October 2, 2008

Mr. Keith E. Litz Co-Owner Electro Finishing, Inc. 6817 W. Lee Highway Rural Retreat, Virginia 24368

Location: Wythe County, VA Registration No. 11200 Facility ID No. 51-197-00077

Dear Mr. Litz:

Attached is a permit to modify and operate a chrome electroplating facility in accordance with the provisions of the Commonwea lth of Virginia State Air Pollution Control Board Regulations for the Control and Abatement of Air Pollution. This permit supersedes your permit dated July 23, 2008.

This permit contains legally enforceable condit ions. Failure to comply may result in a Notice of Violation and civil charges. Please read all permit conditions carefully

. In the course of evaluating the application and arriving at a final decision to approve the project, the Department of En vironmental Quality (DEQ) deem ed the application complete on October 2, 2008.

This approval to modify and operate shall no t relieve Electro Finishing, Inc. of the responsibility to comply with all other lo cal, state, and federal permit regulations.

The Board's Regulations as contained in Ti tle 9 of the Virginia Administrative Code 5-170-200 provide that you may request a formal hear ing from this case decision by filing a petition with the Board within 30 days after this case decision notice was mailed or delivered to you. 9 VAC 5-170-200 provid es that you may request direct consideration of the decision by the Board if the Director of the DEQ made the decision. Please consult the relevant regulations for additional requirements for such requests.Mr. Keith E. Litz October 2, 2008 Page 2

As provided by Rule 2A:2 of the Suprem e Court of Virginia, you have 30 days from the date of service of this decisi on (the date you actually received this decision or the date on which it was mailed to you, whichever occurred fi rst), within which to initiate an appeal of this decision by filing a Notice of Appeal with:

David K. Paylor, Director Department of Environmental Quality P. O. Box 1105 Richmond, VA 23218

In the event that this decision is served on y ou by mail, three days are added to the period in which to file an appeal. Please refer to Part Two A of the Rules of the Supreme Court of Virginia for information on the required content of the Notice of Appeal and for additional requirements governing appeals from decis ions of administrative agencies.

If you have any questions concerning this permi t, please call the regional office at (276) 676-4800.

Sincerely,

Dallas R. Sizemore Regional Director

DRS/TMD/P-11200-08B.doc

Attachments: Permit amendment

c. Director, OAPP (electronic file submission) Manager, Data Analysis (electronic file submission)STATIONARY SOURCE PERMIT TO MODIFY AND OPERATE

This permit supersedes your permit dated July 23, 2008.

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

Electro Finishing, Inc. 6817 West Lee highway Rural Retreat, VA 24368 Registration No. 11200 Facility ID No. 51-197-00077

is authorized to modify and operate a chrome electroplating facility

located at 6817 West Lee Highway, at Rural Retreat in Smyth County, Virginia

in accordance with the C onditions of this permit.

Approved on October 2, 2008.

Dallas R. Sizemore Regional Director

Permit consists of 9 pages. Permit Conditions 1 to 25.Electro Finishing, Inc. Registration Number 11200 October 2, 2008 Page 2

INTRODUCTION
This permit approval is based on the permit a pplications dated August 4, 2008, April 24, 2008, July 5, 2006, March 29, 2005, September 6, 2002, March 21, 2001, November 22, 2000, January 12, 1998, March 3, 1997, June 15, 1996, and October 16, 1995, the permit application letter dated May 23, 2005, amendm ent information dated October 2, 2008, September 18, 2008, S eptember 6, 2006, May 27, 2005, Ap ril 8, 2005, October 16, 2002, May 31, 2001, April 2, 2001, December 4, 7, 11, 2000, and January 11, 2001, and addendum information received July 17 and June 17, 2008, October 28 and 22, 2002, and July 18, 1996. Any changes in the permit application specificati ons or any existing facilities which alter the impact of the facility on air quality may require a permit. Failure to obt ain such a permit prior to construction may result in enforcement action.
Words or terms used in this permit shall have meanings as provided in 9 VAC 5-10-10 of the State Air Pollution Control Board Regulations fo r the Control and Abatement of Air Pollution. The regulatory reference or authority for each c ondition is listed in parentheses () after each condition.
Annual requirements to fulfill legal obligations to maintain current stationary source emissions data will necessitate a prompt response by t he permittee to requests by the DEQ or the Board for information to include, as appropr iate: process and production data; changes in control equipment; and operating schedules. Such requests for information from the DEQ will either be in writing or by personal contact.
The availability of information submitted to the DEQ or the B oard will be governed by applicable provisions of the Fr eedom of Information Act, §§ 2. 2-3700 through 2.2-3714 of the Code of Virginia, § 10.1-1314 (addressing informati on provided to the Board) of the Code of Virginia, and 9 VAC 5-170-60 of the State Air Pollution C ontrol Board Regulations. Information provided to federal officials is subject to appropria te federal law and regulations governing confidentiality of such information.

