# INDIANA 

# D EPARTMENT OF 

# ENVIRONMENTAL 

# MANAGEMENT We make Indiana a cleaner, healthier place to live.

100 North Senate Avenue Frank O’Bannon P. O. Box 6015 Governor Indianapolis, Indiana 46206-6015 (317) 232-8603 Lori F. Kaplan (800) 451-6027 Commissioner www.IN.gov/idem

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# MINOR SOURCE OPERATING PERMIT OFFICE OF AIR QUALITY Baycote Metal Finishing, Inc. 1302 Industrial Drive Mishawaka, Indiana 46544

(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 141-16170-00108

Issued by:Original signed by Paul Dubenetzky Paul Dubenetzky, Branch Chief Office of Air Quality Issuance Date: January 7, 2003 Expiration Date: January 7, 2008Baycote Metal Finishing, Inc. Page 2 of 29

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TABLE OF CONTENTS
A SOURCE SUMMARY 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
B GENERAL CONDITIONS B.1 Permit No Defense [IC 13] B.2 Definitions B.3 Effective Date of the Permit [IC 13-15-5-3] B.4 Permit Term and Renewal [326 IAC 2-6.1-7(a)][326 IAC 2-1.1-9.5] B.5 Modification to Permit [326 IAC 2] B.6 Annual Notification [326 IAC 2-6.1-5(a)(5)] B.7 Preventive Maintenance Plan [326 IAC 1-6-3] B.8 Permit Revision [326 IAC 2-5.1-3(e)(3)] [326 IAC 2-6.1-6] B.9 Inspection and Entry [326 IAC 2-5.1-3(e)(4)(B)] [326 IAC 2-6.1-5(a)(4)] [IC 13-14-2-2] B.10 Transfer of Ownership or Operation [326 IAC 2-6.1-6(d)(3)] B.11 Annual Fee Payment [326 IAC 2-1.1-7] C SOURCE OPERATION CONDITIONS C.1 Particulate Emission Limitations For Processes with Process Weight Rates Less Than One Hundred (100) pounds per hour [40 CFR 52 Subpart P] [326 IAC 6-3-2 ] C.2 Permit Revocation [326 IAC 2-1.1-9] C.3 Opacity [326 IAC 5-1] C.4 Fugitive Dust Emissions [326 IAC 6-4] C.5 Asbestos Abatement Projects [326 IAC 14-10] [326 IAC 18] [40 CFR 61, Subpart M] Testing Requirements C.6 Performance Testing [326 IAC 3-6] Compliance Requirements [326 IAC 2-1.1-11] C.7 Compliance Requirements [326 IAC 2-1.1-11] Compliance Monitoring Requirements C.8 Compliance Monitoring [326 IAC 2-1.1-11] C.9 Monitoring Methods [326 IAC 3] C.10 Pressure Gauge and Other Instrument Specifications [326 IAC 2-1.1-11] [326 IAC 2-6.1-4 (4)(C)] C.11 Compliance Response Plan - Preparation and Implementation 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 General Record Keeping Requirements [326 IAC 2-6.1-5] C.15 General Reporting Requirements [326 IAC 2-1.1-11] [326 IAC 2-6.1-2] [IC 13-14-1-13] C.16 Annual Notification [326 IAC 2-6.1-5(a)(5)]
D.1 EMISSIONS UNIT OPERATION CONDITIONS: Chromium Electroplating Emission Limitations and Standards [326 IAC 2-6.1-5(1)] 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]Baycote Metal Finishing, Inc. Page 3 of 29

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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] Compliance Determination Requirements [326 IAC 2-1.1-11] D.1.7 Performance Testing Requirements [326 IAC 2-1.1-11] [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)] [40 CFR 63.343(c)] [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)] [40 CFR 63.345] [40 CFR 63.347] [326 IAC 20-8-1]
D.2 EMISSIONS UNIT OPERATION CONDITIONS: Boiler Emission Limitations and Standards [326 IAC 2-6.1-5(1)] D.2.1 Particulate Matter Limitation [326 IAC 6-2-3(d)] Chromium Electroplating and Anodizing NESHAP Ongoing Compliance Status Report Malfunction Report Annual NotificationBaycote Metal Finishing, Inc. Page 4 of 29

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SECTION A SOURCE SUMMARY This permit is based on information requested by the Indiana Department of Environmental Management (IDEM), Office of Air Quality (OAQ). The information describing the source contained in Conditions A.1 and A.2 are 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 a stationary chromium electroplating source. Authorized Individual: General Manager Source Address: 1203 Industrial Drive, Mishawaka, Indiana 64544 Mailing Address: 1203 Industrial Drive, Mishawaka, Indiana 64544 General Source Phone: (574) 256-5673 SIC Code: 3471 County Location: St. Joseph Source Location Status: Attainment for all criteria pollutants Source Status: Minor Source Operating Permit Minor Source, under PSD 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) One (1) hard chrome plating tank, identified as Chrome tank 1, constructed in February 1997, using a hexavalent chromium bath and having a rectifier capacity of 4,000 amps and a maximum cumulative rectifier capacity of 23,520,000 amp-hours, equipped with a composite mesh pad system and a mist suppressant containing a wetting agent as controls, and exhausting to the chrome stack. (b) One (1) natural gas-fired boiler, constructed in 1967, exhausting to the boiler stack, heat input capacity: 5.3737 million British thermal units per hour.Baycote Metal Finishing, Inc. Page 5 of 29

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SECTION B GENERAL 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 Termsin this permit shall have the definition assigned to such terms in the referenced regulation. In the absence of definitions in the referenced regulation, the applicable definitions found in the statutes or regulations 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 Permit Term and Renewal [326 IAC 2-6.1-7(a)][326 IAC 2-1.1-9.5] This permit is issued for a fixed term of five (5) years from the issuance date of this permit, as determine d in accordance with IC 4-21.5-3-5(f) and IC 13-15-5-3. Subsequent revisions of this permit do not affect the expiration date. The Permittee shall apply for an operation permit renewal at least ninety (90) days prior to the expiration date. If a timely and sufficient permit application for a renewal has been made, this permit shall not expire and all terms and conditions shall continue in effect until the renewal permit has been issued or denied. B.5 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). B.6 Annual Notification [326 IAC 2-6.1-5(a)(5)] (a) Annual notification shall be submitted to the Office of Air Quality stating whether or not the source is in operation and in compliance with the terms and conditions contained in this permit. (b) Nonc ompliance with any condition must be specifically identified. If there are any permit conditionsor 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 achievecompliance 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 Branch, Office of Air Quality Indiana Department of Environmental Management 100 North Senate Avenue, P.O. Box 6015 Indianapolis, IN 46206-6015Baycote Metal Finishing, Inc. Page 6 of 29

