of excess emissions.

(b) If the OMP fails to address or inadequately addresses an event that meets the

characteristics of a malfunction or a period of excess emissions as indicated by

monitoring data, the Permittee shall revise the OMP within forty five (45) days after such

an event occurs. The revised plan shall include procedures for operating and

maintaining P-1 and P-2, the composite mesh-pad system, and monitoring equipment,

during similar malfunction and excess emissions events, and a program for corrective

action for such events.

(c) If actions taken by the Permittee during periods of malfunction or excess emissions are

inconsistent with the procedures specified in the OMP, the Permittee shall record the

actions taken for that event and shall report by phone such actions within two (2)

working days after commencing actions inconsistent with the plan. This report shall be

followed by a letter within seven (7) working days after the end of the event, unless the

Permittee makes alternative reporting arrangements, in advance, with IDEM, OAM.

(d) The Permittee shall keep the written OMP on record after it is developed to be made

available, upon request, by IDEM, OAM for the life of P-1 and P-2 or until P-1 and P-2

are no longer subject to the provisions of 40 CFR 63.340. In addition, if the OMP is

revised, the Permittee shall keep previous versions of the OMP on record to be made

available for inspection, upon request by IDEM, OAM for a period of five (5) years after

each revision to the plan.

(e) The Permittee may use applicable standard operating procedures (SOP) manuals,

occupational safety and health administration (OSHA) plans, or other existing plans

such as the PMP required in Condition D.1.3, as the OMP provided the alternative plans

meet the criteria listed above in Condition D.1.4(a).

Compliance Determination Requirements

D.1.5 Performance Testing [40 CFR 63.343, 63.344, and 63.7]

(a) The Permittee is required to conduct an initial performance test within 180 days after

startup of the emissions units using the procedures and methods listed in 40 CFR

63.344 and 63.7 and in accordance with the provisions of Condition C.8 - Performance

Testing of this permit.

(b) During the initial performance test, the Permittee shall determine the outlet chromium

concentration of the composite mesh-pad system using the test methods and

procedures in 40 CFR 63.344(c) and shall establish as a site-specific operating

parameter the pressure drop across the system, setting the value that corresponds to

compliance with the emission limitation in Condition D.1.2(a) using the procedures in 40

CFR 63.344(d)(5). The Permittee may conduct multiple performance tests to establish a

range of compliant pressure drop values, or may set as the compliant value the average

pressure drop measured over the three (3) test runs of one performance test, and

accept ±1 inch of water column from this value as the compliant range.

Compliance Monitoring Requirements

D.1.6 Monitoring to Demonstrate Continuous Compliance [40 CFR 63.343(c)(1)] [326 IAC 2-1.1-11]

(a) On and after the date on which the initial performance test required in Condition D.1.5 is
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required to be completed under 40 CFR 63.7, the Permittee shall monitor and record the

pressure drop across the composite mesh-pad system once each day that either tank in

P-1 or P-2 is in operation. To be in compliance with the standards, the composite meshpad system shall be operated within ±1 inch of water column of the pressure drop value

established during the initial performance test, or within the range of compliant values

for pressure drop established during multiple performance tests.

(b) Tank operation or operating time for chromium electroplating is defined as that time

when the rectifier is turned on and a part is in the tank. When there is no part in a tank

for fifteen (15) or more minutes, the tanks will not be considered to be in operation, and

that time will not be considered operating time. Likewise, if the time between placing a

part in the tank is less than fifteen (15) minutes, the tanks will be considered to be in

operation, and that time will be considered part of the operating time.

Record Keeping and Reporting Requirements [326 IAC 2-5.1-3(e)(2)] [326 IAC 2- 6.1-5(a)(2)]

D.1.7 Record Keeping Requirements [40 CFR 63.346] [326 IAC 2-1.1-11]

The Permittee shall maintain records to document compliance with Conditions D.1.2 and D.1.4

using the forms provided with this permit. These records shall be maintained in accordance with

the Section C condition entitled “General Record Keeping Requirements” of this permit, and

include a minimum of the following:

(a) Inspection records for the composite mesh-pad system and monitoring equipment to

document that the inspection and maintenance required by Conditions D.1.3 and D.1.4

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

following:

(1) The device inspected;

(2) The date of inspection;

(3) A brief description of the working condition of the device during the inspection,

including any deficiencies found; and

(4) Any actions taken to correct deficiencies found during the inspection, including

the date(s) such actions were taken.

(b) Records of all maintenance performed on P-1 and P-2, the composite mesh-pad system

and monitoring equipment.

(c) Records of the occurrence, duration, and cause (if known) of each malfunction of P-1

and P-2, the composite mesh-pad system and monitoring equipment and each period of

excess emissions from P-1 and P-2 and the composite mesh-pad system as indicated

by monitoring data collected in accordance with paragraph (g) of this condition.

(d) Records of actions taken during periods of malfunction or excess emissions when such

actions are inconsistent with the OMP.

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

consistency with the provisions of the OMP.

(f) Test reports documenting results of all performance tests and all measurements as may

be necessary to determine the conditions of performance tests, including measurements
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necessary to determine compliance.

(g) 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.

(h) The total operating time of P-1 and the total operating time of P-2 during the reporting

period, operating time as defined in Condition D.1.6(b).

(i) All documentation supporting the notifications and reports required by 40 CFR 63.9 and

63.10, and Condition D.1.8.

D.1.8 Reporting Requirements [40 CFR 63.345 & 63.347] [326 IAC 2-1.1-11]

The notifications and reports required in this section shall be submitted to the address specified

in Condition C.15 - General Reporting Requirements of this permit.

(a) The Permittee may not construct a new emissions unit subject to 326 IAC 20-8-1

(including non-affected sources defined in 40 CFR 63.344(e)), or change, modify, or

reconstruct P-1 or P-2 (including addition of ductwork to the composite mesh-pad

system or change in the air pollution control technique used to comply with Condition

D.1.2) without submitting a Notification of Construction or Reconstruction for these new

or reconstructed emissions units to IDEM, OAM.

(1) The application to construct P-1 and P-2 serves as this notification. Likewise, a

complete application for a permit revision shall serve as this notification for any

new construction or reconstruction.

(2) Pursuant to 326 IAC 2-1.1-2(a), permission must be received from IDEM, OAM

before construction or reconstruction may commence.

(b) The Permittee shall submit an Initial Notification for P-1 and P-2 as follows:

(1) A notification of the date when construction or reconstruction of the emissions

units was commenced shall be submitted no later than thirty (30) calendar days

after such date.

(2) A notification of the actual date of startup of the emissions units shall be

submitted within thirty (30) calendar days after such date.

(c) The Permittee shall notify IDEM, OAM in writing of their intention to conduct the initial

performance test required in Condition D.1.5 and any future performance tests

conducted as required by 40 CFR 63.7 and 63.343(b) at least sixty (60) calendar days

before the test is scheduled to begin.

(1) Pursuant to Condition C.8 - Performance Testing, a test protocol shall be

submitted no later than thirty-five (35) days prior to the intended test date.

(2) In the event the Permittee is unable to conduct the performance test as

scheduled, pursuant to 40 CFR 63.7(b)(2) the Permittee shall notify IDEM, OAM

within five (5) days prior to the scheduled performance test date and specify the

date when the performance test is rescheduled. Pursuant to Condition C.8 -

Performance Testing, the rescheduled performance test date shall be no sooner

than fourteen (14) days after IDEM, OAM is notified in writing of the need to
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reschedule.

(d) A Notification of Compliance Status is required for P-1 and P-2 and shall be submitted to

IDEM, OAM. The notification shall list all of the information required in 40 CFR

63.347(e)(2), including the test report documenting the results of the performance test

required in Condition D.1.5, which contains the elements required by 40 CFR 63.344(a). 

Pursuant to Condition C.8 - Performance Testing, the Notification of Compliance Status

shall be submitted no later than forty-five (45) calendar days following completion of the

performance test required in Condition D.1.5.

(e) The Permittee shall report to IDEM, OAM the results of any future performance test

conducted for P-1 or P-2 as required by 40 CFR 63.7 and 63.343(b). Pursuant to

Condition C.8 - Performance Testing, results of a performance test shall be submitted

no later than forty-five (45) days following the completion of the performance test.

(f) The Permittee shall prepare a summary report to document the ongoing compliance

status of the affected source. The Ongoing Compliance Status Report shall contain the

information identified in 40 CFR 63.347(g)(3), shall be completed using the form

provided with this permit. Because P-1 and P-2 will be located at an area source site,

the Ongoing Compliance Status Report shall be retained on site and made available to

IDEM, OAM upon request. 

(1) The Ongoing Compliance Status Report shall be completed according to the

following schedule except as provided in paragraphs (f)(2) through (4) of this

condition.

(A) The first report shall cover the period from the start-up date of the

emissions units to December 31 of the year in which the emissions units

begin operation.

(B) Following the first year of reporting, the report shall be completed on a

calendar year basis with the reporting period covering from January 1 to

December 31.

(2) If either of the following conditions are met, semiannual reports shall be

prepared and submitted to IDEM, OAM:

(A) The total duration of excess emissions (as indicated by the monitoring

data collected by the Permittee in accordance with 40 CFR 63.343(c)) is

one percent (1%) or greater of the total operating time as defined in

Condition D.1.6(b) for the reporting period; or

(B) The total duration of malfunctions of the add-on air pollution control

device and monitoring equipment is five percent (5%) or greater of the

total operating time as defined in Condition D.1.6(b).

Once the Permittee reports an exceedance as defined above, Ongoing

Compliance Status Reports shall be submitted semiannually until a request to

reduce reporting frequency is approved by IDEM, OAM.

(3) IDEM, OAM may determine on a case-by-case basis that the summary report

shall be completed more frequently and submitted, or that the annual report
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shall be submitted instead of being retained on site, if these measures are

necessary to accurately assess the compliance status of the source.

