# MINOR SOURCE OPERATING PERMIT

OFFICE OF AIR MANAGEMENT

H & L Plating and Grinding, Inc. 410 East Willard Street Muncie, Indiana 47302 (herein known as the Permittee) is hereby authorized to operate subject to the conditions contained herein, the emission units described in Section A (Source Summary) of this permit. This permit is issued to the above mentioned company under the provisions of 326 IAC 2-1.1, 326 IAC 2-6.1 and 40 CFR 52.780, with conditions listed on the attached pages.

Operation Permit No.: MSOP 035-12340-00070

Issued by: Paul Dubenetzky, Branch Chief Office of Air Management Issuance Date:H & L Plating and Grinding, Inc. Page 2 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT TABLE OF CONTENTS SECTION A SOURCE SUMMARY

.................................................. 4 A.1 General Information [326 IAC 2-5.1-3(c)] [326 IAC 2-6.1-4(a)] A.2 Emissions units and Pollution Control Equipment Summary A.3 Part 70 Permit Applicability [326 IAC 2-7-2] SECTION B GENERAL CONSTRUCTION CONDITIONS

................................ 5 B.1 Permit No Defense [IC 13] B.2 Definitions B.3 Effective Date of the Permit [IC13-15-5-3] B.4 Modification to Permit [326 IAC 2] SECTION C SOURCE OPERATION CONDITIONS

..................................... 6 C.1 PSD Minor Source Status [326 IAC 2-2] [40 CFR 52.21] C.2 Preventive Maintenance Plan [326 IAC 1-6-3] C.3 Permit Revision [326 IAC 2-5.1-3(e)(3)] [326 IAC 2-6.1-6] C.4 Inspection and Entry [326 IAC 2-5.1-3(e)(4)(B)] [326 IAC 2-6.1-5(a)(4)] C.5 Transfer of Ownership or Operation [326 IAC 2-6.1-6(d)(3)] C.6 Permit Revocation [326 IAC 2-1-9] C.7 Opacity [326 IAC 5-1] Testing Requirements C.8 Performance Testing [326 IAC 3-6] Compliance Monitoring Requirements C.9 Compliance Monitoring [326 IAC 2-1.1-11] C.10 Monitoring Methods [326 IAC 3] C.11 Compliance Monitoring Plan - Failure to Take Response Steps [326 IAC 1-6] C.12 Actions Related to Noncompliance Demonstrated by a Stack Test Record Keeping and Reporting Requirements C.13 Malfunctions Report [326 IAC 1-6-2] C.14 Monitoring Data Availability [326 IAC 2-6.1-2] [IC 13-14-1-13] C.15 General Record Keeping Requirements [326 IAC 2-6.1-2] C.16 General Reporting Requirements [326 IAC 2-1.1-11] [326 IAC 2-6.1-2] [IC 13-14-1-13] C.17 Annual Notification [326 IAC 2-6.1-5(a)(5)] SECTION D.1 FACILITY OPERATION CONDITIONS

.................................... 15 Emission Limitations and Standards D.1.1 General Provisions Relating to HAPs [326 IAC 20-1-1][40 CFR Part 63, Subpart A] D.1.2 Chromium Electroplating and Anodizing NESHAP [326 IAC 20-8-1] [40 CFR Part 63, Subpart N] D.1.3 Chromium Emissions Limitation [40 CFR 63.342(c)] [40 CFR 63.343(a)(1)&(2)] [326 IAC 20-8-1] D.1.4 Work Practice Standards [40 CFR 63.342(f)] [326 IAC 20-8-1] D.1.5 Preventive Maintenance Plan [326 IAC 1-6-3] D.1.6 Operation and Maintenance Plan [40 CFR 63.342(f)(3)] [326 IAC 20-8-1]TABLE OF CONTENTS (Continued)

H & L Plating and Grinding, Inc. Page 3 of 27 Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT

Compliance Determination Requirements [326 IAC 2-1.1-11] D.1.7 Performance Testing [326 IAC 2-1.1-11] [40 CFR 63.343(b)(1) [40 CFR 63.343(b)(2)] [40 CFR 63.7] [40 CFR 63.344] [326 IAC 20-8-1] Compliance Monitoring Requirements [326 IAC 2-6.1-5(a)(2) D.1.8 Monitoring to Demonstrate Continuous Compliance [326 IAC 2-6.1-5(a)(2)] [326 IAC 20-8-1] Record Keeping and Reporting Requirements [326 IAC 2-6.1-5(a)(2)] D.1.9 Record Keeping Requirements [40 CFR 63.346] [326 IAC 20-8-1] D.1.10 Reporting Requirements [326 IAC 3-6-4(b)] [40 CFR 63.344(a), 63.345 and 63.347] [326 IAC 20-8-1] SECTION D.2 EMISSIONS UNIT OPERATION CONDITIONS

.............................. 22 Emission Limitations and Standards D.2.1 Particulate Matter (PM) [326 IAC 6-3] Compliance Determination Requirements [326 IAC 2-5.1-3(e)(2)] [ 326 IAC 2-6.1-5(a)(2)] D.2.2 Testing Requirements [326 IAC 2-1.1-11] Record Keeping and Reporting Requirement D.2.3 Record Keeping and Reporting Requirements

ONGOING COMPLIANCE STATUSREPORT

............................................ 23 ANNUAL NOTIFICATION

............................................................ 25 MALFUNCTION REPORT

........................................................... 26H & L Plating and Grinding, Inc. Page 4 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT SECTION A SOURCE SUMMARY This permit is based on information requested by the Indiana Department of Environmental Management (IDEM), Office of Air Management (OAM). The information describing the source contained in conditions A.1 through A.3 is descriptive information and does not constitute enforceable conditions. However, the Permittee should be aware that a physical change or a change in the method of operation that may render this descriptive information obsolete or inaccurate may trigger requirements for the Permittee to obtain additional permits or seek modification of this permit pursuant to 326 IAC 2, or change other applicable requirements presented in the permit application.
A.1 General Information [326 IAC 2-5.1-3(c)] [326 IAC 2-6.1-4(a)] The Permittee owns and operates stationary hard chromium electroplating operation.
Authorized Individual: Howard Larsen Source Address: 410 East Willard Street, Muncie, Indiana 47302 Mailing Address: 410 East Willard Street, Muncie, Indiana 47302 Phone Number: 765-286-2911 SIC Code: 3471 County Location: Delaware County Status: Attainment for all criteria pollutants Source Status: Minor Source, under PSD or Emission Offset Rules; Minor Source, Section 112 of the Clean Air Act
A.2 Emissions units and Pollution Control Equipment Summary This stationary source is approved to operate the following emissions units and pollution control devices: (a) Five (5) hard chrome plating tanks identified as tanks 1, 3, 4, 5, and 6, with a maximum cumulative rectifier capacity of 88.2 million Ampere-hours using a composite mesh-pad system as control, and exhausting to stack S1. (b) One (1) arc welding station. (c) Eleven (11) grinders. A.3 Part 70 Permit Applicability [326 IAC 2-7-2] This stationary source is required not to have a Part 70 permit by 326 IAC 2-7-2 (Applicability) because: (a) It is a minor source, as defined in 326 IAC 2-7-1(22); (b) It is not an affected source under Title IV (Acid Deposition Control) of the Clean Air Act, as defined in 326 IAC 2-7-1(3); (c) It is not a source in a source category designated by the United States Environmental Protection Agency (U.S. EPA) under 40 CFR 70.3 (Part 70 - Applicability).H & L Plating and Grinding, Inc. Page 5 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT SECTION B GENERAL CONSTRUCTION CONDITIONS THIS SECTION OF THE PERMIT IS BEING ISSUED UNDER THE PROVISIONS OF 326 IAC 2-1.1 AND 40 CFR 52.780, WITH CONDITIONS LISTED BELOW.
B.1 Permit No Defense [IC 13] This permit to operate does not relieve the Permittee of the responsibility to comply with the provisions of the Indiana Environmental Management Law (IC 13-11 through 13-20; 13-22 through 13-25; and 13-30), the Air Pollution Control Law (IC 13-17) and the rules promulgated thereunder, as well as other applicable local, state, and federal requirements.
B.2 Definitions Terms in this permit shall have the definition assigned to such terms in the referenced regulation. In the absence of definitions in the referenced regulation, any applicable definitions found in IC 13-11, 326 IAC 1-2, and 326 IAC 2-1.1-1 shall prevail. B.3 Effective Date of the Permit [IC13-15-5-3] Pursuant to IC 13-15-5-3, this permit becomes effective upon its issuance.
B.4 Modification to Permit [326 IAC 2] All requirements and conditions of this operating permit shall remain in effect unless modified in a manner consistent with procedures established for modifications of construction permits pursuant to 326 IAC 2 (Permit Review Rules).H & L Plating and Grinding, Inc. Page 6 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT SECTION C SOURCE OPERATION CONDITIONS

