STATIONARY SOURCE PERMIT TO CONSTRUCT AND OPERATE

This permit includes designated equipment subject to

National Emission Standards for Hazardous Air Pollutants.

In compliance with the Federal Clean Air Act and the Commonwealth of Virginia Regulations for the Control and Abatement of Air Pollution,

Trident

12000 Vance Davis Drive Charlotte, North Carolina 28269 Registration No.: 52175

is authorized to modify and operate

a hard chromium electroplating facility

located at

833 Liberty Way Chester, Virginia 23836

in accordance with the Conditions of this permit.

Approved on October 8, 2009.

_____________________________________ James E. Kyle, P.E. Air Permit Manager

Permit consists of 9 pages.

Permit Conditions 1 to 28.Trident Registration Number: 52175 October 8, 2009 Page 2

INTRODUCTION

This permit approval is based on the permit application dated January 4, 2007, including amendment information dated February 15, 2007, February 28, 2 007 and October 2, 2009. Any changes in the permit application specifications or any ex isting facilities which alter the impact of the facility on air quality may require a permit. Failure to obtain such a permit prio r to construction may result in enforcement action.

Words or terms used in this permit shall have meaning s as provided in 9 VAC 5-10-10 of the State Air Pollution Control Board Regulations for the Control and Abatement of Air Pollution. The regulatory reference or authority for each condition is listed in parentheses () after each condition.

Annual requirements to fulfill legal obligations to ma intain current stationary source emissions data will necessitate a prompt response by the permittee to re quests by the DEQ or the Board for information to include, as appropriate: process and production data; changes in control equipment; and operating schedules. Such requests for info rmation from the DEQ will either be in writing or by personal contact.

The availability of information submitted to the DEQ or the Board will be governed by applicable provisions of the Freedom of Information Act, §§ 2.2-3700 through 2.2-3714 of the Code of Virginia, § 10.1-1314 (addressing information provided to the Boar d) of the Code of Virginia, and 9 VAC 5-170-60 of the State Air Pollution Control Board Regulations. Info rmation provided to federal officials is subject to appropriate federal law and regulations gover ning confidentiality of such information.

PROCESS REQUIREMENTS

1. Equipment List - Equipment at this facility consists of the following:

Equipment to be Constructed

Reference No

. Equipment Description Rated Capacity Federal Requirements

Chromium Electroplating Process:

P001-Tank 1 Chromium plating tank #1 (2002) 336 gallons MACT, Subpart N (area source)

Dechroming Operations: DC-1 Dechroming tank #1 238 gallons DC-2 Dechroming tank #2 238 gallons

Equipment Exempt from Permitting

Reference No

. Equipment Description Rated Capacity Exemption Citation

Alkali Copper Plating Process: ALP-1 Alkali plating bath tank #1 159 gallons 9 VAC 5-80-1320 C.1

Acid Copper Plating Process: ACP-1 Acid copper plating tank #1 312 gallons 9 VAC 5-80-1320 C.1 ACP-2 Acid copper plating tank #2 312 gallons 9 VAC 5-80-1320 C.1 ACP-3 Acid copper plating tank #3 312 gallons 9 VAC 5-80-1320 C.1 ACP-4 Acid copper plating tank #4 312 gallons 9 VAC 5-80-1320 C.1

Proofing Operations:

PP-1 & PP-2 Two low-volume single rotation proofing presses 4.7 lbs VOC/hr

combined 9 VAC 5-80-1320 C.1Trident Registration Number: 52175 October 8, 2009 Page 3

Wastewater Evaporators: WE-1 Wastewater evaporator (natural gas) 0.6 MMBtu/hr 9 VAC 5-80-1320 B.1.d WE-2 Wastewater evaporator (natural gas) 0.6 MMBtu/hr 9 VAC 5-80-1320 B.1.d