(4) If the Permittee 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, the Permittee may reduce the frequency of

reporting to annual and/or be allowed to maintain the annual report onsite

according to the conditions and by following the procedures of 40 CFR

63.347(h)(3).
Page 22 of 26

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR MANAGEMENT

COMPLIANCE DATA SECTION

MINOR SOURCE OPERATING PERMIT

ANNUAL NOTIFICATION

This form should be used to comply with the notification requirements under 

326 IAC 2-6.1-5(a)(5). 

Company Name: H.V. Roll Center, Incorporated

Address: 1079 W. State Road 149, Chesterton, IN 46304

City: Chesterton, IN 

Phone #: 219-886-7655

MSOP #: 127-11519-00091

I hereby certify that H.V. Roll Center, Incorporated is 9 still in operation. 

9 no longer in operation.

I hereby certify that H.V. Roll Center, Incorporated is 9 in compliance with the requirements of MSOP

 127-11519-00091.

9 not in compliance with the requirements of 

MSOP 127-11519-00091.

Authorized Individual (typed):

Title:

Signature:

Date:

If there are any conditions or requirements for which the source is not in compliance, provide a narrative

description of how the source did or will achieve compliance and the date compliance was, or will be

achieved.

Noncompliance:
H.V. Roll Center, Incorporated

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MALFUNCTION REPORT

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR MANAGEMENT

FAX NUMBER - 317 233-5967

This form should only be used to report malfunctions applicable to Rule 326 IAC 1-6

and to qualify for the exemption under 326 IAC 1-6-4.

THIS FACILITY MEETS THE APPLICABILITY REQUIREMENTS BECAUSE IT HAS POTENTIAL TO EMIT 25 TONS/YEAR 

PARTICULATE MATTER ?_____, 25 TONS/YEAR SULFUR DIOXIDE ?_____, 25 TONS/YEAR NITROGEN OXIDES?_____, 

25 TONS/YEAR VOC ?_____, 25 TONS/YEAR HYDROGEN SULFIDE ?_____, 25 TONS/YEAR TOTAL REDUCED SULFUR

?_____, 25 TONS/YEAR REDUCED SULFUR COMPOUNDS ?_____, 25 TONS/YEAR FLUORIDES ?_____, 100TONS/YEAR

CARBON MONOXIDE ?_____, 10 TONS/YEAR ANY SINGLE HAZARDOUS AIR POLLUTANT ?_____, 25 TONS/YEAR ANY

COMBINATION HAZARDOUS AIR POLLUTANT ?_____, 1 TON/YEAR LEAD OR LEAD COMPOUNDS MEASURED AS

ELEMENTAL LEAD ?_____, OR IS A SOURCE LISTED UNDER 326 IAC 2-5.1-3(2) ?_____. EMISSIONS FROM

MALFUNCTIONING CONTROL EQUIPMENT OR PROCESS EQUIPMENT CAUSED EMISSIONS IN EXCESS OF

APPLICABLE LIMITATION ________.

THIS MALFUNCTION RESULTED IN A VIOLATION OF: 326 IAC _______ OR, PERMIT CONDITION # _______ AND/OR

PERMIT LIMIT OF _______________

THIS INCIDENT MEETS THE DEFINITION OF ‘MALFUNCTION’ AS LISTED ON REVERSE SIDE ? Y N

THIS MALFUNCTION IS OR WILL BE LONGER THAN THE ONE (1) HOUR REPORTING REQUIREMENT ? Y N

COMPANY:__H.V. Roll Center, Incorporated______________________PHONE NO. (219 )_886-7655____________________

LOCATION: (CITY AND COUNTY)____ Chesterton, IN_____Porter County____________________________________________

PERMIT NO. __11519__ AFS PLANT ID: ___127_____________ AFS POINT ID: ____00091_________ INSP: Scott Anslinger

CONTROL/PROCESS DEVICE WHICH MALFUNCTIONED AND REASON:____________________________________________

_________________________________________________________________________________________________________

DATE/TIME MALFUNCTION STARTED: _____/_____/ 19____ ____________________________________________ AM / PM

ESTIMATED HOURS OF OPERATION WITH MALFUNCTION CONDITION:___________________________________________

DATE/TIME CONTROL EQUIPMENT BACK-IN SERVICE______/______/ 19____ _______________ AM/PM

TYPE OF POLLUTANTS EMITTED: TSP, PM-10, SO2, VOC, OTHER:___________________________________________

ESTIMATED AMOUNT OF POLLUTANT EMITTED DURING MALFUNCTION: _________________________________________

_________________________________________________________________________________________________________

MEASURES TAKEN TO MINIMIZE EMISSIONS:_________________________________________________________________

_________________________________________________________________________________________________________

REASONS WHY FACILITY CANNOT BE SHUTDOWN DURING REPAIRS:

CONTINUED OPERATION REQUIRED TO PROVIDE ESSENTIAL* SERVICES:_______________________________________

CONTINUED OPERATION NECESSARY TO PREVENT INJURY TO PERSONS:_______________________________________

CONTINUED OPERATION NECESSARY TO PREVENT SEVERE DAMAGE TO EQUIPMENT:____________________________

INTERIM CONTROL MEASURES: (IF APPLICABLE)______________________________________________________________

_________________________________________________________________________________________________________

_________________________________________________________________________________________________________

MALFUNCTION REPORTED BY:___________________________________TITLE:_____________________________

 (SIGNATURE IF FAXED)

MALFUNCTION RECORDED BY:_______________________DATE:__________________TIME:__________________

*SEE PAGE 2

PAGE 1 OF 2
H.V. Roll Center, Incorporated

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Page 24 of 26

Please note - This form should only be used to report malfunctions

applicable to Rule 326 IAC 1-6 and to qualify for

the exemption under 326 IAC 1-6-4.

326 IAC 1-6-1 Applicability of rule

Sec. 1. This rule applies to the owner or operator of any facility required to obtain a

permit under 326 IAC 2-5.1 or 326 IAC 2-6.1.

326 IAC 1-2-39 “Malfunction” definition

Sec. 39. Any sudden, unavoidable failure of any air pollution control equipment, process, or

combustion or process equipment to operate in a normal and usual manner. 

*Essential services are interpreted to mean those operations, such as, the providing of electricity

by power plants. Continued operation solely for the economic benefit of the owner or operator shall

not be sufficient reason why a facility cannot be shutdown during a control equipment shutdown.

If this item is checked on the front, please explain rationale:

________________________________________________________________________

________________________________________________________________________

PAGE 2 OF 2
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-

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Permit Reviewer: PR/EVP

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INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR MANAGEMENT

COMPLIANCE DATA SECTION

MINOR SOURCE OPERATING PERMIT

 CHROMIUM ELECTROPLATING NESHAP

 ONGOING COMPLIANCE STATUS REPORT

Source Name: H.V. Roll Center, Incorporated

Source Address: 1079 W. State Road 149, Chesterton, IN 46304

Mailing Address: P.O. Box M828, Gary, IN 46401

Minor Source Operating Permit No.: 127-11519-00091

Tank ID #: P-1 and P-2

Type of process: Hard chromium electroplating

Monitoring Parameter: Pressure drop across the composite mesh pad system

Parameter Value: ±1 inch of water column of the pressure drop value established

during the initial performance test, or within the range of compliant

values for pressure drop established during multiple performance

tests

Limits: The concentration of total chromium in the exhaust gas stream discharged to the atmosphere from

Stack S-1 of P-1 and P-2 shall not exceed 0.015 milligrams of total chromium per dry standard cubic

meter (mg/dscm).

This form is to be used to report compliance for the Chromium Electroplating NESHAP only.

The frequency for completing this report may be altered by the IDEM, OAM, Compliance Branch.

complete this report no later than 30 days after the end of the reporting period, and retain on site unless otherwise notified.

This form consists of 2 pages Page 1 of 2

BEGINNING AND ENDING DATES OF THE REPORTING PERIOD:

TOTAL OPERATING TIME OF THE TANK DURING THE REPORTING PERIOD:

MAJOR AND AREA SOURCES: CHECK ONE

9 NO DEVIATIONS OF THE MONITORING PARAMETER ASSOCIATED WITH THIS TANK FROM THE COMPLIANT

VALUE OR RANGE OF VALUES OCCURRED DURING THIS REPORTING PERIOD.

9 THE MONITORING PARAMETER DEVIATED FROM THE COMPLIANT VALUE OR RANGE OF VALUES DURING THIS

REPORTING PERIOD (THUS INDICATING THE EMISSION LIMITATION MAY HAVE BEEN EXCEEDED, WHICH COULD

RESULT IN MORE FREQUENT REPORTING).

AREA (I.E., NON-MAJOR) SOURCES OF HAP ONLY:

IF DEVIATIONS OCCURRED, LIST THE AMOUNT OF TANK OPERATING TIME EACH MONTH THAT MONITORING RECORDS

SHOW THE MONITORING PARAMETER DEVIATED FROM THE COMPLIANT VALUE OR RANGE OF VALUES.

JAN APR JUL OCT

FEB MAY AUG NOV

MAR JUN SEP DEC

HARD CHROME TANKS / MAXIMUM RECTIFIER CAPACITY LIMITED IN ACCORDANCE WITH 40 CFR 63.342(c)(2) ONLY:

LIST THE ACTUAL AMPERE-HOURS CONSUMED (BASED ON AN AMP-HR METER) BY THE INDIVIDUAL TANK.

JAN APR JUL OCT

FEB MAY AUG NOV

MAR JUN SEP DEC
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CHROMIUM ELECTROPLATING NESHAP

ONGOING COMPLIANCE STATUS REPORT

ATTACH A SEPARATE PAGE IF NEEDED Page 2 of 2

IF THE OPERATION AND MAINTENANCE PLAN REQUIRED BY 40 CFR 63.342 (f)(3) WAS NOT FOLLOWED, PROVIDE AN

EXPLANATION OF THE REASONS FOR NOT FOLLOWING THE PLAN AND DESCRIBE THE ACTIONS TAKEN FOR THAT

EVENT:

DESCRIBE ANY CHANGES IN TANKS, RECTIFIERS, CONTROL DEVICES, MONITORING, ETC. SINCE THE LAST STATUS

REPORT:

ADDITIONAL COMMENTS:

ALL SOURCES: CHECK ONE

9 I CERTIFY THAT THE WORK PRACTICE STANDARDS IN 40 CFR 63.342(f) WERE FOLLOWED IN ACCORDANCE WITH

THE OPERATION AND MAINTENANCE PLAN ON FILE; AND, THAT THE INFORMATION CONTAINED IN THIS REPORT

IS ACCURATE AND TRUE TO THE BEST OF MY KNOWLEDGE.