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(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, OAQ, on or before the date it is due.
B.7 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 (PMPs) within ninety (90) days 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; and (3) Identification and quantification of the replacement parts that will be maintained in inventory for quick replacement. If, due to circumstances beyond the Permittee’s control, the PMPs cannot be prepared and maintained within the above time frame, the Permittee may extend the date an additional ninety (90) days provided the Permittee notifies: Indiana Department of Environmental Management Compliance Branch, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015 The PMP extension notification does not require the certification by an “authorized individual” as defined by 326 IAC 2-1.1-1(1). (b) The Permittee shall implement the PMPs as necessary to ensure that failure to implement a PMP does not cause or contribute to a violation of any limitation on emissions or potential to emit. (c) A

copy of the PMP’s shall be submitted to IDEM, OAQ, upon request and within a reasonable time, and shall be subject to review and approval by IDEM, OAQ. IDEM, OAQ, mayrequire the Permittee to revise its PMP whenever lack of proper maintenance causes or contributes to any violation. The PMP does not require the certification by an “authorized individual” as defined by 326 IAC 2-1.1-1(1). (d) Records of preventive maintenance shall be retained for a period of at least five (5) years. These records shall be kept at the source location for a minimum of three (3) years. 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 request for records to the Permittee, the Permittee shall furnish the records to the Commissioner within a reasonable time. B.8 Permit Revision [326 IAC 2-5.1-3(e)(3)] [326 IAC 2-6.1-6] (a) Permit revisions are governed by the requirements of 326 IAC 2-6.1-6. (b) Any

application requesting an amendment or modification of this permit shall be submitted to:Baycote Metal Finishing, Inc. Page 7 of 29

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Indiana Department of Environmental Management Permits Branch, Office of Air Quality 100 North Senate Avenue, P.O. Box 6015 Indianapolis, Indiana 46206-6015 Any such application shall be certified by an “authorized individual” as defined by 326 IAC 2-1.1-1. (c) The Permittee shall notify the OAQ within thirty (30) calendar days of implementing a notice-only change. [326 IAC 2-6.1-6(d)] B.9 Inspection and Entry [326 IAC 2-5.1-3(e)(4)(B)] [326 IAC 2-6.1-5(a)(4)][IC 13-14-2-2] 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 assertthat the information collected by the agency is confidential and entitled to be treated as such, the Permittee shall allow IDEM, OAQ, 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) Haveaccess 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. B.10 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, OAQ, 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, OAQ, 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.
B.11 Annual Fee Payment [326 IAC 2-1.1-7] (a) The Permittee shall pay annual fees to IDEM, OAQ within thirty (30) calendar days of receipt of a billing.Baycote Metal Finishing, Inc. Page 8 of 29

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(b) The Permittee may call the following telephone numbers: 1-800-451-6027 or 317-233-4230 (ask for OAQ, I/M & Billing Section), to determine the appropriate permit fee.Baycote Metal Finishing, Inc. Page 9 of 29

Mishawaka, Indiana MSOP 141-16170-00108 Permit Reviewer: CAP/MES

SECTION C SOURCE OPERATION CONDITIONS

Entire Source
C.1 Particulate Emission Limitations For Processes with Process Weight Rates Less Than One Hundred (100) pounds per hour [40 CFR 52 Subpart P][326 IAC 6-3-2] (a) Pursuant

to 40 CFR 52 Subpart P, the allowable particulate matter emissions rate from any processnot already regulated by 326 IAC 6-1 or any New Source Performance Standard, and which has a maximum process weight rate less than 100 pounds per hour shall not exceed 0.551 pounds per hour. (b) Pursuant

to 326 IAC 6-3-2(e)(2), the allowable particulate emissions rate from any process notexempt under 326 IAC 6-3-1(b) or (c) which has a maximum process weight rate less than 100 pounds per hour and the methods in 326 IAC 6-3-2(b) through (d) do not apply shall not exceed 0.551 pounds per hour. C.2 Permit Revocation [326 IAC 2-1.1-9] Pursuant to 326 IAC 2-1.1-9 (Revocation of Permits), this permit to operate may be revoked for any of the following causes: (a) Violation of any conditions of this permit. (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.3 Opacity [326 IAC 5-1] Pursuant to 326 IAC 5-1-2 (Opacity Limitations), except as provided in 326 IAC 5-1-3 (Temporary AlternativeOpacity Limitations), opacity shall meet the following, unless otherwise stated in this permit: (a) Opacity

shall not exceed an average of thirty percent (30%) 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. C.4 Fugitive Dust Emissions [326 IAC 6-4] The Permittee shall not allow fugitive dust to escape beyond the property line or boundaries of the property, right-of-way, or easement on which the source is located, in a manner that would violate 326 IAC 6-4 (Fugitive Dust Emissions).Baycote Metal Finishing, Inc. Page 10 of 29

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C.5 Asbestos Abatement Projects [326 IAC 14-10] [326 IAC 18] [40 CFR 61, Subpart M] (a) Notification requirements apply to each owner or operator. If the combined amount of regulated asbestos containing material (RACM) to be stripped, removed or disturbed is at least260 linear feet on pipes or 160 square feet on other facility components, or at least thirty-five(35) cubic feet on all facility components, then the notification requirements of 326 IAC14-10-3 are mandatory. All demolition projects require notification whether or not asbestos is present. (b) The Permittee shall ensure that a written notification is sent on a form provided by the Commissioner

at least ten (10) working days before asbestos stripping or removal work or before demolition begins, per 326 IAC 14-10-3, and shall update such notice as necessary, including, but not limited to the following: (1) When the amount of affected asbestos containing material increases or decreases by at least twenty percent (20%); or (2) If there is a change in the following: (A) Asbestos removal or demolition start date; (B) Removal or demolition contractor; or (C) Waste disposal site. (c) The Permittee shall ensure that the notice is postmarked or delivered according to the guidelines set forth in 326 IAC 14-10-3(2). (d) The notice to be submitted shall include the information enumerated in 326 IAC 14-10-3(3). All required notifications shall be submitted to: Indiana Department of Environmental Management Asbestos Section, Office of Air Quality 100 North Senate Avenue, P.O. Box 6015 Indianapolis, Indiana 46206-6015 The notice shall include a signed certification from the owner or operator that the information provided in this notification is correct and that only Indiana licensed workers and project supervisors will be used to implement the asbestos removal project. The notifications do not require a certification by an “authorized individual” as defined by 326 IAC 2-1.1-1. (e) Procedures for Asbestos Emission Control The Permittee shall comply with the applicable emission control procedures in 326 IAC 14- 10-4 and 40 CFR 61.145(c). Per 326 IAC 14-10-1, emission control requirements are applicable for any removal or disturbance of RACM greater than three (3) linear feet on pipes or three (3) square feet on any other facility components or a total of at least 0.75 cubic feet on all facility components. (f) Indiana Accredited Asbestos Inspector The Permittee shall comply with 326 IAC 14-10-1(a) that requires the owner or operator, prior to a renovation/demolition, to use an Indiana Accredited Asbestos Inspector to thoroughly

inspect the affected portion of the facility for the presence of asbestos. TheBaycote Metal Finishing, Inc. Page 11 of 29