Miscellaneous: -- Four mechanical engravers -- 9 VAC 5-80-1320 C.1 -- One fiber laser for copper engraving -- 9 VAC 5-80-1320 C.1 -- Two milling machines -- 9 VAC 5-80-1320 C.1 -- One lathing machine -- 9 VAC 5-80-1320 C.1

(9 VAC 80-1180 D 3)

2. Emission Controls – Particulate and chromium emissions from the chromium plating tank (Ref. No. P001-Tank 1) shall be controlled by a mesh pad mist eliminator/scrubber in series with a HEPA filter (Ref. No. CD001). The eliminator/scrubber shall be provided with adequate access for inspection and shall be in operation when the chromium plating tank is operating. (9 VAC 5-80-1180 and 9 VAC 5-50-260)

3. Emission Controls – Particulate and chromium emissions from the two (2) dechroming tanks (Ref.

Nos. DC-1 and DC -2) shall be controlled by a mesh pad mist eliminator in series with a HEPA filter (Ref. No. CD002). The eliminator shall maintain a control efficiency for particulates and chromium of no less than 99.0 percent. The eliminator shall be provided with adequate access for inspection and shall be in operation when the two (2) dechroming tanks are operating. (9 VAC 5-80-1180 and 9 VAC 5-50-260)

4. Monitoring Devices - The mesh pad mist eliminator/scrubber (Ref. Nos. CD001) shall be equipped with devices to continuously measure the scrubber liq uid flow rate and differential pressure across the scrubber and mesh pad mist eliminator. Each monitoring device shall be installed, maintained, calibrated and operated in accordance with approved procedures which shall include, as a minimum, the manufacturer's written requirements or recomm endations. Each monitoring device shall be provided with adequate access for inspection and shall be in operation when the scrubber and mesh pad mist eliminator is operating. (9 VAC 5-80-1180 D)

5. Monitoring Device Observation – To ensure good performance, the process/control monitoring device used to continuously measure the scrubber liq uid flow rate and differential pressure across the scrubber and mesh pad mist eliminator shall be observed by the permittee with a frequency of not less than once per day. The permittee shall keep a log of the observations from the process/control monitoring device. The system shall be operated within ± 2 inches of water column of the pressure drop value established during the initial performance test or within the range established during the most recent performance test which demonstrated comp liance with the emission limit in Condition 9. (9 VAC 5-80-1180 D and 40 CFR 63.343(c)(1)(ii))

OPERATING LIMITATIONS

6. Throughput - The maximum chromium plating current for the chroming plating tank (Ref. No. P001- Tank 1) shall not exceed 4,000 amps. (9 VAC 5-80-1180)

7. Throughput - The maximum dechroming plating current fo r the dechroming tanks (Ref. Nos. DC-1 and DC-2) shall not exceed 100 amps each. (9 VAC 5-80-1180)Trident Registration Number: 52175 October 8, 2009 Page 4

8. Requirements by Reference - Except where this permit is more restrictive than the applicable requirement, the MACT equipment as described in Condition 1 shall be operated in compliance with the requirements of 40 CFR 63, Subpart N. (9 VAC 5-80-1180, 9 VAC 5-60-90, and 9 VAC 5-60-100)

EMISSION LIMITS

9. Process Emission Limits - Emissions from the operation of the chromium electroplating process (Ref. Nos. P001-Tank 1) as exhausted from the me sh pad mist eliminator/scrubber (Ref. No. CD001) shall not exceed the limits specified below:

Chromium Compounds 0.015 mg/dscm

These emissions are derived from the estimated ov erall emission contribution from operating limits. Exceedance of the operating limits may be considered credible evidence of the exceedance of emission limits. Compliance with these emission limits may be determined as stated in Conditions 2

and 6. (9 VAC 5-80-1180 and 40 CFR 63.342(c)(2)(i))

10. Visible Emission Limit - Visible emissions from the mesh pad mist eliminator/scrubber exhaust (Ref. No. CD001) shall not exceed 5 per cent opacity as determined by the EPA Method 9 (reference 40 CFR 60, Appendix A). (9 VAC 5-80-1180 and 9 VAC 5-50-260)