9 THE WORK PRACTICE STANDARDS IN 40 CFR 63.342(f) WERE NOT FOLLOWED IN ACCORDANCE WITH THE

OPERATION AND MAINTENANCE PLAN ON FILE, AS EXPLAINED ABOVE AND/OR ON ATTACHED.

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification from a responsible official to complete this report.
Page 1 of 12

Indiana Department of Environmental Management

Office of Air Management

Addendum to the

Technical Support Document for a New Source Construction Permit

and Minor Source Operating Permit 

Source Name: H.V. Roll Center, Incorporated

Source Location: 1079 W. State Road 149, Chesterton, IN 46304

County: Porter

SIC Code: 3471

Operation Permit No.: 127-11519-00091

Permit Reviewer: Phillip Ritz/EVP

On December 21, 1999, the Office of Air Management (OAM) had a notice published in the

Chesterton Tribune, Chesterton, Indiana, stating that H.V. Roll Center, Incorporated, had applied for a

New Source Construction Permit and Minor Source Operating Permit to construct and operate a hard

chromium electroplating operation for reconditioning mill rolls with control. The notice also stated that

OAM proposed to issue a permit for this installation and provided information on how the public could

review the proposed New Source Construction Permit and Minor Source Operating Permit and other

documentation. Finally, the notice informed interested parties that there was a period of thirty (30) days

to provide comments on whether or not this permit should be issued as proposed.

On January 17, 1999, Erin I. Surinak of KERAMIDA Environmental, Inc., submitted comments

on behalf of H.V. Roll Center, Incorporated, on the proposed New Source Construction Permit and Minor

Source Operating Permit. The summary of the comments and corresponding responses is as follows:

Comment 1

Condition C.1, PSD Minor Source Status (c) states the following:

(c) Any change or modification which may increase potential to emit to 10 tons per year of

any single hazardous air pollutant, twenty-five tons per year of any combination of

hazardous air pollutants, or 100 tons per year of any other regulated pollutant from this

source, shall cause this source to be considered a major source under Part 70 Permit

Program, 326 IAC 207, and shall require approval from IDEM, OAM prior to making the

change.

As required by the NESHAP for Chromium Emissions from Hard and Decorative Chromium

Electroplating and Chromium Anodizing Tanks, the facility will be required to submit a Part 70 permit

within five years. We request that this condition be deleted or modified since the facility is already

required to submit an application under the Part 70 permit program. Additionally, an increase in the

source’s potential to emit to 10 tons per year of any single HAP, 25 tons per year of a combination of

HAPs, or 100 tons of any other regulated pollutant would cause the source to be considered a major

source under the Part 70 program but we should have 12 months to apply for this Title V permit after the

source becomes a major source.
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-11519-00091

Permit Reviewer: PR/EVP

Page 2 of 12

Response 1

It is true that 326 IAC 20-8, which incorporates the chromium electroplating NESHAP, states that:

". . . nonmajor [area] sources that have been deferred under 61 FR 27785* shall submit Part 70 permit

applications to the department by December 9, 2000."

However, on December 14, 1999 EPA gave states the option to extend the deferral another 5 years (64

FR 69637). Indiana intends to exercise that option and give all eligible chromium electroplating and

anodizing sources another 5-year deferral from Title V permitting (decorative chromium electroplating or

chromium anodizing operations that use fume suppressants as an emission reduction technology and

decorative chromium electroplating operations that use a trivalent chromium bath that incorporates a

wetting agent as a bath ingredient were permanently exempted from Title V permitting by an earlier EPA

action (61 FR 27785)).

IAC 326 20-8 will be revised to extend the Part 70 application date 5 years to December 9, 2005.

Because the rule revision likely cannot be completed prior to December 9, 2000, IDEM, OAM has begun

work to issue a non-rule policy document that will provide the deferral in the interim until the rule is

revised.

Comment 2

Condition D.1.5 Monitoring to Demonstrate Continuous Compliance (a) states “The Permittee shall

monitor and record the air flow rate across the composite mesh pad system once each day that P-1 and

P-2 are in operation.” According to 40 CFR 63.343(c)(1), the pressure drop across the composite meshpad system shall be monitored and recorded each day that the affected source is operating. Therefore,

the condition should be changed as follows (bold language should be added, language with a line

through it should be deleted):

(a) The Permittee shall monitor and record the air flow rate pressure drop across the

composite mesh pad system once each day that P-1 and P-2 are in operation.

Response 2

40 CFR 63.343(c)(1) requires that the pressure drop, not the air flow rate, across the composite meshpad system shall be monitored and recorded each day that the affected source is operating. Condition

D.1.5 has been replaced with Condition D.1.6 to require pressure drop monitoring and record keeping

and for clarification of compliance determination requirements and compliance monitoring requirements

for the composite mesh-pad system: 

D.1.5 Monitoring to Demonstrate Continuous Compliance [40 CFR 63.343 (c)(1)]

(a) The Permittee shall monitor and record the air flow rate across the composite mesh pad

system once each day that P-1 and P-2 are in operation.

(c) The composite mesh pad system shall be operated at an air flow rate above 27,000 cfm,

or shall be operated within the range of compliant values for air flow rate established

during multiple performance tests that may be conducted in the future.

D.1.6 Monitoring to Demonstrate Continuous Compliance [40 CFR 63.343(c)(1)][326 IAC 2-1.1-

11]

(a) On and after the date on which the initial performance test required in Condition

D.1.5 is required to be completed under 40 CFR 63.7, the Permittee shall monitor

and record the pressure drop across the composite mesh-pad system once each

day that either tank in P-1 or P-2 is in operation. To be in compliance with the

standards, 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 within the range of compliant values for pressure drop
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Chesterton, Indiana MSOP127-11519-00091

Permit Reviewer: PR/EVP

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established during multiple performance tests.

(b) Tank operation or operating time for chromium electroplating is defined as that

time when the rectifier is turned on and a part is in the tank. When there is no part

in a tank for fifteen (15) or more minutes, the tanks will not be considered to be in

operation, and that time will not be considered operating time. Likewise, if the

time between placing a part in the tank is less than fifteen (15) minutes, the tanks

will be considered to be in operation, and that time will be considered part of the

operating time.

Comment 3

Condition D.1.6 Testing Requirements states that the Permittee shall perform VOC testing in accordance

with the provisions of 40 CFR 63.344 utilizing Method 24. The requirements of 40 CFR 63.344 actually

state that “Method 306 or Method 306A, “Determination of Chromium Emissions from Decorative and

Hard Chromium Electroplating and Anodizing Operations,” Appendix A of this part shall be used to

determine the chromium concentration from hard or decorative chromium electroplating tanks or

chromium anodizing tanks.” Therefore, this condition should be changed as follows:

During the period between 30 and 36 months after issuance of this permit, the Permittee shall

perform VOC testing to determine the chromium concentration from the electroplating

tanks in accordance with the provisions of 40 CFR 63.344 utilizing Method 24 306 or 306A (40

CFR 60, Appendix A), or other methods as approved by the Commissioner. In addition to these

requirements, IDEM may require compliance testing when necessary to determine if the facility

is in compliance. Future tests that may be required shall be conducted in accordance with the

provisions of 40 CFR 63.344.

Response 3

Testing for the outlet chromium concentration, not VOC, is required by 40 CFR 63.343(b)(1) and 63.7. 

Condition D.1.6, now Condition D.1.5, has been changed to clarify that the source of testing methods for

hard chromium electroplating tanks is 40 CFR 63.344 (and also 40 CFR 63.7), and to require testing

within 180 days for the new construction: 

D.1.6 Testing Requirements [326 IAC 2-7-6(1)] [40 CFR 63.344]

During the period between 30 and 36 months after issuance of this permit, the Permittee shall

perform VOC testing in accordance with the provisions of 40 CFR 63.344 utilizing Method 24 (40

CFR 60, Appendix A), or other methods as approved by the Commissioner. In addition to these

requirements, IDEM may require compliance testing when necessary to determine if the facility

is in compliance. Future tests that may be required shall be conducted in accordance with the

provisions of 40 CFR 63.344.

D.1.5 Performance Testing [40 CFR 63.343, 63.344, and 63.7]

(a) The Permittee is required to conduct an initial performance test within 180 days

after startup of the emissions units using the procedures and methods listed in

40 CFR 63.344 and 63.7 and in accordance with the provisions of Condition C.8 -

Performance Testing of this permit.

(b) During the initial performance test, the Permittee shall determine the outlet

chromium concentration of the composite mesh-pad system using the test

methods and procedures in 40 CFR 63.344(c) and shall establish as a site-specific

operating parameter the pressure drop across the system, setting the value that

corresponds to compliance with the emission limitation in Condition D.1.2(a)

using the procedures in 40 CFR 63.344(d)(5). The Permittee may conduct multiple

performance tests to establish a range of compliant pressure drop values, or may
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-11519-00091

Permit Reviewer: PR/EVP

Page 4 of 12

set as the compliant value the average pressure drop measured over the three (3)

test runs of one performance test, and accept ±1 inch of water column from this

value as the compliant range.

Comment 4

The Ongoing Compliance Status Report form (copy attached to permit), required to be

completed by Condition D.1.8(d), states that the monitoring parameter is “Surface tension of the

electroplating bath” and the parameter value is ”45 dynes per centimeter”. The facility operates

a mist eliminator/composite mesh pad system and is therefore required to monitor pressure drop

across the system, not surface tension. This form should be revised accordingly. 