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requirement

that the inspector be accredited, pursuant to the provisions of 40 CFR 61, Subpart M, is federally enforceable. Testing Requirements C.6 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 than180 days after initial start-up, if specified in Section D of this approval. All testing shall be performed according to the provisions of 326 IAC3-6 (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, OAQ. 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 Quality 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. (b) The Permittee shall notify IDEM, OAQ of the actual test date at least fourteen (14 days) prior to the actual date. (c) Pursuant

to 326 IAC 3-6-4(b), all test reports must be received by IDEM, OAQ, not later than forty-five (45) days after the completion of the testing. An extension may be granted by the IDEM, OAQ, if the source submits to IDEM, OAQ, a reasonable written explanation not later than five (5) days prior to the end of the initial forty-five (45) day period. Compliance Requirements [326 IAC 2-1.1-11] C.7 Compliance Requirements [326 IAC 2-1.1-11] The commissioner may require stack testing, monitoring, or reporting at any time to assure compliance with all applicable requirements by issuing an order under 326 IAC 2-1.1-11. Any monitoring or testing shall be performed in accordance with 326 IAC 3 or other methods approved by the commissioner or the U.S. EPA. Compliance Monitoring Requirements C.8 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.9 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.0Baycote Metal Finishing, Inc. Page 12 of 29

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C.10 Pressure Gauge and Other Instrument Specifications [326 IAC 2-1.1-11] [326 IAC 2-6.1-4(4)(C) (a) Whenever

a condition in this permit requires the measurement of total static pressure drop acrossany part of the unit or its control device, the gauge employed shall have a scale such that the expected normal reading shall be no less than twenty percent (20%) of full scale and be accurate within plus or minus two percent ( ±2%) of full scale reading. (b) Whenever

a condition in this permit requires the measurement of surface tension, the instrument

employed shall have a scale such that the expected normal reading shall be no lessthan twenty percent (20%) of full scale and be accurate within plus or minus two percent ( ±2%) of full scale reading. (c) The Permittee may request the IDEM, OAQ approve the use of a pressure gauge or other instrument

that does not meet the above specifications provided the Permittee can demonstrate an alternative pressure gauge or other instrument specification will adequately ensure compliance with permit conditions requiring the measurement of pressure drop or other parameters. C.11 Compliance Response Plan - Preparation and Implementation (a) The Permittee is required to prepare a Compliance Response Plan (CRP) for each compliance monitoring condition of this permit. A CRP shall be submitted to IDEM, OAQ upon request. The CRP shall be prepared within ninety (90) days after issuance of this permit by the Permittee, supplemented from time to time by the Permittee, maintained on site, and comprised of: (1) Reasonable response steps that may be implemented in the event that a response stepis needed pursuant to the requirements of Section D of this permit; and an expected time frame for taking reasonable response steps. (2) If, at any time, the Permittee takes reasonable response steps that are not set forth in the Permittee’s current Compliance Response Plan, the Permittee shall amend its Compliance Response Plan to include such response steps taken. (b) For

each compliance monitoring condition of this permit, reasonable response steps shall be taken when indicated by the provisions of that compliance monitoring condition as follows: (1) Reasonable response steps shall be taken as set forth in the Permittee’s current Compliance Response Plan; or (2) If

none of the reasonable response steps listed in the Compliance Response Plan isapplicable or responsive to the excursion, the Permittee shall devise and implementadditional response steps as expeditiously as practical. Taking such additional response steps shall not be considered a deviation from this permit so long asthe Permittee documents such response steps in accordance with this condition. (3) If

the Permittee determines that additional response steps would necessitate that the emissions unit or control device be shut down, the IDEM, OAQ shall be promptly notified of the expected date of the shut down, the status of the applicable compliance monitoring parameter with respect to normal, and the results of the actions taken up to the time of notification. (4) Failure to take reasonable response steps shall constitute a violation of the permit.Baycote Metal Finishing, Inc. Page 13 of 29

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(c) The Permittee is not required to take any further response steps for any of the following reasons: (1) A

false reading occurs due to the malfunction of the monitoring equipment and 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 a minor permit modification to the permit, and such request has not been denied. (3) An automatic measurement was taken when the process was not operating. (4) The process has already returned or is returning to operating within “normal” parameters and no response steps are required. (d) Except

as otherwise provided by a rule or provided specifically in Section D, all monitoring asrequired in Section D shall be performed when the emission unit is operating, except for time necessary to perform quality assurance and maintenance activities. 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 response actions. The Permittee shall submit a description of these response actions to IDEM, OAQ, within thirty (30) days of receipt of the test results. The Permittee shall take appropriate action to minimize excess emissions from the affected emissions unit while the response actions are being implemented. (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, OAQ that retesting in one-hundred and twenty (120) days is not practicable, IDEM, OAQ may extend the retesting deadline. (c) IDEM, OAQ reserves the authority to take any actions allowed under law in response to noncompliant stack tests. The documents submitted pursuant to this condition do not require the certification by an “authorized individual” as defined by 326 IAC 2-1.1-1. 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 Quality (OAQ) 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 OAQ, using the Malfunction Report Forms(2 pages). Notification shall be made by telephone or facsimile, as soon as practic-Baycote Metal Finishing, Inc. Page 14 of 29

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able, 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 of326 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 General Record Keeping Requirements [326 IAC 2-6.1-5] (a) Records of all required data, reports 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. 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 request for records to the Permittee, the Permittee shall furnish the records to the Commissioner within a reasonable time. (b) Unless otherwise specified in this permit, all record keeping requirements not already legally required shall be implemented when operation begins. C.15 General Reporting Requirements [326 IAC 2-1.1-11] [326 IAC 2-6.1-2] [IC 13-14-1-13] (a) 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 Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015 (b) 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, OAQ, on or before the date it is due. (c) Unless otherwise specified in this permit, any quarterly or semi-annual report required in Section D of this permit shall be submitted within thirty (30) days of the end of the reporting period. The reports do not require the certification by an “authorized individual” as defined by 326 IAC 2-1.1-1(1). (d) Th e 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. Reporting periods are based on calendar years. C.16 Annual Notification [326 IAC 2-6.1-5(a)(5)] (a) Annual notification shall be submitted to the Office of Air Quality stating whether or not the source is in operation and in compliance with the terms and conditions contained in this permit.Baycote Metal Finishing, Inc. Page 15 of 29

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(b) Noncompliance with any condition must be specifically identified. If there are any permit conditionsor 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 Branch, Office of Air Quality 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, OAQ, on or before the date it is due.Baycote Metal Finishing, Inc. Page 16 of 29