11. Visible Emission Limit - Visible emissions from mist eliminator exhaust (Ref. No. CD002) shall not exceed 5 percent opacity as determined by the EPA Method 9 (reference 40 CFR 60, Appendix A). (9 VAC 5-80-1180 and 9 VAC 5-50-260)

INITIAL COMPLIANCE DETERMINATION

12. Stack Test - Initial performance tests shall be conducted for chromium emissions from the mesh pad mist eliminator/scrubber (Ref. No. CD001) using Reference Method 306 or 306A to determine compliance with the emission limit contained in Condition 9. The permittee shall establish the pressure drop across the system as a site-speci fic operating parameter, setting the value that corresponds to compliance with the emission limit contained in Condition 9. The tests shall be performed and demonstrate compliance within 60 days after achieving the maximum production rate at which the facility will be operated but in no event later than 180 days after start-up of the permitted facility. Tests shall be conducted and reported and data reduced as set forth in 9 VAC 5-50-30 and 9 VAC 5-60-30, and the test methods and procedures c ontained in each applicable section or subpart

listed in 9 VAC 5-50-410 and 9 VAC 5-60-70. The details of the tests are to be arranged with the Director, Piedmont Region. The permittee shall subm it a test protocol at least 30 days prior to testing. One copy of the test results shall be s ubmitted to the Director, Piedmont Region within 45 days after test completion and shall conform to the te st report format enclosed with this permit. (9 VAC 5-50-30, 9 VAC 5-80-1 200, and 40 CFR 63.344(c)(1))

13. Stack Test - Initial performance tests shall be conducted for chromium emissions from the mesh pad mist eliminator (Ref. No. CD002) to determine co mpliance with the control efficiency requirements contained in Condition 3. The tests shall be per formed and demonstrate compliance within 60 days after achieving the maximum production rate at wh ich the facility will be operated but in no event later than 180 days after start-up of the permitted fac ility. Tests shall be conducted and reported and data

reduced as set forth in 9 VAC 5-50-30 and 9 VAC 5-60-30, and the test methods and procedures contained in each applicable section or subpart lis ted in 9 VAC 5-50-410 and 9 VAC 5-60-70. The details of the tests are to be arranged with the Di rector, Piedmont Region. The permittee shall submitTrident Registration Number: 52175 October 8, 2009 Page 5

a test protocol at least 30 days prior to testing. One copy of the test result s shall be submitted to the Director, Piedmont Region within 45 days after test completion and shall conform to the test report format enclosed with this permit. (9 VAC 5-50-30 and 9 VAC 5-80-1200)

14. Visible Emissions Evaluation - Visible Emission Evaluations (VEE) in accordance with 40 CFR Part 60, Appendix A, Method 9, shall also be cond ucted by the permittee on the mesh pad mist eliminator/scrubber (Ref. No. CD001) and the mesh p ad mist eliminator (Ref. No. CD002). Each test

shall consist of 30 sets of 24 consecutive observati ons (at 15 second intervals) to yield a six minute average. The details of the tests are to be ar ranged with the Director, Piedmont Region. The permittee shall submit a test protocol at least 30 days prior to testing. The evaluation shall be performed and demonstrate compliance within 60 days after achieving the maximum production rate at which the facility will be operated but in no event later than 180 days after start-up of the permitted facility. Should conditions prevent concurrent opacity observations, the Director, Piedmont Region shall be notified in writing, within seven days, and visible emissions testing shall be rescheduled within 30 days. Rescheduled testing shall be conducted under the same conditions (as possible) as the initial performance tests. One copy of the test result shall be submitted to the Director, Piedmont Region within 45 days after test completion and shall c onform to the test report format enclosed with this permit. (9 VAC 5-50-30 and 9 VAC 5-80-1200)

