STATIONARY SOURCE PERMIT TO INSTALL AND OPERATE 

This permit supersedes your permit dated July 21, 2004

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

Regulations for the Control and Abatement of Air Pollution, 

 Standex Engraving, LLC. 

 P.O. Box 38179 

 Richmond, Virginia 23231 

 Registration No.: 50838 

 County Plant ID No.: 087-0122 

is authorized to install and operate 

 a small chromium plating, chemical etching/laser engraving 

facility 

located at 

 5901 Lewis Road, Sandston, Virginia 23150

 

in accordance with the Conditions of this permit. 

Approved on June 18, 2008. 

______________________________________ 

Kyle I. Winter, P.E. 

Deputy Regional Director 

Permit consists of 10 pages. 

Permit conditions: 1 through 34. 
Standex Engraving, LLC. 

Registration No.: 50838 

June 18, 2008 

Page 2 

PERMIT CONDITIONS - the regulatory reference or authority for each condition is listed in 

parentheses ( ) after each condition. 

INTRODUCTION 

This permit approval is based on the permit application dated May 27, 2008, including 

amendment information dated April 27, 2007 and April 28, 2006. Any changes in the permit 

application specifications or any existing facilities which alter the impact of the facility on air 

quality may require a permit. Failure to obtain such a permit prior to construction may result in 

enforcement action. 

Words or terms used in this permit shall have meanings as provided in 9 VAC 5-10-10 of the 

State Air Pollution Control Board Regulations for the Control and Abatement of Air Pollution. 

The regulatory reference or authority for each condition is listed in parentheses () after each 

condition. 

Annual requirements to fulfill legal obligations to maintain current stationary source emissions 

data will necessitate a prompt response by the permittee to requests by the DEQ or the Board for 

information to include, as appropriate: process and production data; changes in control 

equipment; and operating schedules. Such requests for information from the DEQ will either be 

in writing or by personal contact. 

The availability of information submitted to the DEQ or the Board will be governed by 

applicable provisions of the Freedom of Information Act, §§ 2.2-3700 through 2.2-3714 of the 

Code of Virginia, § 10.1-1314 (addressing information provided to the Board) of the Code of 

Virginia, and 9 VAC 5-170-60 of the State Air Pollution Control Board Regulations. 

Information provided to federal officials is subject to appropriate federal law and regulations 

governing confidentiality of such information. 

PROCESS REQUIREMENTS

1. Equipment List – Permitted equipment to be operated at this facility consists of: 

Unit 

Ref. # 

FUEL BURNING Installed Process Max Rate 

Cap. 

B1 CYCLOTHERM C5200 BOILER –NG/#2 FUEL 

OIL 

1977 Steam 7.2 

MMBTU/hr 

B2 CYCLOTHERM C2800 BOILER –NG/#2 FUEL 

OIL 

1967 Steam 3.6 

MMBTU/hr 

- - - - - 

EMERGENCY GENERATORS

G1 KOHLER DIESEL GENERATOR 1990 - 400 kW 

G2 KOHLER DIESEL GENERATOR 1990 - 400 kW 

G3 GENERAC DIESEL GENERATOR 2004 - 375 kW 

- - - - - 

PRIMARY PROCESS EQUIPMENT
Standex Engraving, LLC. 

Registration No.: 50838 

June 18, 2008 

Page 3 

C1 CHROMIUM PLATING TANK- Existing based 

on 40 CFR 63 Subpart N 

1991 Tank 20,000 

Amps 

C2 CHROMIUM PLATING TANK- New based on 

40 CFR 63 Subpart N 

1995 Tank 12,000 

Amps 

C3 DULL CHROMIUM PLATING TANK - New 

based on 40 CFR 63 Subpart N 

2004 Tank 12,000 

Amps 

C4 CHROMIUM PLATING TANK - Existing based 

on 40 CFR 63 Subpart N 

1978 Tank 6,000 

Amps 

C5 CHROMIUM PLATING TANK - Existing based 

on 40 CFR 63 Subpart N 

1978 Tank 12,000 

Amps 

C6 CHROMIUM PLATING TANK - New based on 

40 CFR 63 Subpart N 

2004 Tank 2,000 

Amps 

B1-A&B BLAST ROOM – Two (2) Abrasive Blasters 2001 Blasting 500 lbs/hr. 

