# NEW SOURCE CONSTRUCTION PERMIT

and MINOR SOURCE OPER ATING 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

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### 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

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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

.................................................. 24H.V. Roll Center, Incorporated

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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

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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, W ITH CONDITIONS LISTED BELO W. 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.H.V. Roll Center, Incorporated

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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

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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:H.V. Roll Center, Incorporated

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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.H.V. Roll Center, Incorporated

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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 “authorizedH.V. Roll Center, Incorporated

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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.H.V. Roll Center, Incorporated

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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 theH.V. Roll Center, Incorporated

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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 6015H.V. Roll Center, Incorporated

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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.H.V. Roll Center, Incorporated

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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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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,H.V. Roll Center, Incorporated

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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 monitoringH.V. Roll Center, Incorporated

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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 isH.V. Roll Center, Incorporated

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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 inP-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 measurementsH.V. Roll Center, Incorporated

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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 toH.V. Roll Center, Incorporated

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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 reportH.V. Roll Center, Incorporated

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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 2H.V. Roll Center, Incorporated

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### 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 2H.V. Roll Center, Incorporated

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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 DECH.V. Roll Center, Incorporated

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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

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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 andP-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 240 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 dropH.V. Roll Center, Incorporated

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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 mayH.V. Roll Center, Incorporated

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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 CONDITIONSH.V. Roll Center, Incorporated

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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)).H.V. Roll Center, Incorporated

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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 shallH.V. Roll Center, Incorporated

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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).H.V. Roll Center, Incorporated

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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

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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.H.V. Roll Center, Incorporated

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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 testH.V. Roll Center, Incorporated

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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; orH.V. Roll Center, Incorporated

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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).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

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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 andP-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 240 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 dropH.V. Roll Center, Incorporated

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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 mayH.V. Roll Center, Incorporated

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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 CONDITIONSH.V. Roll Center, Incorporated

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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)).H.V. Roll Center, Incorporated

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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 shallH.V. Roll Center, Incorporated

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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).H.V. Roll Center, Incorporated

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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

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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.H.V. Roll Center, Incorporated

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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 testH.V. Roll Center, Incorporated

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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; orH.V. Roll Center, Incorporated

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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).