# NEW SOURCE CONSTRUCTION PERMIT

and MINOR SOURCE OPER ATING PERMIT OFFICE OF AIR MANAGEMENT

Roembke Manufacturing and Design

1580 Baker Drive Ossian, Indiana 46777

(herein known as the Permittee) is hereby authorized to construct and operate subject to the conditionscontained 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, 326 IAC 2-6.1 and 40 CFR 52.780, with conditions listed on the attached pages.

Operation Permit No.: MSOP 179-11704-00027

Issued by: Paul Dubenetzky, Branch Chief Office of Air Management Issuance Date:Roembke Manufacturing and Design Page 2 of 26

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TABLE OF CONTENTS
A SOURCE SUMMARY

.......................................................... 4 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 [IC 13-15-5-3] 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] 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 2-5.1-3(e)(4)(B)] [326 IAC 2-6.1-5(a)(4)] 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] C.8 Fugitive Dust Emissions [326 IAC 6-4] C.9 Performance Testing [326 IAC 3-6] C.10 Compliance Monitoring [326 IAC 2-1.1-11] C.11 Monitoring Methods [326 IAC 3] C.12 Compliance Monitoring Plan - Failure to Take Response Steps [326 IAC 1-6] C.13 Actions Related to Noncompliance Demonstrated by a Stack Test Record Keeping and Reporting Requirements C.14 Malfunctions Report [326 IAC 1-6-2] C.15 Monitoring Data Availability [326 IAC 2-6.1-2] [IC 13-14-1-3] C.16 General Record Keeping Requirements [326 IAC 2-6.1-2] C.17 General Reporting Requirements [326 IAC 2-1.1-11] [326 IAC 2-6.1-2] [IC 13-14-1-13] C.18 Annual Notification [326 IAC 2-6.1-5(a)(5)]
D.1 EMISSIONS UNIT OPERATION CONDITIONS: Chromium Electroplating

............... 15 Emission Limitations and Standards [326 IAC 2-6.1-5(1)] D.1.1 General Provisions Relating to HAPs [326 IAC 20-1-1][40 CFR Part 63, Subpart A] D.1.2 Chromium Electroplating and Anodizing NESHAP [326 IAC 20-8-1] [40 CFR Part 63, Subpart N] D.1.3 Chromium Emissions Limitation [40 CFR 63.342(c)] [40 CFR 63.343(a)(1)&(2)] D.1.4 Work Practice Standards [40 CFR 63.342(f)] D.1.5 Preventive Maintenance Plan [326 IAC 1-6-3] D.1.6 Operation and Maintenance Plan [40 CFR 63.342(f)(3)] Compliance Determination Requirements [326 IAC 2-1.1-11] D.1.7 Performance Testing Requirements [326 IAC 2-1.1-11] [40 CFR 63.343(b)(2)] [40 CFR 63.7] [40 CFR 63.344] D.1.8 Establishing Site-Specific Operating Parameter Values [40 CFR 63.343(c)] [40 CFR 63.344(d)]Roembke Manufacturing and Design Page 3 of 26

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Compliance Monitoring Requirements [326 IAC 2-5.1-3(e)(2)] [326 IAC 2-6.1-5(a)(2)] D.1.9 Monitoring to Demonstrate Continuous Compliance [326 IAC 2-5.1-3(e)(2)] [326 IAC 2-6.1-5(a)(2)] [40 CFR 63.343(c)] Record Keeping and Reporting Requirements [326 IAC 2-5.1-3(e)(2)] [326 IAC 2-6.1-5(a)(2)] D.1.10 Record Keeping Requirements [326 IAC 2-5.1-3(e)(2)] [40 CFR 63.346] D.1.11 Reporting Requirements [326 IAC 2-5.1-3(e)(2)] [326 IAC 3-6-4(b)] [40 CFR 63.344(a)] [40 CFR 63.345] [40 CFR 63.347]
Chromium Electroplating NESHAP Ongoing Compliance Status Report

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

................................................................ 24 Annual Report

.................................................................... 26Roembke Manufacturing and Design Page 4 of 26

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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 and A.2 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 thisdescriptive information obsolete or inaccurate may trigger requirements for the Permittee to obtain ad ditional 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 stationary small, hard chromium electroplating source. Authorized Individual: Martin F. Adam, Jr. Source Address: 1580 Baker Drive, Ossian, Indiana 46777 Mailing Address: 1580 Baker Drive, Ossian, Indiana 46777 Phone Number: 219 - 622 - 4135 SIC Code: 3470 County Location: Wells 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) One (1) chrome plating tank, identified as Tank 1, controlled with a composite mesh pad system, and exhausting to stack S/V 1, maximum cumulative rectifier capacity: 29,400,000 ampere hours per year. (b) One (1) chrome plating tank, identified as Tank 2, controlled with a composite mesh pad system, and exhausting to stack S/V 1, maximum cumulative rectifier capacity: 11,760,000 ampere hours per year. (c) One (1) space heater, identified as H1, fired by natural gas, heat input capacity: 0.125 million British thermal units per hour. (d) One (1) space heater, identified as H2, fired by natural gas, heat input capacity: 0.1 million British thermal units per hour.Roembke Manufacturing and Design Page 5 of 26

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SECTION B GENERAL CONSTRUCTION CONDITIONS THIS SECTION OF THE PERMIT IS BEING ISSUED UNDER THE PROVISIONS OF 326 IAC 2-1.1 AND 40 CFR 52.780, WITH CONDITIONS LISTED BELOW.
B.1 Permit No Defense [IC 13] This permit to construct does not relieve the Permittee of the responsibility to comply with the provisions of the Indiana Environmental Management Law (IC 13-11 through 13-20; 13-22 through 13- 25; and 13-30), the Air Pollution Control Law (IC 13-17) and the rules promulgated thereunder, as well as other applicable local, state, and federal requirements.
B.2 Definitions Termsin 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 consistentwith 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 conditionsassociated 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.Roembke Manufacturing and Design Page 6 of 26

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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.Roembke Manufacturing and Design Page 7 of 26

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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] The total source potential to emit of each criteria pollutant 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. 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’sshall 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: 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 toRoembke Manufacturing and Design Page 8 of 26

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assertthat 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 Part 70 source is located, or emissions related activity is conducted, or where records must be kept under the conditions of this permit; (b) Haveaccess to and copy, at reasonable times, any records that must be kept under the conditions of this permit; (c) Inspect, at reasonable times, any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this permit; (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. [326 IAC 2-7-6(6)] 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. (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.Roembke Manufacturing and Design Page 9 of 26