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SECTION D.1 EMISSIONS UNIT OPERATION CONDITIONS
Emissions Unit Description: (a) One (1) hard chrome plating tank, identified as Chrome tank 1, constructed in February 1997, using a hexavalent chromium bath and having a rectifier capacity of 4,000 amps and a maximum cumulativerectifier capacity of 23,520,000 amp-hours, equipped with a composite mesh pad system and a mist suppressant containing a wetting agent as controls, and exhausting to the chrome stack. (The information describing the process contained in this emissions unit description box is descriptive information and does not constitute enforceable conditions.) Emission Limitations and Standards [326 IAC 2-6.1-5(1)]
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 tank.
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 Chrome tank 1. The Permittee shall comply with the requirements of this condition on and after the compliance date for the tank. D.1.3 Chromium Emissions Limitation [40 CFR 63.342(c)] [40 CFR 63.343(a)(1)&(2)] [326 IAC 20-8-1] (a) The emission limitations 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 tank, identified as Chrome tank 1 above, is considered a small, new hard chromium electroplating operation. During tank operation, the Permittee shall control chromium emissions discharged to the atmosphere from the tank 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 -6gr/dscf].
D.1.4 Work Practice Standards [40 CFR 63.342(f)] [326 IAC 20-8-1] The following work practice standards apply to Chrome tank 1: (a) Atall times, including periods of startup, shutdown, malfunction and excess emissions, the Permittee shall operate and maintain Chrome tank 1, including the composite mesh pad sys tem, wetting agent 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) Malfunctionsand excess emissions shall be corrected as soon as practicable after their occurrence in accordance with the OMP required by Condition D.1.6. (c) These operation and maintenance requirements are enforceable independent of emissions limitations or other requirements in this section.Baycote Metal Finishing, Inc. Page 17 of 29

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(d) Determination of whether acceptable operation and maintenance procedures are being used will be based on information available to IDEM, OAQ, 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, OAQ may require that the Permittee make changes to the OMP required by Condition D.1.6. Revisions may be required if IDEM, OAQ finds that the plan: (1) Does not address a malfunction or period of excess emissions that has occurred; (2) Failsto provide for the operation of Chrome tank 1, the composite mesh pad system, or the wetting agent 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, composite mesh pad system, wetting agent, monitoring equipment or other causes of excess emissions as quickly as practicable. (f) For

Chrome tank 1, the Permittee shall comply with the requirements of this condition on and after the start-up date of the tank. (g) 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 B-Preventive Maintenance Plan, of this permit, is required for the tank (Chrome tank 1), the wetting agent and the composite mesh pad system, and shall include the following elements: (a) For the composite mesh-pad system (CMP): (1) Quarterly

visual inspections of the device to ensure there is proper drainage, no chromicacid buildup on the pads, and no evidence of chemical attack on the structural integrity of the device. (2) 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. (3) Quarterly

visual inspection of the duct work from the tank to the control device to ensure there are no leaks. (4) Perform wash down of the composite mesh-pads in accordance with manufacturers recommendations. (b) For the fume suppressant containing a wetting agent: Manufacturersrecommendations for maintenance of the monitoring equipment used to measure surface tension. (c) A standardized checklist to document the operation and maintenance criteria for Chrome tank1, the composite mesh pad system, the wetting agent and the monitoring equipment.Baycote Metal Finishing, Inc. Page 18 of 29

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(d) 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. D.1.6 Operation and Maintenance Plan [40 CFR 63.342(f)(3)] [326 IAC 20-8-1] (a) The Permittee shall prepare an Operation and Maintenance Plan (OMP) to be implemented nolater than the startup date of Chrome tank 1. The OMP shall specify the operation and maintenance criteria for the tank, the composite mesh pad system, the wetting agent and monitoring equipment, and shall include the following: (1) The PMP requirements specified in Condition D.1.5. (2) A

systematic procedure for identifying malfunctions and periods of excess emissions of Chrome tank 1, the composite mesh pad system, the wetting agent and 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 characteristicsof 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 Chrometank 1, the air pollution control device, the add-on air pollution control device 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, OAQ. (e) The Permittee shall keep the written OMP on record after it is developed to be made available, upon request, by IDEM, OAQ for the life of Chrome tank 1 or until the tank is 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, OAQ 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] [40 CFR 63.343(b)(2)] [40 CFR 63.7] [40 CFR 63.344] [326 IAC 20-8-1] (a) A

performance test demonstrating initial compliance for Chrome tank 1 was performed on July 27, 1997. A subsequent performance test was performed on February 20, 2001. (1) During the most recent performance test (February 20, 2001), it was determined that the pressure drop range across the composite mesh pad system was 2.65 toBaycote Metal Finishing, Inc. Page 19 of 29

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5.97 inches of water and the average outlet chromium concentration is 0.0046 mg/dscm. (2) During the most recent performance test (February 20, 2001), it was determined that the surface tension of the bath, using Method 306B, Appendix A of 40 CFR 63, was 58.4 dynes/cm. (b) The Permittee is not required to further test Chrome tank 1 by this permit. However, the IDEM may require testing when necessary to determine if the tank is in compliance. If testing is required by the IDEM, compliance with the limit 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 tank, the composite mesh pad system, the wetting agent 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 2-5.1-3(e)(2)] [326 IAC 2-6.1-5(a)(2)] D.1.8 Monitoring to Demonstrate Continuous Compliance [326 IAC 2-6.1-5(a)(2)] [40 CFR 63.343(c)] [326 IAC 20-8-1] (a) Pursuant

to 40 CFR 63.343(c)(1)(ii), when using a composite mesh-pad system to comply wit h the limit 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 the hard chromium electroplating tank is operating. To be in compliance with the standards, the composite mesh-pad system shall be operated within the pressure drop range established during the initial performance test, or within the range of compliant values for pressure drop established during multiple performance tests. (b) Pursuant

to 40 CFR 63.343(c)(5)(ii) and (iii), when using a wetting agent in the electroplating bath to comply with the limit specified in Condition D.1.3, the Permittee shall monitor the surface tension of the electroplating baths. Operation of Chrome tank 1 at a surface tension greater than the value established during a performance test shall constitute noncompliance with the standards. (1) The Permittee shall monitor the surface tension of the electroplating bath during tank operation according to the following schedule: (A) The surface tension shall be measured once every 4 hours during operation of the tank with a stalagmometer or a tensiometer as specified in Method 306B, appendix A of this part. (B) The time between monitoring can be increased if there have been no exceedances. The surface tension shall be measured once every 4 hours of tank operation for the first 40 hours of tank operation after the compliance date. Once there are no exceedances during 40 hours of tank operation, surface tension measurement may be conducted once every 8 hours of tank operation. Once there are no exceedances during 40 hours of tank operation, surface tension measurement may be conducted once per day, with no more than 40 hours of tank operation between measurements on an ongoing basis, until an exceedance occurs. The minimum frequency of monitoring allowed by this subpart is once every 40 hours of tank operation.Baycote Metal Finishing, Inc. Page 20 of 29

