Facility DEC ID: 9146000032
PERMIT Under the Environmental Conservation Law (ECL) IDENTIFICATION INFORMATION Permit Type: Air State Facility Permit ID: 9-1460-00032/00015 Effective Date: 02/19/2003 Expiration Date: No expiration date Permit Issued To: L D MCCAULEY LLC 3875 CALIFORNIA RD ORCHARD PARK, NY 14127
Facility: L D MCCAULEY LLC 3875 CALIFORNIA RD ORCHARD PARK, NY 14127 Contact: MARK E SANO L D MCAULEY 3875 CALIFORNIA ROAD ORCHARD PARK, NY 14127 (716) 662-8980 Description: L.D. McCauley, Inc. is a manufacture of mechanicalanti-theft devices. The manufacturing facility is located at 3875 California Road, Orchard Park, New York. The SIC code for this fac ility is 3499 - Fabricated Metal Products.
FACILITY DESCRIPTION: L. D. McCauley manufactures specialty automotive locking lug nuts, and fasteners for security devices. The operations used in the manufacturing facility include milling, cold forming, heat treatment, finishing (e.g., buffing and polishing), and electroplating. The manufacturing processes specified in the permit include the buffing and polishing, heat treatment, and plating. The milling and cold forming processes are exempt activities. The manufacturing and control equipment associated with the permitted processes are identified in the permit. The equipment associated with the exempt activities are as follows:
1. Fifteen (15) milling machines; 2. One (1) cold extrusion press; 3. Ten (10) lathes; 4. Eleven (11) multispindle screw machines; 5. One 5.32 MMBtu/hr combustion unit; 6. One emergency generator; 7. Four (4) non-contact water cooling towers; and 8. Five (5) non-vapor phase cleaning equipment. APPLICABLE REQUIREMENTS

FINALFacility DEC ID: 9146000032

1. 6NYCRR Part 212 - General Process Emissions: Each permitted and exempt process at the facility is required to limit particulate emissions to less than 0.05 grains per dry standard cubic foot of exhaust gas. In addition, the average opacity from each process is limited to less than 20 percent opacity. The nickel, chromium and hydrogen chloride emissions are controlled by a packed bed scrubber to reduce emissions of these hazardous air pollutants. In accordance with Table 2 of 6NYCRR Part 212, the control efficiency of the packed bed scrubber satisfies the specified control requirements.

2. 40CFR63 Subpart N - National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks: The decorative chromium electroplating tanks use a wetting agent type fume suppressant as the method of compliance. The bath surface tension is required to be maintained below 45 dynes per centimeter. The work practice standards, monitoring, recordkeeping, and reporting requirements for the chromium electroplating process are specified in the permit.
By acceptance of this permit, the permittee agrees that the permit is contingent upon strict compliance with the ECL, all applicable regulations, the General Conditions specified and any Special Conditions included as part of this permit. Permit Administrator: RICHARD P SWEENEY DIVISION OF ENVIRONMENTAL PERMITS 270 MICHIGAN AVE BUFFALO, NY 14203-2999 Authorized Signature: _________________________________ Date: ___ / ___ / _____

FINALFacility DEC ID: 9146000032 Notification of Other State Permittee Obligations
Item A: Permittee Accepts Legal Responsibility and Agrees to Indemnification The permittee expressly agrees to indemnify and hold harmless the Department of Environmental Conservation of the State of New York, its representatives, employees, and agents ("DEC") for all claims, suits, actions, and damages, to the extent attributable to the permittee's acts or omissions in connection with the permittee's undertaking of activities in connection with, or operation and maintenance of, the facility or facilities authorized by the permit whether in compliance or not in compliance with the terms and conditions of the permit. This indemnification does not extend to any claims, suits, actions, or damages to the extent attributable to DEC's own negligent or intentional acts or omissions, or to any claims, suits, or actions naming the DEC and arising under article 78 of the New York Civil Practice Laws and Rules or any citizen suit or civil rights provision under federal or state laws.

Item B: Permittee's Contractors to Comply with Permit The permittee is responsible for informing its independent contractors, employees, agents and assigns of their responsibility to comply with this permit, including all special conditions while acting as the permittee's agent with respect to the permitted activities, and such persons shall be subject to the same sanctions for violations of the Environmental Conservation Law as those prescribed for the permittee.

Item C: Permittee Responsible for Obtaining Other Required Permits The permittee is responsible for obtaining any other permits, approvals, lands, easements and rights-of-way that may be required to carry out the activities that are authorized by this permit.

Item D: No Right to Trespass or Interfere with Riparian Rights This permit does not convey to the permittee any right to trespass upon the lands or interfere with the riparian rights of others in order toperform the permitted work nor does it authorize the impairment of any rights, title, or interest in real or personal property held or vested in a person not a party to the permit.

FINALFacility DEC ID: 9146000032 LIST OF CONDITIONS

DEC GENERAL CONDITIONS General Provisions Facility Inspection by the Department Relationship of this Permit to Other Department Orders and Determinations Applications for Permit Renewals and Modifications Permit Modifications, Suspensions and Revocations by the Department Facility Level Submission of Applications for Permit Modification or Renewal -REGION 9 HEADQUARTERS

DEC Permit Conditions Page 1 of 3 FINALFacility DEC ID: 9146000032 DEC GENERAL CONDITIONS **** General Provisions   GENERAL CONDITIONS - Apply to ALL Authorized Permits.

Condition 1: Facility Inspection by the Department Applicable State Requirement: ECL 19-0305 Item 1.1: The permitted site or facility, including relevant records, is subject to inspection at reasonable hours and intervals by an authorized representative of the Department of Environmental Conservation (the Department) to determine whether the permittee is complying with this permit and the ECL. Such representative may order the work suspended pursuant to ECL 71-0301 and SAPA 401(3). Item 1.2: The permittee shall provide a person to accompany the Department's representative during an inspection to the permit area when requested by the Department. Item 1.3: A copy of this permit, including all referenced maps, drawings and special conditions, must be available for inspection by the Department at all times at the project site or facility. Failure to produce a copy of the permit upon request by a Department representative is a violation of this permit. Condition 2: Relationship of this Permit to Other Department Orders and Determinations Applicable State Requirement: ECL 3-0301.2(m) Item 2.1: Unless expressly provided for by the Department, issuance of this permit does not modify, supersede or rescind any order or determination previously issued by the Department or any of the terms, conditions or requirements contained in such order or determination. Condition 3: Applications for Permit Renewals and Modifications Applicable State Requirement: 6NYCRR 621.13 Item 3.1: The permittee must submit a separate written applicati on to the Department for renewal, modification or transfer of this permit. Such application must include any forms or supplemental information the Department requires. Any renewal, modification or transfer granted by the Department must be in writing. Item 3.2: The permittee must submit a renewal application at least 180 days before expiration of permits for Title V Facility Permits, or at least 30 days before expiration of permits for State Facility Permits. Item 3.3: Permits are transferrable with the approval of the department unless specifically prohibited by the statute, regulation or another permit condition. Applications for permit transfer should be submitted prior to actual

DEC Permit Conditions Page 2 of 3 FINALFacility DEC ID: 9146000032 transfer of ownership. Condition 4: Permit Modifications, Suspensions and Revocations by the Department Applicable State Requirement: 6NYCRR 621.14 Item 4.1: The Department reserves the right to modify, susp end, or revoke this permit in accordance with 6NYCRR Part 621. The gr ounds for modification, suspension or revocation include: a) materially false or inaccurate statements in the permit application or supporting papers; b) failure by the permittee to comply with any terms or conditions of the permit; ibe d in the permit application; d) newly discovered material information or a material change in environmental conditions, relevant technology or applicable law or regulations since the issuance of the existing permit; e) noncompliance with previously issued permit conditions, orders of the commissioner, any provisions of the Environmental Conservation Law or regulations of the Department related to the permitted activity.