each

PB1 Paint Booth w/ 5 lbs/hr Spray Gun 2004 Paint 

Booth 

5 lbs/hr 

- - - - - 

GRAPHICS DEPARTMENT

N1 NICKEL TANK IN SMALL PLATING C1499 

T-1 

Existing Nickel 

plating 

Nickel 

N2 NICKEL TANK C1434/ASS'Y T-90 1/1/94 Nickel 

plating 

Nickel 

 (9 VAC 5-80-1100) 

2. Emission Controls – Chromium emissions from the chromium tanks (Ref. No. C1-C6) shall 

be controlled by scrubbers. The scrubber(s) shall be in operation when the chromium tank(s) 

are operational. Emissions shall also be controlled by good engineering practices, proper 

maintenance, and proper operation of each scrubber. Each scrubber shall be provided with 

adequate access for inspection. 

(9 VAC 5-50-260 and 40 CFR 63 Subpart N) 

3. Emission Controls – Particulate Matter (PM), PM-10 and VOC emissions from the Paint 

Booth (Ref. No. PB1) shall be controlled by filter bed system. The filter bed system shall be 

operating when the paint booth is in operation. The filter bed system shall be changed every 

two hundred and six (206) gallons of paint throughput. Emissions shall also be controlled by 

good engineering practices, proper maintenance, and proper operation of the carbon filter 

system. The system shall be provided with adequate access for inspection. 

(9 VAC 5-50-260) 

4. Emission Controls – Particulate Matter (PM) and PM-10 emissions from two (2) blasters in 

the Blast Room (Ref. No. B1-A and B1-B) shall be controlled by a cyclone with filter 

system. The cyclone shall be operating when the blasters are in operation. Emissions shall 

also be controlled by good engineering practices, proper maintenance, and proper operation 

of the cyclone. The cyclone shall be provided with adequate access for inspection. 

(9 VAC 5-50-260) 
Standex Engraving, LLC. 

Registration No.: 50838 

June 18, 2008 

Page 4 

5. Control Efficiency – Each chromium scrubber shall maintain control efficiency for 

chromium of no less than 98% efficiency. 

(9 VAC 5-50-260 and 40 CFR 63 Subpart N) 

6. Fugitive VOC Emission Controls - Fugitive emission controls shall include the following, 

or equivalent, as a minimum: 

a. Volatile organic compounds shall not be intentionally spilled, discarded to sewers, stored 

in open containers, or handled in any other manner that would result in evaporation 

beyond that consistent with air pollution control practices for minimizing emissions. 

b. All VOC containing receptacles shall be closed at all times except during loading and 

unloading.

c. VOC emissions shall be reduced by storing cleaning solutions and applicators in covered 

containers or machines with remote reservoirs when not in use. 

d. VOC emissions from rags or any other material used to for cleaning, printing machines, 

parts or other areas or used for quality control/quality assurance operations shall be 

minimized by disposal of the rags or other material in a closed container which shall be 

hauled off-site and disposed of properly, including recycling. 

(9 VAC 5-50-260 and 9 VAC 5-50-20) 

7. Monitoring Devices – Each scrubber monitoring device shall be installed, maintained, 

calibrated and operated in accordance with approved procedures which shall include, as a 

minimum, the manufacturer's written requirements or recommendations. Each monitoring 

device shall be provided with adequate access for inspection and shall be in operation when 

the scrubbers are in operation. 

(9 VAC 5-80-1180, 9 VAC 5-50-20 C, VAC 5-50-260 and 40 CFR 63 Subpart) 

8. Monitoring Devices – The cyclone for the blasting operation shall be equipped with a device 

to continuously measure the differential pressure. The monitoring device shall be installed, 

maintained, calibrated and operated in accordance with approved procedures which shall 

include, as a minimum, the manufacturer's written requirements or recommendations. The 

monitoring device shall be provided with adequate access for inspection and shall be in 

operation during blasting operations. 

(9 VAC 5-80-1180, 9 VAC 5-50-20 C, and 9 VAC 5-50-260) 

9. Monitoring Device Observation – Each scrubber monitor shall be observed by the 

permittee with a frequency as recommended by the manufacturer or sufficient to ensure good 

performance for each of the scrubbers. The permittee shall keep a log of the observations or 

continuously recorded measurements from each scrubber monitoring device. 

