Permit Review Report

Permit ID: 1-4720-01919/00001 Renewal Number: 1 08/01/2007

Facility Identification Data

Name: LAWRENCE RIPAK FACILITY

Address: 165 FIELD ST

WEST BABYLON, NY 11704-1416

Owner/Firm

Name: LAWRENCE RIPAK CO INC

Address: 165 FIELD ST

WEST BABYLON, NY 11704-1416, USA

Owner Classification: Corporation/Partnership

Permit Contacts

Air Permitting Contact:

Name: GALLI ENGINEERING PC

Address: 734 WALT WHITMAN RD STE 402A

MELVILLE, NY 11747

Phone:5162719292

 Permit Description

 Introduction

The Title V operating air permit is intended to be a document containing only enforceable terms and conditions as well 

as any additional information, such as the identification of emission units, emission points, emission sources and 

processes, that makes the terms meaningful. 40 CFR Part 70.7(a)(5) requires that each Title V permit have an 

accompanying "...statement that sets forth the legal and factual basis for the draft permit conditions". The purpose for 

this permit review report is to satisfy the above requirement by providing pertinent details regarding the 

permit/application data and permit conditions in a more easily understandable format. This report will also include 

background narrative and explanations of regulatory decisions made by the reviewer. It should be emphasized that this 

permit review report, while based on information contained in the permit, is a separate document and is not itself an 

enforceable term and condition of the permit.

Summary Description of Proposed Project

Application for renewal of Air Title V Facility. 

Attainment Status

LAWRENCE RIPAK FACILITY is located in the town of BABYLON in the county of SUFFOLK.

The attainment status for this location is provided below. (Areas classified as attainment

 are those that meet all ambient air quality standards for a designated criteria

 air pollutant.)

 Criteria Pollutant Attainment Status

___________________________________________________________________________________

Particulate Matter (PM) ATTAINMENT

___________________________________________________________________________________

Particulate Matter < 10μ in diameter (PM10) ATTAINMENT

___________________________________________________________________________________

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Permit Review Report

Permit ID: 1-4720-01919/00001 Renewal Number: 1 08/01/2007

Sulfur Dioxide (SO2) ATTAINMENT

___________________________________________________________________________________

Ozone* SEVERE NON-ATTAINMENT

___________________________________________________________________________________

Oxides of Nitrogen (NOx)** ATTAINMENT

___________________________________________________________________________________

Carbon Monoxide (CO) ATTAINMENT

___________________________________________________________________________________

 * Ozone is regulated in terms of the emissions of volatile organic compounds (VOC) and/or oxides of 

nitrogen (NOx) which are ozone precursors. 

** NOx has a separate ambient air quality standard in addition to being an ozone precursor 

Facility Description

Lawrence Ripak facility performs nondestructive testing, surface finishing, and surface coating of 

aerospace parts. The facility consists of two buildings, the headquarters (building HDQ) located at 165 

Field Street, and adjacent Plant 2 (building 155) at 155 Field Street. High specification parts fabricated 

by others are tested (magnaflux, dye ultrasonic), treated (cadmium and copper plated, chromium and 

sulfuric acid anodized, vapor degreased), and/or painted by using compliant primers and top coats. The 

facility is equipped with a paint shop consisting of seven spray booths, two drying ovens, and an exhaust 

from one mixing/storage room. The facility's painting operations are regulated under 6NYCRR Part 228 

- Surface Coating Processes. Lawrence Ripak is not subject to 40 CFR Part 63 Subpart GG - National 

Emission Standards for Aerospace Manufacturing and Rework Facilities- since the facility is not a major 

source of hazardous air pollutants. The facility conducts vapor degreasing of aerospace parts by using 

perchloroethylene as the working solvent in two vapor degreasers with solvent/air interface areas greater 

than 1.21 square meters located in a non-vented (no physical emission point), draft-free room. The vapor 

degreasing operations are regulated under 40 CFR Part 63 Subpart T - National Emission Standards for 

Halogenated Solvent Cleaning. To comply with Subpart T, the facility is using the control combination 

number 6, which requires a freeboard refrigeration device to chill the air immediately above the vapor 

zone, reduced room draft, and freeboard ratio of 1 to ensure that the perchloroethylene solvent on the 

parts vaporizes within the machine confines or drains back into the machine. Lawrence Ripak uses a 

variety of cyanide based solutions and associated thermal treatments to conduct cadmium and copper 

plating of steel aerospace parts. The emissions from these processes are governed by 6NYCRR Part 212 

- General Process Emission Sources. The facility also conducts acid-based cleaning and uses chromic 

and sulfuric acids for its anodizing processes. Emissions from chromic acid anodizing are regulated 

under 40 CFR Part 63 Subpart N - National Emission Standards for Chromium Emissions from Hard and 

Decorative Chromium Electroplating and Chromium Anodizing Tanks. The waste streams from the 

processes are treated by ultrafiltration, metals precipitation, ph adjust, chrome reduction, and reverse 

osmosis, and may by subject to hazardous waste regulation.

Permit Structure and Description of Operations

The Title V permit for LAWRENCE RIPAK FACILITY

is structured in terms of the following hierarchy: facility, emission unit,

emission point, emission source and process.

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Permit Review Report

Permit ID: 1-4720-01919/00001 Renewal Number: 1 08/01/2007

A facility is defined as all emission sources located at one or more adjacent or

contiguous properties owned or operated by the same person or persons under common

control. The facility is subdivided into one or more emission units (EU). Emission

units are defined as any part or activity of a stationary facility that emits or has

the potential to emit any federal or state regulated air pollutant. An emission unit

is represented as a grouping of processes (defined as any activity involving one or

more emission sources (ES) that emits or has the potential to emit any federal or

state regulated air pollutant). An emission source is defined as any apparatus,

contrivance or machine capable of causing emissions of any air contaminant to the

outdoor atmosphere, including any appurtenant exhaust system or air cleaning device.

[NOTE: Indirect sources of air contamination as defined in 6 NYCRR Part 203 (i.e.

parking lots) are excluded from this definition]. The applicant is required to

identify the principal piece of equipment (i.e., emission source) that directly

results in or controls the emission of federal or state regulated air pollutants from

an activity (i.e., process). Emission sources are categorized by the following

types:

combustion - devices which burn fuel to generate heat, steam or power

incinerator - devices which burn waste material for disposal

control - emission control devices

process - any device or contrivance which may emit air contaminants that

is not included in the above categories.