Entire Source
C.1 PSD Minor Source Status [326 IAC 2-2] [40 CFR 52.21] (a) The total source potential to emit of all criteria pollutants is less than 250 tons per year. Therefore the requirements of 326 IAC 2-2 (Prevention of Significant Deterioration) and 40 CFR 52.21 will not apply. (b) Any change or modification which may increase potential to emit to 250 tons per year from this source, shall cause this source to be considered a major source under PSD, 326 IAC 2-2 and 40 CFR 52.21, and shall require approval from IDEM, OAM prior to making the change. C.2 Preventive Maintenance Plan [326 IAC 1-6-3] (a) If required by specific condition(s) in Section D of this permit, the Permittee shall prepare and maintain Preventive Maintenance Plans (PMP) after issuance of this permit, including the following information on each emissions unit: (1) Identification of the individual(s) responsible for inspecting, maintaining, and repairing emission control devices; (2) A description of the items or conditions that will be inspected and the inspection schedule for said items or conditions; (3) Identification and quantification of the replacement parts that will be maintained in inventory for quick replacement. (b) The Permittee shall implement the Preventive Maintenance Plans as necessary to ensure that failure to implement the Preventive Maintenance Plan does not cause or contribute to a violation of any limitation on emissions or potential to emit. (c) PMP’s shall be submitted to IDEM, OAM, upon request and shall be subject to review and approval by IDEM, OAM. IDEM, OAM may require the Permittee to revise its Preventive Maintenance Plan whenever lack of proper maintenance causes or contributes to any violation. C.3 Permit Revision [326 IAC 2-5.1-3(e)(3)] [326 IAC 2-6.1-6] (a) The Permittee must comply with the requirements of 326 IAC 2-6.1-6 whenever the Permittee seeks to amend or modify this permit. (b) Any application requesting an amendment or modification of this permit shall be submitted to: Indiana Department of Environmental Management Permits Branch, Office of Air Management 100 North Senate Avenue, P.O. Box 6015 Indianapolis, Indiana 46206-6015H & L Plating and Grinding, Inc. Page 7 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT
Any such application should be certified by the “authorized individual” as defined by 326 IAC 2-1.1-1. (c) The Permittee shall notify the OAM within thirty (30) calendar days of implementing a notice-only change. [326 IAC 2-6.1-6(d)] C.4 Inspection and Entry [326 IAC 2-5.1-3(e)(4)(B)] [326 IAC 2-6.1-5(a)(4)] Upon presentation of proper identification cards, credentials, and other documents as may be required by law, and subject to the Permittee’s right under all applicable laws and regulations to assert that the information collected by the agency is confidential and entitled to be treated as such, the Permittee shall allow IDEM, OAM, U.S. EPA, or an authorized representative to perform the following: (a) Enter upon the Permittee's premises where a permitted source is located, or emissions related activity is conducted, or where records must be kept under the conditions of this permit; (b) Have access to and copy, at reasonable times, any records that must be kept under this title or the conditions of this permit or any operating permit revisions; (c) Inspect, at reasonable times, any processes, emissions units (including monitoring and air pollution control equipment), practices, or operations regulated or required under this permit or any operating permit revisions; (d) Sample or monitor, at reasonable times, substances or parameters for the purpose of assuring compliance with this permit or applicable requirements; and (e) Utilize any photographic, recording, testing, monitoring, or other equipment for the purpose of assuring compliance with this permit or applicable requirements. C.5 Transfer of Ownership or Operation [326 IAC 2-6.1-6(d)(3)] Pursuant to [326 IAC 2-6.1-6(d)(3)] : (a) In the event that ownership of this source is changed, the Permittee shall notify IDEM, OAM, Permits Branch within thirty (30) days of the change. (b) The written notification shall be sufficient to transfer the permit to the new owner by an notice-only change pursuant to 326 IAC 2-6.1-6(d)(3). (c) IDEM, OAM shall issue a revised permit. The notification which shall be submitted by the Permittee does require the certification by the “authorized individual” as defined by 326 IAC 2-1.1-1. C.6 Permit Revocation [326 IAC 2-1-9] Pursuant to 326 IAC 2-1-9(a)(Revocation of Permits), this permit to operate may be revoked for any of the following causes: (a) Violation of any conditions of this permit.H & L Plating and Grinding, Inc. Page 8 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT (b) Failure to disclose all the relevant facts, or misrepresentation in obtaining this permit. (c) Changes in regulatory requirements that mandate either a temporary or permanent reduction of discharge of contaminants. However, the amendment of appropriate sections of this permit shall not require revocation of this permit. (d) Noncompliance with orders issued pursuant to 326 IAC 1-5 (Episode Alert Levels) to reduce emissions during an air pollution episode. (e) For any cause which establishes in the judgment of IDEM, the fact that continuance of this permit is not consistent with purposes of this article. C.7 Opacity [326 IAC 5-1] Pursuant to 326 IAC 5-1-2 (Opacity Limitations), except as provided in 326 IAC 5-1-3 (Temporary Alternative Opacity Limitations), opacity shall meet the following, unless otherwise stated in this permit: (a) Opacity shall not exceed an average of forty percent (40%) in any one (1) six (6) minute averaging period as determined in 326 IAC 5-1-4. (b) Opacity shall not exceed sixty percent (60%) for more than a cumulative total of fifteen (15) minutes (sixty (60) readings as measured according to 40 CFR 60, Appendix A, Method 9 or fifteen (15) one (1) minute nonoverlapping integrated averages for a continuous opacity monitor) in a six (6) hour period. Testing Requirements C.8 Performance Testing [326 IAC 3-6] (a) Compliance testing on new emissions units shall be conducted within 60 days after achieving maximum production rate, but no later than 180 days after initial start-up, if specified in Section D of this approval. All testing shall be performed according to the provisions of 326 IAC 3-6 (Source Sampling Procedures), except as provided elsewhere in this permit, utilizing any applicable procedures and analysis methods specified in 40 CFR 51, 40 CFR 60, 40 CFR 61, 40 CFR 63, 40 CFR 75, or other procedures approved by IDEM, OAM. A test protocol, except as provided elsewhere in this permit, shall be submitted to: Indiana Department of Environmental Management Compliance Data Section, Office of Air Management 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015 no later than thirty-five (35) days prior to the intended test date. The Permittee shall submit a notice of the actual test date to the above address so that it is received at least two weeks prior to the test date. (b) All test reports must be received by IDEM, OAM within forty-five (45) days after the completion of the testing. An extension may be granted by the IDEM, OAM, if theH & L Plating and Grinding, Inc. Page 9 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT

source submits to IDEM, OAM, a reasonable written explanation within five (5) days prior to the end of the initial forty-five (45) day period. The documentation submitted by the Permittee does not require certification by the “authorized individual” as defined by 326 IAC 2-1.1-1. Compliance Monitoring Requirements C.9 Compliance Monitoring [326 IAC 2-1.1-11] Compliance with applicable requirements shall be documented as required by this permit. The Permittee shall be responsible for installing any necessary equipment and initiating any required monitoring related to that equipment. All monitoring and record keeping requirements not already legally required shall be implemented when operation begins. C.10 Monitoring Methods [326 IAC 3] Any monitoring or testing required by Section D of this permit shall be performed according to the provisions of 326 IAC 3, 40 CFR 60, Appendix A, or other approved methods as specified in this permit. C.11 Compliance Monitoring Plan - Failure to Take Response Steps [326 IAC 1-6] (a) The Permittee is required to implement a compliance monitoring plan to ensure that reasonable information is available to evaluate its continuous compliance with applicable requirements. This compliance monitoring plan is comprised of: (1) This condition; (2) The Compliance Determination Requirements in Section D of this permit; (3) The Compliance Monitoring Requirements in Section D of this permit; (4) The Record Keeping and Reporting Requirements in Section C (Monitoring Data Availability, General Record Keeping Requirements, and General Reporting Requirements) and in Section D of this permit; and (5) A Compliance Response Plan (CRP) for each compliance monitoring condition of this permit. CRP’s shall be submitted to IDEM, OAM upon request and shall be subject to review and approval by IDEM, OAM. The CRP shall be prepared within ninety (90) days after issuance of this permit by the Permittee and maintained on site, and is comprised of : (A) Response steps that will be implemented in the event that compliance related information indicates that a response step is needed pursuant to the requirements of Section D of this permit; and (B) A time schedule for taking such response steps including a schedule for devising additional response steps for situations that may not have been predicted. (b) For each compliance monitoring condition of this permit, appropriate response steps shall be taken when indicated by the provisions of that compliance monitoring condition.H & L Plating and Grinding, Inc. Page 10 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT

Failure to perform the actions detailed in the compliance monitoring conditions or failure to take the response steps within the time prescribed in the Compliance Response Plan, shall constitute a violation of the permit unless taking the response steps set forth in the Compliance Response Plan would be unreasonable. (c) After investigating the reason for the excursion, the Permittee is excused from taking further response steps for any of the following reasons: (1) The monitoring equipment malfunctioned, giving a false reading. This shall be an excuse from taking further response steps providing that prompt action was taken to correct the monitoring equipment. (2) The Permittee has determined that the compliance monitoring parameters established in the permit conditions are technically inappropriate, has previously submitted a request for an administrative amendment to the permit, and such request has not been denied or; (3) An automatic measurement was taken when the process was not operating; or (4) The process has already returned to operating within “normal” parameters and no response steps are required. (d) Records shall be kept of all instances in which the compliance related information was not met and of all response steps taken. C.12 Actions Related to Noncompliance Demonstrated by a Stack Test (a) When the results of a stack test performed in conformance with Section C - Performance Testing, of this permit exceed the level specified in any condition of this permit, the Permittee shall take appropriate corrective actions. The Permittee shall submit a description of these corrective actions to IDEM, OAM, within thirty (30) days of receipt of the test results. The Permittee shall take appropriate action to minimize emissions from the affected emissions unit while the corrective actions are being implemented. IDEM, OAM shall notify the Permittee within thirty (30) days, if the corrective actions taken are deficient. The Permittee shall submit a description of additional corrective actions taken to IDEM, OAM within thirty (30) days of receipt of the notice of deficiency. IDEM, OAM reserves the authority to use enforcement activities to resolve noncompliant stack tests. (b) A retest to demonstrate compliance shall be performed within one hundred twenty (120) days of receipt of the original test results. Should the Permittee demonstrate to IDEM, OAM that retesting in one-hundred and twenty (120) days is not practicable, IDEM, OAM may extend the retesting deadline. Failure of the second test to demonstrate compliance with the appropriate permit conditions may be grounds for immediate revocation of the permit to operate the affected emissions unit. The documents submitted pursuant to this condition do not require the certification by the “authorized individual” as defined by 326 IAC 2-1.1-1.H & L Plating and Grinding, Inc. Page 11 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT Record Keeping and Reporting Requirements C.13 Malfunctions Report [326 IAC 1-6-2] Pursuant to 326 IAC 1-6-2 (Records; Notice of Malfunction): (a) A record of all malfunctions, including startups or shutdowns of any facility or emission control equipment, which result in violations of applicable air pollution control regulations or applicable emission limitations shall be kept and retained for a period of three (3) years and shall be made available to the Indiana Department of Environmental Management (IDEM), Office of Air Management (OAM) or appointed representative upon request. (b) When a malfunction of any facility or emission control equipment occurs which lasts more than one (1) hour, said condition shall be reported to OAM, using the Malfunction Report Forms (2 pages). Notification shall be made by telephone or facsimile, as soon as practicable, but in no event later than four (4) daytime business hours after the beginning of said occurrence. (c) Failure to report a malfunction of any emission control equipment shall constitute a violation of 326 IAC 1-6, and any other applicable rules. Information of the scope and expected duration of the malfunction shall be provided, including the items specified in 326 IAC 1-6-2(a)(1) through (6). (d) Malfunction is defined as any sudden, unavoidable failure of any air pollution control equipment, process, or combustion or process equipment to operate in a normal and usual manner. [326 IAC 1-2-39] C.14 Monitoring Data Availability [326 IAC 2-6.1-2] [IC 13-14-1-13] (a) With the exception of performance tests conducted in accordance with Section CPerformance Testing, all observations, sampling, maintenance procedures, and record keeping, required as a condition of this permit shall be performed at all times the equipment is operating at normal representative conditions. (b) As an alternative to the observations, sampling, maintenance procedures, and record keeping of subsection (a) above, when the equipment listed in Section D of this permit is not operating, the Permittee shall either record the fact that the equipment is shut down or perform the observations, sampling, maintenance procedures, and record keeping that would otherwise be required by this permit. (c) If the equipment is operating but abnormal conditions prevail, additional observations and sampling should be taken with a record made of the nature of the abnormality. (d) If for reasons beyond its control, the operator fails to make required observations, sampling, maintenance procedures, or record keeping, reasons for this must be recorded. (e) At its discretion, IDEM may excuse such failure providing adequate justification is documented and such failures do not exceed five percent (5%) of the operating time in any quarter.H & L Plating and Grinding, Inc. Page 12 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT (f) Temporary, unscheduled unavailability of staff qualified to perform the required observations, sampling, maintenance procedures, or record keeping shall be considered a valid reason for failure to perform the requirements stated in (a) above. C.15 General Record Keeping Requirements [326 IAC 2-6.1-2] (a) Records of all required monitoring data and support information shall be retained for a period of at least five (5) years from the date of monitoring sample, measurement, report, or application. These records shall be kept at the source location for a minimum of three (3) years and available upon the request of an IDEM, OAM representative. The records may be stored elsewhere for the remaining two (2) years as long as they are available upon request. If the Commissioner makes a written request for records to the Permittee, the Permittee shall furnish the records to the Commissioner within a reasonable time. (b) Records of required monitoring information shall include, where applicable: (1) The date, place, and time of sampling or measurements; (2) The dates analyses were performed; (3) The company or entity performing the analyses; (4) The analytic techniques or methods used; (5) The results of such analyses; and (6) The operating conditions existing at the time of sampling or measurement. (c) Support information shall include, where applicable: (1) Copies of all reports required by this permit; (2) All original strip chart recordings for continuous monitoring instrumentation; (3) All calibration and maintenance records; (4) Records of preventive maintenance shall be sufficient to demonstrate that failure to implement the Preventive Maintenance Plan did not cause or contribute to a violation of any limitation on emissions or potential to emit. To be relied upon subsequent to any such violation, these records may include, but are not limited to: work orders, parts inventories, and operator’s standard operating procedures. Records of response steps taken shall indicate whether the response steps were performed in accordance with the Compliance Response Plan required by Section C - Compliance Monitoring Plan - Failure to take Response Steps, of this permit, and whether a deviation from a permit condition was reported. All records shall briefly describe what maintenance and response steps were taken and indicate who performed the tasks. (d) All record keeping requirements not already legally required shall be implemented when operation begins.H & L Plating and Grinding, Inc. Page 13 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT

C.16 General Reporting Requirements [326 IAC 2-1.1-11] [326 IAC 2-6.1-2] [IC 13-14-1-13] (a) To affirm that the source has met all the compliance monitoring requirements stated in this permit the source shall submit a Quarterly Compliance Monitoring Report. Any deviation from the requirements and the date(s) of each deviation must be reported. The Compliance Monitoring Report shall include the certification by the “authorized individual” as defined by 326 IAC 2-1.1-1(1). (b) The report required in (a) of this condition and reports required by conditions in Section D of this permit shall be submitted to: Indiana Department of Environmental Management Compliance Data Section, Office of Air Management 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015 (c) Unless otherwise specified in this permit, any notice, report, or other submission required by this permit shall be considered timely if the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means, it shall be considered timely if received by IDEM, OAM, on or before the date it is due. (d) Unless otherwise specified in this permit, any quarterly report shall be submitted within thirty (30) days of the end of the reporting period. The report does not require the certification by the “authorized individual” as defined by 326 IAC 2-1.1-1(1). (e) All instances of deviations must be clearly identified in such reports. A reportable deviation is an exceedance of a permit limitation or a failure to comply with a requirement of the permit or a rule. It does not include: (1) An excursion from compliance monitoring parameters as identified in Section D of this permit unless tied to an applicable rule or limit; or (2) A malfunction as described in 326 IAC 1-6-2; or (3) Failure to implement elements of the Preventive Maintenance Plan unless lack of maintenance has caused or contributed to a deviation. (4) Failure to make or record information required by the compliance monitoring provisions of Section D unless such failure exceeds 5% of the required data in any calendar quarter. A Permittee’s failure to take the appropriate response step when an excursion of a compliance monitoring parameter has occurred or failure to monitor or record the required compliance monitoring is a deviation. (f) Any corrective actions or response steps taken as a result of each deviation must be clearly identified in such reports. (g) The first report shall cover the period commencing on the date of issuance of this permit and ending on the last day of the reporting period.H & L Plating and Grinding, Inc. Page 14 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT C.17 Annual Notification [326 IAC 2-6.1-5(a)(5)] (a) Annual notification shall be submitted to the Office of Air Management stating whether or not the source is in operation and in compliance with the terms and conditions contained in this permit. (b) Noncompliance with any condition must be specifically identified. If there are any permit conditions or requirements for which the source is not in compliance at any time during the year, the Permittee must provide a narrative description of how the source did or will achieve compliance and the date compliance was, or will be, achieved. The notification must be signed by an authorized individual. (c) The annual notice shall cover the time period from January 1 to December 31 of the previous year, and shall be submitted in the format attached no later than March 1 of each year to: Compliance Data Section, Office of Air Management Indiana Department of Environmental Management 100 North Senate Avenue, P.O. Box 6015 Indianapolis, IN 46206-6015 (d) The notification shall be considered timely if the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means, it shall be considered timely if received by IDEM, OAM on or before the date it is due.H & L Plating and Grinding, Inc. Page 15 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT SECTION D.1 FACILITY OPERATION CONDITIONS Facility Description [326 IAC 2-7-5(15)]: The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions. One (1) Hard Chromium Electroplating Operation with a maximum cumulative rectifier capacity of 88.2 million Ampere-hours (88.2 million A-hr) consisting of: (a) Five (5) hard chromium electroplating tanks, identified as tanks 1, 3, 4, 5, and 6, equipped with a composite mesh-pad system and exhausting to one (1) stack, identified as S1.
Emission Limitations and Standards
D.1.1 General Provisions Relating to HAPs [326 IAC 20-1-1][40 CFR Part 63, Subpart A] The provisions of 40 CFR Part 63, Subpart A - General Provisions, which are incorporated by reference as 326 IAC 20-1-1, apply to the facility described in this section except when otherwise specified in 40 CFR Part 63, Subpart N. The permittee shall comply with the requirements of this condition on and after the compliance date for the tanks.
D.1.2 Chromium Electroplating and Anodizing NESHAP [326 IAC 20-8-1] [40 CFR Part 63, Subpart N] The provisions of 40 CFR 63, Subpart N - National Emission Standards for Chromium Emissions From Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks, which are incorporated by reference as 326 IAC 20-8-1, apply to tanks 1, 3, 4, 5, and 6. A copy of this rule is attached. The permittee shall comply with the requirements of this condition on and after the compliance date for the tanks. D.1.3 Chromium Emissions Limitation [326 IAC 20-8-1] [40 CFR 63.342(c)] [40 CFR 63.343(a)(1)&(2)] (a) The emission limitations [326 IAC 20-8-1] in this condition apply only during tank operation, and also apply during periods of startup and shutdown as these are routine occurrences for tanks subject to 326 IAC 20-8-1. The emission limitations do not apply during periods of malfunction. (b) The hard chromium electroplating tanks, identified as tanks 1, 3, 4, 5, and 6 above, are considered a large, existing hard chromium electroplating operation. During tank operation, the Permittee shall control chromium emissions discharged to the atmosphere from the tanks by not allowing the concentration of total chromium in the exhaust gas stream discharged to the atmosphere to exceed 0.015 mg/dscm [6.6x10 -6 gr/dscf].
D.1.4 Work Practice Standards [326 IAC 20-8-1] [40 CFR 63.342(f)] The following work practice standards apply to tanks 1, 3 ,4, 5, and 6: (a) At all times, including periods of startup, shutdown, malfunction and excess emissions, the Permittee shall operate and maintain tanks 1, 3, 4, 5, and 6 including the composite mesh-pad system and monitoring equipment, in a manner consistent with good air pollution control practices, consistent with the Operation and Maintenance Plan (OMP) required by Condition D.1.6. (b) Malfunctions and excess emissions shall be corrected as soon as practicable after their occurrence in accordance with the OMP required by Condition D.1.6.H & L Plating and Grinding, Inc. Page 16 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT
(c) These operation and maintenance requirements are enforceable independent of emissions limitations or other requirements in this section. (d) Determination of whether acceptable operation and maintenance procedures are being used will be based on information available to IDEM, OAM, which may include, but is not limited to, monitoring results; review of the OMP, procedures, and records; and inspection of the source. (e) Based on the results of a determination made under paragraph (d) of this condition, IDEM, OAM may require that the Permittee make changes to the OMP required by Condition D.1.6. Revisions may be required if IDEM, OAM finds that the plan: (1) Does not address a malfunction or period of excess emissions that has occurred; (2) Fails to provide for the operation of tanks 1, 3, 4, 5, and 6, or the composite mesh-pad system and process monitoring equipment during a malfunction or period of excess emissions in a manner consistent with good air pollution control practices; or (3) Does not provide adequate procedures for correcting malfunctioning process equipment, monitoring equipment or other causes of excess emissions as quickly as practicable. The work practice standards that address operation and maintenance must be followed during malfunctions and periods of excess emissions. D.1.5 Preventive Maintenance Plan [326 IAC 1-6-3] A Preventive Maintenance Plan (PMP), in accordance with Section C-Preventive Maintenance Plan, of this permit, is required for the tanks 1, 3, 4, 5, and 6 and the composite mesh-pad system. D.1.6 Operation and Maintenance Plan [326 IAC 20-8-1] [40 CFR 63.342(f)(3)] (a) The Permittee shall prepare an Operation and Maintenance Plan (OMP) to be implemented no later than the startup date of tanks 1, 3, 4, 5, and 6. The OMP shall specify the operation and maintenance criteria for the tanks, the composite mesh-pad system and monitoring equipment and shall include the following elements: (1) For the composite mesh-pad system (CMP): (A) Quarterly visual inspections of the device to ensure there is proper drainage, no chromic acid buildup on the pads, and no evidence of chemical attack on the structural integrity of the device. (B) Quarterly visual inspection of the back portion of the mesh pad closest to the fan to ensure there is no breakthrough of chromic acid mist. (C) Quarterly visual inspection of the duct work from the tank to the control device to ensure there are no leaks. (D) Perform washdown of the composite mesh-pads in accordance with manufacturers recommendations.H & L Plating and Grinding, Inc. Page 17 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT

(2) A standardized checklist to document the operation and maintenance criteria for tanks 1, 3, 4, 5, and 6, the composite mesh-pad system and the monitoring equipment. (3) Procedures to be followed to ensure that equipment or process malfunctions due to poor maintenance or other preventable conditions or periods of excess emissions as indicated by monitoring data do not occur