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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 alternativeopacity 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. C.8 Fugitive Dust Emissions [326 IAC 6-4] The Permittee shall not allow fugitive dust to escape beyond the property line or boundaries of the property, right-of-way, or easement on which the source is located, in a manner that would violate 326 IAC 6-4 (Fugitive Dust Emissions). 326 IAC 6-4-2(4) is not federally enforceable. Testing Requirements C.9 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 than180 days after initial start-up, if specified in Section D of this approval. All testing shall be performed according to the provisions of 326 IAC3-6 (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

nolater than thirty-five (35) days prior to the intended test date. The Permittee shall submit a notice of the actual test date to the above address so that it is received at least two weeks prior to the test date. (b) All test reports must be received by IDEM, OAM, within forty-five (45) days after the completion of the testing. An extension may be granted by the IDEM, OAM, if the source submits to IDEM, OAM, a reasonable written explanation within five (5) days prior to the end of the initial forty-five (45) day period. The documentation submitted by the Permittee does not require certification by the “authorized individual” as defined by 326 IAC 2-1.1-1. Compliance Monitoring Requirements C.10 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 alreadyRoembke Manufacturing and Design Page 10 of 26

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legally required shall be implemented when operation begins. C.11 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. C.12 Compliance Monitoring Plan - Failure to Take Response Steps [326 IAC 1-6] (a) The Permittee is required to implement a compliance monitoring plan to ensure that reasonable information is available to evaluate its continuous compliance with applicable requirements. This compliance monitoring plan is comprised of: (1) This condition; (2) The Compliance Determination Requirements in Section D of this permit; (3) The Compliance Monitoring Requirements in Section D of this permit; (4) The Record Keeping and Reporting Requirements in Section C (Monitoring Data Availability, General Record Keeping Requirements, and General Reporting Requirements) and in Section D of this permit; and (5) A

Compliance Response Plan (CRP) for each compliance monitoring condition of thispermit. CRP’s shall be submitted to IDEM, OAM upon request and shall be subjectto review and approval by IDEM, OAM. The CRP shall be prepared within ninety (90) days after issuance of this permit by the Permittee and maintained on site, and is comprised of: (A) Response steps that will be implemented in the event that compliance relate d information indicates that a response step is needed pursuant to the requirements of Section D of this permit; and (B) A

time schedule for taking such response steps including a schedule for devising additional response steps for situations that may not have been predicted. (b) For

each compliance monitoring condition of this permit, appropriate response steps shall be taken when indicated by the provisions of that compliance monitoring condition. Failure to perform the actions detailed in the compliance monitoring conditions or failure to take the response steps within the time prescribed in the Compliance Response Plan, shall constitute a violation of the permit unless taking the response steps set forth in the Compliance Response Plan would be unreasonable. (c) After

investigating the reason for the excursion, the Permittee is excused from taking further response steps for any of the following reasons: (1) The monitoring equipment malfunctioned, giving a false reading. This shall be an excuse from taking further response steps providing that prompt action was taken to correct the monitoring equipment. (2) The Permittee has determined that the compliance monitoring parameters established in the permit conditions are technically inappropriate, has previously submitted a request for an administrative amendment to the permit, and such request hasRoembke Manufacturing and Design Page 11 of 26

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not been denied or;

(3) An automatic measurement was taken when the process was not operating; or (4) The process has already returned to operating within “normal” parameters and no response steps are required. (d) Records shall be kept of all instances in which the compliance related information was not met and of all response steps taken. C.13 Actions Related to Noncompliance Demonstrated by a Stack Test (a) When the results of a stack test performed in conformance with Section C - Performance Testing, of this permit exceed the level specified in any condition of this permit, the Permittee shall take appropriate corrective actions. The Permittee shall submit a description of these correctiveactions to IDEM, OAM, within thirty (30) days of receipt of the test results. The Permittee shall take appropriate action to minimize emissions from the affected emissions unit while the corrective actions are being implemented. IDEM, OAM shall notify the Permittee within thirty (30) days, if the corrective actions taken are deficient. The Permittee shall submit a description of additional corrective actions taken to IDEM, OAM within thirty (30) days of receipt

of the notice of deficiency. IDEM, OAM reserves the authority to use enforcement activities to resolve noncompliant stack tests. (b) A

retest to demonstrate compliance shall be performed within one hundred twenty (120) days of receipt of the original test results. Should the Permittee demonstrate to IDEM, OAM that retesting in one-hundred and twenty (120) days is not practicable, IDEM, OAM may extend the retesting deadline. Failure of the second test to demonstrate compliance with the appropriate permit

conditions may be grounds for immediate revocation of the permit to operate the affected emissions unit. The documents submitted pursuant to this condition do not require the certification by the “authorized individual” as defined by 326 IAC 2-1.1-1. Record Keeping and Reporting Requirements C.14 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 of326 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).Roembke Manufacturing and Design Page 12 of 26

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(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.15 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 C- Performance 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) Asan 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) Atits 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.16 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 maybe stored elsewhere for the remaining two (2) years as long as they are available upon request. If the Commissioner makes a written request for records to the 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.Roembke Manufacturing and Design Page 13 of 26

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(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: workorders, 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 brieflydescribe 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.17 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 permi t the source shall submit a Semi-annual Compliance Monitoring Report. Any deviation from the requirements and the date(s) of each deviation must be reported. The Compliance Monitoring Report shall include the certification by the “authorized individual” as defined by 326 IAC 2-1.1-1(1). (b) The report required in (a) of this condition and reports required by conditions in Section D of this permit shall be submitted to: Indiana Department of Environmental Management Compliance Data Section, Office of Air Management 100 North Senate Avenue, P. O. Box 6015 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 semi-annual 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 isan exceedance of a permit limitation or a failure to comply with a requirement of the permit or a rule. It does not include:Roembke Manufacturing and Design Page 14 of 26

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(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.
APermittee’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 this permit becomes a Minor Source Operating Permit and ending on the last day of the reporting period. C.18 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 notthe 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 achievecompliance and the date compliance was, or will be, achieved. The notification must be signed by an authorized individual. (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.Roembke Manufacturing and Design Page 15 of 26