LAWRENCE RIPAK FACILITY is defined by the following emission unit(s):

Emission unit 1PAINT - PAINT SHOP CONSISTING OF SEVEN SPRAY BOOTHS, TWO 

DRYING OVENS AND EXHAUST FROM ONE MIXING/STORAGE ROOM. ALL COATINGS 

ARE COMPLIANT COATINGS. SPRAY BOOTH 1 INCLUDES EMISSION POINTS 1 AND 2, 

SPRAY BOOTH 2 INCLUDES EMISSION POINT 14, SPRAY BOOTH 3 INCLUDES EMISSION 

POINTS 3 AND 4, SPRAY BOOTH 4 INCLUDES EMISSION POINT 5, SPRAY BOOTH 5 

INCLUDES EMISSION POINT 6, SPRAY BOOTH 6 INCLUDES EMISSION POINT 15, AND 

SPRAY BOOTH 7 INCLUDES EMISSION POINT 16.

Emission unit 1PAINT is associated with the following emission points (EP):

00001, 00002, 00003, 00004, 00005, 00006, 00007, 00013, 00014, 00015, 00016

It is further defined by the following process(es):

Process: CC1 is located at PAINT SHOP, Building HDQ - COMPLIANT COATINGS ARE APPLIED 

TO AEROSPACE PARTS IN SEVEN SPRAY BOOTHS. AFTER AIR DRYING, MOST PARTS 

ARE DRIED IN AN OVEN.

Emission unit 2000VD - VAPOR DEGREASING OPERATION.

It is further defined by the following process(es):

Process: DEG is located at SHIPPING/RECEIVING, Building HDQ - VAPOR DEGREASING OF 

AEROSPACE PARTS USING PERCHLOROETHYLENE AS WORKING SOLVENT. EMISSION 

UNIT CONSISTS OF TWO VAPOR DEGREASER VAPOR ENGINEERING MODEL VDS-84C, 

LOCATED IN A DRAFT FREE ROOM, NON-VENTED (NO PHYSICAL EMISSION POINT). THE 

FOLLOWING CONTROLS ARE EMPLOYED 1) FREEBOARD CHILLER, 2) FREEBOARD RATIO 

(=1.0), 3) WORKING MODE COVER, 4) PARTS RATE OF REMOVAL CONTROLLED AT <8 

FPM, 5) REDUCED ROOM DRAFT, 6) OPERATOR TRAINING AND CERTIFICATION, 7) ON 

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Permit Review Report

Permit ID: 1-4720-01919/00001 Renewal Number: 1 08/01/2007

DELAY TIMER FOR SUMP HEATERS, 8) OFF DELAY TIMER FOR FREEBOARD CHILLER, 9) 

NO LIP EXHAUST.

Emission unit 3CADPL - PLATING OF STEEL AEROSPACE PARTS USING A VARIETY OF 

CYANIDE BASED SOLUTIONS, AND ASSOCIATED THERMAL TREATMENT.

Emission unit 3CADPL is associated with the following emission points (EP):

00008, 00009, 00010

It is further defined by the following process(es):

Process: CN1 is located at AREA III, Building HDQ - CADMIUM PLATING OF STEEL 

AEROSPACE PARTS USING CAUSTIC CYANIDE SOLUTIONS.

Process: CN2 is located at AREA III, Building HDQ - CADMIUM PLATING OF STEEL 

AEROSPACE PARTS USING CAUSTIC CYANIDE SOLUTIONS CONTAINING TITANIUM 

PASTE ADDITIVE (PATENTED BOEING PROCESS).

Process: CN3 is located at AREA III, Building HDQ - CADMIUM PLATING OF STEEL 

AEROSPACE PARTS USING CAUSTIC CYANIDE SOLUTIONS WITH BRIGHTENING AGENTS 

ADDED.

Process: CN4 is located at AREA III, Building HDQ - CADMIUM PLATING OF STEEL 

AEROSPACE PARTS USING CAUSTIC CYANIDE SOLUTIONS AT HIGH CURRENT 

DENSITIES.

Process: CN5 is located at AREA III, Building HDQ - COPPER PLATING OF STEEL AEROSPACE 

PARTS FOR MASKOFF PRIOR TO HEAT TREATING.

Process: CN6 is located at AREA III, Building HDQ - COPPER STRIPPING OF STEEL 

AEROSPACE PARTS AFTER HEAT TESTING (NO ELECTRIC CURRENT).

Process: CN7 is located at AREA III, Building HDQ - CAUSTIC ALKALINE CLEANING OF STEEL 

AEROSPACE PARTS PRIOR TO EITHER COPPER OR CADMIUM PLATING.

Process: CN8 is located at AREA III, Building HDQ - OVEN USED FOR MODERATE 

TEMPERATURE STRESS RELIEF OF PLATED STEEL PARTS.

Emission unit 40ACID - ACID BASED CLEANING AND ANODIZING OF AEROSPACE PARTS.

Emission unit 40ACID is associated with the following emission points (EP):

00011, 00012

It is further defined by the following process(es):

Process: AC1 is located at AREA II, Building HDQ - ALKALINE CLEANING OF NON-FERROUS 

AEROSPACE PARTS.

Process: AC2 is located at AREA II, Building HDQ - ACID PICKLING OF ALUMINUM 

AEROSPACE PARTS.

Process: AC3 is located at AREA II, Building HDQ - ACID PICKLING OF TITANIUM PARTS.

Process: AC4 is located at AREA II, Building HDQ - ACID BASED NICKEL PLATING.

Process: AC5 is located at AREA II, Building HDQ - SULFURIC ACID ANODIZING OF 

ALUMINUM AEROSPACE PARTS.

Process: AC6 is located at AREA II, Building HDQ - SEALING OF NEWLY ANODIZED 

ALUMINUM AEROSPACE PARTS.

Process: AC7 is located at AREA II, Building HDQ - CHROMIC ACID ANODIZING OF 

ALUMINUM AEROSPACE PARTS.

Process: AC8 is located at AREA II, Building HDQ - BORIC-SULFURIC ANODIZING OF 

ALUMINUM AEROSPACE PARTS

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Permit Review Report

Permit ID: 1-4720-01919/00001 Renewal Number: 1 08/01/2007

Emission unit 5PLNT2 - ACID BASED CLEANING AND SULFURIC ACID ANODIZING OF 

AEROSPACE PARTS.

Emission unit 5PLNT2 is associated with the following emission points (EP):

00101, 00102, 00103

It is further defined by the following process(es):

Process: DC1 is located at AREA2, Building 155 - BORIC-SULFURIC ANODIZING OF 

ALUMINUM AEROSPACE PARTS.

Process: DC2 is located at AREA2, Building 155 - SEALING OF NEWLY ANODIZED ALUMINUM 

AEROSPACE PARTS.

Process: DC3 is located at AREA2, Building 155 - ACID PICKLING OF ALUMINUM AEROSPACE 

PARTS.

Process: DC4 is located at AREA2, Building 155 - ACID PICKLING OF TITANIUM AEROSPACE 

PARTS.

Process: DC5 is located at AREA2, Building 155 - NITRIC ACID ETCH OF AEROSPACE PARTS.

Process: DC6 is located at AREA2, Building 155 - ALKALINE CLEANING OF AEROSPACE 

PARTS.