** ** Facility Level   Condition 5: Submission of Applications for Permit Modification or Renewal -REGION 9 HEADQUARTERS Applicable State Requirement: 6NYCRR 621.5(a) Item 5.1: Submission of applications for permit modifi cation or renewal are to be submitted to: NYSDEC Regional Permit Administrator Region 9 Headquarters Division of Environmental Permits 270 Michigan Avenue Buffalo, NY 14203-2999 (716) 851-7165

DEC Permit Conditions Page 3 of 3 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 Permit Under the Environmental Conservation Law (ECL) ARTICLE 19: AIR POLLUTION CONTROL - AIR STATE FACILITY PERMIT IDENTIFICATION INFORMATION Permit Issued To: L D MCCAULEY LLC 3875 CALIFORNIA RD ORCHARD PARK, NY 14127
Facility: L D MCCAULEY LLC 3875 CALIFORNIA RD ORCHARD PARK, NY 14127 Authorized Activity By Standard Industrial Classification Code: 3499 - FABRICATED METAL PRODUCTS, NEC

Air Pollution Control Permit Conditions Page 1 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 LIST OF CONDITIONS

FEDERALLY ENFORCEABLE CONDITIONS Facility Level 1 6NYCRR 212.4(c): Compliance Demonstration 2 6NYCRR 212.6(a): Compliance Demonstration Emission Unit Level EU=1-PLANT,EP=09104,Proc=SCR 3 6NYCRR 212.9(b): Compliance Demonstration 4 6NYCRR 212.11(b)(5): Compliance Demonstration 5 6NYCRR 212.11(b)(5): Compliance Demonstration 6 6NYCRR 212.11(b)(5): Compliance Demonstration 7 40CFR 63.340(a), Subpart N: Compliance Demonstration 8 40CFR 63.340(b), Subpart N: Part 63 General Provisions requirements 9 40CFR 63.340(e), Subpart N: Compliance Demonstration 10 40CFR 63.342(a), Subpart N: Compliance timeframe 11 40CFR 63.342(b)(1), Subpart N: Standards apply during all tank operation 12 40CFR 63.342(b)(2), Subpart N: Compliance Demonstration 13 40CFR 63.342(d)(2), Subpart N: Compliance Demonstration 14 40CFR 63.342(f)(1), Subpart N: Applicab ility of work practice standards 15 40CFR 63.342(f)(2), Subpart N: Acceptable work practices 16 40CFR 63.342(f)(3), Subpart N: Operation and maintenance plan 17 40CFR 63.342(g), Subpart N: Compliance with emission standard 18 40CFR 63.343(a)(1)(i), Subpart N: Compliance Demonstration 19 40CFR 63.343(a)(2), Subpart N: Compliance Demonstration 20 40CFR 63.343(a)(3), Subpart N: Compliance Demonstration 21 40CFR 63.343(b)(2), Subpart N: Compliance Demonstration 22 40CFR 63.343(c)(5), Subpart N: Compliance Demonstration 23 40CFR 63.344(c), Subpart N: Compliance Demonstration 24 40CFR 63.346(a), Subpart N: Compliance Demonstration 25 40CFR 63.346(b), Subpart N: Compliance Demonstration 26 40CFR 63.346(c), Subpart N: Compliance Demonstration 27 40CFR 63.347(a), Subpart N: Reporting Requirements 28 40CFR 63.347(c)(1), Subpart N: Initial Notification for existing sources 29 40CFR 63.347(c)(2), Subpart N: Compliance Demonstration 30 40CFR 63.347(e)(1), Subpart N: Notification of compliance status 31 40CFR 63.347(e)(2), Subpart N: Required content for notification of compliance status 32 40CFR 63.347(e)(4), Subpart N: Compliance Demonstration 33 40CFR 63.347(h)(1), Subpart N: Compliance Demonstration 34 40CFR 63.347(h)(2), Subpart N: Compliance Demonstration 35 40CFR 63.347(h)(3)(i), Subpart N: Compliance Demonstration 36 40CFR 63.347(h)(3)(ii), Subpart N: Compliance Demonstration 37 40CFR 63.347(h)(3)( iii), Subpart N: Compliance Demonstration

Air Pollution Control Permit Conditions Page 2

of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032

STATE ONLY ENFORCEABLE CONDITIONS Facility Level 38 ECL 19-0301: Contaminant List 39 6NYCRR 201-1.4: Unavoidable noncompliance and violations 40 6NYCRR 201-5: Emission Unit Definition 41 6NYCRR 211.2: Air pollution prohibited Emission Unit Level 42 6NYCRR 201-5: Emission Point Definition By Emission Unit 43 6NYCRR 201-5: Process Definition By Emission Unit Permit Effective Date: 02/19/2003 Permit Expiration Date: No expiration date.

Air Pollution Control Permit Conditions Page 3 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 FEDERALLY ENFORCEABLE CONDITIONS ** ** Facility Level  

NOTIFICATION OF GENERAL PERMITTEE OBLIGATIONS This section contains terms and conditions which are federally enforceable. Permittees may also have other obligations under regulations of general applicability Item A: Sealing - 6NYCRR Part 200.5 The Commissioner may seal an air contamination source to prevent its operation if compliance with 6 NYCRR Chapter III is not met within the time provided by an order of the Commissioner issued in the case of the violation. Sealing means labeling or tagging a source to notify any person that operation of the source is prohibited, and also includes physical means of preventing the operation of an air contamination source without resulting in destruction of any equipment associated with such source, and includes, but is not limited to, bolting, chaining or wiring shut control panels, apertures or conduits associated with such source. No person shall operate any air contamination source sealed by the Commissioner in accordance with this section unless a modification has been made which enables such source to comply with all requirements applicable to such modification. Unless authorized by the Commissioner, no person shall remove or alter any seal affixed to any contamination source in accordance with this section.
Item B: Acceptable Ambient Air Quality - 6 NYCRR Part 200.6 Notwithstanding the provisions of 6 NYCRR Chapter III, Subchapter A, no person shall allow or permit any air contamination source to emit air contaminants in quantities which alone or in combination with emissions from other air contamination sources would contravene any applicable ambient air quality standard and/or cause air pollution. In such cases where contravention occurs or may occur, the Commissioner shall specify the degree and/or method of emission control required. Item C: Maintenance of Equipment - 6NYCRR Part 200.7 Any person who owns or operates an air contamination

Air Pollution Control Permit Conditions Page 4 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 source which is equipped with an emission control device shall operate such device and keep it in a satisfactory state of maintenance and repair in accordance with ordinary and necessary practices, standards and procedures, inclusive of manufacturer's specifications, required to operate such device effectively.
Item D: Unpermitted Emission Sources - 6 NYCRR Part 201-1.2 If an existing emission source was subject to the permitting requirements of 6NYCRR Part 201 at the time of construction or modification, and the owner and/or operator failed to apply for a permit for such emission source then the following provisions apply: (a) The owner and/or operator must apply for a permit for such emission source or register the facility in accordance with the provisions of Part 201. (b) The emission source or facility is subject to all regulations that were applicable to it at the time of construction or modification and any subsequent requirements applicable to existing sources or facilities.
Item E: 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 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

Air Pollution Control Permit Conditions Page 5 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 occurred. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. (b) In any enforcement pro ceeding, 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 F: Recycling and Salvage - 6NYCRR Part 201-1.7 Where practical, any person who owns or operates an air contamination source shall recycle or salvage air contaminants collected in an air cleaning device according to the requirements of 6 NYCRR. Item G: Prohibition of Reintroduction of Collected Contaminants to the Air - 6NYCRR Part 201-1.8 No person shall unnecessarily remove, handle, or cause to be handled, collected air contaminants from an air cleaning device for recycling, salvage or disposal in a manner that would reintroduce them to the outdoor atmosphere.
Item H: Proof of Eligibility for Sources Defined as Exempt Activities - 6 NYCRR Part 201-3.2(a) The owner and/or operator of an emission source or unit that is eligible to be exem pt, may be required to certify that it operates within the specific criteria described in 6 NYCRR Subpart 201-3. The owner or operator of any such emission source 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 which contains emission sources or units subject to 6 NYCRR Subpart 201-3, 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.
Item I: Proof of Eligibility for Sources Defined as Trivial Activities - 6 NYCRR Part 201-3.3(a) The owner and/or operator of an emission source or unit that is listed as being trivial in 6 NYCRR Part 201 may be required to certify that it operates within the specific