Response 4

40 CFR 63.343(c)(1) requires that the pressure drop, and not the air flow rate, across the composite

mesh-pad system shall be monitored and recorded each day that the affected source is operating. The

identification numbers for the Tanks has also been changed to remove the terms E-1 and E-2, as P-1

and E-1 both refer to one emission unit and P-2 and E-2 both refer to another unit. The Ongoing

Compliance Status Report form has been revised as follows:

Tank ID #: E-1 and E-2 P-1 and P-2

Type of process: Hard chromium electroplating

Monitoring Parameter: Surface tension of the electroplating bath Pressure drop across the

composite mesh pad system

Parameter Value: 45 dynes per centimeter ±1 inch of water column of the pressure

drop value established during the initial performance test, or within

the range of compliant values for pressure drop established during

multiple performance tests

Limits: The concentration of total chromium in the exhaust gas stream discharged to the

atmosphere from Stack S-1 of P-1 and P-2 shall not exceed 0.015 milligrams of total

chromium per dry standard cubic meter (mg/dscm) of ventilation air (6.6 x 10-6 grains per

dry standard cubic foot (gr/dscf)).

Upon further review, the OAM has decided to make the following revisions to the permit to incorporate

updated language for new hard chromium electroplating operations (bolded language has been added,

the language with a line through it has been deleted). The Table Of Contents has been modified to

reflect these changes.

(a ) Section A.2, the Emissions units and Pollution Control Equipment Summary and the Emission

Unit Description in Section D.1 have been revised as follows to clarify the description of permitted

units:

(a) Two (2) hard chromium electroplating operations, identified as P-1 and P-2, consisting of

two (2) standard sulfate plating tanks (Tanks E-1 and E-2), using a composite mesh-pad

system for control, each having a rectifier with a maximum potential capacity of 12,500

amps, exhausting to one (1) stack identified as S-1.

SECTION D.1 EMISSIONS UNIT OPERATION CONDITIONS
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-11519-00091

Permit Reviewer: PR/EVP

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Emissions Unit Description

(a) Two (2) hard chromium electroplating operations, identified as P-1 and P-2, consisting of two

(2) standard sulfate plating tanks (Tanks E-1 and E-2), using a composite mesh-pad system

for control, each having a rectifier with a maximum potential capacity of 12,500 amps,

exhausting to one (1) stack identified as S-1.

(The information describing the process contained in this emissions unit description box is descriptive

information and does not constitute enforceable conditions.)

(b) The rule citations throughout Section D.1 have been changed to reflect the Minor Source

Operating Permit Program (326 IAC 2-6.1), and not the Part 70 Permit Program (326 IAC 2-7).

(c) Conditions D.1.1 through D.1.4 in the permit section entitled “Emission Limitations and

Standards” have been revised as shown below to: (1)reflect the use of the term “emissions unit”

in revised state permitting rules; (2) be more consistent with the language of the Chromium

Electroplating NESHAP; (3) delete language that was inadvertently included in the draft permit;

and (4) add the requirement to address excess emissions as well as malfunctions if they occur.

By this permit, the Permittee is approved to use a composite mesh-pad system as the emission

reduction technique to comply with the Chromium Electroplating NESHAP. However, IDEM,

OAM encourages the Permittee to also consider the use of fume suppressants to comply as this

technique can achieve a greater degree of emission reductions. Use of fume suppressants can

be approved in a permit modification as an alternative means of compliance in addition to or

instead of the composite mesh-pad system.

Emission Limitations and Standards

D.1.1 General Provisions Relating to HAPs [326 IAC 20-1-1] [40 CFR Part 63, Subpart A]

The provisions of 40 CFR Part 63, Subpart A - General Provisions, which are incorporated as

326 IAC 20-1-1, apply to the facility emissions units described in this section except when

otherwise specified in 40 CFR Part 63, Subpart N.

D.1.2 Chromium Electroplating NESHAP [326 IAC 20-8-1] [40 CFR Part 63, Subpart N] [326 IAC 2-

1.1-11]

This facility is These emissions units 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), which is incorporated by reference as

326 IAC 20-8-1. A copy of this rule is attached. The Permittee shall comply with the

requirements in this condition on and after the startup date.

The emission limitations in this condition apply only during tank operation, and also apply

during periods of startup and shutdown as these are routine occurrences for affected

sources subject to 326 IAC 20-8-1. The emission limitations do not apply during periods

of malfunction, but the work practice standards that address operation and maintenance

and are required by paragraph (b) of this condition must be followed during malfunctions.

(a) The Permittee shall not allow the concentration of total chromium in the exhaust gas

stream During tank operation, the Permittee shall control chromium emissions

discharged to the atmosphere from Stack S-1 of P-1 and P-2 by not allowing the

concentration of total chromium in the exhaust gas stream discharged to the

atmosphere to exceed 0.015 milligrams of total chromium per dry standard cubic meter

(mg/dscm) of ventilation air (6.6 x 10-6 grains per dry standard cubic foot (gr/dscf)).
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(b) The Permittee is subject to the following work practice standards for P-1 and P-2 are

also applicable, which address operation and maintenance practices:

(1) At all times, including periods of startup, shutdown, and malfunction, and

excess emissions, the Permittee shall operate and maintain P-1 and P-2,

including the composite mesh-pad system and monitoring equipment, in a

manner consistent with good air pollution control practices, consistent with

the Operation and Maintenance Plan (OMP) required by Condition D.1.4.

(2) Malfunctions and excess emissions shall be corrected as soon as practicable

after their occurrence in accordance with the OMP required by Condition D.1.4.

(3) These operation and maintenance requirements are enforceable

independent of emissions limitations or other requirements in this section.

(4) Determination of whether acceptable operation and maintenance procedures

are being used will be based on information available to IDEM, OAM, which may

include, but is not limited to, monitoring results; review of the OMP, procedures,

and records; and inspection of the source.

(4 5) Based on the results of a determination made under paragraph (b)(4) of

this condition, IDEM, OAM may require that the Permittee make changes to

the OMP required by Condition D.1.4. Revisions may be required if IDEM,

OAM finds that the plan:

(A) Does not address a malfunction or period of excess emissions that

has occurred;

(B) Fails to provide for the operation of P-1 and P-2, the air pollution control

techniques, or the composite mesh-pad system and process monitoring

equipment during a malfunction or period of excess emissions in a

manner consistent with good air pollution control practices; or

(C) Does not provide adequate procedures for correcting malfunctioning

process equipment, air pollution control techniques, or monitoring

equipment or other causes of excess emissions as quickly as

practicable.

D.1.3 Preventive Maintenance Plan [326 IAC 2-7-5(13) 1-6-3]

A Preventive Maintenance Plan (PMP), in accordance with the Section B condition entitled

“Preventive Maintenance Plans” of this permit is required for P-1 and P-2 and the composite

mesh-pad system.

D.1.4 Operation and Maintenance Plan [40 CFR 63.342(f)(3)] [326 IAC 2-1.1-11]

(a) An Operation and Maintenance Plan (OMP), In accordance with 40 CFR 63.342(f)(3),

The Permittee shall prepare an Operation and Maintenance Plan (OMP) to be

implemented no later than the startup date of the emissions units. The plan shall

be prepared and maintained and shall specify the operation and maintenance criteria for

P-1 and P-2, the composite mesh-pad system, and monitoring equipment, and shall
H.V. Roll Center, Incorporated

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Permit Reviewer: PR/EVP

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include the following elements:

(1) Quarterly visual inspection of the composite mesh-pad 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 device;

(2) Quarterly visual inspection of the back portion of the mesh-pad closest to the fan

to ensure there is no breakthrough of chromic acid mist;

(3) Quarterly visual inspection of the ductwork from the tanks to the control device

to ensure there are no leaks;

(4) Perform washdown of the composite mesh-pads in accordance with

manufacturer’s recommendations.

(5) A standardized checklist to document the operation and maintenance criteria for

P-1 and P-2, the composite mesh-pad system, and monitoring equipment;

(6) Procedures to be followed to ensure that neither equipment or process

malfunctions due to poor maintenance or other preventable conditions nor

excess emissions as indicated by monitoring data do not occur;

(7) A systematic procedure for identifying malfunctions of and periods of excess

emissions from P-1 and P-2, the composite mesh-pad system, and monitoring

equipment; and for implementing corrective actions to address such

malfunctions and periods of excess emissions.

(c b) If the OMP fails to address or inadequately addresses an event that meets the

characteristics of a malfunction or a period of excess emissions as indicated by

monitoring data at the time the plan is initially developed, the Permittee shall revise the

OMP within forty five (45) days after such an event occurs. The revised plan shall

include procedures for operating and maintaining P-1 and P-2, the composite mesh-pad

system, and monitoring equipment, during similar malfunction and excess emissions

events, and a program for corrective action for such events.

(d c) If actions taken by the Permittee during periods of malfunction or excess emissions

are inconsistent with the procedures specified in the OMP, the Permittee shall record the

actions taken for that event and shall report by phone such actions within two (2)

working days after commencing actions inconsistent with the plan. This report shall be

followed by a letter within seven (7) working days after the end of the event, unless the

Permittee makes alternative reporting arrangements, in advance, with IDEM, OAM.

(e d) The Permittee shall keep the written OMP on record after it is developed to be made

available, upon request, by IDEM, OAM for the life of P-1 and P-2 or until P-1 and P-2

are no longer subject to the provisions of 40 CFR 63.340. In addition, if the OMP is

revised, the Permittee shall keep previous versions of the OMP on record to be made

available for inspection, upon request by IDEM, OAM for a period of five (5) years after

each revision to the plan.

(e) The Permittee may use applicable standard operating procedures (SOP) manuals,

occupational safety and health administration (OSHA) plans, or other existing

plans such as the PMP required in Condition D.1.3, as the OMP provided the

alternative plans meet the criteria listed above in Condition D.1.4(a).
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(d) Conditions D.1.5 and D.1.6 in the permit section entitled “Compliance Determination

Requirements” have been revised as shown below to: (1) be more consistent with the language

of the Chromium Electroplating NESHAP; (2) relocate monitoring conditions more properly in a

section entitled “Compliance Monitoring;” (3) correct the site-specific parameter value from “air

flow rate” to “pressure drop across the composite mesh-pad system;” and (4) relocate the

definition of “tank operation and operating time” from the Recordkeeping and Reporting section

of the permit to the Compliance Monitoring section since the definition applies to monitoring as

well.