Process: DC7 is located at AREA1, Building 155 - CYANIDE, ACID, AND PENETRANT RINSES 

AND SETTLING TANKS. WASTE STREAMS FROM PROCESSES IN BUILDINGS 155 AND 165 

ARE TREATED BY ULTRAFILTRATION, METALS PRECIPITATION, PH ADJUST, CHROME 

REDUCTION, AND REVERSE OSMOSIS. THE PROCESS MAY BE SUBJECT TO HAZARDOUS 

WASTE REGULATION.

Title V/Major Source Status

LAWRENCE RIPAK FACILITY is subject to Title V requirements. This determination is based on the 

following information: 

The Title V permit grants the facility a possibility to be a major source of hazardous air pollutants. These 

pollutants are emitted from spray coating, acid-based anodizing, and eletroplating operations.

Program Applicability

The following chart summarizes the applicability of LAWRENCE RIPAK FACILITY with regards to the 

principal air pollution regulatory programs:

 Regulatory Program Applicability ___________________________________________________________________________________

PSD NO

___________________________________________________________________________________

NSR (non-attainment) NO

___________________________________________________________________________________

NESHAP (40 CFR Part 61) NO

___________________________________________________________________________________

NESHAP (MACT - 40 CFR Part 63) YES

___________________________________________________________________________________

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Permit Review Report

Permit ID: 1-4720-01919/00001 Renewal Number: 1 08/01/2007

NSPS NO

___________________________________________________________________________________

TITLE IV NO

___________________________________________________________________________________

TITLE V YES

___________________________________________________________________________________

TITLE VI NO

___________________________________________________________________________________

RACT YES

___________________________________________________________________________________

SIP YES

___________________________________________________________________________________

 NOTES:

PSD Prevention of Significant Deterioration (40 CFR 52) - requirements which pertain to 

major stationary sources located in areas which are in attainment of National Ambient Air Quality 

Standards (NAAQS) for specified pollutants.

 NSR New Source Review (6 NYCRR Part 231) - requirements which pertain to major 

stationary sources located in areas which are in non-attainment of National Ambient Air Quality 

Standards (NAAQS) for specified pollutants.

 NESHAP National Emission Standards for Hazardous Air Pollutants (40 CFR 61) - contaminant 

and source specific emission standards established prior to the Clean Air Act Amendments of 1990 

(CAAA) which were developed for 9 air contaminants (inorganic arsenic, radon, benzene, vinyl chloride, 

asbestos, mercury, beryllium, radionuclides, and volatile HAP’s)

 MACT Maximum Achievable Control Technology (40 CFR 63) - contaminant and source 

specific emission standards established by the 1990 CAAA. Under Section 112 of the CAAA, the US 

EPA is required to develop and promulgate emissions standards for new and existing sources. The 

standards are to be based on the best demonstrated control technology and practices in the regulated 

industry, otherwise known as MACT. The corresponding regulations apply to specific source types and 

contaminants.

 NSPS New Source Performance Standards (40 CFR 60) - standards of performance for 

specific stationary source categories developed by the US EPA under Section 111 of the CAAA. The 

standards apply only to those stationary sources which have been constructed or modified after the 

regulations have been proposed by publication in the Federal Register and only to the specific 

contaminant(s) listed in the regulation.

 Title IV Acid Rain Control Program (40 CFR 72 thru 78) - regulations which mandate the 

implementation of the acid rain control program for large stationary combustion facilities.

 Title VI Stratospheric Ozone Protection (40 CFR 82, Subparts A thru G) - federal requirements 

that apply to sources which use a minimum quantity of CFC’s (chlorofluorocarbons), 

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Permit Review Report

Permit ID: 1-4720-01919/00001 Renewal Number: 1 08/01/2007

HCFC’s(hydrofluorocarbons)or other ozone depleting substances or regulated substitute substances in 

equipment such as air conditioners, refrigeration equipment or motor vehicle air conditioners or 

appliances.

 RACT Reasonably Available Control Technology (6 NYCRR Parts 212.10, 226, 227-2, 228, 

229, 230, 232, 233, 234, 235, 236) - the lowest emission limit that a specific source is capable of 

meeting by application of control technology that is reasonably available, considering technological and 

economic feasibility. RACT is a control strategy used to limit emissions of VOC’s and NOx for the 

purpose of attaining the air quality standard for ozone. The term as it is used in the above table refers to 

those state air pollution control regulations which specifically regulate VOC and NOx emissions.

 SIP State Implementation Plan (40 CFR 52, Subpart HH) - as per the CAAA, all states are 

empowered and required to devise the specific combination of controls that, when implemented, will 

bring about attainment of ambient air quality standards established by the federal government and the 

individual state. This specific combination of measures is referred to as the SIP. The term here refers to 

those state regulations that are approved to be included in the SIP and thus are considered federally 

enforceable.

Compliance Status

 Facility is in compliance with all requirements

SIC Codes 

SIC or Standard Industrial Classification code is an industrial code developed by the

federal Office of Management and Budget for use, among other things, in the classification

of establishments by the type of activity in which they are engaged. Each operating

establishment is assigned an industry code on the basis of its primary activity, which is

determined by its principal product or group of products produced or distributed, or

services rendered. Larger facilities typically have more than one SIC code.

SIC Code Description 3471 ELECTROPLATING,POLISHING,ANODIZING, AND COLORING

 3479 METAL COATING AND ALLIED SERVICES,NEC

 8734 TESTING LABORATORIES

SCC Codes

SCC or Source Classification Code is a code developed and used by the USEPA to categorize

processes which result in air emissions for the purpose of assessing emission factor

information. Each SCC represents a unique process or function within a source category

logically associated with a point of air pollution emissions. Any operation that causes

air pollution can be represented by one or more SCC’s. 

SCC Code Description

3-09-011-02 FABRICATED METAL PRODUCTS

 FABRICATED METAL PRODUCTS - CONVERSION COATING OF METAL

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Permit Review Report

Permit ID: 1-4720-01919/00001 Renewal Number: 1 08/01/2007

 PRODUCTS

 Acid Cleaning Bath (Pickling)