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SECTION D.1 EMISSIONS UNIT OPERATION CONDITIONS Emissions Unit Description: (a) One (1) chrome plating tank, identified as Tank 1, controlled with a composite mesh pad system, and exhausting to stack S/V 1, maximum cumulative rectifier capacity: 29,400,000 ampere hours per year. (b) One (1) chrome plating tank, identified as Tank 2, controlled with a composite mesh pad system, and exhausting to stack S/V 1, maximum cumulative rectifier capacity: 11,760,000 ampere hours per year. (c) One (1) space heater, identified as H1, fired by natural gas, heat input capacity: 0.125 million British thermal units per hour. (d) One (1) space heater, identified as H2, fired by natural gas, heat input capacity: 0.1 million British thermal units per hour. (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 [326 IAC 2-6.1-5(1)]
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 by reference as 326 IAC 20-1-1, apply to the facility described in this section except when otherwise specified in 40 CFR Part 63, Subpart N. The Permittee shall comply with the requirements of this condition on and after the compliance date for the tanks.
D.1.2 Chromium Electroplating and Anodizing NESHAP [326 IAC 20-8-1] [40 CFR Part 63, Subpart N] The provisions of 40 CFR 63, Subpart N - National Emission Standards for Chromium Emissions From Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks, which are incorporated by reference as 326 IAC 20-8-1, apply to Tanks 1 and 2. A copy of this rule is attached. The Permittee shall comply with the requirements of this condition on and after the compliance date for the tanks. D.1.3 Chromium Emissions Limitation [40 CFR 63.342(c)] [40 CFR 63.343(a)(1)&(2)] (a) 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 tanks subject to 326 IAC 20-8-1. The emission limitations do not apply during periods of malfunction. (b) The hard chromium electroplating tanks, identified as Tank 1 and Tank 2, above, are considered a small, new hard chromium electroplating operation. During tank operation, the Permittee shall control chromium emissions discharged to the atmosphere from the tanks by not allowing the concentration of total chromium in the exhaust gas stream discharged to the atmosphere to exceed 0.015 mg/dscm [6.6x10 -6gr/dscf].
D.1.4 Work Practice Standards [40 CFR 63.342(f)] The following work practice standards apply to Tanks 1 and 2:Roembke Manufacturing and Design Page 16 of 26

Ossian, Indiana MSOP 179-11704-00027 Permit Reviewer:MES
(a) At all times, including periods of startup, shutdown, malfunction and excess emissions, the Permittee shall operate and maintain Tanks 1 and 2, including the composite mesh pad system and monitoring equipment, in a manner consistent with good air pollution control practic es, consistent with the Operation and Maintenance Plan (OMP) required by Condition D.1.6. (b) Malfunctionsand excess emissions shall be corrected as soon as practicable after their occurrence in accordance with the OMP required by Condition D.1.6. (c) These operation and maintenance requirements are enforceable independent of emissions limitations or other requirements in this section. (d) 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. (e) Based on the results of a determination made under paragraph (d) of this condition, IDEM, OAM may require that the Permittee make changes to the OMP required by Condition D.1.6. Revisions may be required if IDEM, OAM finds that the plan: (1) Does not address a malfunction or period of excess emissions that has occurred; (2) Failsto provide for the operation of Tanks 1 and 2, 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 (3) Does not provide adequate procedures for correcting malfunctioning process equipment, composite mesh pad system, monitoring equipment or other causes of excess emissions as quickly as practicable. For Tanks 1 and 2, the Permittee shall comply with the requirements of this condition on and after the start-up date of each tank. The work practice standards that address operation and maintenance must be followed during malfunctions and periods of excess emissions. D.1.5 Preventive Maintenance Plan [326 IAC 1-6-3] A Preventive Maintenance Plan (PMP), in accordance with Condition C.2 - Preventive Maintenance Plan, of this permit, is required for the Tanks 1 and 2 and the composite mesh pad system. D.1.6 Operation and Maintenance Plan [40 CFR 63.342(f)(3)] (a) The Permittee shall prepare an Operation and Maintenance Plan (OMP) to be implemented nolater than the startup date of Tanks 1 and 2. The OMP shall specify the operation and maintenance criteria for the tanks, the composite mesh pad system and monitoring equipment and shall include the following elements: For the composite mesh-pad system (CMP): (1) Quarterly

visual inspections of the device to ensure there is proper drainage, no chromicacid buildup on the pads, and no evidence of chemical attack on the structural integrity of the device.Roembke Manufacturing and Design Page 17 of 26

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(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 duct work from the tank to the control device to ensure there are no leaks. (4) Perform washdown of the composite mesh-pads in accordance with manufacturers recommendations. (b) 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.1.5, as the OMP, provided the alternative plans meet the above listed criteria in Condition D.1.6(a). (c) If

the OMP fails to address or inadequately addresses an event that meets the characteristicsof a malfunction or period of excess emissions at the time the plan is initially developed, the Permittee shall revise the OMP within forty-five (45) days after such an eventoccurs. The revised plan shall include procedures for operating and maintaining Tanks1 and 2, the air pollution control device, the add-on air pollution control device and the monitoring equipment, during similar malfunction or period of excess emissions events, and a program for corrective action for such events. (d) If

actions taken by the Permittee during periods of malfunction or period of 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) 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 Tanks 1 and 2 or until the tank is 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 OMPs 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. Compliance Determination Requirements [326 IAC 2-1.1-11]
D.1.7 Performance Testing [326 IAC 2-1.1-11] [40 CFR 63.343(b)(1)] [40 CFR 63.343(b)(2)] [40 CFR 63.7] [40 CFR 63.344] (a) The Permittee is required to conduct an initial performance test within 180 days after startup of Tanks 1 and 2 using the procedures and methods in 40 CFR 63.344 and 40 CFR 63.7 and in accordance with Section C - Performance Testing. (b) The Permittee is not required to further test Tanks 1 and 2 by this permit. However, the IDEM may require testing when necessary to determine if the tanks are in compliance. If testing is required by the IDEM, compliance with the limits specified in Condition D.1.3 shall be determined by a performance test conducted in accordance with 40 CFR 63.344 and Section C - Performance Testing. (c) Any

change, modification, or reconstruction of Tanks 1 and 2, the composite mesh pad system or monitoring equipment may require additional performance testing conducted in accordance with 40 CFR 63.344 and Section C - Performance Testing.Roembke Manufacturing and Design Page 18 of 26