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(C) Onc e an exceedance occurs as indicated through surface tension monitoring, the original monitoring schedule of once every 4 hours must be resumed. A subsequent decrease in frequency shall follow the schedule laid out in paragraph (B) above. For example, if a Permittee had been monitoring a tank once every 40 hours and an exceedance occurs, subsequent

monitoring would take place once every 4 hours of tank operation. Once an exceedance does not occur for 40 hours of tank operation, monitoring can occur once every 8 hours of tank operation. Once an exceedance does not occur for 40 hours of tank operation on this schedule, monitoring can occur once every 40 hours of tank operation. (2) Once a bath solution is drained from Chrome tank 1 and a new solution added, the original monitoring schedule of once every 4 hours must be resumed, with a decrease in monitoring frequency allowed following the procedures in paragraphs (B) and (C) above. (c) Tankoperation 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 2-5.1-3(e)(2)] [326 IAC 2-6.1-5(a)(2)] D.1.9 Record Keeping Requirements [40 CFR 63.346] [326 IAC 20-8-1] 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 wetting agent and monitoring equipment to document that the inspection and maintenance required by Condition D.1.8 havetaken 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. (b) Records of all maintenance performed on Chrome tank 1, the composite mesh pad system and the wetting agent and monitoring equipment. (c) Records of the occurrence, duration, and cause (if known) of each malfunction of Chrome tank1, the composite mesh pad system and the wetting agent and monitoring equipment. (d) Record s of the occurrence, duration, and cause (if known) of each period of excess emissions of Chrome tank 1, the composite mesh pad system and the wetting agent andBaycote Metal Finishing, Inc. Page 21 of 29

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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.1.8(b), of each tank, during the reporting period. (k) Records of the actual cumulative rectifier capacity of each hard chromium electroplating tankexpended during each month of the reporting period, and the total capacity expended to date for a reporting period. (l) Records of the date and time that fume suppressants were added to the electroplating bath, and the amount and type of fume suppressants added. (m) All documentation supporting the notifications and reports required by 40 CFR 63.9 and 63.10 (Subpart A, General Provisions) and by Condition D.1.10. 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] The notifications and reports required in this section shall be submitted to IDEM, OAQ using the address specified in Section C - General Reporting Requirements. (a) Notifications: (1) Initial Notifications The Permittee shall notify IDEM, OAQ in writing that the source is subject to 40 CFRPart 63, Subpart N. The notification shall be submitted no later than one hundred eighty (180) days after the compliance date and shall contain the information listed in 40 CFR 63.347(c)(1). (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, OAQ, and shall list, for each tank, the information identified in 40 CFR 63.347(e)(2). (B) The NCS for Chrome tank 1 shall be submitted to IDEM, OAQ immediately. (3) Notification of Construction or Reconstruction Pursuant to 40 CFR 63.345(b)(1), the Permittee may not construct a new tank subjectto 40 CFR 63, Subpart N (including non-affected tanks defined in 40 CFRBaycote Metal Finishing, Inc. Page 22 of 29

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63.344(e))without submitting a Notification of Construction or Reconstruction (NCR)to IDEM, OAQ. In addition, the Permittee may not change, modify, or reconstructChrome tank 1 without submitting a Notification of Construction or Reconstruction (NCR) to IDEM, OAQ. (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 addition of add-on control devices, or the construction of duct work for the purpose of controlling both existing tanks and non-affected facilities by a common control technique or device. (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 Chrome tank 1 serves as this notification. (D) Pursuant

to 326 IAC 2-1.1-2(a), permission must be received from IDEM, OAQbefore 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 Chrome tank 1 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 Chrome tank 1 is located at a 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, OAQ upon request. (1) T he 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 last report to the date the permitis issued. The second report shall cover the period from the issuance date of this permit to December 31 of the year in which the permit is issued. (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

both of the following conditions are met, semiannual reports shall be prepared and submitted to IDEM, OAQ:Baycote Metal Finishing, Inc. Page 23 of 29

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(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.1.8(b) for the reporting period; and (B) The total duration of malfunctions of the add-on air pollution control device and monitoring equipment is five percent (5%) or greater of the total operating time as defined in Condition D.1.8(b). Once the Permittee reports an exceedance as defined above, Ongoing Compliance StatusReports shall be submitted semiannually until a request to reduce reporting frequency in accordance with 40 CFR 63.347(g)(2) is approved. (3) IDEM, OAQ 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.Baycote Metal Finishing, Inc. Page 24 of 29

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SECTION D.2 EMISSIONS UNIT OPERATION CONDITIONS
Emissions Unit Description: (b) One (1) natural gas-fired boiler, constructed in 1967, exhausting to the boiler stack, heat input capacity: 5.3737 million British thermal units per hour. (The information describing the process contained in this emissions unit description box is descriptive information and does not constitute enforceable conditions.) Emission Limitations and Standards [326 IAC 2-6.1-5(1)]
D.2.1 Particulate Matter Limitation (PM) [326 IAC 6-2-3(d)] Pursuantto 326 IAC 6-2-3 (d) (Particulate emission limitations for sources of indirect heating: emission limitations for facilities specified in 326 IAC 6-2-1 (b)), particulate emissions from all facilities used for indirect heating purposes which were existing and in operation on or before June 8, 1972, shall in no case exceed 0.8 pounds of particulate matter per million British thermal units heat input. Compliance Determination Requirements [326 IAC 2-1.1-11] There are no Compliance Determination Requirements applicable to this facility. Compliance Monitoring Requirements [326 IAC 2-5.1-3(e)(2)] [326 IAC 2-6.1-5(a)(2)] There are no Compliance Monitoring Requirements applicable to this facility.Baycote Metal Finishing, Inc. Page 25 of 29

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### INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY COMPLIANCE DATA SECTION
MINOR SOURCE OPERATING PERMIT CHROMIUM ELECTROPLATING AND ANODIZING NESHAP ONGOING COMPLIANCE STATUS REPORT
Source Name: Baycote Metal Finishing, Inc. Source Address: 1203 Industrial Drive, Mishawaka, Indiana 64544 Mailing Address: 1203 Industrial Drive, Mishawaka, Indiana 64544 Permit No.: MSOP 141-16170-00108 Tank ID #: Chrome tank 1 Type of process: Hard chromium electroplating Monitoring Parameter(s): Pressure drop across the composite mesh pad system Surface tension of the bath Parameter Value(s): Pressure drop: 2.65 - 5.97 inches of water Surface tension: 58.4 dynes/cm 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, OAQ, Compliance Branch. Companiesclassified as a major source : Submit this report no later than 30 days after the end of the reporting period. Companies classified as an area source: 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 DECBaycote Metal Finishing, Inc. Page 26 of 29

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### 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. MALFUNCTION REPORT
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITYBaycote Metal Finishing, Inc. Page 27 of 29

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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 ?_____, 25TONS/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 ELEMENTALLEAD ?_____, 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 SHUTDO WN 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 2 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.Baycote Metal Finishing, Inc. Page 28 of 29

Mishawaka, Indiana MSOP 141-16170-00108 Permit Reviewer: CAP/MES

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 services are 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 2Baycote Metal Finishing, Inc. Page 29 of 29