3-09-011-01 FABRICATED METAL PRODUCTS

 FABRICATED METAL PRODUCTS - CONVERSION COATING OF METAL

 PRODUCTS

 Alkaline Cleaning Bath

3-09-011-03 FABRICATED METAL PRODUCTS

 FABRICATED METAL PRODUCTS - CONVERSION COATING OF METAL

 PRODUCTS

 Anodizing Kettle

3-09-011-99 FABRICATED METAL PRODUCTS

 FABRICATED METAL PRODUCTS - CONVERSION COATING OF METAL

 PRODUCTS

 Other Not Classified

3-09-011-04 FABRICATED METAL PRODUCTS

 FABRICATED METAL PRODUCTS - CONVERSION COATING OF METAL

 PRODUCTS

 Rinsing/Finishing

3-09-010-52 FABRICATED METAL PRODUCTS

 FABRICATED METAL PRODUCTS - ELECTROPLATING

 OPERATIONS

 CADMIUM (CYANIDE) - ELECTROPLATING TANK

3-09-010-42 FABRICATED METAL PRODUCTS

 FABRICATED METAL PRODUCTS - ELECTROPLATING

 OPERATIONS

 COPPER (CYANIDE, INCLUDING STRIKE) - ELECTROPLATING TANK

3-09-010-03 FABRICATED METAL PRODUCTS

 FABRICATED METAL PRODUCTS - ELECTROPLATING

 OPERATIONS

 FABRICATED METALS-ELECTROPLATING-ENTIRE PROCESS-NICKEL

3-09-010-97 FABRICATED METAL PRODUCTS

 FABRICATED METAL PRODUCTS - ELECTROPLATING OPERATIONS

 Other Not Classified

4-01-002-53 ORGANIC SOLVENT EVAPORATION

 ORGANIC SOLVENT EVAPORATION - DEGREASING

 PERCHLOROETHYLENE - GENERAL DEGREASING UNITS

4-02-025-01 SURFACE COATING OPERATIONS

 SURFACE COATING OPERATIONS - MISCELLANEOUS METAL

 PARTS

 Coating Operation

Facility Emissions Summary

In the following table, the CAS No. or Chemical Abstract Series code is an identifier assigned to every 

chemical compound. [NOTE: Certain CAS No.’s contain a ‘NY’ designation within them. These are 

not true CAS No.’s but rather an identification which has been developed by the department to identify 

groups of contaminants which ordinary CAS No.’s do not do. As an example, volatile organic 

compounds or VOC’s are identified collectively by the NY CAS No. 0NY998-00-0.] The PTE refers to 

the Potential to Emit. This is defined as the maximum capacity of a facility or air contaminant source to 

emit any air contaminant under its physical and operational design. Any physical or operational limitation 

on the capacity of the facility or air contamination source to emit any air contaminant , including air 

pollution control equipment and/or restrictions on the hours of operation, or on the type or amount or 

material combusted, stored, or processed, shall be treated as part of the design only if the limitation is 

contained in federally enforceable permit conditions. The PTE Range represents an emission range for a 

contaminant. Any PTE quantity that is displayed represents a facility-wide emission cap or limitation for 

that contaminant. If no PTE quantity is displayed, the PTE Range is provided to indicate the approximate 

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Permit Review Report

Permit ID: 1-4720-01919/00001 Renewal Number: 1 08/01/2007

magnitude of facility-wide emissions for the specified contaminant in terms of tons per year (tpy). The 

term ‘HAP’ refers to any of the hazardous air pollutants listed in section 112(b) of the Clean Air Act 

Amendments of 1990. Total emissions of all hazardous air pollutants are listed under the special NY 

CAS No. 0NY100-00-0. In addition, each individual hazardous air pollutant is also listed under its own 

specific CAS No. and is identified in the list below by the (HAP) designation. 

Cas No. Contaminant Name PTE

 ________________________________

 lbs/yr Range

 000108-10-1 2-PENTANONE, 4-METHYL(HAP) > 0 but < 10 tpy

 007631-86-9 AMORPHOUS SILICA(HAP) > 0 but < 10 tpy

 001309-64-4 ANTIMONY TRIOXIDE(HAP) > 0 but < 10 tpy

 007440-43-9 CADMIUM(HAP) > 0 but < 10 tpy

 000630-08-0 CARBON MONOXIDE > 0 but < 2.5 tpy

 013907-45-4 CHROMATE(HAP) > 0 but < 10 tpy

 007738-94-5 CHROMIC ACID(HAP) > 0 but < 10 tpy

 010588-01-9 CHROMIC ACID DISODIUM > 0 but < 10 tpy

 SALT(HAP)

 007775-11-3 CHROMIC ACID, DISODIUM > 0 but < 10 tpy

 SALT(HAP)

 007440-47-3 CHROMIUM(HAP) > 0 but < 10 tpy

 018540-29-9 CHROMIUM(VI)(HAP) > 0 but < 10 tpy

 000057-12-5 CYANIDE(HAP) > 0 but < 10 tpy

 000111-15-9 ETHANOL, 2-ETHOXY-, > 0 but < 10 tpy

 ACETATE(HAP)

 0NY100-00-0 HAP >= 2.5 tpy but < 10 tpy

 007664-39-3 HYDROGEN FLUORIDE(HAP) > 0 but < 10 tpy

 000078-93-3 METHYL ETHYL KETONE > 0 but < 10 tpy

 000101-68-8 METHYLENE BISPHENYL > 0 but < 10 tpy

 ISOCYANATE(HAP)

 0NY210-00-0 OXIDES OF NITROGEN > 0 but < 2.5 tpy

 0NY075-00-0 PARTICULATES > 0 but < 2.5 tpy

 000127-18-4 PERCHLOROETHYLENE(HAP) > 0 but < 10 tpy

 0NY075-00-5 PM-10 > 0 but < 2.5 tpy

 014808-60-7 QUARTZ(HAP) > 0 but < 10 tpy

 007446-09-5 SULFUR DIOXIDE > 0 but < 2.5 tpy

 007664-93-9 SULFURIC ACID > 0 but < 2.5 tpy

 0NY998-00-0 VOC > 0 but < 2.5 tpy

NOTIFICATION OF GENERAL PERMITTEE OBLIGATIONS

Item A: Emergency Defense - 6NYCRR Part 201-1.5

An emergency constitutes an affirmative defense to an action brought 

for noncompliance with emissions limitations or permit conditions for 

all facilities in New York State.

(a) The affirmative defense of emergency shall be demonstrated through

properly signed, contemporaneous operating logs, or other relevant 

evidence that:

(1) An emergency occurred and that the facility owner and/or operator

can identify the cause(s) of the emergency;

(2) The equipment at the permitted facility causing the emergency was

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Permit Review Report

Permit ID: 1-4720-01919/00001 Renewal Number: 1 08/01/2007

at the time being properly operated;

(3) During the period of the emergency the facility owner and/or 

operator took all reasonable steps to minimize levels of emissions 

that exceeded the emission standards, or other requirements in the 

permit; and

(4) The facility owner and/or operator notified the Department within

two working days after the event occurred. This notice must contain a

description of the emergency, any steps taken to mitigate emissions, 

and corrective actions taken.

(b) In any enforcement proceeding, the facility owner and/or operator 

seeking to establish the occurrence of an emergency has the burden of 

proof.

(c) This provision is in addition to any emergency or upset provision 

contained in any applicable requirement.