Air Pollution Control Permit Conditions Page 6 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 criteria described in 6 NYCRR Subpart 201-3. The owner or operator of any such emission source 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 which contains emission sources or units subject to 6 NYCRR Subpart 201-3, 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.
Item J: Required Emission Tests - 6 NYCRR Part 202-1.1 An acceptable report of measured emissions shall be submitted, as may be required by the Commissioner, to ascertain compliance or noncompliance with any air pollution code, rule, or regulation. Failure to submit a report acceptable to the Commissioner within the time stated shall be sufficient reason for the Commissioner to suspend or deny an operating permit. Notification and acceptable procedures are specified in 6NYCRR Part 202-1.
Item K: Visible Emissions Limited - 6 NYCRR Part 211.3 Except as permitted by a specific part of this Subchapter and for open fires for which a restricted burning permit has been issued, no person shall cause or allow any air contamination source to emit any material having an opacity equal to or greater than 20 percent (six minute average) except for one continuous six-minute period per hour of not more than 57 percent opacity.
Item L: Open Fires - 6 NYCRR Part 215 No person shall burn, cause, suffer, allow or permit the burning in an open fire of garbage, rubbish for salvage, or rubbish generated by industrial or commercial activities.
Item M: 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 thispermit, including, but not

Air Pollution Control Permit Conditions Page 7 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 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 N: 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.

FEDERAL APPLICABLE REQUIREMENTS The following conditions are federally enforceable.

Condition 1: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 212.4(c) Item 1.1: The Compliance Demonstration activity will be performed for the Facility. Regulated Contaminant(s): CAS No: 001310-73-2

SODIUM HYDROXIDE CAS No: 007440-02-0 NICKEL METAL AND INSOLUBLE COMPOUNDS CAS No: 007440-47-3 CHROMIUM CAS No: 007440-66-6 ZINC CAS No: 0NY075-00-0 PARTICULATES Item 1.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description:

Air Pollution Control Permit Conditions Page 8

of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 Emissions of solid particulates from any process source shall not exceed 0. 050 grains of particulates per cubic foot of exhaust gas, expressed at standard conditions on a dry gas basis. Parameter Monitored: PARTICULATES Upper Permit Limit: 0.05 grains per dscf Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Averaging Method: MAXIMUM - NOT TO BE EXCEEDED AT ANY TIME (INSTANTANEOUS/DISCRETE OR GRAB) Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 2: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 212.6(a) Item 2.1: The Compliance Demonstration activity will be performed for the Facility. Regulated Contaminant(s): CAS No: 0NY075-00-0 PARTICULATES Item 2.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: No person will cause or allow emissions having an average opacity during any six consecutive minutes of 20 percent or greater from any process emission source, except only the emission of uncombined water. The Department reserves the right to perform or require the performance of a Method 9 opacity evaluation at any time during facility operation. Parameter Monitored: OPACITY Upper Permit Limit: 20 percent Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Averaging Method: 6-MINUTE AVERAGE (METHOD 9) Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY

Air Pollution Control Permit Conditions Page 9 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 ** ** Emission Unit Level   Condition 3: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 212.9(b) Item 3.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-02-0 NICKEL METAL AND INSOLUBLE COMPOUNDS CAS No: 007647-01-0 HYDROGEN CHLORIDE CAS No: 007440-47-3 CHROMIUM Item 3.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: L.D. McCauley operates plating tanks using chromium, nickel, and zinc metals. The emissions from these plating operations are exhausted through a control device consisting of a packed bed scrubber. The pollutants generated from this process include heavy metals (chromium, nickel, zinc), sodium hydroxide, and hydrochloric acid. L.D. McCauley elected to install and operate a packed bed scrubber to reduce emissions from this process. L. D. McCauley is required to operate and maintain the scrubber at all times during operation of the plating tanks. The scrubber shall be operated and maintained in accordance with manufacturer specifications and as specified in Preventative Maintenance Task #PL75 and PL76. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 4: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 212.11(b)(5)

Air Pollution Control Permit Conditions Page 10of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032

Item 4.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-02-0 NICKEL METAL AND INSOLUBLE COMPOUNDS CAS No: 007647-01-0 HYDROGEN CHLORIDE CAS No: 007440-47-3 CHROMIUM Item 4.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: The pressure differential across the packed scrubber medium shall be operated in the range between 0.0 to 0.5 inches of water. If the pressure is operating outside of this range then the system and gauges shall be checked to determine the source of the problem. Appropriate corrective action shall be completed and documented as per Preventative Maintenance Task #PL75 and PL76. Parameter Monitored: PRESSURE Lower Permit Limit: 0 inches of water Upper Permit Limit: 0.5 inches of water Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Averaging Method: RANGE - NOT TO FALL OUTSIDE OF STATED RANGE AT ANY TIME Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 5: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 212.11(b)(5) Item 5.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s):

Air Pollution Control Permit Conditions Page 11 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 CAS No: 007440-02-0 NICKEL METAL AND INSOLUBLE COMPOUNDS CAS No: 007647-01-0 HYDROGEN CHLORIDE CAS No: 007440-47-3 CHROMIUM Item 5.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: The pressure differential across the mist eliminator shall be operated in the range between 0.0 to 0.3 inches of water. If the pressure is operating outside of this range then the system and gauges shall be checked to determine the source of the problem. Appropriate corrective action shall be completed and documented as per the Preventative Maintenance Task #PL75 and PL76. Parameter Monitored: PRESSURE Lower Permit Limit: 0.0 inches of water Upper Permit Limit: 0.3 inches of water Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Averaging Method: RANGE - NOT TO FALL OUTSIDE OF STATED RANGE AT ANY TIME Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 6: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 212.11(b)(5) Item 6.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 6.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description:

Air Pollution Control Permit Conditions Page 12 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 The pressure reading for the spray manifold shall be operated below 18 pounds per square inch. If the pressure is operating above this value then the system and gauges shall be checked to determine the source of the problem. Appropriate corrective action shall be completed and documented as per the Preventative Maintenance Task #PL75 and PL76. Parameter Monitored: PRESSURE Upper Permit Limit: 18 pounds per square inch gauge Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Averaging Method: MAXIMUM - NOT TO EXCEED STATED VALUE - SEE MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 7: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.340(a) , Subpart N Item 7.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 7.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The affected source to which the provisions of this part apply is each chromium electroplating or chromium anodizing tank at facilities performing hard chromium electroplating, decorative chromium electroplating, or chromium anodizing. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 8: Part 63 General Provisions requirements Effective between the dates of 02/19/2003 and Permit Expiration Date

Air Pollution Control Permit Conditions Page 13 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032
Applicable Federal Requirement: 40CFR 63.340(b) , Subpart N Item 8.1: This Condition applies to Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Item 8.2: Owners or operators of affected sources subject to 40CFR63 Subpart N must also comply with the requirements of Subpart A of Part 63, according to the applicability of Subpart A to such sources, as identified in Table 1 of Subpart N. Subpart A is the General Provisions for the NESHAP for Source Categories regulations. The General Provisions contain requirements for performance testing, monitoring, notification, recordkeeping, reporting, and control devices that may apply to the source. Condition 9: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.340(e) , Subpart N Item 9.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 9.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The Administrator has determined, pursuant to the criteria under section 502(a) of the Act, that an owner or operator of the following types of operations that are not by themselves major sources and that are not located at major sources, as defined under 40CFR70.2, is permanently exempt from title V permitting requirements for that operation: (i) Any decorative chromium electroplating operation or

chromium anodizing operation that uses fume suppressants as an emission reduction technology; and (ii) Any decorative chromium electroplating operation that uses a trivalent chromium bath that incorporates a wetting agent as a bath ingredient.