Should the Permittee decide any time in the future to use fume suppressants as the emissions

reduction technique to comply with the NESHAP, IDEM, OAM wishes to clarify that Method 306B

in Appendix A of 40 CFR Part 63 may be used to measure surface tension.

Compliance Determination Requirements

D.1.5 Performance Testing [40 CFR 63.343, 63.344, and 63.7]

(a) The Permittee is required to conduct an initial performance test within 180 days

after startup of the emissions units using the procedures and methods listed in

40 CFR 63.344 and 63.7 and in accordance with the provisions of Condition C.8 -

Performance Testing of this permit.

(b) During the initial performance test, the Permittee shall determine the outlet

chromium concentration of the composite mesh-pad system using the test

methods and procedures in 40 CFR 63.344(c) and shall establish as a site-specific

operating parameter the pressure drop across the system, setting the value that

corresponds to compliance with the emission limitation in Condition D.1.2(a)

using the procedures in 40 CFR 63.344(d)(5). The Permittee may conduct multiple

performance tests to establish a range of compliant pressure drop values, or may

set as the compliant value the average pressure drop measured over the three (3)

test runs of one performance test, and accept ±1 inch of water column from this

value as the compliant range.

Compliance Monitoring Requirements

D.1.6 Monitoring to Demonstrate Continuous Compliance [40 CFR 63.343(c)(1)][326 IAC 2-1.1-

11]

(a) On and after the date on which the initial performance test required in Condition

D.1.5 is required to be completed under 40 CFR 63.7, the Permittee shall monitor

and record the pressure drop across the composite mesh-pad system once each

day that either tank in P-1 or P-2 is in operation. To be in compliance with the

standards, 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 within the range of compliant values for pressure drop

established during multiple performance tests.

(b) Tank operation or operating time for chromium electroplating is defined as that

time when the rectifier is turned on and a part is in the tank. When there is no part

in a tank for fifteen (15) or more minutes, the tanks will not be considered to be in

operation, and that time will not be considered operating time. Likewise, if the

time between placing a part in the tank is less than fifteen (15) minutes, the tanks

will be considered to be in operation, and that time will be considered part of the

operating time.
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-11519-00091

Permit Reviewer: PR/EVP

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(e) Conditions D.1.7 and D.1.8 in the permit section entitled “Record Keeping and Reporting

Requirements” have been revised as shown below to: (1) be more consistent with the language

of the Chromium Electroplating NESHAP; (2) add the requirement to address excess emissions

as well as malfunctions if they occur; (3) require more frequent reporting if either total duration of

excess emissions or malfunctions exceed thresholds established in the NESHAP instead of both

having to occur; and (4) include all notifications and reporting required for new sources by both

the NESHAP and state new source construction rules.

It is emphasized that where the permit states that approval is required for changes to

recordkeeping or reporting conditions (such as changes in reporting frequency), the approval

shall come from IDEM, OAM. All requests for changes and approvals must be made consistent

with the permitting rules in 326 IAC Article 2. That is, the proper applications must be submitted

if necessary, and all approvals shall be subject to the time lines for issuance stated in the rules.

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3) 5.1-3(e)(2)] [326 IAC 2-7-19 6.1-

5(a)(2)][326 IAC 2-1.1-11]

D.1.7 Record Keeping Requirements [40 CFR 63.346]

(a) The Permittee shall maintain records to document compliance with Conditions D.1.2 and D.1.4

using the forms provided with this permit. These records shall be maintained in accordance with

the Section C condition entitled “General Record Keeping Requirements” of this permit, be kept

for a period of five (5) years, and include a minimum of the following:

(1 a) Inspection records for the composite mesh-pad system and monitoring equipment to

document that the inspection and maintenance required by Conditions D.1.3 and D.1.4

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

following:

(A 1) The device inspected;

(B 2) The date of inspection;

(C 3) A brief description of the working condition of the device during the inspection,

including any deficiencies found; and

(D 4) Any actions taken to correct deficiencies found during the inspection, including

the date(s) such actions were taken.

(2 b) Records of all maintenance performed on P-1 and P-2, the composite mesh-pad system

and monitoring equipment.

(3 c) Records of the occurrence, duration, and cause (if known) of each malfunction of P-1

and P-2, the composite mesh-pad system and monitoring equipment and each period

of excess emissions from P-1 and P-2 and the composite mesh-pad system as

indicated by monitoring data collected in accordance with paragraph (g) of this

condition.

(4 d) Records of actions taken during periods of malfunction or excess emissions when

such actions are inconsistent with the OMP.

(5 e) Other records, which may take the form of checklists, necessary to demonstrate

consistency with the provisions of the OMP.
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(6 f) 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.

(7 g) 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.

(10 h) The total operating time of P-1 and the total operating time of P-2 during the reporting

period, operating time as defined in Condition D.1.6(b).

(i) All documentation supporting the notifications and reports required by 40 CFR

63.9 and 63.10, and Condition D.1.8.

D.1.8 Reporting Requirements [40 CFR 63.345 & 63.347] [326 IAC 2-1.1-11]

The notifications and reports required in this section shall be submitted to the address

specified in Condition C.15 - General Reporting Requirements of this permit.

(a) The Permittee may not construct a new emissions unit subject to 326 IAC 20-8-1

(including non-affected sources defined in 40 CFR 63.344(e)), or change, modify,

or reconstruct P-1 or P-2 (including addition of ductwork to the composite meshpad system or change in the air pollution control technique used to comply with

Condition D.1.2) without submitting a Notification of Construction or

Reconstruction for these new or reconstructed emissions units to IDEM, OAM.

(1) The application to construct P-1 and P-2 serves as this notification. 

Likewise, a complete application for a permit revision shall serve as this

notification for any new construction or reconstruction.

(2) Pursuant to 326 IAC 2-1.1-2(a), permission must be received from IDEM,

OAM before construction or reconstruction may commence.

(b) The Permittee shall submit an Initial Notification for P-1 and P-2 as follows:

(1) A notification of the date when construction or reconstruction of the

emissions units was commenced shall be submitted no later than thirty

(30) calendar days after such date.

(2) A notification of the actual date of startup of the emissions units shall be

submitted within thirty (30) calendar days after such date.

(c) The Permittee shall notify IDEM, OAM in writing of their intention to conduct the

initial performance test required in Condition D.1.5 and any future performance

tests conducted as required by 40 CFR 63.7 and 63.343(b) at least sixty (60)

calendar days before the test is scheduled to begin.

(1) Pursuant to Condition C.8 - Performance Testing, a test protocol shall be

submitted no later than thirty-five (35) days prior to the intended test date.

(2) In the event the Permittee is unable to conduct the performance test as

scheduled, pursuant to 40 CFR 63.7(b)(2) the Permittee shall notify IDEM,

OAM within five (5) days prior to the scheduled performance test date and

specify the date when the performance test is rescheduled. Pursuant to

Condition C.8 - Performance Testing, the rescheduled performance test
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date shall be no sooner than fourteen (14) days after IDEM, OAM is notified

in writing of the need to reschedule.

(d) A Notification of Compliance Status is required for P-1 and P-2 and shall be

submitted to IDEM, OAM. The notification shall list all of the information required

in 40 CFR 63.347(e)(2), including the test report documenting the results of the

performance test required in Condition D.1.5, which contains the elements

required by 40 CFR 63.344(a). Pursuant to Condition C.8 - Performance Testing,

the Notification of Compliance Status shall be submitted no later than forty-five

(45) calendar days following completion of the performance test required in

Condition D.1.5.

(e) The Permittee shall report to IDEM, OAM the results of any future performance test

conducted for P-1 or P-2 as required by 40 CFR 63.7 and 63.343(b). Pursuant to

Condition C.8 - Performance Testing, results of a performance test shall be

submitted no later than forty-five (45) days following the completion of the

performance test.

(f) The Permittee shall prepare a summary report to document the ongoing

compliance status of the affected source. The Ongoing Compliance Status Report

shall contain the information identified in 40 CFR 63.347(g)(3), shall be completed

using the form provided with this permit. Because P-1 and P-2 will be located at

an area source site, the Ongoing Compliance Status Report shall be retained on

site and made available to IDEM, OAM upon request. 

(1) The Ongoing Compliance Status Report shall be completed according to

the following schedule except as provided in paragraphs (f)(2) through (4)

of this condition.

(A) The first report shall cover the period from the start-up date of the

emissions units to December 31 of the year in which the emissions

units begin operation.

(B) Following the first year of reporting, the report shall be completed

on a calendar year basis with the reporting period covering from

January 1 to December 31.

(2) If either of the following conditions are met, semiannual reports shall be

prepared and submitted to IDEM, OAM:

(A) The total duration of excess emissions (as indicated by the

monitoring data collected by the Permittee in accordance with

40 CFR 63.343(c)) is one percent (1%) or greater of the total

operating time as defined in Condition D.1.6(b) for the reporting

period; or
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-11519-00091

Permit Reviewer: PR/EVP

Page 12 of 12

(B) The total duration of malfunctions of the add-on air pollution

control device and monitoring equipment is five percent (5%) or

greater of the total operating time as defined in Condition D.1.6(b).

Once the Permittee reports an exceedance as defined above, Ongoing

Compliance Status Reports shall be submitted semiannually until a

request to reduce reporting frequency is approved by IDEM, OAM.

(3) IDEM, OAM may determine on a case-by-case basis that the summary

report shall be completed more frequently and submitted, or that the

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

measures are necessary to accurately assess the compliance status of the

source.

(4) If the Permittee 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, the Permittee may reduce the

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

report onsite according to the conditions and by following the procedures

of 40 CFR 63.347(h)(3).
Mail to: Permit Administration & Development Section

Office Of Air Management

100 North Senate Avenue

P. O. Box 6015

Indianapolis, Indiana 46206-6015

H.V. Roll Center, Incorporated

P.O. Box M 828 

Gary, IN 46401

Affidavit of Construction

I, , being duly sworn upon my oath, depose and say:

(Name of the Authorized Representative)

1. I live in County, Indiana and being of sound mind and over twenty-one

(21) years of age, I am competent to give this affidavit.

2. I hold the position of for .

 (Title) (Company Name)

3. By virtue of my position with ,I have personal

(Company Name)

knowledge of the representations contained in this affidavit and am authorized to make

these representations on behalf of .