Ossian, Indiana MSOP 179-11704-00027 Permit Reviewer:MES

D.1.8 Establishing Site-Specific Operating Parameter Values [40 CFR 63.343(c)] [40 CFR 63.344(d)] During the initial performance test and pursuant to 40 CFR 63.343(c)(1)(i), when using a composite mesh-pad system to comply with the limits specified in Condition D.1.3, the Permittee shall determine the outlet chromium concentration using the test methods 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 applicable emission limitation using the procedures in 40 CFR 63.344(d)(4) and (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 test runs of one performance test, and accept ±1 inch of water column from this value as the compliant range. Compliance Monitoring Requirements [326 IAC 2-5.1-3(e)(2)] [326 IAC 2-6.1-5(a)(2)] D.1.9 Monitoring to Demonstrate Continuous Compliance [326 IAC 2-5.1-3(e)(2)] [326 IAC 2-6.1-5(a)(2)] (a) Pursuant

to 40 CFR 63.343(c)(1)(ii), when using a composite mesh-pad system to comply with the limits specified in Condition D.1.3, the Permittee shall monitor and record the pressure drop across the composite mesh-pad system during tank operation once each day that the hard chromium electroplating tank is operating. 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) Tankoperation or operating time is defined as that time when a part is in the tank and the rectifier is turned on. If the amount of time that no part is in the tank is fifteen minutes or longer, that time is not considered operating time. Likewise, if the amount of time between placing parts in the tank (i.e., when no part is in the tank) is less than fifteen minutes, that time between plating the two parts is considered operating time. Record Keeping and Reporting Requirements [326 IAC 2-5.1-3(e)(2)] [326 IAC 2-6.1-5(a)(2)] D.1.10 Record Keeping Requirements [326 IAC 2-5.1-3(e)(2)] [40 CFR 63.346] The Permittee shall maintain records to document compliance with Conditions D.1.3, D.1.4 and D.1.6 using the forms provided with this permit. These records shall be maintained in accordance with Section C - 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 documentthat the inspection and maintenance required by Conditions D.1.7 and D.1.9 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 Tanks 1 and 2, the composite mesh pad system and monitoring equipment.Roembke Manufacturing and Design Page 19 of 26

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(c) Records of the occurrence, duration, and cause (if known) of each malfunction of Tanks 1 and 2, the composite mesh pad system and monitoring equipment. (d) Records of the occurrence, duration, and cause (if known) of each period of excess emissions of Tanks 1 and 2, the composite mesh pad system and monitoring equipment as indicated by monitoring data collected in accordance with this condition. (e) Records of actions taken during periods of malfunction or excess emissions when such actions are inconsistent with the OMP. (f) Othe r records, which may take the form of checklists, necessary to demonstrate consistency with the provisions of the OMP. (g) Test reports documenting results of all performance tests. (h) All measurements as may be necessary to determine the conditions of performance tests, including measurements necessary to determine compliance. (i) 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. (j) The total process operating time, as defined in Condition D.1.9(b), of each tank, during the reporting period. (k) Records of the actual cumulative rectifier capacity of each hard chromium electroplating tankexpended during each month of the reporting period, and the total capacity expended to date for a reporting period. (l) All documentation supporting the notifications and reports required by 40 CFR 63.9 and 63.10 (Subpart A, General Provisions) and by Condition D.1.11.
D.1.11 Reporting Requirements [326 IAC 2-5.1-3(e)(2)] [326 IAC 3-6-4(b)] [40 CFR 63.344(a), 63.345 and 63.347] The notifications and reports required in this section shall be submitted to IDEM, OAM using the address specified in Section C - General Reporting Requirements. (a) Notifications: (1) Initial Notifications The Permittee shall submit an Initial Notification for each new or reconstructed tank as follows: (A) A notification of the actual dates when construction of Tanks 1 and 2 commenced shall be submitted no later than thirty (30) days after such dates. (B) A

notification of the actual date of startup of Tanks 1 and 2 shall be submitted within thirty (30) days after such date. (2) Notification of Performance Test The Permittee shall notify IDEM, OAM in writing of their intention to conduct a performance test at least sixty (60) days before the test is scheduled to begin. (A) Pursuant

to Section C - Performance Testing, a test protocol shall be sub-Roembke Manufacturing and Design Page 20 of 26

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mitted no later than thirty-five (35) days prior to the intended test date. (B) 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 Section C - Performance Testing, the rescheduled performance test date shall be no sooner than fourteen (14) days after IDEM, OAM is notified in writing of the need to reschedule. (3) A

Notification of Compliance Status (NCS) is required each time that the facility becomes subject to the requirements of 40 CFR Part 63 Subpart N. (A) The NCS shall be submitted to IDEM, OAM, and shall list, for each tank, the information identified in 40 CFR 63.347(e)(2). (B) The NCS for Tanks 1 and 2 shall be submitted to IDEM, OAM no later than forty-five(45) days following completion of the compliance demonstration pursuant to Section C - Performance Testing. (4) Notification of Construction or Reconstruction Pursuant to 40 CFR 63.345(b)(1), the Permittee may not construct a new tank subjectto 40 CFR 63, Subpart N (including non-affected tanks defined in 40 CFR 63.344(e))without submitting a Notification of Construction or Reconstruction (NCR)to IDEM, OAM. In addition, the Permittee may not change, modify, or reconstructTanks 1 and 2 without submitting a Notification of Construction or Reconstruction (NCR) to IDEM, OAM. (A) The NCR shall contain the information identified in 40 CFR 63.345(b) (2) and (3). (B) A change, modification, or reconstruction of this facility includes any change in the air pollution control techniques, the addition of add-on control devices, or the construction of duct work for the purpose of controlling both existing tanks and non-affected facilities by a common control technique or device [i.e., the addition of duct work to the CMP system]. (C) A

complete application to construct new chromium electroplating or chromium anodizing tanks serves as this notification. Likewise, the complete application to modify or reconstruct Tanks 1 and 2 serves as this notification. (D) Pursuant

to 326 IAC 2-1.1-2(a), permission must be received from IDEM, OAM before construction, modification, or reconstruction may commence.Roembke Manufacturing and Design Page 21 of 26

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(b) Performance Test Results The Permittee shall document results from the initial performance test and any future performance tests in a complete test report that containsthe information required in 40 CFR 344(a). The Permittee shall submit reports of performance test results as part of the Notification of Compliance Status, described in 40 CFR 63.347(e), no later than forty-five (45) days following the completion of the performance test. (c) Ongoing Compliance Status Report The Permittee shall prepare summary reports to document the ongoing compliance status of Tanks 1 and 2 using the Ongoing Compliance Status Report form provided with this permit. This report shall contain the information specified in 40 CFR 63.347(g)(3). Because Tanks 1 and 2 are located at site that is an area source of hazardous air pollutants (HAPs), 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 (c)(2). (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.1.9(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.1.9(b). Once the Permittee reports an exceedance as defined above, Ongoing Compliance StatusReports shall be submitted semiannually until a request to reduce reporting frequency in accordance with 40 CFR 63.347(g)(2) is approved. (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.Roembke Manufacturing and Design Page 22 of 26