PROCESS REQUIREMENTS

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

Ref. No. Equipment Description Rated Capacity Federal Requirements Original Permit Date Equipment to be added as part of the facility modification:

7 One 1100 gallon hard chrome electroplating tank 6000 amp max rectifier cap 40 CFR 63, Subpart N 7/22/2008

8 One 750 gallon hard chrome electroplating tank 2 × 4000 amp max rectifier cap 40 CFR 63, Subpart N 7/22/2008

9 One 500 gallon hard chrome electroplating tank 4000 amp max rectifier cap 40 CFR 63, Subpart N 7/22/2008

10 One 500 gallon hard chrome activation electroplating tank 3000 amp max rectifier cap 40 CFR 63, Subpart N 7/22/2008
11 One adhesive coating dip tank 50 gal capacity - 10/03/2008Electro Finishing, Inc. Registration Number 11200 October 2, 2008 Page 3

Ref. No. Equipment Description Rated Capacity Federal Requirements Original Permit Date Equipment to be modified:

6 One DeVilbiss JGA 510 spray gun 18.75 gal/hr - 9/19/2006
Previously permitted equipment:

1 One decorative chrome electroplating tank 1000 amp rectifier (shared) 40 CFR 63, Subpart N 2 One hard chrome electroplating tank 40 CFR 63, Subpart N 3 One hard chrome electroplating tank 500 amp max rectifier cap 40 CFR 63, Subpart N 4 One hard chrome electroplating tank 300 gal 40 CFR 63, Subpart N - One 2000 ampere rectifier - 6A One metal dip tank 750 inserts/hr - 6B One metal dip tank 500 inserts/hr -
Registered Equipment:

12 One 500 gallon hard chrome electroplating tank 4000 amp max rectifier cap 40 CFR 63, Subpart N n/a

Specifications included in the permit under this condition are for informational purposes only and do not form enforceable terms or conditions of the permit. (9 VAC 5-80-1180 D.3)

2. Emission Controls - Particulate emissions fr om the permitted hard chrome electroplating tanks shall be controlled by packed bed/composite mesh pad (CMP) scrubbers, or equivalent. The scrubbers sh all be provided with adequate access for inspection. (9 VAC 5-50-260 and 9 VAC 5-80-1180)

3. Emission Controls - Particulate emissions from the de corative chrome electroplating tank shall be controlled by the use of a wetting agent type fume suppressant in the plating bath while maintaining the bath surf ace tension at a level not to exceed 45 dynes per centimeter, or equivalent control device. (9 VAC 5-50-260 and 9 VAC 5-80-1180)

4. Emission Controls - Particulate emissions from the DeVilbiss spray gun shall be controlled by a Grainger paint filter system, or equivalent. The Grainger paint filter system shall be provided with ade quate access for inspection. (9 VAC 5-50-260 and 9 VAC 5-80-1180)

5. Testing/Monitoring Ports - The permitted facility shall be constructed so as to allow for emissions testing and monitoring upon r easonable notice at any time, using appropriate methods. Test ports shall be provided when r equested at the appropriateElectro Finishing, Inc. Registration Number 11200 October 2, 2008 Page 4

locations or in accordance with the applic able performance specification (reference 40 CFR Part 60, Appendix B). (9 VAC 5-50-30 F)

OPERATING/EMISSION LIMITATIONS

6. Throughput - The throughput of the following coati ng materials (or their equivalents) to the DeVilbiss spray gun shall not exceed the s pecified limits, calculated monthly as the sum of each consecutive 12-month period: Chemlok 233 Adhesive 2.25 gal/hr 2500 gal/yr Toluene solution 2.25 gal/hr 2500 gal/yr The DeVilbiss spray gun is limited to an hourly rate of 4.5 gallons/hr, calculated monthly by dividing the total gallons of Chemlok adhesive and thinner mixt ure sprayed for the month by the total number of hour s spraying time for that month. (9 VAC 5-80-1180)

7. Throughput - The consumption of adhesive materi als (or their equivalents) in the adhesive dip tank shall not exceed the specif ied limits, calculated monthly as the sum of each consecutive 12-month period: Chemlok 5150 Adhesive 1.13 gal/hr 50 gal/yr Denatured Alcohol (Ethanol SIS A1) 3.38 gal/hr 150 gal/yr (9 VAC 5-80-1180)