(9 VAC 5-50-50 H and 40 CFR 63 Subpart N) 

10. Monitoring Device Observation - The monitoring device used to continuously measure the 

differential pressure drop across the control device shall be observed by the permittee with a 

frequency as recommended by the manufacturer or sufficient enough to ensure good 
Standex Engraving, LLC. 

Registration No.: 50838 

June 18, 2008 

Page 5 

performance. The permittee shall keep a log of the continuously recorded measurements 

from the monitoring device. 

 (9 VAC 5-50-50 H) 

11. Test/Monitoring Ports - The permitted facility shall be constructed so as to allow for 

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

methods. Test ports shall be provided when requested at the appropriate locations. 

(9 VAC 5-50-30 F) 

OPERATING/EMISSION LIMITATIONS

12. Operating Hours - The Chromium plating operation (Ref. No. C1-C6) shall not operate 

more than 59,999,999 Amp hours per year, using non-resetable meters, calculated monthly as 

the sum of each consecutive 12-month period. 

(9 VAC 5-80-1180 and 40 CFR 63 Subpart N) 

13. Operating Hours - The nickel plating (Ref. No. N1-N2) shall not operate more than 500,000 

Amp hours per year, using non-resetable meters, calculated monthly as the sum of each 

consecutive 12-month period. 

(9 VAC 5-80-1180)

14. Operating Hours - The three emergency generators, (Ref. No. G1- G3) shall not each 

operate more than 500 hours per year, calculated monthly as the sum of each consecutive 12-

month period. 

(9 VAC 5-80-1180) 

15. Fuel - The approved fuel for the three emergency generators, (Ref. No. G1- G3) is No. 2 fuel 

oil. A change in the fuel may require a permit to modify and operate. 

(9 VAC 5-80-1180) 

16. Throughput - The calculated throughput of VOC of all paints, inks, or solvents used at the 

facility shall not exceed 28 tons per year, calculated monthly as the sum of each consecutive 

12-month period. 

(9 VAC 5-80-1180) 

17. Fuels - The No. 2 fuel oil shall meet the specifications below: 

DISTILLATE OIL which meets the ASTM D396 specification for numbers 1 or 2 fuel oil: 

Maximum sulfur content per shipment: 0.5% 

(9 VAC 5-80-1180) 

18. Fuel Certification - The facility shall obtain a certification from the fuel supplier with each 

shipment of No. 2 distillate oil. Each fuel supplier certification shall include the following: 

a. The name of the fuel supplier; 

b. The date on which the distillate oil was received; 
Standex Engraving, LLC. 

Registration No.: 50838 

June 18, 2008 

Page 6 

c. The volume of distillate oil delivered in the shipment; 

d. A statement that the distillate oil, complies with the American Society for Testing and 

Materials specifications for numbers 1 or 2 fuel oil, 

e. The sulfur content of the distillate oil. 

(9 VAC 5-170-160) 

19. Chromium Emission Limits– Emissions checked by stack tests from the operation 

Chromium Tanks (Ref. No. C1-C6) of the chromium departments shall not exceed the limits 

specified below: 

Chromium from Tank C1 0.03 mg/dscm of ventilation air 

(6.6x10- 6 gr/dscf) 

Chromium from Tanks C2 and C3 0.015 mg/dscm of ventilation air 

 (6.6x10- 6 gr/dscf) 

Chromium from Tanks C4, C5, and C6 0.026 mg/dscm of ventilation air 

 (6.6x10- 6 gr/dscf) 

(9 VAC 5-50-260 and 40 CFR 63 Subpart N) 

20. Emission Limits - Emissions from the operation of the three emergency generators (Ref. No. 

G1 - G3) combined shall not exceed the limits specified below: 

Particulate Matter (PM) 1.2 lbs/hr 0.28 tons/yr 

PM-10 1.2 lbs/hr 0.28 tons/yr

Sulfur Dioxide 1.05 lbs/hr 0.26 tons/yr 

Nitrogen Oxides 15.92 lbs/hr 3.98 tons/yr 

 (as NOx) 

Carbon Monoxide 3.43 lbs/hr 0.86 tons/yr 

Volatile Organic 1.3 lbs/hr 0.32 tons/yr 

 Compounds (VOC) 

 

These emissions are derived from the estimated overall emission contribution from operating 

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

exceedance of emission limits. Compliance with these emission limits may be determined as 

stated in Conditions 1, 14, 15, 17, and 18. 