RECORDS

15. On Site Records - The permittee shall maintain records of emission data and operating parameters as necessary to demonstrate compliance with this permit. The content and format of such records shall be arranged with the Director, Piedmont Region. These records shall include, but are not limited

to:

a. Annual amp-hours of the chromium electroplating process, calculated monthly as the sum of each consecutive 12-month period. Compliance fo r the consecutive 12-month period shall be demonstrated monthly by adding the total for the mo st recently completed calendar month to the individual monthly totals for the preceding 11 months.

b. The maximum chromium plating current for the chromium electroplating tank (Ref. Nos. P001- Tank 1).

c. The maximum dechroming plating current for t he dechroming tanks (Ref. Nos. DC-1 and DC-2).

d. Material Safety Data Sheets (MSDS) other vendor information as approved by DEQ showing VOC content, toxic compound content, and HAP content for each ink and solvent used.

e. The results of the control device monitoring ob servations (log) required by Condition 5, any

corrective actions taken for abnormal observat ion readings, and any documentation certifying compliant control device operating conditions du ring periods of abnormal observation readings.

f. Inspection records for the mesh pad mist eliminator/scrubber (Ref. No. CD001) and the process/control monitoring equipment to document that the inspection and maintenance required in 40 CFR 63.342(f) have taken place. The record can be a checklist to include the device inspected, the date of inspection, a brief descripti on of the working condition of the device during the inspection, and any actions taken to corr ect deficiencies found during the inspection.

g. Results of all stack tests, visible em ission evaluations and performance evaluations.

h. Scheduled and unscheduled maintenance and operator training.Trident Registration Number: 52175 October 8, 2009 Page 6

These records shall be available for inspection by the DEQ and shall be current for the most recent five years. (9 VAC 5-80-1180, 9 VAC 5-50-50, and 40 CFR 63.346(b))

16. Operation and Maintenance Plan - The permittee shall prepare an operation and maintenance plan for the chromium plating tank (Ref. No. P001-Tank 1) which shall include:

a. Specify the operation and maintenance crit eria for the tank, the mesh pad mist eliminator/scrubber (Ref. No. CD001), and the pr ocess/control monitoring equipment, and shall

include a standardized checklist to document t he operation and maintenance of this equipment;

b. The work practice standards for the mesh pad mist eliminator/scrubber (Ref. No. CD001) and the process/control monitoring equipment, as listed below:

i. Visually inspect device to ensure there is proper drainage, no chronic acid buildup on the pads, and no evidence of chemical attack on the structural integrity of the device 1/quarter.

ii. Visually inspect back portion of the mesh pad closest to the fan to ensure there is no breakthrough of chromic acid mist 1/quarter.

iii. Visually inspect ductwork fr om tank to the control device to ensure there are no leaks 1/quarter.

iv. Perform wash-down of the composite mesh pads in accordance with manufacturers recommendations per manufacturer.

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 ma lfunctions of the tank, the mesh pad mist eliminator/scrubber (Ref. No. CD001), and the process/control monitoring equipment and for implementing corrective actions to address such malfunctions.

The permittee shall keep the written operation and maintenance plan on record and these records shall be available for inspection by the DEQ and s hall be current for the most recent five years. (9 VAC 5-80-1180, 9 VAC 5-50-5 0, and 40 CFR 63.342(f)(3))

17. Emissions Testing - The facility shall be constr ucted/modified/installed so as to allow for emissions testing upon reasonable notice at any time, using app ropriate methods. This includes constructing the facility/equipment such that volumetric flow rate s and pollutant emission rates can be accurately determined by applicable test methods and providing a stack or duct that is free from cyclonic flow. Sampling ports shall be provided when requested at the appropriate locations and safe sampling platforms and access shall be provided. (9 VAC 5-50-30 F and 9 VAC 5-80-1180)

NOTIFICATIONS

18. Initial Notifications - The permittee shall furnish written notif ication to the Director, Piedmont Region

of:

a. The actual date on which construction of t he hard chromium electroplating facility commenced within 30 days after such date.Trident Registration Number: 52175 October 8, 2009 Page 7

b. The anticipated start-up date of the hard chro mium electroplating fac ility postmarked not more than 60 days nor less than 30 days prior to such date.

c. The actual start-up date of the hard chromium electroplating facility with in 15 days after such

date.

d. The anticipated date of stack tests and visible emission evaluations postmarked at least 60 days prior to such date.

e. The date of compliance status to MACT, Subpart N no later than 90 days after the completion of the stack test required in Condition 12. This not ification shall include all items listed in 40 CFR 63.347(e)).