Item B: Public Access to Recordkeeping for Title V Facilities - 6NYCRR Part 

201-1.10(b)

The Department will make available to the public any permit 

application, compliance plan, permit, and monitoring and compliance 

certification report pursuant to Section 503(e) of the Act, except for

information entitled to confidential treatment pursuant to 6NYCRR Part

616 - Public Access to records and Section 114(c) of the Act.

Item C: Timely Application for the Renewal of Title V Permits - 6 NYCRR Part 

201-6.3(a)(4)

Owners and/or operators of facilities having an issued Title V permit

shall submit a complete application at least 180 days, but not more 

than eighteen months, prior to the date of permit expiration for 

permit renewal purposes.

Item D: Certification by a Responsible Official - 6 NYCRR Part 

201-6.3(d)(12)

Any application, form, report or compliance certification required to

be submitted pursuant to the federally enforceable portions of this 

permit shall contain a certification of truth, accuracy and 

completeness by a responsible official. This certification shall state

that based on information and belief formed after reasonable inquiry, 

the statements and information in the document are true, accurate, and

complete.

Item E: Requirement to Comply With All Conditions - 6 NYCRR Part 

201-6.5(a)(2)

The permittee must comply with all conditions of the Title V facility

permit. Any permit non-compliance constitutes a violation of the Act 

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Permit ID: 1-4720-01919/00001 Renewal Number: 1 08/01/2007

and is grounds for enforcement action; for permit termination, 

revocation and reissuance, or modification; or for denial of a permit 

renewal application.

Item F: Permit Revocation, Modification, Reopening, Reissuance or 

Termination, and Associated Information Submission Requirements - 6 

NYCRR Part 201-6.5(a)(3)

This permit may be modified, revoked, reopened and reissued, or 

terminated for cause. The filing of a request by the permittee for a 

permit modification, revocation and reissuance, or termination, or of 

a notification of planned changes or anticipated noncompliance does 

not stay any permit condition.

Item G: Cessation or Reduction of Permitted Activity Not a Defense - 6NYCRR 

Part 201-6.5(a)(5)

It shall not be a defense for a permittee in an enforcement action to

claim that a cessation or reduction in the permitted activity would 

have been necessary in order to maintain compliance with the 

conditions of this permit.

Item H: Property Rights - 6 NYCRR Part 201-6.5(a)(6)

This permit does not convey any property rights of any sort or any 

exclusive privilege.

Item I: Severability - 6 NYCRR Part 201-6.5(a)(9)

If any provisions, parts or conditions of this permit are found to be

invalid or are the subject of a challenge, the remainder of this 

permit shall continue to be valid.

Item J: Permit Shield - 6 NYCRR Part 201-6.5(g)

All permittees granted a Title V facility permit shall be covered 

under the protection of a permit shield, except as provided under 6 

NYCRR Subpart 201-6. Compliance with the conditions of the permit 

shall be deemed compliance with any applicable requirements as of the 

date of permit issuance, provided that such applicable requirements 

are included and are specifically identified in the permit, or the 

Department, in acting on the permit application or revision, 

determines in writing that other requirements specifically identified 

are not applicable to the major stationary source, and the permit 

includes the determination or a concise summary thereof. Nothing 

herein shall preclude the Department from revising or revoking the 

permit pursuant to 6 NYCRR Part 621 or from exercising its summary 

abatement authority. Nothing in this permit shall alter or affect the

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following:

i. The ability of the Department to seek to bring suit on behalf of 

the State of New York, or the Administrator to seek to bring suit on 

behalf of the United States, to immediately restrain any person 

causing or contributing to pollution presenting an imminent and 

substantial endangerment to public health, welfare or the environment 

to stop the emission of air pollutants causing or contributing to such

pollution;

ii. The liability of a permittee of the Title V facility for any 

violation of applicable requirements prior to or at the time of permit

issuance;

iii. The applicable requirements of Title IV of the Act;

iv. The ability of the Department or the Administrator to obtain 

information from the permittee concerning the ability to enter, 

inspect and monitor the facility.

Item K: Reopening for Cause - 6 NYCRR Part 201-6.5(i)

This Title V permit shall be reopened and revised under any of the 

following circumstances:

i. If additional applicable requirements under the Act become 

applicable where this permit's remaining term is three or more years, 

a reopening shall be completed not later than 18 months after 

promulgation of the applicable requirement. No such reopening is 

required if the effective date of the requirement is later than the 

date on which this permit is due to expire, unless the original permit

or any of its terms and conditions has been extended by the Department

pursuant to the provisions of Part 201-6.7 and Part 621.

ii. The Department or the Administrator determines that the permit 

contains a material mistake or that inaccurate statements were made in

establishing the emissions standards or other terms or conditions of 

the permit.

iii. The Department or the Administrator determines that the Title V 

permit must be revised or reopened to assure compliance with 

applicable requirements.

iv. If the permitted facility is an "affected source" subject to the 

requirements of Title IV of the Act, and additional requirements 

(including excess emissions requirements) become applicable. Upon 

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approval by the Administrator, excess emissions offset plans shall be 

deemed to be incorporated into the permit.

 Proceedings to reopen and issue Title V facility permits shall follow

the same procedures as apply to initial permit issuance but shall 

affect only those parts of the permit for which cause to reopen 

exists.

 Reopenings shall not be initiated before a notice of such intent is 

provided to the facility by the Department at least thirty days in 

advance of the date that the permit is to be reopened, except that 

the Department may provide a shorter time period in the case of an 

emergency.

Item L: Permit Exclusion - ECL 19-0305

The issuance of this permit by the Department and the receipt thereof

by the Applicant does not and shall not be construed as barring, 

diminishing, adjudicating or in any way affecting any legal, 

administrative or equitable rights or claims, actions, suits, causes 

of action or demands whatsoever that the Department may have against 

the Applicant for violations based on facts and circumstances alleged 

to have occurred or existed prior to the effective date of this 

permit, including, but not limited to, any enforcement action 

authorized pursuant to the provisions of applicable federal law, the 

Environmental Conservation Law of the State of New York (ECL) and 

Chapter III of the Official Compilation of the Codes, Rules and 

Regulations of the State of New York (NYCRR). The issuance of this 

permit also shall not in any way affect pending or future enforcement 

actions under the Clean Air Act brought by the United States or any 

person.

Item M: Federally Enforceable Requirements - 40 CFR 70.6(b)

All terms and conditions in this permit required by the Act or any 

applicable requirement, including any provisions designed to limit a 

facility's potential to emit, are enforceable by the Administrator and

citizens under the Act. The Department has, in this permit, 

specifically designated any terms and conditions that are not required

under the Act or under any of its applicable requirements as being 

enforceable under only state regulations.

NOTIFICATION OF GENERAL PERMITTEE OBLIGATIONS

Item A: General Provisions for State Enforceable Permit Terms and Condition -

6 NYCRR Part 201-5

Any person who owns and/or operates stationary sources shall operate 

and maintain all emission units and any required emission control 

devices in compliance with all applicable Parts of this Chapter and 

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existing laws, and shall operate the facility in accordance with all 

criteria, emission limits, terms, conditions, and standards in this 

permit. Failure of such person to properly operate and maintain the 

effectiveness of such emission units and emission control devices may 

be sufficient reason for the Department to revoke or deny a 

permit.