Air Pollution Control Permit Conditions Page 14 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 L.D. McCauley operates a decorative chromium electroplating tank using fume suppressants as the emission control technology. L. D. McCauley is not a major source of emissions. As such, under current operating conditions, L.D. McCauley qualifies for the exemption and is permanently exempt from Title V permitting requirements. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 10: Compliance timeframe Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.342(a) , Subpart N Item 10.1: This Condition applies to Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Item 10.2: Each owner or operator of an affected source subject to the provisions of 40CFR63 Subpart N shall comply with the requirements of Subpart N on and after the compliance dates specified in 40CFR63.343(a). All affected sources are regulated by applying maximum achievable control tec hnology. Condition 11: Standards apply during all tank operation Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.342(b)(1 ), Subpart N Item 11.1: This Condition applies to Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Item 11.2: The emission limits of 40CFR63.342 apply only during tank operation, and also apply during periods of start-up and shutdown as these are routine occurrences for affected sources subject to 40CFR63 Subpart N. The emission limitations do not apply during periods of malfunction, but the work practice standards that address operation and maintenance and that are required by 40CFR63.342(f) must be followed during malfunctions. Condition 12: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.342(b)(2 ), Subpart N

Air Pollution Control Permit Conditions Page 15 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 Item 12.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 12.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: If an owner or operator is controlling a group of tanks with a common add-on air pollution control device, the emission limitations of paragraphs (c), (d), and (e) of this section apply whenever any one affected source is operated. L.D. McCauley utilizes a packed bed scrubber to control emissions from a group of tanks used for chromium, nickel, and zinc plating. However, the add-on control device is not the method used to comply with this chromium standard. The chromium tanks are controlled by utilizing a chemical fume suppressant containing a wetting agent, as indicated in paragraph (d)(2). As such, this section does not apply under current operating conditions. L.D. McCauley will be required to comply with this section when the chemical fume suppressant is no longer used and the chromium emissions are controlled only by the packed bed scrubber. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 13: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.342(d)(2 ), Subpart N Item 13.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s):

Air Pollution Control Permit Conditions Page 16 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 CAS No: 007440-47-3 CHROMIUM Item 13.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: An owner and operator of a decorative electroplating facility or anodizing facility utilizing chemical fume suppressants or wetting agents may not allow the surface tension of the electroplating or anodizing bath contained within the affected source to exceed 45 dynes per centimeter at any time during operation of the tank. Parameter Monitored: SURFACE TENSION Upper Permit Limit: 45 dynes per centimeter Reference Test Method: 40CFR63Method 306B Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 14: Applicability of work practice standards Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.342(f)(1 ), Subpart N Item 14.1: This Condition applies to Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Item 14.2: The work practice standards of 40CFR63.342 address operation and maintenance practices. All owners or operators subject to the standards in section 63.342(c) and 63.342(d) are subject to these work practice standards. At all times, including periods of startup, shutdown, and malfunction, owners or operators shall operate and maintain any affected source, including associated air pollution control devices and monitoring equipment, in a manner consistent with good air pollution control practices, consistent with the operation and maintenance plan required by paragraph (f)(3) of section 63.342. Malfunctions shall be corrected as soon as practicable after their occurrence in accordance with the operation and maintenance plan required by paragraph (f)(3) of section 63.342. Operation and maintenance requirements established pursuant to section 112 of the Act are enforceable

Air Pollution Control Permit Conditions Page 17 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 independent of emission limitations or other requirements in relevant standards. Condition 15: Acceptable work practices Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.342(f)(2 ), Subpart N Item 15.1: This Condition applies to Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Item 15.2: The work practice standards of Section 63.342 address operation and maintenance practices. All owners or operators subject to the standards in paragraph (c) and (d) of section 63.342 are subject to these work practices. Determination of whether acceptable operation and maintenance procedures are being used will be based on information available to the Administrator, which may include, but is not limited to, monitoring results; review of the operation and maintenance plan, procedures, and records; and inspection of the source. Based on the results of a determination made under 63. 342(f)(2)(i), the Administrator may require that an owner or operator of an affected source make changes to the operation and maintenance plan required by 63.342(f)(3) for that source. Revisions may be required if the Administrator finds that the plan: (A) Does not address a malfunction that has occurred; (B) Fails to provide for the operation of the affected source, the air pollution control system and process monitoring equipment during a malfunction in a manner consistent with good air pollution control practices; or (C) Does not provide adequate procedures for correcting malfunctioning process equipment, air pollution control techniques, or monitoring equipment as quickly as possible. Condition 16: Operation and maintenance plan Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.342(f)(3 ), Subpart N Item 16.1: This Condition applies to Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Item 16.2: The owner or operator of an affected source subject to the work practices of 40CFR63.342(f) shall prepare an operation and maintenance plan to be implemented no later than the compliance date. The plan shall be incorporated by reference into the source's Title V permit, if and when a Title V permit is required. The plan shall include the following elements:

Air Pollution Control Permit Conditions Page 18 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 (A) The plan shall specify the operation and maintenance criteria for the affected source, the add-on air pollution control device (if such a device is used to comply with the emission limits), and the process and control system monitoring equipment, and shall include a standardized checklist to document the operation and maintenance of this equipment; (B) For sources using an add-on air pollution control device or monitoring equipment to comply with Subpart N, the plan shall incorporate the work practice standards for that device or monitoring equipment, as identified in Table 1 of Subpart N, if the equipment used is identified in Table 1; (C) If the specific equipment used is not identified in Table 1 of Subpart N, the plan shall incorporate proposed work practice standards. These proposed work practice standards shall be submitted to the Administrator for approval as part of the submittal required under section 63. 343(d); (D) The plan shall specify procedures to be followed to ensure that equipment or process malfunctions due to poor maintenance or other preventable conditions do no occur; and(E) The plan shall include a systematic procedure for identifying malfunctions of process equipment, addon air pollution control devices, and process and control system monitoring equipment and for implementing corrective actions to address such malfunctions. If the operation and maintenance plan fails to address or inadequately addresses an event that meets the characteristics of a malfunction at the time the plan is initially developed, the owner or operator shall revise the operation and maintenance plan within 45 days after such an event occurs. The revised plan shall include procedures for operating and maintaining the process equipment, add-on air pollution control device, or monitoring equipment during similar malfunction events, and a program for corrective action for such events. Recordkeeping associated with the operation and maintenance plan is identified in section 63.346(b). Reporting associated with the operation and maintenance plan is identified in sections 63.347 (g) and (h) and paragraph (f)(3)(iv) of section 63.342. If actions taken by the owner or operator during periods of malfunction are inconsistent with the procedures specified in the operation and maintenance plan required by paragraph (f)(3)(i) of section 63.342, the owner or operator shall record the actions taken for that event and shall report by p hone such actions within 2 working days after commencing actions inconsistent with the plan. This report shall be followed by a letter within 7 working days after the end of the event, unless the owner or operator makes alternative reporting arrangements, in advance, with the Administrator. The owner or operator shall keep the written oper ation and maintenance plan on record after it is developed to be made available for inspection, upon request, by the Administrator for the life of the affected source or until the source is no longer subject to the provisions of subpart N. In addition, if the operation and maintenance plan is revised, the owner or operator shall keep previous (i.e., superseded) versions of the operation and maintenance plan on record to be made available for inspection, upon request, by the Administrator for a period of 5 years after each revision to the plan. To satisfy the requirements of paragraph (f)(3) of section 63.342, the owner or operator may use

Air Pollution Control Permit Conditions Page 19 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 applicable standard operating procedure (SOP) manuals, Occupational Safety and Health Administration (OSHA) plans, or other existing plans, provided the alternative plans meet the requirements of section 63.342. Condition 17: Compliance with emission standard Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.342(g) , Subpart N Item 17.1: This Condition applies to Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Item 17.2: The standards of 40CFR63 Subpart N that apply to chromic acid baths shall not be met by using a reducing agent to change the form of chromium from hexavalent to trivalent. Condition 18: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.343(a)(1 )(i), Subpart N Item 18.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 18.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator of an existing affected source shall comply with the emission limitation no later than 1 year after January 25, 1995, if the affected source is a decorative chromium electroplating tank. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 19: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date

