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 a nd 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 referen ce or authority for each condition is listed in parentheses ( ) after each condition.

INTRODUCTION

This permit approval is based on the perm it 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 su ch 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 fo r the Control and Abatement of Air Pollution. The regulatory reference or authority for each co ndition is listed in parentheses () after each

condition.

Annual requirements to fulfill lega l 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: proc ess 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 informa tion 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 o fficials is subject to appropria te 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 EQUIPMENTStandex 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. Th e scrubber(s) shall be in operation when the chromium tank(s) are operational. Emissions shall also be c ontrolled 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. Th e 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 em issions 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 ope ration. Emissions shall also be controlled by good e ngineering practices, proper main tenance, and proper operation of the cyclone. The cyclone shall be pr ovided 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 scr ubber 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 intent ionally spilled, discarde d to sewers, stored in open containers, or handled in any othe r manner that would result in evaporation beyond that consistent with air pollution c ontrol 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 re duced 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 ma terial 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 ma terial in a closed c ontainer 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 require ments 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, VA C 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 diffe rential pressure. The monitori ng device shall be installed, maintained, calibrated and operated in accord ance with approved procedures which shall include, as a minimum, the manuf acturer's written requirements or recommendations. The monitoring device shall be provided with adeq uate 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 perm ittee 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 de vice shall be observed by the permittee with a frequency as recommended by the manufactur er or sufficient enough to ensure goodStandex 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 c onstructed so as to allow for emissions testing and monitoring upon reasonab le notice at any time , using appropriate methods. Test ports shall be provided when requested at the appr opriate locations. (9 VAC 5-50-30 F)

OPERATING/EMISSION LIMITATIONS

12. Operating Hours - The Chromium plating operation (R ef. 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 consecu tive 12-month period. (9 VAC 5-80-1180 and 40 CFR 63 Subpart N)

13. Operating Hours - The nickel plating (Ref. No. N1-N 2) 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 throug hput 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 m eet 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 obtai n a certification from the fuel supplier with each shipment of No. 2 distillate oil. Each fuel supplier certification sha ll include the following:

a. The name of the fuel supplier;

b. The date on which the di stillate 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, comp lies 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-C 6) 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 th e three emergency ge nerators (Ref. No. G1 - G3) combined shall not exc eed 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 NO

x )

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 estimate d overall emission cont ribution 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) em issions from the use of all inks, 100% VOC solvents, Oakite #33, CIMTECH 100, a nd paints combined shall not exceed the limits specified below:

Volatile Organic 28.0 tons/yr Compounds (VOC)

These emissions are derived from the estimate d overall emission cont ribution 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-mi nute period in any one hour in which visible emissions shall not exceed twenty (20) per cent opacity as determined by the EPA Method 9 (reference 40 CFR 60, Appendix A). This c ondition 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 C ondition 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 complian ce 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 chromi um plating tanks, calculated monthly as

the sum of each consecu tive 12-month period.

b. Monthly and annual Amp hours for the nickel plating tanks, calcula ted 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 proc ess 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 maintena nce 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, Pi edmont 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 a nd the equipment is again in operation, the permittee shall notify the Di rector, 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, reco nstruction, or modificat ion 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 othe r 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 w ithin 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 th e 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 ap plicable to a permitted emissions unit, ;

d. Causes emissions from the stationary source wh ich 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 author ized local, state, and federal representatives, upon the pres entation 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 th e terms and conditions of this permit;

b. To have access to and copy at reasonable ti mes 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, eq uipment, 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 in spection 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 pe riods of start-up, shutdown, and malfunction, the permittee shall, to the ex tent practicable, maintain and operate the affected source, including associated air pollution control equipment, in a manner consistent with good air pollution control prac tices 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 main tain 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 r ecommendations, at a minimum.

d. Train operators in the proper operation of all such equipment and familiarize the operators with the written ope rating procedures. The permitt ee shall maintain records of the training provided including the names of trai nees, the date of training and the nature of the training.

Records of maintenance and traini ng 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 failu re of the facility or its associated air pollution control equipment that results in ex cess emissions for more than one hour. Records shall include the date, time, dur ation, description (emission unit, pollutant affected, cause), corrective action, preventive measures taken and name of person ge nerating 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 late r than four daytim e business hours after the malfunction is discovered. The permittee shall provide a writt en statement giving all pertinent facts, including the estimated duration of the breakdo wn, within two weeks of discovery of the malfunction. When the condition causing the fa ilure or malfunction has been corrected and the equipment is again in operation, the permitte e 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 operatio n 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 tran sfer of ownership of a st ationary source, the new owner shall abide by any current permit issued to the previous owner. The new owner shall notify the Director, Piedmont Regi on, 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)