The owner or operator of the permitted facility must maintain all 

required records on-site for a period of five years and make them 

available to representatives of the Department upon request. 

Department representatives must be granted access to any facility 

regulated by this Subpart, during normal operating hours, for the 

purpose of determining compliance with this and any other state and 

federal air pollution control requirements, regulations or law.

Regulatory Analysis

Location Regulation Short Description Condition

Facility/EU/EP/Process/ES

FACILITY ECL 19-0301 Powers and Duties of the 55

 Department with respect

 to air pollution control

4-0ACID/-/AC7/CANOD 40CFR 63-N.340(b) Subpart N - Chromium 47

 Electroplating NESHAP

4-0ACID/-/AC7/CANOD 40CFR 63-N.342(d)(2) Subpart N - Standards 48

4-0ACID/-/AC7/CANOD 40CFR 63-N.342(f) Subpart N - Standards 49

4-0ACID/-/AC7/CANOD 40CFR 63-N.346(a) Subpart N - 50

 Recordkeeping

 requirements

4-0ACID/-/AC7/CANOD 40CFR 63-N.346(b) Subpart N - 51

 Recordkeeping

 requirements

4-0ACID/-/AC7/CANOD 40CFR 63-N.347(a) Subpart N - Reporting 52

 requirements

4-0ACID/-/AC7/CANOD 40CFR 63-N.347(h) Subpart N - Reporting 53

 requirements

4-0ACID/-/AC7/CANOD 40CFR 63-N.347(h)(2) Subpart N - Exceedance 54

 reporting requirements

2-000VD 40CFR 63-T.463(a) 33, 34,

 35, 36,

 37

2-000VD 40CFR 63-T.463(b)(2)(i) 38

2-000VD 40CFR 63-T.463(d) 39

2-000VD 40CFR 63-T.463(e)(2)(i) 40

2-000VD 40CFR 63-T.463(e)(2)(ii) 41

2-000VD 40CFR 63-T.463(e)(2)(v) 42

2-000VD 40CFR 63-T.467(a) Subpart T- Recordkeeping 43

 requirements

2-000VD 40CFR 63-T.467(b) Subpart T- Recordkeeping 44

 requirements

2-000VD 40CFR 63-T.468(f) Subpart T- Reporting 45

 requirements

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2-000VD 40CFR 63-T.468(i) Subpart T- Reporting 46

 requirements

FACILITY 40CFR 68 Chemical accident 20

 prevention provisions

FACILITY 40CFR 82-F Protection of 21

 Stratospheric Ozone -

 recycling and emissions

 reduction

FACILITY 6NYCRR 200.6 Acceptable ambient air 1

 quality.

FACILITY 6NYCRR 200.7 Maintenance of equipment. 10

1-PAINT 6NYCRR 200.7 Maintenance of equipment. 27

FACILITY 6NYCRR 201-1.4 Unavoidable noncompliance 56

 and violations

FACILITY 6NYCRR 201-1.7 Recycling and Salvage 11

FACILITY 6NYCRR 201-1.8 Prohibition of 22

 reintroduction of

 collected contaminants to

 the air

FACILITY 6NYCRR 201-3.2(a) Exempt Activities - Proof 12

 of eligibility

FACILITY 6NYCRR 201-3.3(a) Trivial Activities - 13

 proof of eligibility

FACILITY 6NYCRR 201-6 Title V Permits and the 23, 25,

 Associated Permit 26

 Conditions

FACILITY 6NYCRR 201-6.5(a)(4) General conditions 14

FACILITY 6NYCRR 201-6.5(a)(7) General conditions

Fees 2

FACILITY 6NYCRR 201-6.5(a)(8) General conditions 15

FACILITY 6NYCRR 201-6.5(c) Permit conditions for 3

 Recordkeeping and

 Reporting of Compliance

 Monitoring

FACILITY 6NYCRR 201-6.5(c)(2) Permit conditions for 4

 Recordkeeping and

 Reporting of Compliance

 Monitoring

FACILITY 6NYCRR 201-6.5(c)(3)(ii) Permit conditions for 5

 Recordkeeping and

 Reporting of Compliance

 Monitoring

FACILITY 6NYCRR 201-6.5(d)(5) Compliance schedules 16

FACILITY 6NYCRR 201-6.5(e) Compliance Certification 6

FACILITY 6NYCRR 201-6.5(f)(6) Off Permit Changes 17

FACILITY 6NYCRR 202-1.1 Required emissions tests. 18

FACILITY 6NYCRR 202-2.1 Emission Statements - 7

 Applicability

FACILITY 6NYCRR 202-2.5 Emission Statements - 8

 record keeping

 requirements.

FACILITY 6NYCRR 211.2 General Prohibitions - 57

 air pollution

 prohibited.

FACILITY 6NYCRR 211.3 General Prohibitions - 19

 visible emissions

 limited

3-CADPL/00008 6NYCRR 212.9(b) General Process Emission 58

 Sources - tables

4-0ACID/00012 6NYCRR 212.9(b) General Process Emission 59

 Sources - tables

5-PLNT2/00101/DC1 6NYCRR 212.9(b) General Process Emission 60

 Sources - tables

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FACILITY 6NYCRR 215 Open Fires 9

1-PAINT 6NYCRR 228.3(a) Recordkeeping, reports 28

 for VOCs

FACILITY 6NYCRR 228.4 Opacity 24

1-PAINT 6NYCRR 228.5(a) VOC recordkeeping by the 29

 facility

1-PAINT 6NYCRR 228.8 Table 2 30, 31,

 32

Applicability Discussion:

 Mandatory Requirements: The following facility-wide regulations are included in all Title V permits: 

ECL 19-301.

This section of the Environmental Conservation Law establishes the powers and duties

assigned to the Department with regard to administering the air pollution control

program for New York State.

6NYCRR Part 200-.6

Acceptable ambient air quality - prohibits contravention of ambient air quality

standards without mitigating measures

6NYCRR Part 200-.7

Anyone owning or operating an air contamination source which is equipped with an

emission control device must operate the control consistent with ordinary and

necessary practices, standards and procedures, as per manufacturer's specifications

and keep it in a satisfactory state of maintenance and repair so that it operates

effectively

6NYCRR Part 201-1.4

This regulation specifies the actions and recordkeeping and reporting requirements

for any violation of an applicable state enforceable emission standard that results

from a necessary scheduled equipment maintenance, start-up, shutdown, malfunction or

upset in the event that these are unavoidable.