Air Pollution Control Permit Conditions Page 20of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032
Applicable Federal Requirement: 40CFR 63.343(a)(2 ), Subpart N Item 19.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 19.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator of a new or reconstructed affected source that has initial startup after January 25, 1995, shall comply immediately upon startup of the source. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 20: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.343(a)(3 ), Subpart N Item 20.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 20.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator of an existing area source that increases actual or potential emissions of hazardous air pollutants such that the area source becomes a major

Air Pollution Control Permit Conditions Page 21 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 source must comply with the provisions for existing major sources, including the reporting provisions of 40CFR63.347(g), immediately upon becoming a major source. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 21: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.343(b)(2 ), Subpart N Item 21.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 21.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: If the owner or operator of an affected source meets all of the following criteria, an initial performance test is not required to be conducted under this subpart: (i) The affected source is a decorative chromium electroplating tank or a chromium anodizing tank; and (ii) A wetting agent is used in the plating or anodizing bath to inhibit chromium emissions from the affected source; and (iii) The owner or operator complies with the applicable surface tension limit of 40CFR63. 342(d)(2) as demonstrated through the continuous compliance monitoring required by 40CFR63.343(c)(5)(ii). Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 22: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date

Air Pollution Control Permit Conditions Page 22 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032
Applicable Federal Requirement: 40CFR 63.343(c)(5 ), Subpart N Item 22.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 22.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: During the initial performance test, the owner or operator of an affected source complying with the emission limitations in §63.342 thr ough the use of a wetting agent in the electroplating or anodizing bath shall determine the outlet chromium concentration using the procedures in §63.344(c). The owner or operator shall establish as the site-specific operating parameter the surface tension of the bath using Method 306B, appendix A of Part 63, setting the maximum value that corresponds to compliance with the applicable emission limitation. In lieu of establishing the maximum surface tension during the performance test, the owner or operator may accept 45 dynes/cm as the maximum surface tension value that corresponds to compliance with the applicable emission limitation. However, the owner or operator is exempt from conducting a performance test only if the criteria of paragraph (b)(2) of Section 63.343 are met. On and after the date on which the initial performance test is required to be completed under §63.7, the owner or operator of an affected source shall monitor the surface tension of the electroplating or anodizing bath. Operation of the affected source at a surface tension greater than the value established during the performance test, or greater than 45 dynes/cm if the owner or operator is using this value in accordance with paragraph (c)(5)(i) of

Air Pollution Control Permit Conditions Page 23 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 section 63.343, shall cons titute noncompliance with the standards. The surface tension shall be monitored according to the following schedule: (A) The surface tension shall be measured once every 4 hours during operation of the tank with a stalagmometer or a tensiometer as specified in Method 306B, appendix A of Part 63. (B) The time between monitoring can be increased if there have been no exceedances. The surface tension shall be measured once every 4 hours of tank operation for the first 40 hours of tank operation after the compliance date. Once there are no exceedances during 40 hours of tank operation, surface tension measurement may be conducted once every 8 hours of tank operation. Once there are no exceedances during 40 hours of tank operation, surface tension measurement may be conducted once every 40 hours of tank operation on an ongoing basis, until an exceedance occurs. The minimum frequency of monitoring allowed by Subpart N is once every 40 hours of tank operation. (C) Once an exceedance occurs as indicated through surface tension monitoring, the original monitoring schedule of once every 4 hours must be resumed. A subsequent decrease in frequency shall follow the schedule laid out in paragraph (c)(5)(ii)(B) of section 63.343. Once a bath solution is drained from the affected tank and a new solution added, the original monitoring schedule of once every 4 hours must be resumed, with a decrease in monitoring frequency allowed following the procedures of paragraphs (c)(5)(ii) (B) and (C) of section 63.343. Parameter Monitored: SURFACE TENSION Upper Permit Limit: 45 dynes per centimeter Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Averaging Method: MAXIMUM - NOT TO BE EXCEEDED AT ANY TIME (INSTANTANEOUS/DISCRETE OR GRAB) Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 23: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.344(c) , Subpart N

Air Pollution Control Permit Conditions Page 24 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 Item 23.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 23.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Each owner or operator subject to the provisions of this subpart and required by 40CFR63.343(b) to c onduct an initial performance test shall use the test methods identified in this section todemonstrate compliance with the standards in 40CFR63.342. Met hod 306B, "Surf ace Tension Measurement and Recordkeeping for Tanks Used at Decorative Chromium and Anodizing Facilities," appendix A of 40CFR63 shall be used to measure the surface tension of electroplating and anodizing baths. Alternative test methods may also be used if the method has been validated using Method 301, appendix A of this part and if approved by the Administrator. Procedures for requesting and obtaining approval are contained in 40CFR63.7(f). Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 24: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.346(a) , Subpart N Item 24.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM

Air Pollution Control Permit Conditions Page 25 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032

Item 24.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator of each affected source subject to 40CFR 63 Subpart N shall fulfill all recordkeeping requirements outlined in section 63. 346 and in the General Provisions to 40CFR 63 (40CFR63 Subpart A). The records specific for Subpart N are listed as items numbered 1 through 16 under section 63. 346(b). Subpart A requirements are specified in Table 1 to Subpart N. They are listed as follows: 63.10(a)(3): If any State requires a report that contains all the information required in a report listed in Subpart A, an owner or operator may send the Administrator a copy of the report sent to the State to satisfy the requirements of Subpart A for that report.
63.10(a)(4(ii): After a State has been delegated the authority to implement and enforce recordkeeping and reporting requirements established under this part, the owner or operator of an affected source in such State subject to such requirements shall submit reports to the delegated State authority (which may be the same as the permitting authority). In addition, if the delegated (permitting) authority is the State, the owner or operator shall send a copy of each report submitted to the State to the appropriate Regional Office of the EPA, as specified in paragraph (a)(4)(i) of section 63.10. The Regional Office may waive this requirement for any reports at its discretion. 63.10(a)(5): If an owner or operator of an affected source in a State with delegated authority is required to submit periodic reports under Part 63 to the State, and if the State has an established timeline for the submission of periodic reports that is consistent with the reporting frequency(ies) specified for such source under Part 63, the owner or operator may change the dates by which periodic reports under Part 63 shall be submitted (without changing the frequency of reporting) to be consistent with

Air Pollution Control Permit Conditions Page 26 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 the State's schedule by mutual agreement between the owner or operator and the State. For each relevant standard established pursuant to section 112 of the Act, the allowance in the previous sentence applies in each State beginning 1 year after the affected source's compliance date for that standard. Procedures governing the implementation of this provision are specified in §63.9(i). 63.10(a)(6): If an owner or operator supervises one or more stationary sources affected by more than one standard established pursuant to section 112 of the Act, he/she may arrange by mutual agreement between the owner or operator and the Administrator (or the State permitting authority) a common schedule on which periodic reports required for each source shall be submitte d throughout the year. The allowance in the previous sentence applies in each State beginning 1 year after the latest compliance date for any relevant standard established pursuant to section 112 of the Act for any such affected source(s). Procedures governing the implementation of this provision are specified in §63.9(i). 63.10(a)(7): If an owner or operator supervises one or more stationary sources affected by standards established pursuant to section 112 of the Act (as amended November 15, 1990) and standards set under part 60, part 61, or both such parts of this chapter, he/she may arrange by mutual agreement between the owner or operator and the Administrator (or the State permitting authority) a common schedule on which periodic reports required by each relevant (i.e., applicable) standard shall be submitted throughout the year. The allowance in the previous sentence applies in each State beginning 1 year after the stationary source is required to be in comp liance with the relevant section 112 standard, or 1 year after the stationary source is required to be in comp liance with the applicable part 60 or part 61 standard, whichever is latest. Procedures governing the implementation of this provision are specified in §63.9(i). 63.10(b): The owner or operator of an affected source subject to the provisions of Part 63 shall maintain files of all information (including all reports and notifications) required by Part 63 recorded in a form suitable and readily available for expeditious inspection and review. The files shall be retained for at least 5