(9 VAC 5-50-50 and 9 VAC 5-80-1180)

REPORTING

19. Ongoing Compliance Status Reports - The permittee shall prepare a summary report to document the ongoing compliance status of the chromium platin g tank (Ref. No. P001-Tank 1). The report shall contain all items listed in 40 CFR 63.347(g)(3) and shall be completed annually and retained on site. The time duration may change if 40 CFR 63.347(h)(2) conditions are met. (9 VAC 5-50-50, 9 VAC 5-80-1180, and 40 CFR 63.347(h))

GENERAL CONDITIONS

20. Permit Invalidation – This permit to construct the hard chro mium electroplating facility shall become invalid, unless an extension is granted by the DEQ, if:

a. A program of continuous construction, reconstr uction, or modification is not commenced within the latest of the following:

i. 18 months from the date of this permit;

ii. Nine months from the date that the last per mit or other authorization was issued from any other governmental entity;

iii. Nine months from the date of t he last resolution of any litigat ion concerning any such permits or authorization; or

b. A program of construction, reconstruction, or modification is discontinued for a period of 18 months or more, or is not completed within a reasonable time, except for a DEQ approved period between phases of a phased construction project. (9 VAC 5-80-1210)

21. Permit Suspension/Revocation - This permit may be suspended or revoked if the permittee:

a. Knowingly makes material misstatements in the permit application or any amendments to it;

b. Fails to comply with the conditions of this permit;

c. Fails to comply with any emission standards applicable to a permitted emissions unit, ;

d. Causes emissions from the stationary source whic h result in violations of , or interfere with the attainment and maintenance of, any ambient air quality standard; orTrident Registration Number: 52175 October 8, 2009 Page 8

e. Fails to operate in conformance with any applicable control strategy, including any emission standards or emission limitations, in the State Implementation Plan in effect at the time an application for this permit is submitted. (9 VAC 5-80-1210 F)

22. Right of Entry - The permittee shall allow authorized loca l, state, and federal representatives, upon the presentation of credentials:

a. To enter upon the permittee's pr emises on which the facility is loca ted or in which any records are required to be kept under the terms and conditions of this permit;

b. To have access to and copy at reasonable ti mes any records required to be kept under the terms and conditions of this permit or the Stat e Air Pollution Control Board Regulations;

c. To inspect at reasonable times any facility, equipment, or process subject to the terms and conditions of this permit or the State Ai r Pollution Control Board Regulations; and

d. To sample or test at reasonable times.

For purposes of this condition, the time for inspection shall be deemed reasonable during regular business hours or whenever the facility is in operation. Nothing contained herein shall make an inspection time unreasonable during an emergency. (9 VAC 5-170-130 and 9 VAC 5-80-1180)

23. Maintenance/Operating Procedures – At all times, including periods of start-up, shutdown, and malfunction, the permittee shall, to the extent prac ticable, maintain and operate the affected source, including associated air pollution control equipmen t, in a manner consistent with good air pollution control practices for minimizing emissions.

The permittee shall take the following measures in order to minimize the duration and frequency of excess emissions, with respect to air pollution cont rol equipment and process equipment which affect

such emissions:

a. Develop a maintenance schedule and maintain records of all scheduled and non-scheduled

maintenance.

b. Maintain an inventory of spare parts.

c. Have available written operating procedures for equipment. These procedures shall be based on the manufacturer's recommendations, at a minimum.

d. Train operators in the proper operation of a ll such equipment and familiarize the operators with the written operating procedures, prior to their first operation of such equipment. The permittee shall maintain records of the training provided incl uding the names of trainees, the date of training and the nature of the training.