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### INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR MANAGEMENT COMPLIANCE DATA SECTION MINOR SOURCE OPERATING PERMIT CHROMIUM ELECTROPLATING AND ANODIZING NESHAP ONGOING COMPLIANCE STATUS REPORT Source Name: Roembke Manufacturing and Design Source Address: 1580 Baker Drive, Ossian, Indiana 46777 Mailing Address: 1580 Baker Drive, Ossian, Indiana 46777 MSOP No.: 179-11704-00027 Tank ID #: Type of process: Hard Chromium Electroplating Monitoring Parameter: Pressure drop across the composite mesh pad system Parameter Value: Limits: Total chromium in the exhaust gas stream discharged to the atmosphere shall not exceed 0.015 mg/dscm [6.6x10 -6gr/dscf] This form is to be used to report compliance for the Chromium Electroplating and Anodizing NESHAP only. The frequency for completing this report may be altered by IDEM, OAM, Compliance Branch. Companies classified as a major source : submit this report no later than 30 days after the end of the reporting period. Companies classified as an area source : 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 DECRoembke Manufacturing and Design Page 23 of 26

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### CHROMIUM ELECTROPLATING AND ANODIZING 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 to complete this report. MALFUNCTION REPORT
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENTRoembke Manufacturing and Design Page 24 of 26

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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 ?_____, 25TONS/YEAR SULFUR DIOXIDE ?_____, 25 TONS/YEAR NITROGEN OXIDES ?_____, 25TONS/YEAR VOC ?_____, 25 TONS/YEAR HYDROGEN SULFIDE ?_____, 25 TONS/YEAR TOTAL REDUCED SULFUR ?_____, 25 TONS/YEAR REDUCED SULFUR COMPOUNDS ?_____, 25 TONS/YEAR FLUORIDES ?_____, 100 TONS/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 ELEMENTALLEAD ?_____, 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: Roembke Manufacturing and Design PHONE NO. : 219 - 622 - 4135 LOCATION: (CITY AND COUNTY) Ossian / Wells PERMIT NO. 179-11704 AFS PLANT ID: 179-00027 AFS POINT ID: INSP: CONTROL/PROCESS DEVICE WHICH MALFUNCTIONED AND REASON: DATE/TIME MALFUNCTION STARTED: ______/______/ 20_____ AM / PM ESTIMATED HOURS OF OPERATION WITH MALFUNCTION CONDITION:
DATE/TIME CONTROL EQUIPMENT BACK-IN SERVICE______/______/ 20____ 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 SHUTDO WN DURING REPAIRS:
CONTINUED OPERATION REQUIRED TO PROVIDE ESSENTIAL * SERVICES: CONTINUED OPERATION NECESSARY TO PREVENT INJURY TO PERSONS: CONTINUED OPERATION NECESSARY TO PREVENT SEVERE DAMAGE TO EQUIPMENT: INTERIM CONTROL MEASURES: (IF APPLICABLE)
MALFUNCTION REPORTED BY: __________________________________ TITLE: (SIGNATURE IF FAXED) MALFUNCTION RECORDED BY: ______________________ DATE: _________________ TIME: *SEE PAGE 2 PAGE 1 OF 2 Please note - This form should only be used to report malfunctions

applicable to Rule 326 IAC 1-6 and to qualify forRoembke Manufacturing and Design Page 25 of 26

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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 servicesare 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 2INDIANA 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: Roembke Manufacturing and Design
Address: 1580 Baker Drive City: Ossian
Phone #: (219) 622-4135
MSOP #: 179-11704-00027
I hereby certify that Roembke Manufacturing and Design is 

### 9 still in operation. 

### 9 no longer in operation. I hereby certify that Roembke Manufacturing and Design is 

### 9 in compliance with the requirements of MSOP 179-11704-00027. 

### 9 not in compliance with the requirements of MSOP 179-11704- 00027. 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:Page 1 of 4



## Indiana Department of Environmental Management

Office of Air Management Addendum to the Technical Support Document for New Construction and Operation
Source Name: Roembke Manufacturing and Design Source Location: 1580 Baker Drive, Ossian, Indiana 46777 County: Wells Construction Permit No.: MSOP 179-11704-00027 SIC Code: 3470 Permit Reviewer: CarrieAnn Ortolani On April 24, 2000, the Office of Air Management (OAM) had a notice published in the Bluffton News Banner, Bluffton, Indiana, stating that Roembke Manufacturing and Design had applied for a construction permitto construct and operate stationary small, hard chromium electroplating source with composite mesh pad systems as controls. 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 permit and other documentation. Finally, thenotice 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 May 8, 2000, Evelyn B. Crooks of Environmental Compliance Source, Ltd., submitted comments on theproposed construction permit. The summary of the comments and corresponding responses are as follows: The permit language, if changed, has deleted language as strikeouts and new language bolded.

Comment 1: Condition A.1 - The authorized individual is Martin F. Adam, Jr. Mr. Adam signed the permit application. Response 1: Section A.1 has been revised as follows: A.1 General Information [326 IAC 2-5.1-3(c)] [326 IAC 2-6.1-4(a)] The Permittee owns and operates stationary small, hard chromium electroplating source.
Authorized Individual: Jim Steffen Martin F. Adam, Jr. Source Address: 1580 Baker Drive, Ossian, Indiana 46777 Mailing Address: 1580 Baker Drive, Ossian, Indiana 46777 Phone Number: 219 - 622 - 4135 SIC Code: 3470 County Location: Wells 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

Comment 2: Condition C.16(d) - Roembke interprets this condition as taking effect when the tank operations begin, not on the date of permit issuance.Roembke Manufacturing and Design Page 2 of 4

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Response 2: As indicated in Condition C.16 (d), all record keeping requirements not already legally required shall be implemented when operation begins. Comment 3: Condition C.17 - This condition contradicts Condition D.1.11(c)(1) and the TSD. Roembke is required tocomplete an annual Ongoing Compliance Status Report (OCSR) unless excess emissions or malfunctions exceed the time limits in D.1.11(c)(2). Roembkerequests confirmation that this report replaces the OCSR previously filed under the NESHAPrule. If this report does not replace the earlier one, Roembke will not accept a duplicate requirement as a permit condition. Response 3: The Semi-annual Compliance Monitoring Report is a separate report from the Ongoing Compliance Status Report. The Semi-annual Compliance Monitoring Report is used to affirm that the source has met all of the compliance monitoring requirements by reporting any deviation from the requirements and the date(s) of each deviation

. This is report is submitted to IDEM semi-annually. The Ongoing Compliance Status Report documents the ongoing compliance status of Tanks 1 and 2 using the Ongoing Compliance Status Report form provided with the permit

