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 docum ent 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 fact ual basis for the draft permit conditions". The purpose for this permit review report is to satisfy the above re quirement 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 pr ovided below. (Areas classified as attainment are those that meet all ambient air qu ality 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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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 tes ting, 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 dr ying 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 Manuf acturing and Rework Facilities- since the facility is not a major source of hazardous air pollutants. The facility conduc ts 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 Subpa rt T, the facility is using the control combination number 6, which requires a freeboard refrigeration device to chill the air imme diately 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 preci pitation, ph adjust, chro me 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 follo wing hierarchy: facility, emission unit, emission point, emission source and process.

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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 intoone 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 orhas 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 defi nition]. 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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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 S TEEL AEROSPACE PARTS USING CAUSTIC CYANIDE SOLUTIONS. Process: CN2 is located at AREA III, Building HDQ - CADMIUM PLATING OF S TEEL 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 S TEEL AEROSPACE PARTS USING CAUSTIC CYANIDE SOLUTIONS WITH BRIGHTENING AGENTS ADDED. Process: CN4 is located at AREA III, Building HDQ - CADMIUM PLATING OF S TEEL AEROSPACE PARTS USING CAUSTIC CYANIDE SOLUTIONS AT HIGH CURRENT DENSITIES. Process: CN5 is located at AREA III, Building HDQ - COPPER PLATING OF S TEEL AEROSPACE PARTS FOR MASKOFF PRIOR TO HEAT TREATING. Process: CN6 is located at AREA III, Building HDQ - COPPER STRIPPING OF S TEEL AEROSPACE PARTS AFTER HEAT TESTING (NO ELECTRIC CURRENT). Process: CN7 is located at AREA III, Building HDQ - CAUSTIC ALKALINE CLEANING OF S TEEL 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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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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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 Ai r 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 C AAA. Under Section 112 of the C AAA, 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 C AAA. 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 progr am 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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HCFC’s(hydrofluorocarbons)or other oz one depleting substances or re gulated 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 st andard 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 comb ination 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 ty pically 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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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 whic h 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. 0NY 998-00-0.] The PTE refers to the Potential to Emit. This is defined as the maximu m 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 contaminati on 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 re presents 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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magnitude of facility-wide emissions for the specified c ontaminant in terms of tons per year (tpy). The term ‘HAP’ refers to any of the h azardous air pollutants listed in section 112(b) of the Clean Air Act Amendments of 1990. Total emissions of all h azardous air pollutants are listed under the special NY CAS No. 0NY100-00-0. In add ition, each individual hazardous air pollu tant 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 Ra nge

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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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 - 6 NYCRR 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 A ccess 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 facilitie s having an issued Title V permit shall submit a complete application at least 180 days, but not more than eighteen months, prior to th e 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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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 comp liance 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 c onditions 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 re quirements specifically identified are not applicable to the major stationary source, and the permit includes the determination or a c oncise 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 Admi nistrator 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 c oncerning 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 Administra tor 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 "a ffected 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 Depa rtment 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 en forceable 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 app licable Parts of this Chapter and

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existing laws, and shall operate th e facility in accordance with all criteria, emission limits, terms, c onditions, 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 speci fic 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 an y 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 othe r 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 De partment may request in writing, within a reasonable time, in order to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit orto 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 a ssociated with the emissions from their facility.

6NYCRR 201-6.5(a)(8) This is a mandatory condition for all fac ilities subject to Title V requirements. It allows the Department to inspect the facility to dete rmine 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 term s, what information must be contained in any required compliance monitoring records a nd 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 re sponsible 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 te rms 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 TitleV 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 requ ired 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 availabl e 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 oranimal 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 servici ng, 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 reco rd 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 opti ons 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 operati onal 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 th e 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 topcoa ts 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 surfactan t that maintains the surface tension of the solution in the baths below 45 dynes per centimeter.

6. Cyanide and sulfuric acid emissions from proce ss tanks shall be monitored in order to limit these emissions below 1.0 and 0.7 pounds per hour, respectively.

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