Records of maintenance and training shall be maintained on site for a period of five years and shall be made available to DEQ personnel upon request. (9 VAC 5-50-20 E and 9 VAC 5-80-1180 D)

24. Record of Malfunctions – The permittee shall maintain record s of the occurrence and duration of any bypass, malfunction, shutdown or failure of the facility or its associated air pollution control equipment that results in excess emissions for more than one hour. Records shall include the date,Trident Registration Number: 52175 October 8, 2009 Page 9

time, duration, description (emission unit, pollutant affected, cause), corrective action, preventive measures taken and name of person generating the record. (9VAC 5-20-180 J and 9 VAC 5-80-1180 D)

25. Notification for Facility or Control Equipment Malfunction - The permittee shall furnish notification to the Director, Piedmont Region of malf unctions of the affected facility or related air pollution control equipment that may cause excess emissions for more than one hour, by facsimile transmission, telephone or telegraph. Such notifica tion shall be made as soon as practicable but no later than four daytime business hours after the malfunction is discovered. The permittee shall provide a written statement giving all pertinent fa cts, including the estimated duration of the breakdown, within two weeks of discovery of the malfunction. When the condition causing the failure or malfunction has been corrected and the equipment is again in operation, the permittee shall notify the Director, Piedmont Region. (9 VAC 5-20-180 C and 9 VAC 5-80-1180)

26. Violation of Ambient Air Quality Standard - The permittee shall, upon request of the DEQ, reduce the level of operation or shut down a facility, as nec essary to avoid violating any primary ambient air quality standard and shall not return to normal operation until such time as the ambient air quality

standard will not be violated. (9 VAC 5-20-180 I and 9 VAC 5-80-1180)

27. Change of Ownership - In the case of a transfer of owners hip of a stationary source, the new owner shall abide by any current permit issued to t he previous owner. The new owner shall notify the Director, Piedmont Region of the change of ownership within 30 days of the transfer. (9 VAC 5-80-1240)

28. Permit Copy - The permittee shall ke ep a copy of this permit on the prem ises of the facility to which it applies. (9 VAC 5-80-1180)SOURCE TESTING REPORT FORMAT

Report Cover

1. Plant name and location 2. Units tested at source (indicate Ref. No. used by source in permit or registration)

3. Test Dates. 4. Tester; name, address and report date

Certification 1. Signed by team leader/certified obs erver (include certification date) 2. Signed by responsible company official 3. *Signed by reviewer

Copy of approved test protocol

Summary 1. Reason for testing

2. Test dates

3. Identification of unit tested & the maximum rated capacity 4. *For each emission unit, a table showing: a. Operating rate

b. Test Methods

c. Pollutants tested d. Test results for each run and the run average

e. Pollutant standard or limit 5. Summarized process and control equipment data for each run and the average, as required by the test protocol

6. A statement that test wa s conducted in accordance with the test pr otocol or identification & discussion of deviations, including the likely impact on results 7. Any other important information

Source Operation 1. Description of proc ess and control devices 2. Process and control equipment flow diagram 3. Sampling port location and dimensioned cross sect ion Attached protocol includes: sketch of stack (elevation view) showing sampling port locations, upst ream and downstream flow disturbances and their distances from ports; and a sketch of stack (plan vi ew) showing sampling ports, ducts entering the stack and

stack diameter or dimensions

Test Results

1. Detailed test results for each run 2. *Sample calculations 3. *Description of collected samples, to include audits when applicable

Appendix 1. *Raw production data

2. *Raw field data 3. *Laboratory reports 4. *Chain of custody records for lab samples 5. *Calibration procedures and results 6. Project participants and titles 7. Observers’ names (industry and agency) 8. Related correspondence 9. Standard procedures

_____ * Not applicable to visible emission evaluations