(9 VAC 5-50-260) 
Standex Engraving, LLC. 

Registration No.: 50838 

June 18, 2008 

Page 7 

21. Emission Limits – Volatile Organic Compound (VOC) emissions from the use of all inks, 

100% VOC solvents, Oakite #33, CIMTECH 100, and paints combined shall not exceed the 

limits specified below: 

Volatile Organic 28.0 tons/yr 

 Compounds (VOC) 

 

These emissions are derived from the estimated overall emission contribution from operating 

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

exceedance of emission limits. Compliance with these emission limits may be determined as 

stated in Conditions 6 and 16. 

(9 VAC 5-50-260) 

22. Visible Emission Limit - Visible emissions from the with the facility shall not exceed ten 

(10) percent opacity except during one six-minute period in any one hour in which visible 

emissions shall not exceed twenty (20) percent opacity as determined by the EPA Method 9 

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

startup, shutdown, and malfunction. 

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

23. Requirements by Reference - Except where this permit is more restrictive than the 

applicable requirement, the MACT equipment as described in Condition 1 shall be operated 

in compliance with the requirements of 40 CFR 63 Subpart N. 

(9 VAC 5-60-10C) 

RECORDS

24. On Site Records - The permittee shall maintain records of emission data and operating 

parameters as necessary to demonstrate compliance with this permit. The content and format 

of such records shall be arranged with the Piedmont Regional Office. These records shall 

include, but are not limited to: 

a. Monthly and annual Amp hours for the chromium plating tanks, calculated monthly as 

the sum of each consecutive 12-month period. 

b. Monthly and annual Amp hours for the nickel plating tanks, calculated monthly as the 

sum of each consecutive 12-month period. 

c. Monthly and annual hours of operation for each generator, calculated monthly as the sum 

of each consecutive 12-month period. 

d. Monthly and annual consumption of all paints, inks, muriatic acid, CIMTECH 100, 

Oakite #33, 100% VOC solvents and other process related chemical products, calculated 

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

e. All fuel supplier certifications. 
Standex Engraving, LLC. 

Registration No.: 50838 

June 18, 2008 

Page 8 

f. All Material Safety Data Sheets (MSDS) or other vendor information showing VOC 

content, toxic compound or HAP content, water content, and solids content for all process 

areas. 

g. Operational, observation records and control device monitoring records for all scrubbers, 

all thermal oxidizers and associated gages/alarms, the cyclone, the baghouse and the paint 

booth filter system.

h. All scheduled and unscheduled maintenance records, and operator training.

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

recent five (5)years. 

(9 VAC 5-50-50) 

NOTIFICATIONS

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

notification to the Director, Piedmont Region, of malfunctions of the affected facility or 

related air pollution control equipment that may cause excess emissions for more than one (1) 

hour, by facsimile transmission, telephone or telegraph. Such notification shall be made as 

soon as practicable but not later than four (4) daytime business hours of the malfunction. 

The permittee shall provide a written statement giving all pertinent facts, including the 

estimated duration of the breakdown, within fourteen (14) days of the occurrence. When the 

condition causing the failure or malfunction has been corrected and the equipment is again in 

operation, the permittee shall notify the Director, Piedmont Region, in writing. 

(9 VAC 5-20-180 C) 

GENERAL CONDITIONS

26. Permit Invalidation – This permit to install the equipment listed in Condition No. 1 shall 

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

a. A program of continuous construction, reconstruction, or modification is not commenced 

within the latest of the following; 

 i. 18 months from the date of this permit; 

ii. Nine months from the date that the last permit or other authorization was issued from 

any other governmental entity; 

iii. Nine months from the date of the last resolution of any litigation concerning any such 

permits or authorization; or 

b. A program of construction, reconstruction, or modification is discontinued for a period of 

18 months or more, or is not completed within a reasonable time, except for a DEQ 

approved period between phases of a phased construction project. 

(9 VAC 5-80-1210) 
Standex Engraving, LLC. 