. The Ongoing Compliance Status Reportis only submitted to IDEM, OAM, when 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.1.9 (b) for the reporting period; or 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 asdefined in Condition D.1.9(b). Once the Permittee reports an exceedance as defined above, Ongoing Compliance Status Reports shall be submitted semi-annually until a request to reduce reporting frequency in accordance with 40 CFR 63.347(g)(2) is approved. Otherwise, the Ongoing Compliance Status Reportis kept on site and made available to IDEM upon request. The Ongoing Compliance Status Reportsmay contain some information from the Semi-annual Compliance Monitoring Report. Comment 4: Condition C.17(g) - Roembkeinterprets this condition as the first report period commencing on the date when tank operations begin, not the date of permit issuance. This is a construction permit as well as an MSOP. Response 4: This conditions will become effective when the permit becomes a Minor Source Operating Permit as described by Condition B.6. Condition C.17(g) has been revised as follows: (g) The first report shall cover the period commencing on the date of issuance of

this permit becomes a Minor Source Operating Permit and ending on the last day of the reporting period. Comment 5: Condition D.1.5 - The Preventive Maintenance Plan requirement is in Section C.2, not Section B.Roembke Manufacturing and Design Page 3 of 4

Ossian, Indiana MSOP 179-11704-00027 Permit Reviewer:MES

Response 5: D.1.5 Preventive Maintenance Plan [326 IAC 1-6-3] A Preventive Maintenance Plan (PMP), in accordance with Section B Condition C.2 - Preventive Maintenance Plan, of this permit, is required for the Tanks 1 and 2 and the composite mesh pad system. Comment 6: Condition D.1.11(a)(1) - Roembke requests clarification of the Initial Notifications. Is this in addition toor instead of the Affidavit of Construction? If it is an additional notification, Roembke objects to the burden of unnecessary and redundant reports. Response 6: The Initial Notifications in Condition D.1.11(a)(1) are required by 40 CFR 63.344(a), 63.345 and 63.347. The Affidavit of Construction is required by 326 IAC 2-5.1-3(h). Pursuant to 326 IAC 2-5.1- 3(i)(1), a source may operate upon submission of an affidavit of construction that affirms that the sourceis described by, and will comply with, the construction permit as issued or previously amended. Therefore, there are no changes to the permit as a result of this comment. Comment 7: Condition D.1.11(a)(3) - What is the format for the NCS report: How does it differ from the performance test results required in Condition C.9? Response 7: Thereis no set format for the NCS provided it lists, for each tank, the information identified in 40 CFR 63.347(e)(2). As indicated in Condition C.9, Condition D.1.11(a)(3) and Condition D.1.11(b), all test reports must be received by IDEM, OAM, within forty-five (45) days after the completion of the testing. The test report required by Condition C.9 is the same as that required by Conditions D.1.11(a)(3) and D.1.11(b). Therefore, the Permittee can comply with all three (3) conditions by submitting one report, with testing for each tank. Comment 8: Condit ion D.1.11(a)(4) - Roembke requests that equivalent language to provide Operational Flexibility [as defined in 326 IAC 2-8-15(b) through (d)] be added. This flexibility is as important (if not more so) to a minor source permit holder as it is to a FESOP permit holder. Response 8: The operational flexibility given to sources with Federally Enforceable State Operating Permits (FESOPs) by 326 IAC 2-8-15(b) and (c)only apply to FESOP sources because of the source-wide emission limitations in the FESOP. Since there are no emission limitations in this permit and this is nota FESOP, these rules cannot be applicable. There were no alternate operating scenarios indicated in the permit application and this is not a FESOP source. Therefore, 326 IAC 2-8-15(d) also cannot be applicable. Comment 9: Condition D.1.11(b) - Please see the related comment at D.1.11(a)(3). Roembke requests clarification regarding those items (in addition to the performance test results) that are required in the NCS.Roembke Manufacturing and Design Page 4 of 4

Ossian, Indiana MSOP 179-11704-00027 Permit Reviewer:MES

Response 9: See Response 7. Comment 10: Condition D.1.11(c)(1) - Please see the related comment to Condition C.17 above. Response 10: See Response 3. Comment 11: General Comment - The reporting and documentation requirements of this permit are a major burden totally out of proportion with the source's potential to emit. Response 11:
All Conditions in the permit are necessary for the source to comply with the requirements of 326 IAC 2-5.1-3, Permits, and 326 IAC 2-6.1, Minor Source Operating Permit. Nearly all of the requirements areindependently required by 40 CFR 63, Subpart N - National Emission Standards for Chromium Emissions From Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks

. The high toxicity of this regulated pollutant results in significant health impacts in the many communities of Indiana located near sources of chromium mist. IDEM is unaware of any information that contradicts studies released by U.S. EPA that link exposure to chromium in the ambientair with cancer. IDEM believes there is valid justification for requiring these sources of airborne hexavalent chromium to obtain a Minor Source Operating Permit (MSOP). IDEM’s MSOP requirement

for chrome sources provides a simpler and cheaper permit process than the Title V permitting process. To sustain the effectiveness of Indiana’s compliance assistance program for chromium emissions isIDEM’s goal. A single reference document readily available to all interested parties that explains all major site-specific requirements should minimize future confusion. It will help to ensure that noncompliance is minimized.

Upon further review, the OAM has decided to make the following change to the construction permit: The permit language is changed to read as follows (deleted language appears as strikeouts , new language is bolded) : Condition D.1.9 (b) is revised as follows: Tankoperation or operating time is defined as that time when a part is in the tank and the rectifier is turned on. If the amount of time that no part is in the tankis fifteen minutes or longer, that time isnot considered operating time. Likewise, if the amount of time between placing parts in the tank (i.e., when no part is in the tank) is less that than fifteen minutes, that time between plating the two parts is considered operating time.Page 1 of 7



## Indiana Department of Environmental Management

Office of Air Management Technical Support Document (TSD) for a New Source Construction and Minor Source Operating Permit Source Background and Description Source Name: Roembke Manufacturing and Design Source Location: 1580 Baker Drive, Ossian, Indiana 46777 County: Wells SIC Code: 3470 Operation Permit No.: MSOP 179-11704-00027 Permit Reviewer: CarrieAnn Ortolani
The Office of Air Management (OAM) has reviewed an application from Roembke Manufacturing and Design relating to the construction and operation of a small, hard chromium electroplating source. Permitted Emission Units and Pollution Control Equipment There are no permitted emission units at this source. Unpermitted Emission Units and Pollution Control Equipment There are no unpermitted facilities operating at this source during this review process. New Emission Units and Pollution Control Equipment The source consists of the following new emission units and pollution control devices: (a) One (1) chrome plating tank, identified as Tank 1, controlled with a composite mesh pad system, and exhausting to stack S/V 1, maximum cumulative rectifier capacity: 29,400,000 ampere hours per year. (b) One (1) chrome plating tank, identified as Tank 2, controlled with a composite mesh pad system, and exhausting to stack S/V 1, maximum cumulative rectifier capacity: 11,760,000 ampere hours per year. (c) One (1) space heater, identified as H1, fired by natural gas, heat input capacity: 0.125 million British thermal units per hour. (d) One (1) space heater, identified as H2, fired by natural gas, heat input capacity: 0.1 million British thermal units per hour.Roembke Manufacturing and Design Page 2 of 7