Mishawaka, Indiana MSOP 141-16170-00108 Permit Reviewer: CAP/MES



### INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY COMPLIANCE BRANCH

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: Baycote Metal Finishing, Inc.
Address: 1203 Industrial Drive City: Mishawaka
Phone #: (574) 256-5673
MSOP #: 141-16170-00108
I hereby certify that Baycote Metal Finishing, Inc. is 

### 9 still in operation. 

### 9 no longer in operation. I hereby certify that Baycote Metal Finishing, Inc. is 

### 9 in compliance with the requirements of MSOP 141-16170-00108. 

### 9 not in compliance with the requirements of MSOP 141-16170-00108. 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:

Rev. 9/28/99Page 1 of 10



## Indiana Department of Environmental Management

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

Source Background and Description
Source Name: Baycote Metal Finishing, Inc. Source Location: 1302 Industrial Drive, Mishawaka, Indiana 46544 County: St. Joseph SIC Code: 3471 Operation Permit No.: MSOP 141-16170-00108 Permit Reviewer: CarrieAnn Paukowits The Office of Air Quality (OAQ) has reviewed an application from Baycote Metal Finishing, Inc. relating to the operation of a chromium electroplating source. Permitted Emission Units and Pollution Control Equipment There are no permitted facilities operating at this source during this review process. Unpermitted Emission Units and Pollution Control Equipment The source also consists of the following unpermitted facilities/units that did not require permits under 326 IAC 2-1, but require permits under 326 IAC 2-5 and 326 IAC 2-6: (a) One (1) hard chrome plating tank, identified as Chrome tank 1, constructed in February 1997, using a hexavalent chromium bath and having a rectifier capacity of 4,000 amps and a maximum cumulative rectifier capacity of 23,520,000 amp-hours, equipped with a composite mesh pad system and a mist suppressant containing a wetting agent as controls, and exhausting to the chrome stack. (b) One (1) natural gas-fired boiler, constructed in 1967, exhausting to the boiler stack, heat input capacity: 5.3737 million British thermal units per hour. New Emission Units and Pollution Control Equipment There are no new facilities proposed at this source during this review process. Existing Approvals The source has no previous approvals.Baycote Metal Finishing, Inc. Page 2 of 10

Mishawaka, Indiana MSOP 141-16170-00108 Permit Reviewer: MES

Stack Summary
Stack ID Operation Height (feet) Diameter

(feet) Flow Rate

(acfm) Temperature

( E F) Chrome stack Hard chrome

electroplating 28.0 1.67 8,021 80

Boiler Stack Boiler 27.08 1.00 2,145 350
Enforcement Issue (a) The applicant applied for the Minor Source Operating Permit (MSOP) after December 27, 1999. Therefore, the source is not in compliance with the compliance schedule under 326 IAC 2-6.1-3. (b) IDEM is reviewing this matter and will take appropriate action.
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.
An application for the purposes of this review was received on September 30, 2002, with additional information received on October 17 and November 1, 2002. Emission Calculations Chromium emissions (Single HAP) from the biggest chromium electroplating source in Indiana are lessthan ten (10) tons per year and Baycote Metal Finishing, Inc. is a much smaller source in comparison. Therefore, no emission calculations were necessary for the chromium electroplating because the chromium emissions from this source will be less than ten (10) tons per year. See AppendixA (pages 1 and 2 of 2) of this document for detailed emissions calculations for the boiler.
Potential To Emit Pursuantto 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.”Baycote Metal Finishing, Inc. Page 3 of 10

Mishawaka, Indiana MSOP 141-16170-00108 Permit Reviewer: MES

Pollutant Potential To Emit (tons/year) PM 0.045 PM 10 0.179 SO 2 0.014 VOC 0.129 CO 1.98 NO X 2.35

HAPs Potential To Emit (tons/year) Benzene 0.00005 Dichlorobenzene 0.00003 Formaldehyde 0.00177 Hexane 0.0424 Toluene 0.00008 Lead 0.00001 Cadmium 0.00003 Chromium Less than 10 Manganese 0.00001 Nickel 0.00005 TOTAL less than 10.0 (a) The existing source is subject to 326 IAC 20-8 but not subject to 326 IAC 2-5.5-1(b)(2) (registration)because the source uses hexavalent chromium for decorative coating instead of trivalent chromium and the source emits less than major source levels. Therefore, the source is subject to the provisions of 326 IAC 2-6.1-3(a). (b) Fugitive Emissions Since this type of operation is not one of the twenty-eight (28) listed source categories under 326 IAC 2-2 and since there are no applicable New Source Performance Standards that were in effect on August 7, 1980, the fugitive particulate matter (PM) and volatile organic compound (VOC) emissions are not counted toward determination of PSD and Emission Offset applicability.
Actual Emissions No previous emission data has been received from the source.Baycote Metal Finishing, Inc. Page 4 of 10

Mishawaka, Indiana MSOP 141-16170-00108 Permit Reviewer: MES

Limited Potential to Emit The table below summarizes the total potential to emit, reflecting all limits, of the emission units.

Limited Potential to Emit (tons/year) Process/facility PM PM 10 SO 2 VOC CO NO X HAPs Chrome electroplating - - - - - - less than 10 Boiler 0.045 0.179 0.014 0.129 1.98 2.35 0.044 Total Emissions 0.045 0.179 0.014 0.129 1.98 2.35 less than 10.0 County Attainment Status The source is located in St. Joseph County.

Pollutant Status PM 10 attainment SO 2 attainment NO 2 attainment Ozone attainment CO attainment Lead attainment (a) Volatile organic compounds (VOC) are precursors for the formation of ozone. Therefore, VOC emissions are considered when evaluating the rule applicability relating to the ozone standards. St. Joseph County has been designated as attainment or unclassifiable for ozone. Therefore, VOC emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2 and 40 CFR 52.21. (b) St. Joseph County has been classified as attainment or unclassifiable for all remaining 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.
Part 70 Permit Determination 326 IAC 2-7 (Part 70 Permit Program) This existing source based on the emissions summarized in this permit, MSOP 141-16170, is not subject to the Part 70 Permit requirements because the potential to emit (PTE) of: (a) each criteria pollutant is less than one hundred (100) tons per year, (b) a single hazardous air pollutant (HAP) is less than ten (10) tons per year, andBaycote Metal Finishing, Inc. Page 5 of 10

