### MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

June 4, 2004

NEW SOURCE REVIEW PERMIT TO INSTALL

No. 213

- 01B

ISSUED TO

Perfection Industries, Inc.

LOCATED AT

18571 Weaver Street
Detroit, Michigan 48228

IN THE COU NTY

OF

Wayne

STATE REGISTRATION NUMBER

N0305

The Air Quality Division has approved this Permit to Install, pursuant to the delegation of authority from the Michigan Department of Environmental Quality. This permit is hereby issued in
accordance with and subject to P art 5505(1) of Article II, Chapter I, Part 55 (Air Pollution Control) of P.A. 451 of 1994. Pursuant to Air Pollution Control Rule 336.1201(1), this permit constitutes
the permittee’s authority to install the identified emission unit(s) in accordance with all administrative rules of the Department and the attached conditions

. Operation of the emission unit(s) identified in this Permit to I nstall is allowed pursuant to Rule 336.1201(6).

DATE OF RECEIPT OF ALL INFORMATION REQUIRED BY RULE 203: 

## 5/21/2004

DATE PERMIT TO INSTALL APPROVED: 

## 6/4/2004 SIGNATURE:

DATE PERMIT VOIDED: SIGNATURE:

DATE PERMIT REVOK ED: SIGNATURE:Perfection Industries , Inc. June 4 , 2004

Permit No. 213

- 01B Page 1 of 7

PERMIT TO INSTALL

Table of Contents

Section Page

Alphabetical Listing of Common Abbreviations / Acronyms

................................ ................................ ........... 2

General Conditions

................................ ................................ ................................ ................................ ....... 3

Emission Unit Identification

................................ ................................ ................................ .......................... 5

Flexible Group Identification

................................ ................................ ................................ ........................ 5

Flexible Group Special Conditions

................................ ................................ ................................ ................ 5Perfection Industries , Inc. June 4 , 2004

Permit No. 213

- 01B Page 2 of 7

Common Abbreviations / Acronyms

Common Acronyms Pollutant/Measurement Abbreviations

AQD Air Quality Division B tu British Thermal Unit

ANSI American National Standar ds Institute °C Degrees Celsius

BACT Best Available Control Technology CO Carbon Monoxide

CAA Clean Air Act dscf Dry standard cubic foot

CEM Continuous Emission Monitoring dscm Dry standard cubic meter

CFR Code of Federal Regulations °F Degrees Fahre nheit

COM Continuous Opacity Monitoring gr Grains

EPA Environmental Protection Agency Hg Mercury

EU Emission Unit hr Hour

FG Flexible Group H 2 S Hydrogen Sulfide

GACS Gallon of Applied Coating Solids hp Horsepower

GC General Condition lb Pound

HAP Hazardous Air Pollutant m Meter

HVLP High Volume Low Pressure * mg Milligram

ID Identification mm Millimeter

LAER Lowest Achievable Emission Rate MM Million

MACT Maximum Achievable Control Technology MW Megawatts

MAERS Michigan Air Emissions Reporting System NOx Oxides of Nitrogen

MAP Malfunction Abatement Plan PM Particulate Matter

MDEQ Michigan Department of Environmental Quality PM

- 10 Particulate Matter less than 10 microns diameter

MIOSHA Michigan Occupational Safety & Health

Administ ration pph Pound per hour

MSDS Material Safety Data Sheet ppm Parts per million

NESHAP National Emission Standard for Hazardous Air

Pollutants ppmv Parts per million by volume

NSPS New Source Performance Standards ppmw Parts per million by weight

NSR New Source Review psia Pounds per square inch absolute

PS Performance Specification psig Pounds per square inch gauge

PSD Prevention of Significant Deterioration scf Standard cubic feet

PTE Permanent Total Enclosure sec Seconds

PTI Permit to Install SO 2 Sulfur Dioxide

RACT Reasonable Available Control Technology THC Total Hydrocarbons

ROP Renewable Operating Permit tpy Tons per year

SC Special Condition Number μg Microgram

SCR Selective Catalytic Reduction VOC Volatile Organic Compounds

SRN State Registration Number yr Year

TAC Toxic Air Contaminant

VE Visible Emissions

* For High Volume Low Pressure (HVLP) applicators, the pressure measured at the HVLP gun air cap shall not exceed ten
(10) pounds per square inch gauge (psi g).Perfection Industries , Inc. June 4 , 2004

Permit No. 213

- 01B Page 3 of 7

GENERAL CONDITIONS

1. The process or process equipment covered by this permit shall not be reconstructed, relocated, or
modified, unless a Permit to Install authorizing such action is issued by the Department, except to the extent such action is exempt from the Permit to Install requirements by any applicable rule.