(Company Name)

4. I hereby certify that H.V. Roll Center, Incorporated, 1079 W. State Road 149, Chesterton, IN 46304, has

constructed the hard chromium electroplating operation for reconditioning mill rolls in conformity with the

requirements and intent of the construction permit application received by the Office of Air Management on

November 1, 1999 and as permitted pursuant to New Source Construction Permit and Minor Source

Operating Permit No. MSOP127-11519-00091, Plant ID No. 127-00091 issued on 

Further Affiant said not.

I affirm under penalties of perjury that the representations contained in this affidavit are true, to the best of my information

and belief.

 

Signature

 

Date

STATE OF INDIANA)

 )SS

COUNTY OF )

Subscribed and sworn to me, a notary public in and for County and State of

Indiana on this day of , 19 .

My Commission expires: 

 

Signature

 

Name (typed or printed)
Page 1 of 12

Indiana Department of Environmental Management

Office of Air Management

Addendum to the

Technical Support Document for a New Source Construction Permit

and Minor Source Operating Permit 

Source Name: H.V. Roll Center, Incorporated

Source Location: 1079 W. State Road 149, Chesterton, IN 46304

County: Porter

SIC Code: 3471

Operation Permit No.: 127-11519-00091

Permit Reviewer: Phillip Ritz/EVP

On December 21, 1999, the Office of Air Management (OAM) had a notice published in the

Chesterton Tribune, Chesterton, Indiana, stating that H.V. Roll Center, Incorporated, had applied for a

New Source Construction Permit and Minor Source Operating Permit to construct and operate a hard

chromium electroplating operation for reconditioning mill rolls with control. The notice also stated that

OAM proposed to issue a permit for this installation and provided information on how the public could

review the proposed New Source Construction Permit and Minor Source Operating Permit and other

documentation. Finally, the notice informed interested parties that there was a period of thirty (30) days

to provide comments on whether or not this permit should be issued as proposed.

On January 17, 1999, Erin I. Surinak of KERAMIDA Environmental, Inc., submitted comments

on behalf of H.V. Roll Center, Incorporated, on the proposed New Source Construction Permit and Minor

Source Operating Permit. The summary of the comments and corresponding responses is as follows:

Comment 1

Condition C.1, PSD Minor Source Status (c) states the following:

(c) Any change or modification which may increase potential to emit to 10 tons per year of

any single hazardous air pollutant, twenty-five tons per year of any combination of

hazardous air pollutants, or 100 tons per year of any other regulated pollutant from this

source, shall cause this source to be considered a major source under Part 70 Permit

Program, 326 IAC 207, and shall require approval from IDEM, OAM prior to making the

change.

As required by the NESHAP for Chromium Emissions from Hard and Decorative Chromium

Electroplating and Chromium Anodizing Tanks, the facility will be required to submit a Part 70 permit

within five years. We request that this condition be deleted or modified since the facility is already

required to submit an application under the Part 70 permit program. Additionally, an increase in the

source’s potential to emit to 10 tons per year of any single HAP, 25 tons per year of a combination of

HAPs, or 100 tons of any other regulated pollutant would cause the source to be considered a major

source under the Part 70 program but we should have 12 months to apply for this Title V permit after the

source becomes a major source.
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-11519-00091

Permit Reviewer: PR/EVP

Page 2 of 12

Response 1

It is true that 326 IAC 20-8, which incorporates the chromium electroplating NESHAP, states that:

". . . nonmajor [area] sources that have been deferred under 61 FR 27785* shall submit Part 70 permit

applications to the department by December 9, 2000."

However, on December 14, 1999 EPA gave states the option to extend the deferral another 5 years (64

FR 69637). Indiana intends to exercise that option and give all eligible chromium electroplating and

anodizing sources another 5-year deferral from Title V permitting (decorative chromium electroplating or

chromium anodizing operations that use fume suppressants as an emission reduction technology and

decorative chromium electroplating operations that use a trivalent chromium bath that incorporates a

wetting agent as a bath ingredient were permanently exempted from Title V permitting by an earlier EPA

action (61 FR 27785)).

IAC 326 20-8 will be revised to extend the Part 70 application date 5 years to December 9, 2005.

Because the rule revision likely cannot be completed prior to December 9, 2000, IDEM, OAM has begun

work to issue a non-rule policy document that will provide the deferral in the interim until the rule is

revised.

Comment 2

Condition D.1.5 Monitoring to Demonstrate Continuous Compliance (a) states “The Permittee shall

monitor and record the air flow rate across the composite mesh pad system once each day that P-1 and

P-2 are in operation.” According to 40 CFR 63.343(c)(1), the pressure drop across the composite meshpad system shall be monitored and recorded each day that the affected source is operating. Therefore,

the condition should be changed as follows (bold language should be added, language with a line

through it should be deleted):

(a) The Permittee shall monitor and record the air flow rate pressure drop across the

composite mesh pad system once each day that P-1 and P-2 are in operation.

Response 2

40 CFR 63.343(c)(1) requires that the pressure drop, not the air flow rate, across the composite meshpad system shall be monitored and recorded each day that the affected source is operating. Condition

D.1.5 has been replaced with Condition D.1.6 to require pressure drop monitoring and record keeping

and for clarification of compliance determination requirements and compliance monitoring requirements

for the composite mesh-pad system: 

D.1.5 Monitoring to Demonstrate Continuous Compliance [40 CFR 63.343 (c)(1)]

(a) The Permittee shall monitor and record the air flow rate across the composite mesh pad

system once each day that P-1 and P-2 are in operation.

(c) The composite mesh pad system shall be operated at an air flow rate above 27,000 cfm,

or shall be operated within the range of compliant values for air flow rate established

during multiple performance tests that may be conducted in the future.

D.1.6 Monitoring to Demonstrate Continuous Compliance [40 CFR 63.343(c)(1)][326 IAC 2-1.1-

11]

(a) On and after the date on which the initial performance test required in Condition

D.1.5 is required to be completed under 40 CFR 63.7, the Permittee shall monitor

and record the pressure drop across the composite mesh-pad system once each

day that either tank in P-1 or P-2 is in operation. To be in compliance with the

standards, 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 within the range of compliant values for pressure drop
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-11519-00091

Permit Reviewer: PR/EVP

Page 3 of 12

established during multiple performance tests.

(b) Tank operation or operating time for chromium electroplating is defined as that

time when the rectifier is turned on and a part is in the tank. When there is no part

in a tank for fifteen (15) or more minutes, the tanks will not be considered to be in

operation, and that time will not be considered operating time. Likewise, if the

time between placing a part in the tank is less than fifteen (15) minutes, the tanks

will be considered to be in operation, and that time will be considered part of the

operating time.

Comment 3

Condition D.1.6 Testing Requirements states that the Permittee shall perform VOC testing in accordance

with the provisions of 40 CFR 63.344 utilizing Method 24. The requirements of 40 CFR 63.344 actually

state that “Method 306 or Method 306A, “Determination of Chromium Emissions from Decorative and

Hard Chromium Electroplating and Anodizing Operations,” Appendix A of this part shall be used to

determine the chromium concentration from hard or decorative chromium electroplating tanks or

chromium anodizing tanks.” Therefore, this condition should be changed as follows:

During the period between 30 and 36 months after issuance of this permit, the Permittee shall

perform VOC testing to determine the chromium concentration from the electroplating

tanks in accordance with the provisions of 40 CFR 63.344 utilizing Method 24 306 or 306A (40

CFR 60, Appendix A), or other methods as approved by the Commissioner. In addition to these

requirements, IDEM may require compliance testing when necessary to determine if the facility

is in compliance. Future tests that may be required shall be conducted in accordance with the

provisions of 40 CFR 63.344.

Response 3

Testing for the outlet chromium concentration, not VOC, is required by 40 CFR 63.343(b)(1) and 63.7. 

Condition D.1.6, now Condition D.1.5, has been changed to clarify that the source of testing methods for

hard chromium electroplating tanks is 40 CFR 63.344 (and also 40 CFR 63.7), and to require testing

within 180 days for the new construction: 

D.1.6 Testing Requirements [326 IAC 2-7-6(1)] [40 CFR 63.344]

During the period between 30 and 36 months after issuance of this permit, the Permittee shall

perform VOC testing in accordance with the provisions of 40 CFR 63.344 utilizing Method 24 (40

CFR 60, Appendix A), or other methods as approved by the Commissioner. In addition to these

requirements, IDEM may require compliance testing when necessary to determine if the facility

is in compliance. Future tests that may be required shall be conducted in accordance with the

provisions of 40 CFR 63.344.

D.1.5 Performance Testing [40 CFR 63.343, 63.344, and 63.7]

(a) The Permittee is required to conduct an initial performance test within 180 days

after startup of the emissions units using the procedures and methods listed in

40 CFR 63.344 and 63.7 and in accordance with the provisions of Condition C.8 -

Performance Testing of this permit.

(b) During the initial performance test, the Permittee shall determine the outlet

chromium concentration of the composite mesh-pad system using the test

methods and procedures in 40 CFR 63.344(c) and shall establish as a site-specific

operating parameter the pressure drop across the system, setting the value that

corresponds to compliance with the emission limitation in Condition D.1.2(a)

using the procedures in 40 CFR 63.344(d)(5). The Permittee may conduct multiple

performance tests to establish a range of compliant pressure drop values, or may
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-11519-00091

Permit Reviewer: PR/EVP

Page 4 of 12

set as the compliant value the average pressure drop measured over the three (3)

test runs of one performance test, and accept ±1 inch of water column from this

value as the compliant range.

Comment 4

The Ongoing Compliance Status Report form (copy attached to permit), required to be

completed by Condition D.1.8(d), states that the monitoring parameter is “Surface tension of the

electroplating bath” and the parameter value is ”45 dynes per centimeter”. The facility operates

a mist eliminator/composite mesh pad system and is therefore required to monitor pressure drop

across the system, not surface tension. This form should be revised accordingly. 