Ossian, Indiana MSOP 179-11704-00027 Permit Reviewer:MES
Existing Approvals There are no existing approvals for this source. Stack Summary

Stack ID Operation Height (feet) Diameter

(feet) Flow Rate

(acfm) Temperature

( E F) S/V 1 Chrome Plating Tanks

1 and 2 20.0 1.17 N/A 68

Enforcement Issue There are no enforcement actions pending. Recommendation The staff recommends to the Commissioner that the operation be approved. This recommendation is based on the following facts and conditions: Unless otherwise stated, information used in this review was derived from the application and additional information submitted by the applicant.
A complete application for the purposes of this review was received on December 28, 1999. A letter was received on March 27, 2000 indicating that the source is moving to the location in this permit. Therefore, the source is being permitted as a new minor source. Emission Calculations Chromium emissions (single HAP) from the biggest chromium electroplating source in Indiana are lessthan ten (10) tons per year and Roembke Manufacturing and Design is a much smaller source in comparison. Therefore, no emission calculations were necessary for the chromium electroplating because the chromium emissions from this source will be less than ten (10) tons per year. See AppendixA (pages 1 and 2 of 2) of this document for detailed emissions calculations for natural gas combustion. Potential To Emit Pursuantto 326 IAC 2-1.1-1(16), Potential to Emit is defined as “the maximum capacity of a stationary source or emissions unit to emit any air pollutant under its physical and operational design. Any physical or operational limitation on the capacity of a source to emit an air pollutant, including air po llution control equipment and restrictions on hours of operation or type or amount of material combusted, stored, or processed shall be treated as part of its design if the limitation is enforceable by the U. S. EPA, the department, or the appropriate local air pollution control agency.”
Pollutant Potential To Emit (tons/year) PM 0.002 PM 10 0.007 SO 2 0.001Roembke Manufacturing and Design Page 3 of 7

Ossian, Indiana MSOP 179-11704-00027 Permit Reviewer:MES

Pollutant Potential To Emit (tons/year) VOC 0.005 CO 0.083 NO X 0.099

HAPs Potential To Emit (tons/year) Chromium less than 10 TOTAL less than 25 (a) The potential to emit (as defined in 326 IAC 2-7-1(29)) of each pollutant is less than 100 tons per year. Therefore, the source is not subject to the provisions of 326 IAC 2-7. (b) The potential to emit (as defined in 326 IAC 2-7-1(29))of any single HAP is less than ten (10)tons per year and the potential to emit (as defined in 326 IAC 2-7-1(29)) of a combination HAPS is less than twenty-five (25) tons per year. Therefore, the source is not subject to the provisions of 326 IAC 2-7. (c) The new source is subject to 326 IAC 20-8 but not subject to 326 IAC 2-5.5-1(b)(2), Registration, because the source is not a decorative coating plant. The source is a hard chromium electroplating source and the source emits less than major source levels (see (a) and (b) above). Therefore, the source is subject to the provisions of 326 IAC 2-5.1-3(a)(2) (A) and 326 IAC 2-6.1-3(a). Actual Emissions No previous emission data has been received from the source. Limited Potential to Emit The table below summarizes the total potential to emit, reflecting all limits, of the significant emission units.

Limited Potential to Emit (tons/year) Process/facility PM PM 10 SO 2 VOC CO NO X HAPs Chromium Electroplating 0.00 0.00 0.00 0.00 0.00 0.00 < 10
Space Heating 0.002 0.007 0.001 0.005 0.083 0.099 0.002 Total Emissions 0.002 0.007 0.001 0.005 0.083 0.099 < 10Roembke Manufacturing and Design Page 4 of 7

Ossian, Indiana MSOP 179-11704-00027 Permit Reviewer:MES
County Attainment Status The source is located in Wells County.
Pollutant Status PM 10 attainment SO 2 attainment NO 2 attainment Ozone attainment CO attainment Lead attainment (a) Volatile organic compounds (VOC) and oxides of nitrogen are precursors for the formation of ozone. Therefore, VOC and NO X emissions are considered when evaluating the rule applicability

relating to the ozone standards. Wells County has been designated as attainmentfor ozone. Therefore, VOC and NO X emissions were reviewed pursuant to the requirements for PSD, 326 IAC 2-2 and 40 CFR 52.21. (b) Wells County has been classified as attainment or unclassifiable for all other criteria pollutants. Therefore, these emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2 and 40 CFR 52.21. (c) Fugitive Emissions Since this type of operation is not one of the 28 listed source categories under 326 IAC 2-2, 40 CFR 52.21, or 326 IAC 2-3 and since there are no applicable New Source Performance Standardsthat were in effect on August 7, 1980, the fugitive particulate matter (PM) and volatile organic compound (VOC) emissions are not counted toward determination of PSD and Emission Offset applicability. Source Status Existing Source PSD Definition (emissions after controls, based on 8,760 hours of operation per year at rated capacity and/ or as otherwise limited):
Pollutant Emissions (ton/yr) PM 0.002 PM 10 0.007 SO 2 0.001 VOC 0.005 CO 0.083 NO X 0.099Roembke Manufacturing and Design Page 5 of 7