6NYCRR Part 201-1.7

Requires the recycle and salvage of collected air contaminants where practical

6NYCRR Part 201-1.8

Prohibits the reintroduction of collected air contaminants to the outside air

6NYCRR Part 201-3.2(a)

An owner and/or operator of an exempt emission source or unit may be required to

certify that it operates within the specific criteria described in this Subpart.

All required records must be maintained on-site for a period of 5 years and made

available to department representatives upon request. In addition, department

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representatives must be granted access to any facility which contains exempt emission

sources or units, during normal operating hours, for the purpose of determining

compliance with this and any other state and federal air pollution control

requirements, regulations, or law.

6NYCRR Part 201-3.3(a)

The owner and/or operator of a trivial emission source or unit may be required to

certify that it operates within the specific criteria described in this Subpart. All

required records must be maintained on-site for a period of 5 years and made

available to department representatives upon request. In addition, department

representatives must be granted access to any facility which contains trivial

emission sources or units subject to this Subpart, during normal operating hours, for

the purpose of determining compliance with this and any other state and federal air

pollution control requirements, regulations, or law.

6NYCRR Part 201-6

This regulation applies to those terms and conditions which are subject to Title V

permitting. It establishes the applicability criteria for Title V permits, the

information to be included in all Title V permit applications as well as the permit

content and terms of permit issuance. This rule also specifies the compliance,

monitoring, recordkeeping, reporting, fee, and procedural requirements that need to

be met to obtain a Title V permit, modify the permit and demonstrate conformity with

applicable requirements as listed in the Title V permit. For permitting purposes,

this rule specifies the need to identify and describe all emission units, processes

and products in the permit application as well as providing the Department the

authority to include this and any other information that it deems necessary to

determine the compliance status of the facility.

6NYCRR 201-6.5(a)(4)

This mandatory requirement applies to all Title V facilities. It requires the

permittee to provide information that the Department may request in writing, within a

reasonable time, in order to determine whether cause exists for modifying, revoking

and reissuing, or terminating the permit or to determine compliance with the permit.

The request may include copies of records required to be kept by the permit.

6NYCRR 201-6.5(a)(7)

This is a mandatory condition that requires the owner or operator of a facility

subject to Title V requirements to pay all applicable fees associated with the

emissions from their facility.

6NYCRR 201-6.5(a)(8)

This is a mandatory condition for all facilities subject to Title V requirements. It

allows the Department to inspect the facility to determine compliance with this

permit, including copying records, sampling and monitoring, as necessary.

6NYCRR Part 201-6.5(c)

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This requirement specifies, in general terms, what information must be contained in

any required compliance monitoring records and reports. This includes the date, time

and place of any sampling, measurements and analyses; who performed the analyses;

analytical techniques and methods used as well as any required QA/QC procedures;

results of the analyses; the operating conditions at the time of sampling or

measurement and the identification of any permit deviations. All such reports must

also be certified by the designated responsible official of the facility.

6NYCRR Part 201-6.5(c)(2)

This requirement specifies that all compliance monitoring and recordkeeping is to be

conducted according to the terms and conditions of the permit and follow all QA

requirements found in applicable regulations. It also requires monitoring records

and supporting information to be retained for at least 5 years from the time of

sampling, measurement, report or application. Support information is defined as

including all calibration and maintenance records and all original strip-chart

recordings for continuous monitoring instrumentation, and copies of all reports

required by the permit.

6NYCRR Part 201-6.5(c)(3)(ii)

This regulation specifies any reporting requirements incorporated into the permit

must include provisions regarding the notification and reporting of permit deviations

and incidences of noncompliance stating the probable cause of such deviations, and

any corrective actions or preventive measures taken.

6NYCRR 201-6.5(d)(5)

This condition applies to every Title V facility subject to a compliance schedule.

It requires that reports, detailing the status of progress on achieving compliance

with emission standards, be submitted semiannually.

6NYCRR Part 201-6.5(e)

Sets forth the general requirements for compliance certification content; specifies

an annual submittal frequency; and identifies the EPA and appropriate regional office

address where the reports are to be sent.

6NYCRR 201-6.5(f)(6)

This condition allows changes to be made at the facility, without modifying the

permit, provided the changes do not cause an emission limit contained in this permit

to be exceeded. The owner or operator of the facility must notify the Department of

the change. It is applicable to all Title V permits which may be subject to an off

permit change.

6NYCRR Part 202-1.1

This regulation allows the department the discretion to require an emission test for

the purpose of determining compliance. Furthermore, the cost of the test, including

the preparation of the report are to be borne by the owner/operator of the source.

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6NYCRR Part 202-2.1

Requires that emission statements shall be submitted on or before April 15th each

year for emissions of the previous calendar year.

6NYCRR Part 202-2.5

This rule specifies that each facility required to submit an emission statement must

retain a copy of the statement and supporting documentation for at least 5 years and

must make the information available to department representatives.

6NYCRR Part 211-.2

This regulation prohibits any emissions of air contaminants to the outdoor atmosphere

which may be detrimental to human, plant or animal life or to property, or which

unreasonably interferes with the comfortable enjoyment of life or property regardless

of the existence of any specific air quality standard or emission limit.

6 NYCRR Part 211.3

This condition requires that the opacity (i.e., the degree to which emissions other

than water reduce the transmission of light) of the emissions from any air

contamination source be less than 20 percent (six minute average) except for one

continuous six-minute period per hour of not more than 57 percent.

6 NYCRR Part 215

Prohibits open fires at industrial and commercial sites.

40 CFR Part 68.

This Part lists the regulated substances and there applicability thresholds and sets

the requirements for stationary sources concerning the prevention of accidental

releases of these substances.

40 CFR Part 82, Subpart F

Subpart F requires the reduction of emissions of class I and class II refrigerants to

the lowest achievable level during the service, maintenance, repair, and disposal of

appliances in accordance with section 608 of the Clean Air Act Amendments of 1990.

This subpart applies to any person servicing, maintaining, or repairing appliances

except for motor vehicle air conditioners. It also applies to persons disposing of

appliances, including motor vehicle air conditioners, refrigerant reclaimers,

appliance owners, and manufacturers of appliances and recycling and recovery

equipment. Those individuals, operations, or activities affected by this rule, may

be required to comply with specified disposal, recycling, or recovery practices, leak

repair practices, recordkeeping and/or technician certification requirements.

Facility Specific Requirements

In addition to Title V, LAWRENCE RIPAK FACILITY has been determined to be subject to the 

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following regulations:

40CFR 63-N.340 (b) 

 This requires compliance with the general provisions which contains requirements for performance 

testing, monitoring, notification, recordkeeping, reporting, and control devices . 

40CFR 63-N.342 (d) (2) 

Suface tension of electroplating bath should be maintained at/below 45.0 dynes/centimeter 

40CFR 63-N.342 (f) 

The owner/operator shall operate and maintain any affected source in a manner consistent with good air 

pollution control practices at all times. Malfunction should be corrected as soon as posiible. The 

owner/operator shall keep the written O/M plan on record to be avilable for inspection upon request, by 

the administrator until the source is no longer subject to Subpart N. 