Air Pollution Control Permit Conditions Page 27 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. At a minimum, the most recent 2 years of data shall be retained on site. The remaining 3 years of data may be retained off site. Such files may be maintained on microfilm, on a computer, on computer floppy disks, on magnetic tape disks, or on microfiche. Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 25: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.346(b) , Subpart N Item 25.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 25.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator of an affected source subject to the provisions of 40CFR 63 Subpart N shall maintain the following records for such source: (1) Inspection records for the add-on air pollution control device, if such a device is used, and monitoring equipment, to document that the inspection and maintenance required by the work practice standards of §63.342(f) and Table 1 of §63.342 have taken pl ace. The record can take the form of a checklist and should identify the device inspected, the date of inspec tion, a brief description of the working condition of the device during the inspection, and any actions taken to correct deficiencies found during the inspection. (2) Records of all maintenance performed on the affected source, the add-on air pollution control device, and monitoring equipment; (3) Records of the occurrence, duration, and cause (if known) of each malfunction of process, add-on air

Air Pollution Control Permit Conditions Page 28 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 pollution control, and monitoring equipment; (4) Records of actions taken during periods of malfunction when such actions are inconsistent with the operation and maintenance plan; (5) Other records, which may take the form of checklists, necessary to demonstrate consistency with the provisions of the operation and maintenance plan required by §63.342(f)(3); (6) Test reports documenting results of all performance tests; (7) All measurements as may be necessary to determine the conditions of performance tests, including measurements necessary to determine compliance with the special compliance procedures of §63.344(e); (8) Records of monitoring data required by §63.343(c) that are used to demonstrate compliance with the standard including the date and time the data are collected; (9) The specific identification (i.e., the date and time of commencement and completion) of each period of excess emissions, as indicated by monitoring data, that occurs during malfunction of the process, add-on air pollution control, or monitoring equipment; (10) The specific identification (i.e., the date and time of commencement and completion) of each period of excess emissions, as indicated by monitoring data, that occurs during periods other than malfunction of the process, add-on air pollution control, or monitoring equipment; (11) The total process operating time of the affected source during the reporting period; (12) Records of the actual cumulative rectifier capacity of hard chromium electroplating tanks at a facility expended during each month of the reporting period, and the total capacity expended to date for a reporting period, if the owner or operator is using the actual cumulative rectifier capacity to determine facility size in accordance with §63. 342(c)(2); (13) For sources using fume suppressants to comply with the standards, records of the date and time that fume suppressants are added to the electroplating or anodizing bath; (14) For sources complying with §63.342(e), records of the bath components purchased, with the wetting agent clearly identified as a bath constituent contained in one of the components; (15) Any information demonstrating whether a source is meeting the requirements for a waiver of recordkeeping or

Air Pollution Control Permit Conditions Page 29 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 reporting requirements, if the source has been granted a waiver under §63.10(f); and (16) All documentation supporting the notifications and reports required by §63.9, §63.10, and §63.347. Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 26: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.346(c) , Subpart N Item 26.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 26.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: All records required by 40CFR63 Subpart N shall be maintained for a period of 5 years in accordance with section 63.10(b)(1). Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 27: Reporting Requirements Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.347(a) , Subpart N Item 27.1: This Condition applies to Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Item 27.2: The owner or operator of each affected source subject to 40CFR63 Subpart N shall fulfill all reporting requirements outlined in section 63. 347 and in the General Provisions to 40 CFR part 63. General Provisions requirements are identified in Table 1 of Subpart N. These reports shall be made to the Administrator at the appropriate address as identified in §63.13 or to

Air Pollution Control Permit Conditions Page 30of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 the delegated State authority. (1) Reports may be sent by U.S. mail, fax, or by another courier. (i) Submittals sent by U.S. mail shall be postmarked on or before the specified date. (ii) Submittals sent by other methods shall be received by the Administrator on or before the specified date. (2) If acceptable to both the Administrator and the owner or operator of an affected source, reports may be submitted on electronic media. Condition 28: Initial Notification for existing sources Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.347(c)(1 ), Subpart N Item 28.1: This Condition applies to Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Item 28.2: The owner or operator of an affected source that has an initial startup before January 25, 1995, shall notify the Administrator in writing that the source is subject to Subpart N. The notification was to be submitted no later than 180 calendar days after January 25, 1995, and was to contain the following information: (i) The name, title, and address of the owner or operator; (ii) The address (i.e., physical location) of each affected source; (iii) A statement that subpart N of Part 63 is the basis for this notification; (iv) Identification of the applicable emission limitation and compliance date for each affected source; (v) A brief description of each affected source, including the type of process operation performed; (vi) For sources performing hard chromium electropl ating, the maximum potential cumulative potential rectifier capacity; (vii) For sources performing hard chromium electroplating, a statement of whether the affected source(s) is located at a small or a large, hard chromium electroplating facility and whether this will be demonstrated through actual or maximum potential cumulative rectifier capacity; (viii) For sources performing hard chromium electroplating tanks, a statement of whether the owner or operator of an affected source(s) will limit the maximum potential cumulative rectifier capacity in accordance with §63. 342(c)(2) such that the hard chromium electroplating fac ility is considered small; and (ix) A statement of whether the affected source is located at a major source or an area source as defined in §63.2. Condition 29: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.347(c)(2 ), Subpart N Item 29.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR

Air Pollution Control Permit Conditions Page 31 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032
Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 29.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator of a new or reconstructed affected source that has an initial startup after January 25, 1995 shall submit an initial notification (in addition to the notification of construction or reconstruction required by 40CFR63.345(b)), as follows: (i) A notification of the date when construction or reconstruction was commenced, shall be submitted no later than 30 calendar days after such date, if construction or reconstruction was commenced after January 25, 1995; and (ii) A notification of the actual date of startup of the source shall be submitted within 30 calendar days after such date. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 30: Notification of compliance status Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.347(e)(1 ), Subpart N Item 30.1: This Condition applies to Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Item 30.2: A notification of compliance status is required each time that an affected source becomes subject to the requirements of 40CFR 63 Subpart N. Condition 31: Required content for notification of compliance status Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.347(e)(2 ), Subpart N Item 31.1: This Condition applies to Emission Unit: 1-PLANT Emission Point: 09104

Air Pollution Control Permit Conditions Page 32 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 Process: SCR Item 31.2: The notification of compliance status shall be submitted to the New York State Department of Environmental Conservation Regional Office. A copy shall also be sent to the United States Environmental Protection Agency Region II office. The notification shall list for each affected source: (i) The applicable emission limitation and the methods that were used to determine compliance with this limitation; (ii) If a performance test is required by Subpart N, the test report documenting the results of the performance test, which contains the elements required by §63.344(a), including measurements and calculations to support the special compliance provisions of §63.344(e) if these are being followed; (iii) The type and quantity of hazardous air pollutants emitted by the source reported in mg/dscm or mg/hr if the source is using the special provisions of §63.344(e) to comply with the standards. (If the owner or operator is subject to the construction and reconstruction provisions of §63.345 and had previously submitted emission estimates, the owner or operator shall state that this report corrects or verifies the previous estimate.) For sources not required to conduct a performance test in accordance with §63. 343(b), the surface tension measurement may fulfill this requirement; (iv) For each monitored parameter for which a compliant value is to be established under §63.343(c), the specific operating parameter value, or range of values, that corresponds to compliance with the applicable emission limit; (v) The methods that will be used to determine continuous compliance, including a description of monitoring and reporting requirements, if methods differ from those identified in this subpart; (vi) A description of the air pollution control technique for each emission point; (vii) A statement that the owner or operator has completed and has on file the operation and maintenance plan as required by the work practice standards in §63.342(f); (viii) If the owner or operator is determining facility size based on actual cumulative rectifier capacity in accordance with §63. 342(c)(2), records to support that the fac ility is small. For existing sources, records from any 12-month period preceding the compliance date shall be used or a description of how operations will change to meet a small designation shall be provided. For new sources, records of projected rectifier capacity for the first 12-month period of tank operation shall be used; (ix) A statement by the owner or operator of the affected source as to whether the source has complied with the provisions of this subpart. Condition 32: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.347(e)(4 ), Subpart N Item 32.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s):