Ossian, Indiana MSOP 179-11704-00027 Permit Reviewer:MES
(a) This existing source is not a major stationary source because no attainment regulated pollutant is emitted at a rate of 250 tons per year or more, and it is not in one of the 28 listed source categories. (b) These emissions were based on the potential to emit of the entire source. Part 70 Permit Determination 326 IAC 2-7 (Part 70 Permit Program) This new source is not subject to the Part 70 Permit requirements because the potential to emit (PTE) of: (a) each criteria pollutant is less than one hundred (100) tons per year, (b) a single hazardous air pollutant (HAP) is less than ten (10) tons per year, and (c) any combination of HAPS is less than twenty-five (25) tons/year. This is the first air approval issued to this source. Federal Rule Applicability (a) There are no New Source Performance Standards (NSPS)(326 IAC 12 and 40 CFR Part 60) applicable to this source. (b) Tanks1 and 2 are subject to the National Emission Standards for Hazardous Air Pollutants, 326 IAC 14, (40 CFR 63, Subpart N, and 326 IAC 20-1-1). A copy of this rule is attached. Pursuant to 40 CFR 63, Subpart N, and 326 IAC 20-1-1, the chromium electroplating operations are subject to the following conditions: (1) Emission limitation: The Permittee shall comply with the requirements of this condition on and after the compliance date for the tanks. The hard chromium electroplating tanks, identified as Tanks 1 and 2, are considered a small, new hard chromium electroplating operation. During tank operation, the Permittee shall control chromium emissions discharged to the atmosphere from the tanksby not allowing the concentration of total chromium in the exhaust gas stream discharged to the atmosphere to exceed fifteen-thousandth milligrams of total chromium per dry standard cubic meter of ventilation air (0.015 mg/dscm) [equivalentto six and six-tenths times ten raised to the power of negative six grains of total chromium per dry standard cubic foot of ventilation air (6.6x10 -6gr/dscf)]. (2) Monitoring Requirements: Pursuant to 40 CFR 63.343(c)(1)(ii), when using a composite mesh-pad system to complywith the limits specified above, the Permittee shall monitor and record the pressure drop across the composite mesh-pad system during tank operation once each day that the hard chromium electroplating tank is operating. 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.Roembke Manufacturing and Design Page 6 of 7

Ossian, Indiana MSOP 179-11704-00027 Permit Reviewer:MES

(3) Reporting Requirements: A summary report shall be prepared to document the ongoing compliance status of the chromium electroplating operation. This report shall be completed annually, retained on site, and made available to IDEM upon request. If there are significant exceedan ce of chromium air emission limits (as defined in 40 CFR Part 63.347 (h)(2)), then semiannual reports shall be submitted to: Indiana Department of Environmental Management Air Compliance Branch, Office of Air Management Chromium Electroplating 100 North Senate Avenue, P.O. Box 6015 Indianapolis, Indiana 46206 (4) The chromium electroplating operations shall be subject to the record keeping and reporting requirement as indicated in the chromium electroplating NESHAP. State Rule Applicability - Entire Source 326 IAC 2-6 (Emission Reporting) This source is located in Wells County and the potential to emit VOC and NO X is less than one hundred (100) tons per year. The potential to emit PM 10is less than one-hundred (100) tons per year. Therefore, 326 IAC 2-6 does not apply. 326 IAC 5-1 (Opacity Limitations) Pursuant to 326 IAC 5-1-2 (Opacity Limitations), except as provided in 326 IAC 5-1-3 (Temporary alternativeopacity limitations), opacity shall meet the following, unless otherwise stated in this permit: (a) Opacity

shall not exceed an average of forty percent (40%) 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. State Rule Applicability - Individual Facilities There are no state rules applicable to individual facilities at this source. Air Toxic Emissions Indiana presently requests applicants to provide information on emissions of the 188 hazardous air pollutants(HAPs) set out in the Clean Air Act Amendments of 1990. These pollutants are either carcinogenicor otherwise considered toxic and are commonly used by industries. They are listed as air toxics on the Office of Air Management (OAM) Construction Permit Application Form Y. This source will emit levels of air toxics less than those which constitute a major source according to Section 112 of the 1990 Clean Air Act Amendments.Roembke Manufacturing and Design Page 7 of 7

Ossian, Indiana MSOP 179-11704-00027 Permit Reviewer:MES

Conclusion
The operation of this chromium electroplating source shall be subject to the conditions of the attached proposed Minor Source Operating Permit 039-11719-00413.Appendix A: Emissions Calculations Page 1 of 2 TSD App A Natural Gas Combustion Only MM BTU/HR <100 Two (2) Space Heaters Company Name: Roembke Manufacturing and Design Address City IN Zip: 1580 Baker Drive, Ossian, Indiana 46777

MSOP: 179-11704 Plt ID: 179-00027 Reviewer: CarrieAnn Ortolani Date: February 23, 2000

Heat Input Capacity Potential Throughput MMBtu/hr MMCF/yr

0.23 1.97

Pollutant PM* PM10* SO2 NOx VOC CO Emission Factor in lb/MMCF 1.9 7.6 0.6 100.0 5.5 84.0 **see below Potential Emission in tons/yr 0.002 0.007 0.001 0.099 0.005 0.083 *PM emission factor is filterable PM only. PM10 emission factor is filterable and condensable PM10 combined. **Emission Factors for NOx: Uncontrolled = 100, Low NOx Burner = 50, Low NOx Burners/Flue gas recirculation = 32 Methodology All emission factors are based on normal firing. MMBtu = 1,000,000 Btu MMCF = 1,000,000 Cubic Feet of Gas Potential Throughput (MMCF) = Heat Input Capacity (MMBtu/hr) x 8,760 hrs/yr x 1 MMCF/1,000 MMBtu Emission Factors are from AP 42, Chapter 1.4, Tables 1.4-1, 1.4-2, 1.4-3, SCC #1-02-006-02, 1-01-006-02, 1-03-006-02, and 1-03-006-03 (SUPPLEMENT D 3/98) Emission (tons/yr) = Throughput (MMCF/yr) x Emission Factor (lb/MMCF)/2,000 lb/ton Note: Check the applicable rules and test methods for PM and PM10 when using the above emission factors to confirm that the correct factor is used (i.e., condensable included/not included). See page 2 for HAPs emissions calculations.Appendix A: Emissions Calculations Page 2 of 2 TSD App A Natural Gas Combustion Only MM BTU/HR <100 Two (2) Space Heaters HAPs Emissions Company Name: Roembke Manufacturing and Design Address City IN Zip: 1580 Baker Drive, Ossian, Indiana 46777

MSOP: 179-11704 Plt ID: 179-00027 Reviewer: CarrieAnn Ortolani Date: February 23, 2000

HAPs - Organics Benzene Dichlorobenzene Formaldehyde Hexane Toluene Emission Factor in lb/MMcf 2.1E-03 1.2E-03 7.5E-02 1.8E+00 3.4E-03

Potential Emission in tons/yr 2.070E-06 1.183E-06 7.391E-05 1.774E-03 3.351E-06

HAPs - Metals Lead Cadmium Chromium Manganese Nickel Emission Factor in lb/MMcf 5.0E-04 1.1E-03 1.4E-03 3.8E-04 2.1E-03

Potential Emission in tons/yr 4.928E-07 1.084E-06 1.380E-06 3.745E-07 2.070E-06

Methodology is the same as page 1. The five highest organic and metal HAPs emission factors are provided above. Additional HAPs emission factors are available in AP-42, Chapter 1.4.