40CFR 63-N.346 (a) 

The owner or operator of an affected sources to the provisions of Part 63 shall maintain files of all 

inforation required by Part 63 recorded in a form suitable and readily avilable for expeditious inspection 

and review. At leasat most recent 2 years of data shall be retained on site.

40CFR 63-N.346 (b) 

The owner/operator of the chromic acid bath shall maintain the necessary records pertaining to the 

chemical fume suppressant.

40CFR 63-N.347 (a) 

This requires fulfillment of all reporting requirements of Subpart N. 

40CFR 63-N.347 (h) 

This requires the owner or operator of an affected source that is located at an area source site to submit an 

acceptanble summary report to document the ongoing compliance status of the affected source. 

40CFR 63-N.347 (h) (2) 

This condition describes the requirements for reporting excess emissions and malfunctions.

40CFR 63-T.463 (a) 

This reference is the heading for the existing and new in-line and batch vapor solvent cleaning machine 

design requirements (e.g., freeboard ratio, cover, minimize drafts) which are needed to minimize solvent 

loss.

40CFR 63-T.463 (b) (2) (i) 

This reference lists the seven control equipment options for batch vapor solvent cleaning machines with 

an opening greater than 13 square feet. However, other equivalent methods of control can be established.

40CFR 63-T.463 (d) 

This reference is the heading to all of the required work and operational practices that existing and new 

in-line and batch vapor solvent cleaning machines must meet.

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40CFR 63-T.463 (e) (2) (i) 

This reference provides the freeboard refrigeration device standards that must be met during each 

monitoring period.

40CFR 63-T.463 (e) (2) (ii) 

This reference provides the reduced room draft standards that must be met during each monitoring 

period. Also, the operating conditions which are used to meet the reduced room draft standard must be 

maintained continuously.

40CFR 63-T.463 (e) (2) (v) 

This reference provides the dwell requirements that must be met during each monitoring period.

40CFR 63-T.467 (a) 

This reference requires specific records to be kept, for solvent cleaning machines subject to this section, 

for the lifetime of the machine.

40CFR 63-T.467 (b) 

This reference requires specific records to be kept, for solvent cleaning machines subject to this section, 

for a period of five years.

40CFR 63-T.468 (f) 

This reference provides the annual report requirements for batch vapor and in-line solvent cleaning 

machines which are subject to this subdivision (i.e., complying with the provisions in section 63.463). 

Each annual report must be submitted by February 1.

40CFR 63-T.468 (i) 

This reference provides the conditions that must be met in order to change the exceedance reporting 

frequency from quarterly, or more frequent as determined by the EPA, back to semiannually.

6NYCRR 212 .9 (b) 

This section refers to Table 2 which specifies the degree of control required for Gases and Liquid 

Particulate Emissions (Environmental Rating of A, B, C or D) and Solid Particulate Emissions 

(Environmental Rating A or D) but excluding Volatile Organic Compound Emissions in the New York 

City Metropolitan Area.

6NYCRR 228 .3 (a) 

This citation prohibits the use of coatings that exceed the maximum permitted pounds of volatile organic 

compounds per gallon, unless a coating system meeting certain requirements is used.

6NYCRR 228 .4

This citation prohibits any person from emitting (or to allow emissions) to the outdoor atmosphere having 

an average opacity of 20 percent or greater for any consecutive six-minute period from any emission 

source subject to this Part.

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6NYCRR 228 .5 (a) 

This citation requires the owner or operator of any emission source subject to 6 NYCRR Part 228 to 

maintain and, upon request, provide the Department with a certification from the coating 

supplier/manufacturer which verifies the parameters used to determine the actual volatile organic 

compound (VOC) content of each as applied coating. In addition it requires the purchase, usage and/or 

production records of the coating material, including solvents and any additional information required to 

determine compliance with Part 228 , to be maintained in a format acceptable to the Department; and 

upon request, submitted to the Department.

6NYCRR 228 .8

Table 2 lists the processes and a description of products that are regulated by Part 228 and the maximum 

permitted pounds of volatile organic compounds per gallon of coating at application.

Compliance Certification

 Summary of monitoring activities at LAWRENCE RIPAK FACILITY: 

Location Type of Monitoring Cond No.

Facility/EU/EP/Process/ES

4-0ACID/-/AC7/CANOD monitoring of process or control device 48

 parameters as surrogate

4-0ACID/-/AC7/CANOD record keeping/maintenance procedures 49

4-0ACID/-/AC7/CANOD record keeping/maintenance procedures 50

4-0ACID/-/AC7/CANOD record keeping/maintenance procedures 51

2-000VD monitoring of process or control device 33

 parameters as surrogate

2-000VD record keeping/maintenance procedures 34

2-000VD monitoring of process or control device 35

 parameters as surrogate

2-000VD record keeping/maintenance procedures 36

2-000VD work practice involving specific 37

 operations

2-000VD monitoring of process or control device 38

 parameters as surrogate

2-000VD record keeping/maintenance procedures 39

2-000VD monitoring of process or control device 40

 parameters as surrogate

2-000VD monitoring of process or control device 41

 parameters as surrogate

2-000VD record keeping/maintenance procedures 42

2-000VD record keeping/maintenance procedures 43

2-000VD record keeping/maintenance procedures 44

2-000VD record keeping/maintenance procedures 45

1-PAINT record keeping/maintenance procedures 27

FACILITY record keeping/maintenance procedures 5

FACILITY record keeping/maintenance procedures 6

FACILITY record keeping/maintenance procedures 7

3-CADPL/00008 intermittent emission testing 58

4-0ACID/00012 intermittent emission testing 59

5-PLNT2/00101/DC1 intermittent emission testing 60

FACILITY monitoring of process or control device 24

 parameters as surrogate

1-PAINT record keeping/maintenance procedures 29

1-PAINT work practice involving specific 30

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 operations

1-PAINT work practice involving specific 31

 operations

1-PAINT work practice involving specific 32

 operations

Basis for Monitoring

. The facility shall be inspected daily for any open containers containing VOCs.

2. Particulate emissions from spray booths shall be monitored in order to comply with emission 

limitations of 0.05 grains per dry standard cubic foot and stack opacities not to exceed 20 percent.

3. Only compliant maskants, primers, and topcoats in spray coating operations shall be used.

4. Batch vapor cleaning machines shall use the control option 6 as per federal regulation 40 CFR Part 63 

Subpart T.

5. Chromic acid anodizer tanks shall employ a surfactant that maintains the surface tension of the solution 

in the baths below 45 dynes per centimeter.

6. Cyanide and sulfuric acid emissions from process tanks shall be monitored in order to limit these 

emissions below 1.0 and 0.7 pounds per hour, respectively. 

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