[R336.1201(1)]

2. If the installation, construction, reconstruction, relocation, or modification of the equipment for which
this permit has been ap

proved has not commenced within 18 months, or has been interrupted for 18
months, this permit shall become void unless otherwise authorized by the Department. Furthermore, the
permittee or the designated authorized agent shall notify the Department via th e Supervisor, Permit
Section, Air Quality Division, Michigan Department of Environmental Quality, P

. O

. Box 30260, Lansing, Michigan 48909, if it is decided not to pursue the installation, construction, reconstruction,

relocation, or modification of the equ ipment allowed by this Permit to Install. [R336.1201(4)]

3. If this Permit to Install is issued for a process or process equipment located at a stationary source that is
not subject to the Renewable Operating Permit program requirements pursuant to R336. 1210, operation
of the process or process equipment is allowed by this permit if the equipment performs in accordance

with the terms and conditions of this Permit to Install. [R336.1201(6)(b)]

4. The Department may, after notice and opportunity for a hea ring, revoke this Permit to Install if evidence
indicates the process or process equipment is not performing in accordance with the terms and
conditions of this permit or is violating the Department’s rules or the Clean Air Act. [R336.1201(8),

Section 551 0 of Act 451, PA 1994]

5. The terms and conditions of this Permit to Install shall apply to any person or legal entity that now or hereafter owns or operates the process or process equipment at the location authorized by this Permit to

Install. If the ne w owner or operator submits a written request to the Department pursuant to R336.1219
and the Department approves the request, this permit will be amended to reflect the change of
ownership or operational control. The request must include all of the infor mation required by subrules
(1)(a), (b), and (c) of R336.1219. The written request shall be sent to the District Supervisor, Air
Quality Division, Michigan Department of Environmental Quality. [R336.1219]

6. Operation of this equipment shall not result in the emission of an air contaminant which causes injurious effects to human health or safety, animal life, plant life of significant economic value, or property, or
which causes unreasonable interference with the comfortable enjoyment of life and propert y. [R336.1901]

7. The permittee shall provide notice of an abnormal condition, start

- up, shutdown, or malfunction that
results in emissions of a hazardous or toxic air pollutant which continue for more than one hour in
excess of any applicable standard o r limitation , or emissions of any air contaminant continuing for more

than two hours in excess of an applicable standard or limitation , as required in R ule 912 , to the

Department . The notice shall be provided no t later than two business days after start

- u p, shutdown, or
discovery of the abnormal condition or malfunction. Written reports, if required, must be filed with the

Department

within 10 days after the start

- up or shutdown occurred, within 10 days after the abnormal

conditions or malfunction has bee n corrected

, or within 30 days of discovery of the abnormal condition
or malfunction, whichever is first. The written reports shall include all of the information required in

R ule 912(5)

. [R336.1912]

8. Approval of this permit does not exempt the permit tee from complying with any future applicable
requirements which may be promulgated under Part 55 of 1994 PA 451, as amended or the Federal

Clean Air Act.Perfection Industries , Inc. June 4 , 2004

Permit No. 213

- 01B Page 4 of 7

9. Approval of this permit does not obviate the necessity of obtaining such permits or approvals fr om other
units of government as required by law.

10. Operation of this equipment may be subject to other requirements of Part 55 of 1994 PA 451, as

amended and the rules promulgated thereunder.