Response 4

40 CFR 63.343(c)(1) requires that the pressure drop, and not the air flow rate, across the composite

mesh-pad system shall be monitored and recorded each day that the affected source is operating. The

identification numbers for the Tanks has also been changed to remove the terms E-1 and E-2, as P-1

and E-1 both refer to one emission unit and P-2 and E-2 both refer to another unit. The Ongoing

Compliance Status Report form has been revised as follows:

Tank ID #: E-1 and E-2 P-1 and P-2

Type of process: Hard chromium electroplating

Monitoring Parameter: Surface tension of the electroplating bath Pressure drop across the

composite mesh pad system

Parameter Value: 45 dynes per centimeter ±1 inch of water column of the pressure

drop value established during the initial performance test, or within

the range of compliant values for pressure drop established during

multiple performance tests

Limits: The concentration of total chromium in the exhaust gas stream discharged to the

atmosphere from Stack S-1 of P-1 and P-2 shall not exceed 0.015 milligrams of total

chromium per dry standard cubic meter (mg/dscm) of ventilation air (6.6 x 10-6 grains per

dry standard cubic foot (gr/dscf)).

Upon further review, the OAM has decided to make the following revisions to the permit to incorporate

updated language for new hard chromium electroplating operations (bolded language has been added,

the language with a line through it has been deleted). The Table Of Contents has been modified to

reflect these changes.

(a ) Section A.2, the Emissions units and Pollution Control Equipment Summary and the Emission

Unit Description in Section D.1 have been revised as follows to clarify the description of permitted

units:

(a) Two (2) hard chromium electroplating operations, identified as P-1 and P-2, consisting of

two (2) standard sulfate plating tanks (Tanks E-1 and E-2), using a composite mesh-pad

system for control, each having a rectifier with a maximum potential capacity of 12,500

amps, exhausting to one (1) stack identified as S-1.

SECTION D.1 EMISSIONS UNIT OPERATION CONDITIONS
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-11519-00091

Permit Reviewer: PR/EVP

Page 5 of 12

Emissions Unit Description

(a) Two (2) hard chromium electroplating operations, identified as P-1 and P-2, consisting of two

(2) standard sulfate plating tanks (Tanks E-1 and E-2), using a composite mesh-pad system

for control, each having a rectifier with a maximum potential capacity of 12,500 amps,

exhausting to one (1) stack identified as S-1.

(The information describing the process contained in this emissions unit description box is descriptive

information and does not constitute enforceable conditions.)

(b) The rule citations throughout Section D.1 have been changed to reflect the Minor Source

Operating Permit Program (326 IAC 2-6.1), and not the Part 70 Permit Program (326 IAC 2-7).

(c) Conditions D.1.1 through D.1.4 in the permit section entitled “Emission Limitations and

Standards” have been revised as shown below to: (1)reflect the use of the term “emissions unit”

in revised state permitting rules; (2) be more consistent with the language of the Chromium

Electroplating NESHAP; (3) delete language that was inadvertently included in the draft permit;

and (4) add the requirement to address excess emissions as well as malfunctions if they occur.

By this permit, the Permittee is approved to use a composite mesh-pad system as the emission

reduction technique to comply with the Chromium Electroplating NESHAP. However, IDEM,

OAM encourages the Permittee to also consider the use of fume suppressants to comply as this

technique can achieve a greater degree of emission reductions. Use of fume suppressants can

be approved in a permit modification as an alternative means of compliance in addition to or

instead of the composite mesh-pad system.

Emission Limitations and Standards

D.1.1 General Provisions Relating to HAPs [326 IAC 20-1-1] [40 CFR Part 63, Subpart A]

The provisions of 40 CFR Part 63, Subpart A - General Provisions, which are incorporated as

326 IAC 20-1-1, apply to the facility emissions units described in this section except when

otherwise specified in 40 CFR Part 63, Subpart N.

D.1.2 Chromium Electroplating NESHAP [326 IAC 20-8-1] [40 CFR Part 63, Subpart N] [326 IAC 2-

1.1-11]

This facility is These emissions units 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), which is incorporated by reference as

326 IAC 20-8-1. A copy of this rule is attached. The Permittee shall comply with the

requirements in this condition on and after the startup date.

The emission limitations in this condition apply only during tank operation, and also apply

during periods of startup and shutdown as these are routine occurrences for affected

sources subject to 326 IAC 20-8-1. The emission limitations do not apply during periods

of malfunction, but the work practice standards that address operation and maintenance

and are required by paragraph (b) of this condition must be followed during malfunctions.

(a) The Permittee shall not allow the concentration of total chromium in the exhaust gas

stream During tank operation, the Permittee shall control chromium emissions

discharged to the atmosphere from Stack S-1 of P-1 and P-2 by not allowing the

concentration of total chromium in the exhaust gas stream discharged to the

atmosphere to exceed 0.015 milligrams of total chromium per dry standard cubic meter

(mg/dscm) of ventilation air (6.6 x 10-6 grains per dry standard cubic foot (gr/dscf)).
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-11519-00091

Permit Reviewer: PR/EVP

Page 6 of 12

(b) The Permittee is subject to the following work practice standards for P-1 and P-2 are

also applicable, which address operation and maintenance practices:

(1) At all times, including periods of startup, shutdown, and malfunction, and

excess emissions, the Permittee shall operate and maintain P-1 and P-2,

including the composite mesh-pad system and monitoring equipment, in a

manner consistent with good air pollution control practices, consistent with

the Operation and Maintenance Plan (OMP) required by Condition D.1.4.

(2) Malfunctions and excess emissions shall be corrected as soon as practicable

after their occurrence in accordance with the OMP required by Condition D.1.4.

(3) These operation and maintenance requirements are enforceable

independent of emissions limitations or other requirements in this section.

(4) Determination of whether acceptable operation and maintenance procedures

are being used will be based on information available to IDEM, OAM, which may

include, but is not limited to, monitoring results; review of the OMP, procedures,

and records; and inspection of the source.

(4 5) Based on the results of a determination made under paragraph (b)(4) of

this condition, IDEM, OAM may require that the Permittee make changes to

the OMP required by Condition D.1.4. Revisions may be required if IDEM,

OAM finds that the plan:

(A) Does not address a malfunction or period of excess emissions that

has occurred;

(B) Fails to provide for the operation of P-1 and P-2, the air pollution control

techniques, or the composite mesh-pad system and process monitoring

equipment during a malfunction or period of excess emissions in a

manner consistent with good air pollution control practices; or

(C) Does not provide adequate procedures for correcting malfunctioning

process equipment, air pollution control techniques, or monitoring

equipment or other causes of excess emissions as quickly as

practicable.

D.1.3 Preventive Maintenance Plan [326 IAC 2-7-5(13) 1-6-3]

A Preventive Maintenance Plan (PMP), in accordance with the Section B condition entitled

“Preventive Maintenance Plans” of this permit is required for P-1 and P-2 and the composite

mesh-pad system.

D.1.4 Operation and Maintenance Plan [40 CFR 63.342(f)(3)] [326 IAC 2-1.1-11]

(a) An Operation and Maintenance Plan (OMP), In accordance with 40 CFR 63.342(f)(3),

The Permittee shall prepare an Operation and Maintenance Plan (OMP) to be

implemented no later than the startup date of the emissions units. The plan shall

be prepared and maintained and shall specify the operation and maintenance criteria for

P-1 and P-2, the composite mesh-pad system, and monitoring equipment, and shall
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-11519-00091

Permit Reviewer: PR/EVP

Page 7 of 12

include the following elements:

(1) Quarterly visual inspection of the composite mesh-pad 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 device;

(2) Quarterly visual inspection of the back portion of the mesh-pad closest to the fan

to ensure there is no breakthrough of chromic acid mist;

(3) Quarterly visual inspection of the ductwork from the tanks to the control device

to ensure there are no leaks;

(4) Perform washdown of the composite mesh-pads in accordance with

manufacturer’s recommendations.

(5) A standardized checklist to document the operation and maintenance criteria for

P-1 and P-2, the composite mesh-pad system, and monitoring equipment;

(6) Procedures to be followed to ensure that neither equipment or process

malfunctions due to poor maintenance or other preventable conditions nor

excess emissions as indicated by monitoring data do not occur;

(7) A systematic procedure for identifying malfunctions of and periods of excess

emissions from P-1 and P-2, the composite mesh-pad system, and monitoring

equipment; and for implementing corrective actions to address such

malfunctions and periods of excess emissions.

(c b) If the OMP fails to address or inadequately addresses an event that meets the

characteristics of a malfunction or a period of excess emissions as indicated by

monitoring data at the time the plan is initially developed, the Permittee shall revise the

OMP within forty five (45) days after such an event occurs. The revised plan shall

include procedures for operating and maintaining P-1 and P-2, the composite mesh-pad

system, and monitoring equipment, during similar malfunction and excess emissions

events, and a program for corrective action for such events.

(d c) If actions taken by the Permittee during periods of malfunction or excess emissions

are inconsistent with the procedures specified in the OMP, the Permittee shall record the

actions taken for that event and shall report by phone such actions within two (2)

working days after commencing actions inconsistent with the plan. This report shall be

followed by a letter within seven (7) working days after the end of the event, unless the

Permittee makes alternative reporting arrangements, in advance, with IDEM, OAM.

(e d) The Permittee shall keep the written OMP on record after it is developed to be made

available, upon request, by IDEM, OAM for the life of P-1 and P-2 or until P-1 and P-2

are no longer subject to the provisions of 40 CFR 63.340. In addition, if the OMP is

revised, the Permittee shall keep previous versions of the OMP on record to be made

available for inspection, upon request by IDEM, OAM for a period of five (5) years after

each revision to the plan.

(e) The Permittee may use applicable standard operating procedures (SOP) manuals,

occupational safety and health administration (OSHA) plans, or other existing

plans such as the PMP required in Condition D.1.3, as the OMP provided the

alternative plans meet the criteria listed above in Condition D.1.4(a).
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-11519-00091

Permit Reviewer: PR/EVP

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(d) Conditions D.1.5 and D.1.6 in the permit section entitled “Compliance Determination

Requirements” have been revised as shown below to: (1) be more consistent with the language

of the Chromium Electroplating NESHAP; (2) relocate monitoring conditions more properly in a

section entitled “Compliance Monitoring;” (3) correct the site-specific parameter value from “air

flow rate” to “pressure drop across the composite mesh-pad system;” and (4) relocate the

definition of “tank operation and operating time” from the Recordkeeping and Reporting section

of the permit to the Compliance Monitoring section since the definition applies to monitoring as

well.