Mishawaka, Indiana MSOP 141-16170-00108 Permit Reviewer: MES
(c) any combination of HAPs is less than twenty-five (25) tons per year. This is the first air approval issued to this source. 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) The one (1) natural gas-fired boiler is not subject to the requirements of 40 CFR 60.40, 60.40a, 60.40b or 60.40c (Subparts D, Da, Db and Dc) because it was constructed prior to August 17, 1971, which is the earliest applicability date of these rules. (c) The one (1) chromium electroplating tank, identified as Chrome tank 1, is subject to the Nationa l Emission Standards for Hazardous Air Pollutants, 326 IAC 14, (40 CFR 63, SubpartN, and 326 IAC 20-8-1). Pursuant to 40 CFR 63, Subpart N, and 326 IAC 20-8-1, the chromium electroplating operations are subject to the following conditions: (1) The Permittee shall comply with the requirements of this condition on and after the compliance date for the tank. The hard chromium electroplating tank, identified as Chrome tank 1, is considered a small, new hard chromium electroplating operation. During tank operation, the Permittee shall control chromium emissions discharged to the atmosphere from the tankby 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) [equivalentto 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 (A) Pursuant to 40 CFR 63.343(c)(1)(ii), when using a composite mesh-pad system to comply with the limit specified above, the Permittee shall monitor and record the pressure drop across the composite mesh-pad system during tank operation once each day that the hard chromium electroplating tankis operating. To be in compliance with the standards, the composite mesh-pad system shall be operated within the pressure drop range established during the initial performance test, or within the range of compliant values for pressure drop established during multiple performance tests. (B) Pursuant

to 40 CFR 63.343(c)(5)(ii) and (iii), when using a wetting agent in the electroplating bath to comply with the limit specified above, the Permittee shall monitor the surface tension of the electroplating baths. Operation of Chrome tank 1 at a surface tension greater than the value established during a performance test shall constitute noncompliance with the standards. The Permittee shall monitor the surface tension of the electroplating bath during tank operation according to the following schedule: (i) The surface tension shall be measured once every 4 hours during operation of the tank with a stalagmometer or a tensiometer as specified in Method 306B, appendix A of this part. (ii) The time between monitoring can be increased if there have beenBaycote Metal Finishing, Inc. Page 6 of 10

Mishawaka, Indiana MSOP 141-16170-00108 Permit Reviewer: MES

noexceedances. The surface tension shall be measured once every4 hours of tank operation for the first 40 hours of tank operation after the compliance date. Once there are no exceedances during 40 hours of tank operation, surface tension measurement

may be conducted once every 8 hours of tank operation. Once there are no exceedances during 40 hours of tank operation, surface tension measurement may be conducted once per day, with no more than 40 hours of tank operation between measurements on an ongoing basis, until an exceedance occurs. The minimum frequency of monitoring allowed by this subpart is once every 40 hours of tank operation. (iii) Once an exceedance occurs as indicated through surface tension monitoring, the original monitoring schedule of once every 4 hours mustbe resumed. A subsequent decrease in frequency shall followthe schedule laid out in paragraph (B) above. For example, if a Permittee had been monitoring a tank once every 40 hours and an exceedance occurs, subsequent monitoring would take place once every 4 hours of tank operation. Once an exceedance does notoccur for 40 hours of tank operation, monitoring can occur once every 8 hours of tank operation. Once an exceedance does notoccur for 40 hours of tank operation on this schedule, monitoring can occur once every 40 hours of tank operation. Once a bath solution is drained from Chrome tank 1 and a new solution added, the original monitoring schedule of once every 4 hours must be resumed, with a decrease in monitoring frequency allowed following the procedures in paragraphs (B) and (C) above. (C) 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. (3) Reporting Requirements The notifications and reports required in this section shall be submitted to IDEM, OAQusing the address specified in Section C - General Reporting Requirements. (A) Notifications: (i) Initial Notifications The Permittee shall notify IDEM, OAQ in writing that the source is subjectto 40 CFR Part 63, Subpart N. The notification shall be submitted no later than one hundred eighty (180) days after the compliance date and shall contain the information listed in 40 CFR 63.347(c)(1). (ii) A Notification of Compliance Status (NCS) is required each time that the facility becomes subject to the requirements of 40 CFR Part63 Subpart N. The NCS shall be submitted to IDEM, OAQ, and shall list, for each tank, the information identified in 40 CFRBaycote Metal Finishing, Inc. Page 7 of 10

Mishawaka, Indiana MSOP 141-16170-00108 Permit Reviewer: MES
63.347(e)(2). The NCS for Chrome tank 1 shall be submitted to IDEM, OAQ immediately. (iii) 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 nonaffected tanks defined in 40 CFR 63.344(e)) without submitting a Notific ation of Construction or Reconstruction (NCR) to IDEM, OAQ. In addition, the Permittee may not change, modify, or reconstructChrome tank 1 without submitting a Notification of Construction or Reconstruction (NCR) to IDEM, OAQ. The NCR shall contain the information identified in 40 CFR 63.345(b) (2) and (3). A change, modification, or reconstruction of this facility includes any change in the air pollution control techniques, the addition of add-on control devices, or the construction of duct work for the purpose of controlling both existing tanks and non-affected facilitiesby a common control technique or device. A complete application to construct new chromium electroplating or chromium anodizing tanks serves as this notification. Likewise, the complete application to modify or reconstruct Chrome tank 1 serves as this notification. Pursuant to 326 IAC 2-1.1-2(a), permission must be received from IDEM, OAQ 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 Chrome tank 1 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 Chrome tank 1 is located at a 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, OAQ upon request. (D) If

both of the following conditions are met, semiannual reports shall be prepared and submitted to IDEM, OAQ: (i) 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 above for the reporting period; and (ii) The total duration of malfunctions of the add-on air pollution control device and monitoring equipment is five percent (5%) orBaycote Metal Finishing, Inc. Page 8 of 10

Mishawaka, Indiana MSOP 141-16170-00108 Permit Reviewer: MES
greater of the total operating time as defined above. 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. IDEM, OAQ may determine on a case-by-case basis that the summaryreport 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. State Rule Applicability - Entire Source 326 IAC 2-2 (Prevention of Significant Deterioration (PSD)) Construction of the hard chromium electroplating source, that commenced prior to August 7, 1977, was not subject to the requirements of 326 IAC 2-2, PSD. The source, modified in 1997, is still not subjectto the requirements of 326 IAC 2-2 because the potential to emit each criteria pollutant is less than 250 tons per year. 326 IAC 2-6 (Emission Reporting) This source is located in St. Joseph County, the potential to emit VOC and NO X are less than ten (10)tons per year, and the potentials to emit CO, PM 10and SO 2are less than one hundred (100) tons per year. Therefore, 326 IAC 2-6 does not apply. 326 IAC 5-1 (Opacity Limitations) This source is located north of Kern Road and East of Pine Road in St. Joseph County. Therefore, pursuant to 326 IAC 5-1-2 (Opacity limitations), except as provided in 326 IAC 5-1-3 (Temporary alternativeopacity limitations), opacity shall meet the following, unless otherwise stated in this permit: (a) Opacity

shall not exceed an average of thirty percent (30%) 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. State Rule Applicability - Individual Facilities 326 IAC 6-1 (Nonattainment Area Limitations) Pursuant to 326 IAC 6-1-1, this source is not subject to the requirements of 326 IAC 6-1 because it is not mentioned in 326 IAC 6-1-8.1 through 6-1-18 and the source does not have potential PM emissions of one hundred (100) tons per year or more or actual PM emissions of ten (10) tons per year or more.Baycote Metal Finishing, Inc. Page 9 of 10