Air Pollution Control Permit Conditions Page 33 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 CAS No: 007440-47-3 CHROMIUM Item 32.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: For sources that are not required to complete a performance test in accordance with 40CFR63. 343(b), the notification of compliance status shall be submitted to the Administrator no later than 30 days after the compliance date specified in 40CFR63.343(a). Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 33: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.347(h)(1 ), Subpart N Item 33.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 33.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator of an affected source that is located at an area source site shall prepare a summary report to document the ongoing compliance status of the affected source. The report shall be completed annually on a calendar year basis and retained on site except as provided in 40CFR63.347(h)(2). The reports shall be made available to the Administrator upon request. The report shall be completed annually except as provided in paragraph 40CFR63.347(h)(2). The report must contain the following information:

Air Pollution Control Permit Conditions Page 34 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032
(1) The company name and address of the affected source; (2) An identification of the operating parameter that is monitored for compliance determ ination, as required by 40CFR63.343(c); (3) The relevant emission limitation for the affected source, and the operating parameter value, or range of values, that correspond to compliance with this emission limitation as specified in the notification of compliance status required by paragraph (e) of section 63.347; (4) The beginning and ending dates of the reporting period; (5) A description of the type of process performed in the affected source; (6) The total operating time of the affected source during the reporting period; (7) A summary of operating parameter values, including the total duration of excess emissions expressed as a percent of the total source operating time during the reporting period, and a breakdown of the total duration of excess emissions during the reporting period into those that are due to process upsets, control equipment malfunctions, other known causes, and unknown causes; (8) A certification by a responsible official, as defined in 40CFR63.2, that the work practice standards in 40CFR63.342(f) were followed in accordance with the operation and maintenance plan for the source; (9) If the operation and maintenance plan required by 40CFR63.342(f)(3) was not followed , an explanation of the reasons for not following the provisions, an assessment of whether any excess emission and/or parameter monitoring exceedances are believed to have occurred, and a copy of the report(s) required by 40CFR63.342(f)(3)(iv) documenting that the operation and maintenance plan was not followed; (10) A description of any changes in monitoring, processes, or controls since the last reporting period; (11) The name, title, and signature of the responsible official who is certifying the accuracy of the report; and (12) The date of the report. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION

Air Pollution Control Permit Conditions Page 35 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032

Condition 34: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.347(h)(2 ), Subpart N Item 34.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 34.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: (i) If both of the following conditions are met, semiannual reports shall be prepared and submitted to the Administrator: (A) The total duration of excess emissions (as indicated by the monitoring data collected by the owner or operator of the affected source in accordance with 40CFR63. 343(c)) is 1 percent or greater of the total operating time for the reporting period; and (B) The total duration of malfunctions of the add-on air pollution control device and monitoring equipment is 5 percent or greater of the total operating time. (ii) Once an owner or operator of an affected source reports an exceedance as defined above, ongoing compliance status reports shall be submitted semiannually until a request to reduce reporting frequency under paragraph (h)(3) of this section is approved. (iii) The Administrator may determine on a case-by-case basis that the summary report shall be completed more frequently and submitted, or that the annual report shall be submitted instead of being retained on site, if these measures are necessary to accurately assess the compliance status of the source. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION

Air Pollution Control Permit Conditions Page 36 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 35: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.347(h)(3 )(i), Subpart N Item 35.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 35.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: An owner or operator who is required to submit ongoing compliance status reports on a semiannual (or more frequent) basis, or is required to submit its annual report instead of retaining it on site, may reduce the frequency of reporting to annual and/or be allowed to maintain the annual report on site if all of the following conditions are met: (A) For 1 full year (e.g., 2 semiannual or 4 quarterly reporting periods), the ongoing compliance status reports demonstrate that the affected source is in compliance with the relevant emission limit; (B) The owner or operator continues to comply with all applicable recordkeeping and monitoring requirements of subpart A of this part and this subpart; and (C) The Administrator does not object to a reduced reporting frequency for the affected source, as provided in paragraphs (h)(3)(ii) and (iii) of this section. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 36: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.347(h)(3 )(ii), Subpart N

Air Pollution Control Permit Conditions Page 37 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032

Item 36.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 36.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The frequency of submitting ongoing compliance status reports may be reduced only after the owner or operator notifies the Administrator in writing of his or her intention to make such a change, and the Administrator does not object to the intended change. In deciding whether to approve a reduced reporting frequency, the Administrator may review information concerning the source's previous performance history during the 5-year recordkeeping period prior to the intended change, or the recordkeeping period since the source's compliance date, whichever is shorter. Records subject to review may include performance test results, monitoring data, and evaluations of an owner or operator's conformance with emission limitations and work practice standards. Such information may be used by the Administrator to make a judgement about the sources potential for noncompliance in the future. If the Administrator disapproves the owner or operator's request to reduce reporting frequency, the Administrator will notify the owner or operator in writing within 45 days after receiving notice of the owner or operator's intentions. The notification from the Administrator to the owner or operator will specify the grounds on which the disapproval is based. In the absence of a notice of disapproval within 45 days, approval is automatically granted. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 37: Compliance Demonstration Effective between the dates of 02/19/2003 and Permit Expiration Date

Air Pollution Control Permit Conditions Page 38 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032
Applicable Federal Requirement: 40CFR 63.347(h)(3)( iii), Subpart N Item 37.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PLANT Emission Point: 09104 Process: SCR Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 37.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: As soon as the monitoring data required by 40CFR63. 343(c) show that the source is not in compliance with the relevant emission limit, the frequency of reporting shall revert to semiannual, and the owner shall state this exceedance in the ongoing compliance status report for the next reporting period. After demonstrating ongoing compliance with the relevant emission limit for another full year, the owner or operator may again request approval from the Administrator to reduce reporting frequency as allowed by paragraph (h)(3) of this section. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION

Air Pollution Control Permit Conditions Page 39 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032

STATE ONLY ENFORCEABLE CONDITIONS ** ** Facility Level  

NOTIFICATION OF GENERAL PERMITTEE OBLIGATIONS This section contains terms and conditions which are not federally enforceable. Permittees may also have other obligations under regulations of general applicability Item A: Public Access to Recordkeeping for Facilities With State Facility Permits - 6 NYCRR Part 201-1.10(a) Where emission source owners and/or operators keep records pursuant to compliance with the operational flexibility requirements of 6 NYCRR Subpart 201-5.4(b)(1) , and/or the emission capping requirements of 6 NYCRR Subparts 201-7.2(d), 201-7.3(f), 201-7.3(g), 201-7.3(h)(5), 201-7.3(i) and 201-7.3(j), the Department will make such records available to the public upon request in accordance with 6 NYCRR Part 616 - Public Access to Records. Emission source owners and/or operators must submit the record s required to comply with the request within sixty working days of written notification by the Department of receipt of the request. Item B: 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 devi ces in compliance with all applicable Parts of this Chapter and 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 f acility 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

Air Pollution Control Permit Conditions Page 40of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 law.

STATE ONLY APPLICABLE REQUIREMENTS The following conditions are state only enforceable.