11. Except as provided in subrules (2) and (3) or unless t he special conditions of the Permit to Install
include an alternate opacity limit established pursuant to subrule (4) of R336.1301, the permittee shall
not cause or permit to be discharged into the outer air from a process or process equipment a visible

em ission of density greater than the most stringent of the following. The grading of visible emissions

shall be determined in accordance with R336.1303. [R336.1301]

a) A six

- minute average of 20 percent opacity, except for one six

- minute average per hour of not
more than 27 percent opacity.

b) A visible emission limit specified by an applicable federal new source performance standard.

c) A visible emission limit specified as a condition of this permit to install.

12. Collected air contaminants shall be removed as necessary to maintain the equipment at the required
operating efficiency. The collection and disposal of air contaminants shall be performed in a manner so
as to minimize the introduction of contaminants to the outer air. Transport of collect ed air contaminants
in Priority I and II areas requires the use of material handling methods specified in R336.1370(2).

[ R336 .1370]

1 3

. The Department may require the permittee to conduct acceptable performance tests, at the permittee ’s
expense, in accor dance with R336.2001 and R336.2003, under any of the conditions listed in

R336.2001. [ R336 .2001]Perfection Industries , Inc. June 4 , 2004

Permit No. 213

- 01B Page 5 of 7

SPECIAL CONDITIONS

Emission Unit Identification

Emission Unit ID Emission Unit Description Stack Ident ification

EUCHROME2 Hard chrome electroplating tank with a composite mesh
pad system for control which is shared with the other

four hard chrome electro

plating tanks

. SVCHROME1

EUCHROME3 Hard chrome electroplating tank with a composite mesh
pad system fo

r control which is shared with the other

four hard chrome electro

plating tanks

. SVCHROME1

EUCHROME4 Hard chrome electroplating tank with a composite mesh
pad system for control which is shared with the other

four hard chrome electro

plating tanks

. SVCHRO ME1

EUCHROME5 Hard chrome electroplating tank with a composite mesh
pad system for control which is shared with the other

four hard chrome electro

plating tanks

. SVCHROME1

EUCHROME6 Hard chrome electroplating tank with a composite mesh
pad system for co

ntrol which is shared with the other

four hard chrome electro

plating tanks

. SVCHROME1

Changes to the equipment described in this table are subject to the requirements of R336.1201, except as
allowed by R336.1278 to R336.1290.

Flexible Group Identific ation

Flexible Group ID Emission Units Included in Flexible Group Stack Identification

FGCHROME1 EUCHROME2, EUCHROME3, EUCHRO ME4,

EUCHROME5 and

EUCHROME6 SVCHROME1

The following conditions apply to : FGCHROME1

Emission Limits

Pollutant Equipment Limit Time

Period Testing/

Monitoring

Method Applicable

Requirements

1.1a Total

chromium FGCHROME1 0.0 06 milligram per
dry standard cubic
meter, corrected

to

70°F and 29.92
inches Hg Test

Method SC 1.5,

SC 1.7,

SC 1.8,

SC 1.9 R336.1225,

R336.1941

40 CFR Part 63
Subpart N

1.1b Total

chromium FGCHROME1 4.0 * 10

- 4 pph Test

Method SC 1.5,

SC 1.7,

SC 1.8,

SC 1.9 R336.1225,

R336.1941

40 CFR Part 63
Subpart N

Equipment

1.2 The permittee shall not operate FGCHROME1 unless the composite mesh pad system is installed,
maintained, and operated in a satisfactory manner. [R336.1225, R336.1941, 40 CFR Part 63 Subpart N]Perfection Industries , Inc. June 4 , 2004

Permit No. 213

- 01B Page 6 of 7

1.3 The permittee shall equip and maint ain the composite mesh pad system with a differential pressure
monitoring device. [ R336.1225, R336.1910, R336.1941, 40 CFR 63.343(c)]

Process/Operational Limits

1.4 Within 30 calendar days after compliance testing, the permittee shall submit to the AQD District
Supervisor, a n ew approvable operation and maintenance plan only if the pressure drop value is different
than the pressure drop value determined during the previous compliance test . The plan shall contain all
information required by 40 CFR 63.342 (f)(3)(i), which includes the following: [R336.1225, R336.194 1

, 40 CFR Part 63 Subpart N]

a) Operation and maintenance criteria for FGCHROME1, add

- on control device(s), and for the
process and control device(s) monitoring equipment as well as a standardi zed checklist to
document the operation and maintenance of the equipment;

b) The work practice standards for the add

- on control device(s) and monitoring equipment;

c) Procedures to be followed to ensure that equipment or process malfunctions due to poor
maintenance or other preventable conditions do not occur; and

d) A systematic procedure for identifying process equipment, add

- on control device(s) and
monitoring equipment malfunctions and for implementing corrective actions to address such

malfunctions

.