. (4) A systematic procedure for identifying malfunctions and periods of excess emissions of tanks 1, 3, 4, 5, and 6, the composite mesh-pad system and the monitoring equipment; and for implementing corrective actions to address such malfunctions and periods of excess emissions. (b) The Permittee may use applicable standard operating procedures (SOP) manuals, Occupational Safety and Health Administration (OSHA) plans, or other existing plans such as the PMP required in Condition D.1.5, as the OMP, provided the alternative plans meet the above listed criteria in Condition D.1.6(a). (C) If the OMP fails to address or inadequately addresses an event that meets the characteristics of a malfunction or period of excess emissions at the time the plan is initially developed, the Permittee shall revise the OMP within forty-five (45) days after such an event occurs. The revised plan shall include procedures for operating and maintaining tanks 1, 3, 4, 5, and 6, the composite mesh-pad system and the monitoring equipment, during similar malfunction or period of excess emissions events, and a program for corrective action for such events. (d) If actions taken by the Permittee during periods of malfunction or period of excess emissions are inconsistent with the procedures specified in the OMP, the Permittee shall record the actions taken for that event and shall report by phone such actions within two (2) working days after commencing actions inconsistent with the plan. This report shall be followed by a letter within seven (7) working days after the end of the event, unless the Permittee makes alternative reporting arrangements, in advance, with IDEM, OAM. (e) The Permittee shall keep the written OMP on record after it is developed to be made available, upon request, by IDEM, OAM for the life of tanks 1, 3, 4, 5, and 6 or until the tanks are no longer subject to the provisions of 40 CFR 63.340. In addition, if the OMP is revised, the Permittee shall keep previous versions of the OMPs on record to be made available for inspection, upon request by IDEM, OAM for a period of five (5) years after each revision to the plan. Compliance Determination Requirements [326 IAC 2-1.1-11]
D.1.7 Performance Testing [326 IAC 2-1.1-11] [326 IAC 20-8-1] [40 CFR 63.343(b)(2)] [40 CFR 63.7] [40 CFR 63.344] (a) A performance test demonstrating initial compliance for tanks 1, 3, 4, 5, and 6 was performed on March 7, 1997. During the initial performance test, it was determined that the average pressure drop across the composite mesh pad system was 4.20 inches of water and the average outlet chromium concentration was 0.00987 mg/dscm.H & L Plating and Grinding, Inc. Page 18 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT (b) The Permittee is not required to further test tanks 1, 3, 4, 5, and 6 by this permit. However, the IDEM may require testing when necessary to determine if the tanks are in compliance. If testing is required by the IDEM, compliance with the limits specified in Condition D.1.3 shall be determined by a performance test conducted in accordance with 40 CFR 63.344 and Section C - Performance Testing. (c) Any change, modification, or reconstruction of the tanks 1, 3, 4, 5, and 6, the composite mesh-pad system or monitoring equipment may require additional performance testing conducted in accordance with 40 CFR 63.344 and Section C - Performance Testing. Compliance Monitoring Requirements [326 IAC 2-6.1-5(a)(2) D.1.8 Monitoring to Demonstrate Continuous Compliance [326 IAC 2-6.1-5(a)(2)] [326 IAC 20-8-1] (a) Pursuant to 40 CFR 63.343(c)(1)(ii), when using a composite mesh-pad system to comply with the limits specified in Condition D.1.3, the Permittee shall monitor and record the pressure drop across the composite mesh-pad system during tank operation once each day that a hard chromium electroplating tank is operating. To be in compliance with the standards, the composite mesh-pad system shall be operated within ±1 inch of water column of the pressure drop value established during the initial performance test, or within the range of compliant values for pressure drop established during multiple performance tests. (b) Tank operation or operating time is defined as that time when a part is in the tank and the rectifier is turned on. If the amount of time that no part is in the tank is fifteen minutes or longer, that time is not considered operating time. Likewise, if the amount of time between placing parts in the tank (i.e., when no part is in the tank) is less than fifteen minutes, that time between plating the two parts may be considered operating time. Record Keeping and Reporting Requirements [326 IAC 2-6.1-5(a)(2)] D.1.9 Record Keeping Requirements [326 IAC 20-8-1] [40 CFR 63.346] The Permittee shall maintain records to document compliance with Conditions D.1.3, D.1.4 and D.1.6 using the forms provided with this permit. These records shall be maintained in accordance with Section C - General Record Keeping Requirements of this permit and include a minimum of the following: (a) Inspection records for the composite mesh-pad system and monitoring equipment to document that the inspection and maintenance required by Conditions D.1.7 and D.1.9 have taken place. The record can take the form of a checklist and should identify the following: (1) The device inspected; (2) The date of inspection; (3) A brief description of the working condition of the device during the inspection, including any deficiencies found; and (4) Any actions taken to correct deficiencies found during the inspection, including the date(s) such actions were taken.H & L Plating and Grinding, Inc. Page 19 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT (b) Records of all maintenance performed on tanks 1, 3, 4, 5, and 6, the composite meshpad system and the monitoring equipment. (c) Records of the occurrence, duration, and cause (if known) of each malfunction of tanks 1, 3, 4, 5 and 6, the composite mesh-pad system and monitoring equipment. (d) Records of the occurrence, duration, and cause (if known) of each period of excess emissions of tanks 1, 3, 4, 5 and 6, the composite mesh-pad system and monitoring equipment as indicated by monitoring data collected in accordance with this condition. (e) Records of actions taken during periods of malfunction or excess emissions when such actions are inconsistent with the OMP. (f) Other records, which may take the form of checklists, necessary to demonstrate consistency with the provisions of the OMP. (g) Test reports documenting results of all performance tests. (h) All measurements as may be necessary to determine the conditions of performance tests, including measurements necessary to determine compliance. (i) Records of monitoring data required by 40 CFR 63.343(c) that are used to demonstrate compliance with the standard including the date and time the data are collected. (j) The total process operating time, as defined in Condition D.1.9(b), of each tank, during the reporting period. (k) Records of the actual cumulative rectifier capacity of each hard chromium electroplating tank expended during each month of the reporting period, and the total capacity expended to date for a reporting period. (l) All documentation supporting the notifications and reports required by 40 CFR 63.9 and 63.10 (Subpart A, General Provisions) and by Condition D.1.11. D.1.10 Reporting Requirements [326 IAC 3-6-4(b)] [326 IAC 20-8-1] [40 CFR 63.344(a), 63.345 and 63.347] The notifications and reports required in this section shall be submitted to IDEM, OAM using the address specified in Section C - General Reporting Requirements. (a) Notifications: (1) Initial Notifications The notification that the source is subject to 40 CFR Part 63, Subpart N containing the information listed in 40 CFR 63.347(c)(1) was submitted to IDEM on January 12, 1996. (2) A Notification of Compliance Status (NCS) is required each time that the facility becomes subject to the requirements of 40 CFR Part 63 Subpart N. (A) The NCS shall be submitted to IDEM, OAM, and shall list, for each tank, the information identified in 40 CFR 63.347(e)(2).H & L Plating and Grinding, Inc. Page 20 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT (B) The NCS for tanks 1, 3, 4, 5, and 6 shall be submitted to IDEM, OAM immediately. (3) Notification of Construction or Reconstruction Pursuant to 40 CFR 63.345(b)(1), the Permittee may not construct a new tank subject to 40 CFR 63, Subpart N (including non-affected tanks defined in 40 CFR 63.344(e)) without submitting a Notification of Construction or Reconstruction (NCR) to IDEM, OAM. In addition, the Permittee may not change, modify, or reconstruct tanks 1, 3, 4, 5, and 6 without submitting a Notification of Construction or Reconstruction (NCR) to IDEM, OAM. (A) The NCR shall contain the information identified in 40 CFR 63.345(b) (2) and (3). (B) A change, modification, or reconstruction of this facility includes any change in the air pollution control techniques, the construction of duct work for the purpose of controlling both existing tanks and non-affected facilities by a common control technique or device (i.e., the addition of duct work to the CMP system). (C) A complete application to construct new chromium electroplating or chromium anodizing tanks serves as this notification. Likewise, the complete application to modify or reconstruct tanks 1, 3, 4, 5, and 6 serves as this notification. (D) Pursuant to 326 IAC 2-1.1-2(a), permission must be received from IDEM, OAM before construction, modification, or reconstruction may commence. (b) Performance Test Results The Permittee shall document results from any future performance tests in a complete test report that contains the information required in 40 CFR 344(a). The Permittee shall submit reports of performance test results as part of the Notification of Compliance Status, described in 40 CFR 63.347(e), no later than forty-five (45) days following the completion of the performance test. (c) Ongoing Compliance Status Report The Permittee shall prepare summary reports to document the ongoing compliance status of tanks 1, 3, 4, 5, and 6 using the Ongoing Compliance Status Report form provided with this permit. This report shall contain the information specified in 40 CFR 63.347(g)(3). Because tanks 1, 3, 4, 5, and 6 are located at site that is an area source of hazardous air pollutants (HAPs), the Ongoing Compliance Status Report shall be retained on site and made available to IDEM, OAM upon request. (1) The Ongoing Compliance Status Report shall be completed according to the following schedule except as provided in paragraphs (c)(2). (A) The first report shall cover the period from the issuance date of this permit to December 31 of the year in which the permit is issued.H & L Plating and Grinding, Inc. Page 21 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT (B) Following the first year of reporting, the report shall be completed on a calendar year basis with the reporting period covering from January 1 to December 31. (2) If either of the following conditions are met, semiannual reports shall be prepared and submitted to IDEM, OAM: (A) The total duration of excess emissions (as indicated by the monitoring data collected by the Permittee in accordance with 40 CFR 63.343(c)) is one percent (1%) or greater of the total operating time as defined in Condition D.1.9(b) for the reporting period; or (B) The total duration of malfunctions of the composite mesh-pad system and monitoring equipment is five percent (5%) or greater of the total operating time as defined in Condition D.1.9(b). Once the Permittee reports an exceedance as defined above, Ongoing Compliance Status Reports shall be submitted semiannually until a request to reduce reporting frequency in accordance with 40 CFR 63.347(g)(2) is approved. (3) IDEM, OAM 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.H & L Plating and Grinding, Inc. Page 22 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT SECTION D.2 EMISSIONS UNIT OPERATION CONDITIONS (b) One (1) Arc welding station.