Condition 38: Contaminant List Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable State Requirement: ECL 19-0301 Item 38.1: Emissions of the following contaminants are subject to contaminant specific requirements in this permit(emission limits, control requirements or compliance monitoring conditions).
CAS No: 007440-47-3 Name: CHROMIUM CAS No: 007647-01-0 Name: HYDROGEN CHLORIDE CAS No: 007440-02-0 Name: NICKEL METAL AND INSOLUBLE COMPOUNDS CAS No: 0NY075-00-0 Name: PARTICULATES CAS No: 001310-73-2 Name: SODIUM HYDROXIDE CAS No: 007440-66-6 Name: ZINC Condition 39: Unavoidable noncompliance and violations Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable State Requirement: 6NYCRR 201-1.4 Item 39.1: At the discretion of the commissioner a violation of any applicable emission standard for necessary scheduled equipment maintenance, start-up/shutdown conditions and malfunctions or upsets may be excused if such violations are unavoidable. The following actions and recordkeeping and reporting requirements must be adhered to in such circumstances. (a) The facility owner and/or operator shall comp ile and maintain records of all equipment

Air Pollution Control Permit Conditions Page 41 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 maintenance or start-up/shutdown activities when they can be expected to result in an exceedance of any applicable emission standard, and shall submit a report of such activities to the commissioner's representative when requested to do so in writing or when so required by a condition of a permit issued for the corresponding air contamination source except where conditions elsewhere in this permit which contain more stringent reporting and notification provisions for an applicable requirement, in which case they supercede those stated here. Such reports shall describe why the violation was unavoidable and shall include the time, frequency and dur ation of the maintenance and/or start-up/shutdown activities and the identification of air contaminants, and the estimated emission rates. If a facility owner and/or operator is subject to continuous stack monitoring and quarterly reporting requirements, he need not submit reports for equipment maintenance or start-up/shutdown for the facility to the commissioner's representative. (b) In the event that emissions of air contaminants in excess of any emission standard in 6 NYCRR Chapter III Subchapter A occur due to a malfunction, the facility owner and/or operator shall report such malfunction by telephone to the commissioner's representative as soon as possible during normal working hours, but in any event not later than two working days after becoming aware that the malfunction occurred. Within 30 days thereafter, when requeste d in writing by the commissi oner's representative, the facility owner and/or operator shall submit a written report to the commissioner's representative describing the malfunction, the corrective action taken, identification of air contaminants, and an estimate of the emission rates. These reporting requirements are superceded by conditions elsewhere in this permit which contain reporting and notification provisions for applicable requirements more stringent than those above. (c) The Department may also require the owner and/or operator to include in reports described under (a) and (b) above an estimate of the maximum ground level concentration of each air contaminant emitted and the effect of such emissions depending on the deviation of the malfunction and the air contaminants emitted. (d) In the event of maintenance, start-up/shutdown or malfunction conditions which result in emissions exceeding any applicable emission standard , the facility owner and/oroperator shall take appropriate action to prevent emissions which will result in contravention of any applicable ambient air quality standard. Reasonably available control technology, as determined by the commissioner,. shall be applied during any maintenance, start-up/shutdown or malfunction condition subject to this paragraph. (e) In order to have a violation of a federal regulation (such as a new source performance standard or national emissions standard for hazardous air pollutants) excused, the specific federal regulation must provide for an affirmative defense during start-up, shutdowns, malfunctions or upsets. Condition 40: Emission Unit Definition Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable State Requirement: 6NYCRR 201-5 Item 40.1: The facility is authorized to perform regulated processes under this permit for: Emission Unit: 1-PLANT Emission Unit Description: This emission unit comprises the entire facility. The

Air Pollution Control Permit Conditions Page 42 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 associated emission points include 09104 (zinc/nickel/chromium plating), 02701 (flap wheel polishing), and 02702 (buffing). The processes include heat treating (0HT), polishing (HAR), buffing (TOP), and plating/packed scrubber (SCR). Condition 41: Air pollution prohibited Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable State Requirement: 6NYCRR 211.2 Item 41.1: No person shall cause or allow emissions of air contaminants to the outdoor atmosphere of such quantity, characteristic or duration which are injurious to human , plant or animal life or to property, or which unreasonably interfere with the comfortable enjoyment of life or property. Notwithstanding the existence of specific air quality standards or emission limits, this prohibition applies, but is not limited to, any particulate, fume, gas, mist, odor, smoke, vapor, pollen, toxic or deleterious emission, either alone or in combination with others.

** ** Emission Unit Level **** Condition 42: Emission Point Definition By Emission Unit Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable State Requirement: 6NYCRR 201-5 Item 42.1: The following emission points are included in this permit for the cited Emission Unit: Emission Unit: 1-PLANT Emission Point: 02701 Height (ft.): 30 Diameter (in.): 17 Emission Point: 02702 Height (ft.): 32 Diameter (in.): 16 Emission Point: 09104 Height (ft.): 32 Length (in.): 47 Width (in.): 62 Condition 43: Process Definition By Emission Unit Effective between the dates of 02/19/2003 and Permit Expiration Date Applicable State Requirement: 6NYCRR 201-5

Air Pollution Control Permit Conditions Page 43 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 Item 43.1: This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: 1-PLANT Process: 0HT Process Description: Emissions from the process identified as 0HT, inlcude minor quench oil emissions from the heat treat furnaces. The quench oil is designed to extract heat rapidly from parts during the quenching process. There are three heat treat furnaces identified as 01301 (blue furn ace), 01302 (purple furnace), and 01304 (red furn ace). Emission Source/Control: 01301 - Process Emission Source/Control: 01302 - Process Emission Source/Control: 01304 - Process Item 43.2: This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: 1-PLANT Process: HAR Process Description: Emissions from the process identified as HAR, include particles from polishing and buffing of metal parts. The particulate emissions are controlled by a fabric filter identified as 02701 and exhausted thr ough an emission point identified as 02701. The buffing machine associated with the process is identified as BUFF1. Emission Source/Control: 02701 - Control Control Type: FABRIC FILTER Emission Source/Control: BUFF1 - Process Item 43.3: This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: 1-PLANT Process: SCR Process Description: Plating operations including zinc, nickel, and chromium metals. Emissions from these plating tanks are exhausted through a packed bed scrubber identified as 09104. The exhaust from the scrubber is vented through emission point

Air Pollution Control Permit Conditions Page 44 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 09104. The pollutants em itted from this process are heavy metals (zinc, nickel, chromium), sodium hydroxide and hydrochloric acid. The process equipment associated with this process include two chromium electroplating tanks (CHROM, BLCHR), surface tension fume suppressant (SUPPR), three nickel tanks (NICK1, NICK2, NICK3), one zinc tank (ZINC1), one zinc/nickel tank which is 90% zinc/10% nickel alloy (ZNCNI), a zinc acid tank (ACID1), a nickel chromium acid tank (ACID2), a zinc cleaner tank (WASH1), and two nickel chromium cleaners (WASH2, WASH3). Emission Source/Control: 09104 - Control Control Type: GAS SCRUBBER (GENERAL, NOT CLASSIFIED) Emission Source/Control: SUPPR - Control Control Type: CHEMICAL FUME SUPPRESSANT - WETTING AGENT FOR REDUCING SURFACE TENSION Emission Source/Control: ACID1 - Process Emission Source/Control: ACID2 - Process Emission Source/Control: BLCHR - Process Emission Source/Control: CHROM - Process Emission Source/Control: NICK1 - Process Emission Source/Control: NICK2 - Process Emission Source/Control: NICK3 - Process Emission Source/Control: WASH1 - Process Emission Source/Control: WASH2 - Process Emission Source/Control: WASH3 - Process Emission Source/Control: ZINC1 - Process Emission Source/Control: ZNCNI - Process Item 43.4: This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: 1-PLANT Process: TOP

Air Pollution Control Permit Conditions Page 45 of 46 FINALPermit ID: 9-1460-00032/00015 Facility DEC ID: 9146000032 Process Description: Emissions from the process identified as TOP, include particles from polishing and buffing of metal parts. The particulate emissions are controlled by a fabric filter identified as 02702. The exhuast from the fabric filter is vented through emission point 02702. The buffing processing equipment is identifed as BUFF2. Emission Source/Control: 02702 - Control Control Type: FABRIC FILTER Emission Source/Control: BUFF2 - Process

Air Pollution Control Permit Conditions Page 46 of 46 FINAL