Registration No.: 50838 

June 18, 2008 

Page 9 

27. Permit Suspension/Revocation - This permit may be suspended or revoked if the permittee: 

a. Knowingly makes material misstatements in the permit application or any amendments to 

it; 

b. Fails to comply with the conditions of this permit; 

c. Fails to comply with any emission standards applicable to a permitted emissions unit, ; 

d. Causes emissions from the stationary source which result in violations of , or interfere 

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

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

emission standards or emission limitations, in the State Implementation Plan in effect at 

the time an application for this permit is submitted. 

(9 VAC 5-80-1210 F) 

28. Right of Entry - The permittee shall allow authorized local, state, and federal 

representatives, upon the presentation of credentials: 

a. To enter upon the permittee's premises on which the facility is located or in which any 

records are required to be kept under the terms and conditions of this permit; 

b. To have access to and copy at reasonable times any records required to be kept under the 

terms and conditions of this permit or the State Air Pollution Control Board Regulations; 

c. To inspect at reasonable times any facility, equipment, or process subject to the terms and 

conditions of this permit or the State Air Pollution Control Board Regulations; and 

d. To sample or test at reasonable times. 

For purposes of this condition, the time for inspection shall be deemed reasonable during 

regular business hours or whenever the facility is in operation. Nothing contained herein 

shall make an inspection time unreasonable during an emergency. 

(9 VAC 5-170-130 and 9 VAC 5-80-1180) 

29. Maintenance/Operating Procedures - At all times, including periods of start-up, shutdown, 

and malfunction, the permittee shall, to the extent practicable, maintain and operate the 

affected source, including associated air pollution control equipment, in a manner consistent 

with good air pollution control practices for minimizing emissions. 

The permittee shall take the following measures in order to minimize the duration and 

frequency of excess emissions, with respect to air pollution control equipment and process 

equipment which affect such emissions: 

a. Develop a maintenance schedule and maintain records of all scheduled and 

non-scheduled maintenance. 
Standex Engraving, LLC. 

Registration No.: 50838 

June 18, 2008 

Page 10 

b. Maintain an inventory of spare parts and filter media. 

c. Have available written operating procedures for process equipment and air pollution 

control equipment required in Conditions No. 3 through 9. These procedures shall be 

based on the manufacturer's recommendations, at a minimum. 

d. Train operators in the proper operation of all such equipment and familiarize the 

operators with the written operating procedures. The permittee shall maintain records of 

the training provided including the names of trainees, the date of training and the nature 

of the training. 

Records of maintenance and training shall be maintained on site for a period of five (5) years 

and shall be made available to DEQ personnel upon request. 

(9 VAC 5-50-20 E and 9 VAC 5-80-1180 D) 

30. Record of Malfunctions – The permittee shall maintain records of the occurrence and 

duration of any bypass, malfunction, shutdown or failure of the facility or its associated air 

pollution control equipment that results in excess emissions for more than one hour. Records 

shall include the date, time, duration, description (emission unit, pollutant affected, cause), 

corrective action, preventive measures taken and name of person generating the record. 

(9 VAC 5-20-180 J and 9 VAC 5-80-1180 D) 

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

notification to the Director, Piedmont Region of malfunctions of the affected facility or 

related air pollution control equipment that may cause excess emissions for more than one 

hour, by facsimile transmission, telephone or telegraph. Such notification shall be made as 

soon as practicable but no later than four daytime business hours after the malfunction is 

discovered. The permittee shall provide a written statement giving all pertinent facts, 

including the estimated duration of the breakdown, within two weeks of discovery of the 

malfunction. When the condition causing the failure or malfunction has been corrected and 

the equipment is again in operation, the permittee shall notify the Director, Piedmont Region. 

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

32. Violation of Ambient Air Quality Standard - The permittee shall, upon request of the 

DEQ, reduce the level of operation or shut down a facility, as necessary to avoid violating 

any primary ambient air quality standard and shall not return to normal operation until such 

time as the ambient air quality standard will not be violated. 

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

33. Change of Ownership - In the case of a transfer of ownership of a stationary source, the new 

owner shall abide by any current permit issued to the previous owner. The new owner shall 

notify the Director, Piedmont Region, of the change in ownership within thrity (30) days of 

the transfer. 

(9 VAC 5-80-1240) 

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

to which it applies. 

(9 VAC 5-80-1180)