8. Throughput – The total combined throughput for the clear cement and black cement dipping processes shall not exceed 2,500,000 inserts per year, calculated monthly as the sum of each consec utive 12 month period. (9 VAC 5-80-1180)

9. Emission Limits – Emissions from the clear cem ent and the black cement dipping processes shall not exceed the following: Volatile Organic Compounds (VOC) 3.56 lb/hr 5.59 tons/yr

These emissions are derived from the estima ted overall emission contribution from operating limits. Exceedance of the operating limits s hall be considered credible evidence of the exceedance of emission limit s. Compliance with these emission limits may be determined as stated in Condition 8. (9 VAC 5-80-1180)

10. Emission Limits – The emissions from the application of adhesives in the DeVilbiss spray gun shall not exceed the following: Volatile Organic Compounds (VOC) 30.02 lb/hr 16.68 tons/yr

These emissions are derived from the estima ted overall emission contribution from operating limits. Exceedance of the operating limits s hall be considered credibleElectro Finishing, Inc. Registration Number 11200 October 2, 2008 Page 5

evidence of the exceedance of emission limit s. Compliance with these emission limits may be determined as stated in Condition 6. (9 VAC 5-80-1180)

11. Emission Limits – The emissions from the application of adhesives in the adhesive dip tank shall not exceed the following: Volatile Organic Compounds (VOC) 30.03 lb/hr 0.67 tons/yr

These emissions are derived from the estima ted overall emission contribution from operating limits. Exceedance of the operating limits s hall be considered credible evidence of the exceedance of emission limit s. Compliance with these emission limits may be determined as stated in Condition 7. (9 VAC 5-80-1180)

12. Visible Emission Limit - Visible emissions from the Gr ainger paint filter exhaust shall not exceed five percent (5%) opacity as determined by EPA Method 9 (reference 40 CFR 60, Appendix A). This condition applie s at all times except during startup, shutdown and malfunction. (9 VAC 5-50-260)

13. Visible Emission Limit - Visible emissions from all packed bed/composite mesh pad scrubber exhausts shall not exceed five per cent (5%) opacity as determined by EPA Method 9 (reference 40 CFR 60, Appendix A). This condi tion applies at all times except during startup, shutdown and malfunction. (9 VAC 5-50-80 and 9 VAC 5-50-260)

RECORDS

14. On-Site Records - The permittee shall maintain records of emission data and operating parameters as necessary to demon strate compliance with this permit. The content and format of such records shall be arranged with the Director, Southwest Regional Office. These records shall include, but are not limited to:

a. The combined total number of hours of operation of the seven (7) hard chrome electroplating tanks (Reference No’s. 2, 3, 4, 7, 8, 9, and 10), calculated monthly as the sum of each consecutive 12-month period. b. The combined total yearly amp-hours for the seven (7) hard chrome electroplating tanks (Reference No’s. 2, 3, 4, 7, 8, 9, and 10) calculat ed monthly as the sum of each consecutive 12-month period. c. Monthly and annual throughput (in ga llons) of Chemlok 5150 adhesive and denatured alcohol mixture in the adhesive dip tank. Annual throughput shall be calculated monthly as the sum of each consecutive 12-month period. d. Monthly and annual throughput (in gallo ns) of Chemlok 233 adhesive and toluene mixture to the DeVilbiss spray gun. A nnual throughput shall be calculated monthly as the sum of each consecutive 12-mont h period. The hourly throughput shall beElectro Finishing, Inc. Registration Number 11200 October 2, 2008 Page 6

determined by dividing the total gallons of Chemlok 233 adhesive mixture sprayed for the month by the tota l number of hours spraying time for that month. e. Total annual combined throughput of insert s from the dipping processes, calculated monthly as the sum of each consecutive 12 month period.

f. MSDS records for the clear cement and bla ck cement, or their equivalents, used in the dipping processes. g. MSDS records for all adhesive dip tank and DeVilbiss spray coatings, adhesives, and thinners. These records shall be available for inspection by the DEQ and shall be current for the most recent five (5) years. (9 VAC 5-50-50)

NOTIFICATIONS

15. Initial Notifications - The permittee shall furnish wri tten notification to the Director, Southwest Regional Office regarding: a. The actual date on which facility modifi cation commenced (addition of the four (4) hard chrome electroplating tanks (Referenc e No.’s 7, 8, 9, and 10)) within 30 days after such date. b. The actual start-up date of the modification (four (4) hard chrome electroplating tanks (Reference No.’s 7, 8, 9, an d 10) within 15 days after such date. (9 VAC 5-50-50 and 9 VAC 5-80-1180)