Emission Limitations and Standards
D.2.1 Particulate Matter (PM) [326 IAC 6-3] Pursuant to 326 IAC 6-3 (Process Operations), the allowable PM emission rate from the welding operation shall not exceed 0.016 pounds per hour when operating at a process weight rate of 0.5 pounds per hour. The pounds per hour limitation was calculated with the following equation: Interpolation and extrapolation of the data for the process weight rate up to 60,000 pounds per hour shall be accomplished by use of the equation: E = 4.10 P 0.67 where E = rate of emission in pounds per hour; and P = process weight rate in tons per hour Compliance Determination Requirements [326 IAC 2-5.1-3(e)(2)] [ 326 IAC 2-6.1-5(a)(2)]
D.2.2 Testing Requirements [326 IAC 2-1.1-11] The Permittee is not required to test this emissions unit by this permit. However, IDEM may require compliance testing when necessary to determine if the emissions unit is in compliance. If testing is required by IDEM compliance with the PM limit specified in Condition D.2.1 shall be determined by a performance test conducted in accordance with Section C - Performance Testing. Record Keeping and Reporting Requirement D.2.3 Record Keeping and Reporting Requirements There are no record keeping or reporting requirements for these facilities.Page 23 of 27 INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR MANAGEMENT COMPLIANCE DATA SECTION MINOR SOURCE OPERATING PERMIT CHROMIUM ELECTROPLATING AND ANODIZING NESHAP ONGOING COMPLIANCE STATUS REPORT Source Name: H & L Plating and Grinding, Inc. Source Address: 410 East Willard Street, Muncie, Indiana 47302 Mailing Address: 410 East Willard Street, Muncie, Indiana 47302 MSOP Permit No.: 035-12340-00070 Tank ID #: 1, 3, 4, 5, and 6 Type of process: Hard, Chromium Electroplating Process Monitoring Parameter: Pressure drop across the composite mesh-pad system Parameter Value: 4.20 +1 inch of water column Limits: Total chromium concentration may not exceed 0.015 mg/dscm This form is to be used to report compliance for the Chromium Electroplating and Anodizing NESHAP only. The frequency for completing this report may be altered by IDEM, OAM, Compliance Branch. Complete this report no later than 30 days after the end of the reporting period, and retain on site unless otherwise notified. This form consists of 2 pages Page 1 of 2 BEGINNING AND ENDING DATES OF THE REPORTING PERIOD: TOTAL OPERATING TIME OF THE TANK DURING THE REPORTING PERIOD:

MAJOR AND AREA SOURCES: CHECK ONE 9 NO DEVIATIONS OF THE MONITORING PARAMETER ASSOCIATED WITH THIS TANK FROM THE COMPLIANT VALUE OR RANGE OF VALUES OCCURRED DURING THIS REPORTING PERIOD. 9 THE MONITORING PARAMETER DEVIATED FROM THE COMPLIANT VALUE OR RANGE OF VALUES DURING THIS REPORTING PERIOD (THUS INDICATING THE EMISSION LIMITATION MAY HAVE BEEN EXCEEDED, WHICH COULD RESULT IN MORE FREQUENT REPORTING).

AREA (I.E., NON-MAJOR) SOURCES OF HAP ONLY : IF DEVIATIONS OCCURRED, LIST THE AMOUNT OF TANK OPERATING TIME EACH MONTH THAT MONITORING RECORDS SHOW THE MONITORING PARAMETER DEVIATED FROM THE COMPLIANT VALUE OR RANGE OF VALUES. JAN APR JUL OCT FEB MAY AUG NOV MAR JUN SEP DEC

HARD CHROME TANKS / MAXIMUM RECTIFIER CAPACITY LIMITED IN ACCORDANCE WITH 40 CFR 63.342(c)(2) ONLY: LIST THE ACTUAL AMPERE-HOURS CONSUMED (BASED ON AN AMP-HR METER) BY THE INDIVIDUAL TANK. JAN APR JUL OCT FEB MAY AUG NOV MAR JUN SEP DECH & L Plating and Grinding, Inc. Page 24 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT CHROMIUM ELECTROPLATING AND ANODIZING NESHAP ONGOING COMPLIANCE STATUS REPORT
ATTACH A SEPARATE PAGE IF NEEDED Page 2 of 2 IF THE OPERATION AND MAINTENANCE PLAN REQUIRED BY 40 CFR 63.342 (f)(3) WAS NOT FOLLOWED, PROVIDE AN EXPLANATION OF THE REASONS FOR NOT FOLLOWING THE PLAN AND DESCRIBE THE ACTIONS TAKEN FOR THAT EVENT:

DESCRIBE ANY CHANGES IN TANKS, RECTIFIERS, CONTROL DEVICES, MONITORING, ETC. SINCE THE LAST STATUS REPORT:

ADDITIONAL COMMENTS:

ALL SOURCES: CHECK ONE 9 I CERTIFY THAT THE WORK PRACTICE STANDARDS IN 40 CFR 63.342(f) WERE FOLLOWED IN ACCORDANCE WITH

THE OPERATION AND MAINTENANCE PLAN ON FILE; AND, THAT THE INFORMATION CONTAINED IN THIS REPORT IS ACCURATE AND TRUE TO THE BEST OF MY KNOWLEDGE. 9 THE WORK PRACTICE STANDARDS IN 40 CFR 63.342(f) WERE NOT FOLLOWED IN ACCORDANCE WITH THE

OPERATION AND MAINTENANCE PLAN ON FILE, AS EXPLAINED ABOVE AND/OR ON ATTACHED. Submitted by: Title/Position: Signature: Date: Phone: Attach a signed certification to complete this report.Page 25 of 27 INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR MANAGEMENT COMPLIANCE DATA SECTION MINOR SOURCE OPERATING PERMIT ANNUAL NOTIFICATION This form should be used to comply with the notification requirements under 326 IAC 2-6.1-5(a)(5). Company Name: H & L Plating and Grinding
Address: 410 East Willard Street City: Muncie, Indiana 47302
Phone #: 765-286-2911
MSOP #: 035-12340-00070
I hereby certify that [source]is 9still in operation. 9no longer in operation. I hereby certify that [source]is 9in compliance with the requirements of MSOP 035-12340-00070 9not in compliance with the requirements of MSOP 035-12340-00070 Authorized Individual (typed):
Title: Signature:
Date:
If there are any conditions or requirements for which the source is not in compliance, provide a narrative description of how the source did or will achieve compliance and the date compliance was, or will be achieved. Noncompliance:H & L Plating and Grinding, Inc. Page 26 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT

Rev 3/99 MALFUNCTION REPORT
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR MANAGEMENT FAX NUMBER - 317 233-5967 This form should only be used to report malfunctions applicable to Rule 326 IAC 1-6

and to qualify for the exemption under 326 IAC 1-6-4.