Should the Permittee decide any time in the future to use fume suppressants as the emissions

reduction technique to comply with the NESHAP, IDEM, OAM wishes to clarify that Method 306B

in Appendix A of 40 CFR Part 63 may be used to measure surface tension.

Compliance Determination Requirements

D.1.5 Performance Testing [40 CFR 63.343, 63.344, and 63.7]

(a) The Permittee is required to conduct an initial performance test within 180 days

after startup of the emissions units using the procedures and methods listed in

40 CFR 63.344 and 63.7 and in accordance with the provisions of Condition C.8 -

Performance Testing of this permit.

(b) During the initial performance test, the Permittee shall determine the outlet

chromium concentration of the composite mesh-pad system using the test

methods and procedures in 40 CFR 63.344(c) and shall establish as a site-specific

operating parameter the pressure drop across the system, setting the value that

corresponds to compliance with the emission limitation in Condition D.1.2(a)

using the procedures in 40 CFR 63.344(d)(5). The Permittee may conduct multiple

performance tests to establish a range of compliant pressure drop values, or may

set as the compliant value the average pressure drop measured over the three (3)

test runs of one performance test, and accept ±1 inch of water column from this

value as the compliant range.

Compliance Monitoring Requirements

D.1.6 Monitoring to Demonstrate Continuous Compliance [40 CFR 63.343(c)(1)][326 IAC 2-1.1-

11]

(a) On and after the date on which the initial performance test required in Condition

D.1.5 is required to be completed under 40 CFR 63.7, the Permittee shall monitor

and record the pressure drop across the composite mesh-pad system once each

day that either tank in P-1 or P-2 is in operation. To be in compliance with the

standards, 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 within the range of compliant values for pressure drop

established during multiple performance tests.

(b) Tank operation or operating time for chromium electroplating is defined as that

time when the rectifier is turned on and a part is in the tank. When there is no part

in a tank for fifteen (15) or more minutes, the tanks will not be considered to be in

operation, and that time will not be considered operating time. Likewise, if the

time between placing a part in the tank is less than fifteen (15) minutes, the tanks

will be considered to be in operation, and that time will be considered part of the

operating time.
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-11519-00091

Permit Reviewer: PR/EVP

Page 9 of 12

(e) Conditions D.1.7 and D.1.8 in the permit section entitled “Record Keeping and Reporting

Requirements” have been revised as shown below to: (1) be more consistent with the language

of the Chromium Electroplating NESHAP; (2) add the requirement to address excess emissions

as well as malfunctions if they occur; (3) require more frequent reporting if either total duration of

excess emissions or malfunctions exceed thresholds established in the NESHAP instead of both

having to occur; and (4) include all notifications and reporting required for new sources by both

the NESHAP and state new source construction rules.

It is emphasized that where the permit states that approval is required for changes to

recordkeeping or reporting conditions (such as changes in reporting frequency), the approval

shall come from IDEM, OAM. All requests for changes and approvals must be made consistent

with the permitting rules in 326 IAC Article 2. That is, the proper applications must be submitted

if necessary, and all approvals shall be subject to the time lines for issuance stated in the rules.

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3) 5.1-3(e)(2)] [326 IAC 2-7-19 6.1-

5(a)(2)][326 IAC 2-1.1-11]

D.1.7 Record Keeping Requirements [40 CFR 63.346]

(a) The Permittee shall maintain records to document compliance with Conditions D.1.2 and D.1.4

using the forms provided with this permit. These records shall be maintained in accordance with

the Section C condition entitled “General Record Keeping Requirements” of this permit, be kept

for a period of five (5) years, and include a minimum of the following:

(1 a) Inspection records for the composite mesh-pad system and monitoring equipment to

document that the inspection and maintenance required by Conditions D.1.3 and D.1.4

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

following:

(A 1) The device inspected;

(B 2) The date of inspection;

(C 3) A brief description of the working condition of the device during the inspection,

including any deficiencies found; and

(D 4) Any actions taken to correct deficiencies found during the inspection, including

the date(s) such actions were taken.

(2 b) Records of all maintenance performed on P-1 and P-2, the composite mesh-pad system

and monitoring equipment.

(3 c) Records of the occurrence, duration, and cause (if known) of each malfunction of P-1

and P-2, the composite mesh-pad system and monitoring equipment and each period

of excess emissions from P-1 and P-2 and the composite mesh-pad system as

indicated by monitoring data collected in accordance with paragraph (g) of this

condition.

(4 d) Records of actions taken during periods of malfunction or excess emissions when

such actions are inconsistent with the OMP.

(5 e) Other records, which may take the form of checklists, necessary to demonstrate

consistency with the provisions of the OMP.
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-11519-00091

Permit Reviewer: PR/EVP

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(6 f) 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.

(7 g) 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.

(10 h) The total operating time of P-1 and the total operating time of P-2 during the reporting

period, operating time as defined in Condition D.1.6(b).

(i) All documentation supporting the notifications and reports required by 40 CFR

63.9 and 63.10, and Condition D.1.8.

D.1.8 Reporting Requirements [40 CFR 63.345 & 63.347] [326 IAC 2-1.1-11]

The notifications and reports required in this section shall be submitted to the address

specified in Condition C.15 - General Reporting Requirements of this permit.

(a) The Permittee may not construct a new emissions unit subject to 326 IAC 20-8-1

(including non-affected sources defined in 40 CFR 63.344(e)), or change, modify,

or reconstruct P-1 or P-2 (including addition of ductwork to the composite meshpad system or change in the air pollution control technique used to comply with

Condition D.1.2) without submitting a Notification of Construction or

Reconstruction for these new or reconstructed emissions units to IDEM, OAM.

(1) The application to construct P-1 and P-2 serves as this notification. 

Likewise, a complete application for a permit revision shall serve as this

notification for any new construction or reconstruction.

(2) Pursuant to 326 IAC 2-1.1-2(a), permission must be received from IDEM,

OAM before construction or reconstruction may commence.

(b) The Permittee shall submit an Initial Notification for P-1 and P-2 as follows:

(1) A notification of the date when construction or reconstruction of the

emissions units was commenced shall be submitted no later than thirty

(30) calendar days after such date.

(2) A notification of the actual date of startup of the emissions units shall be

submitted within thirty (30) calendar days after such date.

(c) The Permittee shall notify IDEM, OAM in writing of their intention to conduct the

initial performance test required in Condition D.1.5 and any future performance

tests conducted as required by 40 CFR 63.7 and 63.343(b) at least sixty (60)

calendar days before the test is scheduled to begin.

(1) Pursuant to Condition C.8 - Performance Testing, a test protocol shall be

submitted no later than thirty-five (35) days prior to the intended test date.

(2) In the event the Permittee is unable to conduct the performance test as

scheduled, pursuant to 40 CFR 63.7(b)(2) the Permittee shall notify IDEM,

OAM within five (5) days prior to the scheduled performance test date and

specify the date when the performance test is rescheduled. Pursuant to

Condition C.8 - Performance Testing, the rescheduled performance test
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-11519-00091

Permit Reviewer: PR/EVP

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date shall be no sooner than fourteen (14) days after IDEM, OAM is notified

in writing of the need to reschedule.

(d) A Notification of Compliance Status is required for P-1 and P-2 and shall be

submitted to IDEM, OAM. The notification shall list all of the information required

in 40 CFR 63.347(e)(2), including the test report documenting the results of the

performance test required in Condition D.1.5, which contains the elements

required by 40 CFR 63.344(a). Pursuant to Condition C.8 - Performance Testing,

the Notification of Compliance Status shall be submitted no later than forty-five

(45) calendar days following completion of the performance test required in

Condition D.1.5.

(e) The Permittee shall report to IDEM, OAM the results of any future performance test

conducted for P-1 or P-2 as required by 40 CFR 63.7 and 63.343(b). Pursuant to

Condition C.8 - Performance Testing, results of a performance test shall be

submitted no later than forty-five (45) days following the completion of the

performance test.

(f) The Permittee shall prepare a summary report to document the ongoing

compliance status of the affected source. The Ongoing Compliance Status Report

shall contain the information identified in 40 CFR 63.347(g)(3), shall be completed

using the form provided with this permit. Because P-1 and P-2 will be located at

an area source site, the Ongoing Compliance Status Report shall be retained on

site and made available to IDEM, OAM upon request. 

(1) The Ongoing Compliance Status Report shall be completed according to

the following schedule except as provided in paragraphs (f)(2) through (4)

of this condition.

(A) The first report shall cover the period from the start-up date of the

emissions units to December 31 of the year in which the emissions

units begin operation.

(B) Following the first year of reporting, the report shall be completed

on a calendar year basis with the reporting period covering from

January 1 to December 31.

(2) If either of the following conditions are met, semiannual reports shall be

prepared and submitted to IDEM, OAM:

(A) The total duration of excess emissions (as indicated by the

monitoring data collected by the Permittee in accordance with

40 CFR 63.343(c)) is one percent (1%) or greater of the total

operating time as defined in Condition D.1.6(b) for the reporting

period; or
H.V. Roll Center, Incorporated

Chesterton, Indiana MSOP127-11519-00091

Permit Reviewer: PR/EVP

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(B) The total duration of malfunctions of the add-on air pollution

control device and monitoring equipment is five percent (5%) or

greater of the total operating time as defined in Condition D.1.6(b).

Once the Permittee reports an exceedance as defined above, Ongoing

Compliance Status Reports shall be submitted semiannually until a

request to reduce reporting frequency is approved by IDEM, OAM.

(3) IDEM, OAM may determine on a case-by-case basis that the summary

report shall be completed more frequently and submitted, or that the

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

measures are necessary to accurately assess the compliance status of the

source.

(4) If the Permittee 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, the Permittee may reduce the

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

report onsite according to the conditions and by following the procedures

of 40 CFR 63.347(h)(3).