Mishawaka, Indiana MSOP 141-16170-00108 Permit Reviewer: MES
326 IAC 6-2-3 (Particulate Emissions Limitations for Facilities Constructed prior to September 21, 1983) The one (1) boiler constructed in 1967, with a heat input capacity of 5.3737 million British thermal unitsper hour, must comply with the PM emission limitation of 326 IAC 6-2-3. This limitation is based on the following equation is given in 326 IAC 6-2-3: Pt = C x a x h / 76.5 x Q 0.75x N 0.25 where:
Pt= Pounds of particulate matter emitted per million British thermal units (lb/MMBtu) heat

input Q = Total source maximum operating capacity rating in million British thermal units per hour (MMBtu/hr) heat input. The maximum operating capacity rating is defined as the maximum capacity at which the facility is operated or the nameplate capacity, whichever is specified in the facility’s permit application, except when some lower capacity iscontained in the facility’s operation permit; in which case, the capacity specified in the operation permit shall be used. C = Maximum ground level concentration with respect to distance from the point source atthe “critical” wind speed for level terrain. This shall equal 50 micrograms per cubic meter for a period not to exceed a sixty (60) minute time period.
N = Number of stacks in fuel burning operation.

a = Plumerise factor which is used to make allowance for less than theoretical plume rise. The value 0.67 shall be used for Qless than or equal to 1,000 mmBtu/hr heat input. The value 0.8 shall be used for Q greater than 1,000 mmBtu/hr heat input.
h = Stack height in feet. For the one (1) boiler: Pt = 50 x 0.67 x 27.08 / 76.5 x (5.3737) 0.75x 1 0.25= 3.36 lb/MMBtu Pursuant to 326 IAC 6-2-3(d), particulate emissions from all facilities used for indirect heating purposes which were existing and in operation on or before June 8, 1972, shall in no case exceed 0.8 lb/mmBtu heat input. Therefore, the one (1) boiler is limited to emissions of 0.8 pound per million British thermal units. Based on Appendix A, the potential to emit PM emissions from the one (1) boiler limited to 0.8 pound PM per million British thermal units is: 0.045 tons/yr × (2000 lbs/ton / 8760 hrs/yr) = 0.010 lb/hr (0.010 lb/hr / 5.3737 MMBtu/hr) = 0.002 lb PM per MMBtu Therefore, the one (1) boiler will comply with this rule. 326 IAC 6-3 (Particulate Emission Limitations for Manufacturing Processes) Pursuant to 326 IAC 6-3-1(c)(6), this rule is not applicable to the chrome electroplating operations because a particulate limit for the electroplating is established in 326 IAC 20-8-1.Baycote Metal Finishing, Inc. Page 10 of 10

Mishawaka, Indiana MSOP 141-16170-00108 Permit Reviewer: MES
326 IAC 20-1-1 (Incorporation of federal regulations) The chromium electroplating operation, subject to 326 IAC 20-8, is required to comply with the requirements of 40 CFR 63, Subpart A, concerning general provisions for emission standards for hazardous air pollutants. 326 IAC 20-8 (Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks) The chromium electroplating operation is required to comply with the requirements of 40 CFR 63, SubpartN, National Emission Standards for Chromium Emissions from Hard and Decorative Electroplating and Anodizing Tanks. as described in the “Federal Rule Applicability” section of this TSD. Conclusion The operation of this chromium electroplating source shall be subject to the conditions of the attached proposed Minor Source Operating Permit 141-16170-00108.

### Appendix A: Emissions Calculations Page 1 of 2 TSD App A Natural Gas Combustion Only MM BTU/HR <100

Company Name: Baycote Metal Finishing, Inc. Address City IN Zip: 1302 Industrial Drive, Mishawaka, Indiana 46544

MSOP: 141-16170 Plt ID: 141-00108 Reviewer: CarrieAnn Paukowits Date: September 30, 2002 Steam Generating Capacity lbs/hr 3161 Heat Input Capacity Potential Throughput MMBtu/hr MMCF/yr

5.3737 47.07

Pollutant PM* PM10* SO2 NOx VOC CO Emission Factor in lb/MMCF 1.9 7.6 0.6 100.0 5.5 84.0 **see below Potential Emission in tons/yr 0.045 0.179 0.014 2.35 0.129 1.98 *PM emission factor is filterable PM only. PM10 emission factor is filterable and condensable PM10 combined. **Emission Factors for NOx: Uncontrolled = 100, Low NOx Burner = 50, Low NOx Burners/Flue gas recirculation = 32 Methodology All emission factors are based on normal firing. Heat input capacity (MMBtu/hr) = (Steam Generating capacity x 1.7E3)/1000000 MMBtu = 1,000,000 Btu MMCF = 1,000,000 Cubic Feet of Gas Potential Throughput (MMCF) = Heat Input Capacity (MMBtu/hr) x 8,760 hrs/yr x 1 MMCF/1,000 MMBtu Emission Factors are from AP 42, Chapter 1.4, Tables 1.4-1, 1.4-2, 1.4-3, SCC #1-02-006-02, 1-01-006-02, 1-03-006-02, and 1-03-006-03 (SUPPLEMENT D 3/98) Emission (tons/yr) = Throughput (MMCF/yr) x Emission Factor (lb/MMCF)/2,000 lb/ton Note: Check the applicable rules and test methods for PM and PM10 when using the above emission factors to confirm that the correct factor is used (i.e., condensable included/not included). See page 2 for HAPs emissions calculations.

### Appendix A: Emissions Calculations Page 2 of 2 TSD App A Natural Gas Combustion Only MM BTU/HR <100 HAPs Emissions

Company Name: Baycote Metal Finishing, Inc. Address City IN Zip: 1302 Industrial Drive, Mishawaka, Indiana 46544

MSOP: 141-16170 Plt ID: 141-00108 Reviewer: CarrieAnn Paukowits Date: September 30, 2002

HAPs - Organics Benzene Dichlorobenzene Formaldehyde Hexane Toluene Emission Factor in lb/MMcf 2.1E-03 1.2E-03 7.5E-02 1.8E+00 3.4E-03

Potential Emission in tons/yr 4.94E-05 2.82E-05 1.77E-03 4.24E-02 8.00E-05

HAPs - Metals Lead Cadmium Chromium Manganese Nickel Total Emission Factor in lb/MMcf 5.0E-04 1.1E-03 1.4E-03 3.8E-04 2.1E-03 HAPs

Potential Emission in tons/yr 1.18E-05 2.59E-05 3.30E-05 8.94E-06 4.94E-05 0.044

Methodology is the same as page 1. The five highest organic and metal HAPs emission factors are provided above. Additional HAPs emission factors are available in AP-42, Chapter 1.4.