THIS FACILITY MEETS THE APPLICABILITY REQUIREMENTS BECAUSE IT HAS POTENTIAL TO EMIT 25 TONS/YEAR PARTICULATE MATTER ?_____, 25 TONS/YEAR SULFUR DIOXIDE ?_____, 25 TONS/YEAR NITROGEN OXIDES?_____, 25 TONS/YEAR VOC ?_____, 25 TONS/YEAR HYDROGEN SULFIDE ?_____, 25 TONS/YEAR TOTAL REDUCED SULFUR ?_____, 25 TONS/YEAR REDUCED SULFUR COMPOUNDS ?_____, 25 TONS/YEAR FLUORIDES ?_____, 100 TONS/YEAR CARBON MONOXIDE ?_____, 10 TONS/YEAR ANY SINGLE HAZARDOUS AIR POLLUTANT ?_____, 25 TONS/YEAR ANY COMBINATION HAZARDOUS AIR POLLUTANT ?_____, 1 TON/YEAR LEAD OR LEAD COMPOUNDS MEASURED AS ELEMENTAL LEAD ?_____, OR IS A SOURCE LISTED UNDER 326 IAC 2-5.1-3(2) ?_____. EMISSIONS FROM MALFUNCTIONING CONTROL EQUIPMENT OR PROCESS EQUIPMENT CAUSED EMISSIONS IN EXCESS OF APPLICABLE LIMITATION ________. THIS MALFUNCTION RESULTED IN A VIOLATION OF: 326 IAC _______ OR, PERMIT CONDITION # _______ AND/OR PERMIT LIMIT OF _______________ THIS INCIDENT MEETS THE DEFINITION OF ‘MALFUNCTION’ AS LISTED ON REVERSE SIDE ? Y N THIS MALFUNCTION IS OR WILL BE LONGER THAN THE ONE (1) HOUR REPORTING REQUIREMENT ? Y N COMPANY:________________________________________________________PHONE NO. ( )________________________ LOCATION: (CITY AND COUNTY)______________________________________________________________________________ PERMIT NO. _________________ AFS PLANT ID: _________________ AFS POINT ID: _________________ INSP:___________ CONTROL/PROCESS DEVICE WHICH MALFUNCTIONED AND REASON:_____________________________________________

_________________________________________________________________________________________________________ DATE/TIME MALFUNCTION STARTED: _____/_____/ 20____ _____________________________________________ AM / PM ESTIMATED HOURS OF OPERATION WITH MALFUNCTION CONDITION: ____________________________________________
DATE/TIME CONTROL EQUIPMENT BACK-IN SERVICE______/______/ 20____ _______________ AM/PM

TYPE OF POLLUTANTS EMITTED: TSP, PM-10, SO2, VOC, OTHER:___________________________________________ ESTIMATED AMOUNT OF POLLUTANT EMITTED DURING MALFUNCTION: _________________________________________

_________________________________________________________________________________________________________ MEASURES TAKEN TO MINIMIZE EMISSIONS:_________________________________________________________________

_________________________________________________________________________________________________________ REASONS WHY FACILITY CANNOT BE SHUTDOWN DURING REPAIRS: CONTINUED OPERATION REQUIRED TO PROVIDE ESSENTIAL* SERVICES:_______________________________________ CONTINUED OPERATION NECESSARY TO PREVENT INJURY TO PERSONS:_______________________________________ CONTINUED OPERATION NECESSARY TO PREVENT SEVERE DAMAGE TO EQUIPMENT:____________________________ INTERIM CONTROL MEASURES: (IF APPLICABLE)______________________________________________________________

_________________________________________________________________________________________________________

_________________________________________________________________________________________________________ MALFUNCTION REPORTED BY:___________________________________TITLE:_____________________________ (SIGNATURE IF FAXED) MALFUNCTION RECORDED BY:_______________________DATE:__________________TIME:__________________ *SEE PAGE 2 PAGE 1 OF 2H & L Plating and Grinding, Inc. Page 27 of 27

Muncie, Indiana MSOP 035-12340-00070 Permit Reviewer: ERG/MT

Rev 3/99

Please note - This form should only be used to report malfunctions

applicable to Rule 326 IAC 1-6 and to qualify for the exemption under 326 IAC 1-6-4.

326 IAC 1-6-1 Applicability of rule Sec. 1. This rule applies to the owner or operator of any facility required to obtain a permit under 326 IAC 2-5.1 or 326 IAC 2-6.1. 326 IAC 1-2-39 “Malfunction” definition Sec. 39. Any sudden, unavoidable failure of any air pollution control equipment, process, or combustion or process equipment to operate in a normal and usual manner.

* Essential servicesare interpreted to mean those operations, such as, the providing of electricity by power plants. Continued operation solely for the economic benefit of the owner or operator shall not be sufficient reason why a facility cannot be shutdown during a control equipment shutdown. If this item is checked on the front, please explain rationale:

PAGE 2 OF 2Page 1 of 5



## Indiana Department of Environmental Management

Office of Air Management Technical Support Document (TSD) for a Minor Source Operating Permit

Source Background and Description Source Name: H & L Plating and Grinding, Inc. Source Location: 410 East Willard Street, Muncie, Indiana 47302 County: Delaware SIC Code: 3471 Operation Permit No.: 035-12340-00070 Permit Reviewer: ERG/MT The Office of Air Management (OAM) has reviewed an application from H & L Plating and Grinding relating to the operation of a hard chrome plating process. Unpermitted Emission Units and Pollution Control Equipment The source consists of the following unpermitted facilities/units: (a) Five (5) hard chrome plating tanks identified as tanks 1, 3, 4, 5, and 6, with a maximum cumulative rectifier capacity of 88.2 million Ampere-hours using a composite mesh-pad system as control, and exhausting to stack S1. (b) One (1) arc welding station. (c) Eleven (11) grinders. Because all grinding is performed with the metal part underwater, emissions from grinding are considered negligible. Permitted Emission Units and Pollution Control Equipment There are no permitted facilities operating at this source during this review. Enforcement Issue (a) IDEM is aware that this facility is not in compliance with 326 IAC 2-6.1-3(a) which required the source to submit a permit application by December 25, 1999. (b) IDEM is reviewing this matter and will take appropriate action. This proposed permit is intended to satisfy the requirements of the operating permit rules. Recommendation The staff recommends to the Commissioner that the operation be approved. This recommendation is based on the following facts and conditions: Unless otherwise stated, information used in this review was derived from the application and additional information submitted by the applicant.H & L Plating and Grinding

Muncie, Indiana Permit Reviewer: ERG/MT Page 2 of 5 MSOP No. 035-12340-00070
A complete application for the purposes of this review was received on June 2, 2000. Emission Calculations (a) Chromium emissions (single HAP) from the biggest source in Indiana is less than ten (10) tons per year. Therefore, no calculations were necessary for the hard chromium electroplating operation because the emissions from this source will be less than ten (10) tons per year. (b) See Appendix A of this document for detailed emissions calculations for the welding operation. (Appendix A, pages 1 of 1).
Potential To Emit Pursuant to 326 IAC 2-1.1-1(16), Potential to Emit is defined as “the maximum capacity of a stationary source or emissions unit to emit any air pollutant under its physical and operational design. Any physical or operational limitation on the capacity of a source to emit an air pollutant, including air pollution control equipment and restrictions on hours of operation or type or amount of material combusted, stored, or processed shall be treated as part of its design if the limitation is enforceable by the U. S. EPA, the department, or the appropriate local air pollution control agency.”
Pollutant Potential To Emit (tons/year) PM 0.05 PM-10 0.05 SO 2 0 VOC 0 CO 0 NO x 0

HAP’s Potential To Emit (tons/year) Chromium Compounds Less than 10 Manganese Compounds Less than 10

Total Less than 25 (a) The potential to emit (as defined in 326 IAC 2-7-1(29)) of any single HAP is less than ten (10) tons per year and the potential to emit (as defined in 326 IAC 2-7-1(29)) of a combination of HAPs is less than twenty-five (25) tons per year. Therefore, the source is not subject to the provisions of 326 IAC 2-7. Actual Emissions No previous emission data has been received from this source. County Attainment Status The source is located in Delaware County.H & L Plating and Grinding

Muncie, Indiana Permit Reviewer: ERG/MT Page 3 of 5 MSOP No. 035-12340-00070

Pollutant Status PM-10 attainment SO 2 attainment NO 2 attainment Ozone attainment CO attainment Lead attainment (a) Volatile organic compounds (VOC) and oxides of nitrogen (NOx) are precursors for the formation of ozone. Therefore, VOC emissions are considered when evaluating the rule applicability relating to the ozone standards. Delaware County has been designated as attainment or unclassifiable for ozone. Therefore, VOC and NOx emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2 and 40 CFR 52.21. (b) Delaware County has been classified as attainment or unclassifiable for all criteria pollutants. Therefore, these emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2 and 40 CFR 52.21. Source Status Existing Source PSD, Part 70 or FESOP Definition (emissions after controls, based on 8,760 hours of operation per year at rated capacity and/ or as otherwise limited):