Monitoring

1. 5 The permittee shall perform inspections of the composite mesh pad (CMP) system as follows:

[ R336.1225

, R336.1910, R336.1941, 40 CFR Part 63 Subpart N]

a) Determine pressure drop across the CMP system on a daily basis. If the pressure drop across the

control varie s by more than ±1 inch of water column , from the pressure drop determined during
compliance testing, the variation shall be documented, and the operation and maintenance procedures shall be reviewed. Any corrective action shal l be documented.

b) Visually inspect the CMP system, on a quarterly basis, to ensure there is proper drainage, no
chromic acid build up on the pads, and no evidence of chemical attack on the structural integrity

of the control device.

c) Visually inspect

the back portion of the mesh pad closest to the fan, on a quarterly basis, to ensure there is no breakthrough of chromic acid mist.

d) Visually inspect ductwork from tanks to the CMP system, on a quarterly basis, to ensure there are

no leaks.

e) Perform

wash

- down of composite mesh pads in accordance with manufacturer’s

recommendations.

1.6 The permittee shall monitor emissions and operating and maintenance information in accordance with the
National Emission Standards for Hazardous Air Pollutants as spe cified in 40 CFR Part 63 Subparts A and

N. [R336.1941, 40 CFR Part 63 Subpart N]Perfection Industries , Inc. June 4 , 2004

Permit No. 213

- 01B Page 7 of 7

Testing

1. 7 By September 30, 2004, verification of chromium emission rates from FGCHROME1, by testing at
owner's expense, in accordance with 40 CFR Part 63 Subparts A a nd N, will be required. The permittee
shall notify the District Supervisor in writing of the intention to conduct a performance test at least 6 0
calendar days before the test is scheduled to begin, in accordance with 40 CFR 63.347(d). Stack testing

proce dures and the location of stack testing ports shall be in accordance with the applicable federal
Reference Methods, 40 CFR Part 63 Appendix A. No less than 60 days prior to testing, a complete stack
test plan shall be submitted to the AQD. The final plan must be approved by the AQD prior to testing. Verification of emission rates includes the submittal of a complete report of the test results to the AQD
District Supervisor within 9 0 days following the last date of the test. [R336.1225

, R336.2001,

R336.2 002, R336.2003, 40 CFR Part 63 Subpart N]

Recordkeeping/Reporting/Notification

1 .8 The permittee shall maintain records of inspections required to comply with applicable work practice standards of 40 CFR 63.342(f). Each inspection record shall identify the device inspected, the date,
approximate time of inspection, and a brief description of the working condition of the device during the
inspection. The permittee shall also record any actions taken to correct the deficiencies found during the
inspection . All records shall be kept on file for a period of at least five years and made available to the

Department upon request. [ R336. 1225, R336.1910, R336.1941, 40 CFR Part 63 Subpart N]

1 .9 The permittee shall keep records of emission information and opera ting and maintenance information to comply with the National Emission Standards for Hazardous Air Pollutants as specified in 40 CFR Part 63
Subparts A and N. All source emissions and operating and maintenance information shall be kept on file
for a period of at least five years and made available to the Department upon request. [R336.1941, 40

CFR Part 63 Subpart N]

1 .10 The p

ermittee shall submit the Ongoing Compliance Status notification to the Department in accordance

with 40 CFR Part 63.347: [R336.19 41, 40 CFR Part 63 Subpart N]

Stack/Vent Restrictions

Stack & Vent ID Maximum Area

( square inches) Minimum Height Above

Ground Level (feet) Applicable
Requirements

1.1 1a SVCHROME1 991 26 R336.1225
The exhaust gases shall be discharged unobstructed ve rtically upwards to the ambient air.