Pollutant Emissions (ton/yr) PM 0.05 PM10 0.05 SO 2 0 VOC 0 CO 0 NOx 0 (a) This existing source is nota major stationary source because no attainment pollutant is emitted at a rate of 250 tons per year or greater and it is not in one of the 28 listed source categories. Part 70 Permit Determination 326 IAC 2-7 (Part 70 Permit Program) This existing source is not subject to the Part 70 Permit requirements because the potential to emit (PTE) of: (a) Each criteria pollutant is less than 100 tons per year, (b) A single hazardous air pollutant (HAP) is less than 10 tons per year, and (c) Any combination of HAPs is less than 25 tons/year. This status is based on all the air approvals issued to the source.H & L Plating and Grinding

Muncie, Indiana Permit Reviewer: ERG/MT Page 4 of 5 MSOP No. 035-12340-00070

Federal Rule Applicability (a) There are no New Source Performance Standards (NSPS) (326 IAC 12 and 40 CFR Part 60) applicable to this source. (b) Tanks 1, 3, 4, 5, and 6 are subject to the National Emission Standards for Hazardous Air Pollutants, 326 IAC 14, (40 CFR 63, Subpart N, and 326 IAC 20-1-1). Pursuant to 40 CFR 63, Subpart N, and 326 IAC 20-1-1, the chromium electroplating operations are subject to the following conditions: (1) Emission limitation: The permittee shall comply with the requirements of this condition on and after the compliance date for the tanks. The hard chromium electroplating tanks, identified as tanks 1, 3, 4, 5 and 6 above, are considered a large, existing hard chromium electroplating operation. During tank operation, the Permittee shall control chromium emissions discharged to the atmosphere from the tank(s) by not allowing the concentration of total chromium in the exhaust gas stream discharged to the atmosphere to exceed fifteen-thousandth milligrams of total chromium per dry standard cubic meter of ventilation air (0.015 mg/dscm) [equivalent to six and six-tenths times ten raised to the power of negative six grains of total chromium per dry standard cubic foot of ventilation air (6.6x10 -6gr/dscf)]. (2) Monitoring Requirements: Tanks 1, 3, 4, 5 and 6 shall be operated such that the pressure drop across that composite mesh-pad system shall be within ± 1 inch of water column of the pressure drop value established during the initial performance test, or within the range of compliant values for pressure drop established during multiple performance tests. The pressure drop shall be monitored once each day that a hard chromium electroplating tank is operating. (3) Reporting Requirements: A summary report shall be prepared to document the ongoing compliance status of the chromium electroplating operation. This report shall be completed annually, retained on site, and made available to IDEM upon request. If there are significant exceedance of chromium air emission limits (as defined in 40 CFR Part 63.347(h)(2)), then semiannual reports shall be submitted to: Indiana Department of Environmental Management Air Compliance Branch, Office of Air Management Chromium Electroplating 100 North Senate Avenue, P.O. Box 6015 Indianapolis, Indiana 46206 (4) The chromium electroplating operations shall be subject to the record keeping and reporting requirement as indicated in the chromium electroplating NESHAP.H & L Plating and Grinding

Muncie, Indiana Permit Reviewer: ERG/MT Page 5 of 5 MSOP No. 035-12340-00070
State Rule Applicability - Entire Source 326 IAC 2-4.1 (Major Source of the Hazardous Air Pollutants) This source is not a major source of HAP and it has been an existing source for over twelve (12) years. Therefore, 326 IAC 2-4.1 does not apply. 326 IAC 2-6 (Emission Reporting) This source is located in Delaware County and the potential to emit of any of the criteria pollutants is less than one hundred (100) tons per year. Therefore, 326 IAC 2-6 does not apply. The source will be required to annually submit a statement of the actual emissions of all federally regulated pollutants from the source, for the purpose of fee assessment. 326 IAC 5-1 (Visible Emissions Limitations) Pursuant to 326 IAC 5-1-2 (Opacity Limitations), except as provided in 326 IAC 5-1-3 (Temporary Exemptions), opacity shall meet the following, unless otherwise stated in this permit: (a) Opacity shall not exceed an average of forty percent (40%) any one (1) six (6) minute averaging period as determined in 326 IAC 5-1-4. (b) Opacity shall not exceed sixty percent (60%) for more than a cumulative total of fifteen (15) minutes (sixty (60) readings) as measured according to 40 CFR 60, Appendix A, Method 9 or fifteen (15) one (1) minute nonoverlapping integrated averages for a continuous opacity monitor) in a six (6) hour period. State Rule Applicability - Individual Facilities 326 IAC 6-3-2 (Process Operations) The particulate matter (PM) from welding shall be limited by the following: Interpolation and extrapolation of the data for the process weight rate up to sixty thousand (60,000) pounds per hour shall be accomplished by use of the equation: E = 4.10 P 0.67 where E = rate of emission in pounds per hour and P = process weight rate in tons per hour Conclusion The operation of this hard chrome plating process shall be subject to the conditions of the attached proposed Minor Source Operating Permit 035-12340-00070.Appendix A: Emissions Calculations Page 1 of 1 TSD App A Welding and Thermal Cutting Company Name: H & L Plating and Grinding Address City IN Zip: 410 East Willard Street, Muncie, Indiana 47302

Permit ID: 035-12340 Plt ID: 00070 Reviewer: ERG/MT Date: 06/29/00

PROCESS Number of Max. electrode EMISSION FACTORS* EMISSIONS HAPS Stations consumption per (lb pollutant/lb electrode) (lbs/hr) (lbs/hr) WELDING station (lbs/hr) PM = PM10 Mn Ni Cr PM = PM10 Mn Ni Cr Submerged Arc 0 0 0.036 0.011 0.000 0.000 0.000 0 0.000 Metal Inert Gas (MIG)(carbon steel) 0 0 0.0055 0.0005 0.000 0.000 0.000 0 0.000 Stick (E7018 electrode) 1 0.5 0.0211 0.0009 0.011 0.000 0.000 0 0.000 Tungsten Inert Gas (TIG)(carbon steel) 0 0 0.0055 0.0005 0.000 0.000 0.000 0 0.000 Oxyacetylene(carbon steel) 0 0.0055 0.0005 0.000 0.000 0.000 0 0.000

Number of Max. Metal Max. Metal EMISSION FACTORS EMISSIONS HAPS Stations Thickness Cutting Rate (lb pollutant/1,000 inches cut, 1" thick)** (lbs/hr) (lbs/hr) FLAME CUTTING Cut (in.) (in./minute) PM = PM10 Mn Ni Cr PM = PM10 Mn Ni Cr Oxyacetylene 0 0 0 0.1622 0.0005 0.0001 0.0003 0.000 0.000 0.000 0.000 0.000 Oxymethane 0 0 0 0.0815 0.0002 0.0002 0.000 0.000 0.000 0.000 0.000 Plasma** 0 0 0 0.0039 0.000 0.000 0.000 0.000 0.000

EMISSION TOTALS

Potential Emissions lbs/hr 0.01 0.000 Potential Emissions lbs/day 0.25 0.011 Potential Emissions tons/year 0.05 0.002

METHODOLOGY *Emission Factors are default values for carbon steel unless a specific electrode type is noted in the Process column. **Emission Factor for plasma cutting from American Welding Society (AWS). Trials reported for wet cutting of 8 mm thick mild steel with 3.5 m/min cutting speed (at 0.2 g/min emitted). Therefore, the emission factor for plasma cutting is for 8 mm thick rather than 1 inch, and the maximum metal thickness is not used in calculating the emissions. Using AWS average values: (0.25 g/min)/(3.6 m/min) x (0.0022 lb/g)/(39.37 in./m) x (1,000 in.) = 0.0039 lb/1,000 in. cut, 8 mm thick Plasma cutting emissions, lb/hr: (# of stations)(max. cutting rate, in./min.)(60 min./hr.)(emission factor, lb. pollutant/1,000 in. cut, 8 mm thick) Cutting emissions, lb/hr: (# of stations)(max. metal thickness, in.)(max. cutting rate, in./min.)(60 min./hr.)(emission factor, lb. pollutant/1,000 in. cut, 1" thick) Welding emissions, lb/hr: (# of stations)(max. lbs of electrode used/hr/station)(emission factor, lb. pollutant/lb. of electrode used) Emissions, lbs/day = emissions, lbs/hr x 24 hrs/day Emissions, tons/yr = emissions, lb/hr x 8,760 hrs/year x 1 ton/2,000 lbs. Welding and other flame cutting emission factors are from an internal training session document. Refer to AP-42, Chapter 12.19 for additional emission factors for welding. welding.wk4 (11/99)