16. Notification for Control Equipment Maintenance - The permittee shall furnish notification to the Director, S outhwest Regional Office of the intention to shut down or bypass, or both, air pollution control equi pment for necessary scheduled maintenance, which results in excess emi ssions for more than one hour, at least 24 hours prior to the shutdown. The notification s hall include, but is not limited to, the following information:

a. Identification of the air pollution control equipment to be taken out of service, as well as its location, and registration number; b. The expected length of ti me that the air pollution c ontrol equipment will be out of service; c. The nature and quantity of emissions of air pollutants likely to occur during the shutdown period;

d. Measures that will be taken to minimize the length of the shutdown or to negate the effect of the outage. (9 VAC 5-20-180 B)Electro Finishing, Inc. Registration Number 11200 October 2, 2008 Page 7

17. Notification for Facility or C ontrol Equipment Malfunction - The permittee shall furnish notification to the Director, Southw est Regional Office of malfunctions of the affected facility or related air pollution control equipment that may cause excess emissions for more than one hour, by facsimile transmission, telephone or telegraph. Such notification shall be made as soon as pr acticable but not later than four daytime business hours after the malfunction is discovered. The permittee shall provide a written statement giving all pertinent fact s, including the estimated duration of the breakdown, within 14 days of the occurrence. When the condition causing the failure or malfunction has been corrected and the equipment is again in operation, the permittee shall notify the Director, S outhwest Regional Office in writing. (9 VAC 5-20-180 C)

GENERAL CONDITIONS

18. Permit Invalidation – The provisions of this permit per taining to the modification of the electroplating facility with the addition of the four electroplating tanks (Ref. No.’s 7 - 10) shall become invalid, unless an extension is granted by the DEQ, if: a. A program of continuous modification is not commenced within the latest of the following: i. 18 months from July 23, 2008;
ii. Nine months from the date that the last permit or ot her authorization was issued from any other governmental entity;
iii. Nine months from the date of the last resolution of any litigation concerning any such permits or authorization; or b. A program of modification is discontinued for a period of 18 months or more, or is not completed within a reasonable time , except for a DEQ approved period between phases of a phased construction project. (9 VAC 5-80-1210)

19. Permit Suspension/Revocation - This permit may be su spended or revoked if the permittee: a. Knowingly makes material misstatements in the application for this permit or any amendments to it; b. Fails to comply with the conditions of this permit; c. Fails to comply with any emission standar ds applicable to the equipment listed in Condition 1; d. Causes emissions from this facility which result in violations of, or interferes with the attainment and maintenance of, any ambient air quality standard; e. Fails to operate this facility in conf ormance with any applicab le control strategy, including any emission standards or emission limitations, in the State Implementation Plan in effect on the date that the application for this permit is submitted;Electro Finishing, Inc. Registration Number 11200 October 2, 2008 Page 8

f. Fails to construct, modify, or operate th is facility in accordance with the application for this permit or any amendments to it; or g. Allows the permit to become invalid. (9 VAC 5-80-1210)

20. Right of Entry - The permittee shall allow author ized local, state, and federal representatives, upon the pres entation of credentials: a. To enter upon the permittee's premises on wh ich the facility is located or in which any records are required to be kept under the terms and condition s of this permit; b. To have access to and copy at reasonable times any records required to be kept under the terms and conditions of this permi t or the State Air Pollution Control Board Regulations; c. To inspect at reasonable times any fac ility, equipment, or proc ess subject to the terms and conditions of this permit or the State Air Pollution Control Board Regulations; and d. To sample or test at reasonable times. For purposes of this conditi on, the time for inspection shall be deemed reasonable during regular business hours or whenever t he facility is in operation. Nothing contained herein shall make an inspecti on time unreasonable during an emergency. (9 VAC 5-170-130 and 9 VAC 5-80-1180)

21. Maintenance/Operating Procedures - The permittee shall take the following measures in order to minimize the dur ation and frequency of excess emissions, with respect to the air pollution control equi pment which affect such emissions: a. Develop a maintenance schedule and main tain records of all scheduled and nonscheduled maintenance. These records shall be maintained on site for a period of five (5) years and shall be made available to DEQ personnel upon request. b. Maintain an inventory of spare parts that are needed to minimi ze durations of air pollution control equipment breakdowns. c. Have available written operating pr ocedures for equipment. These procedures shall be based on the manufacturer's recommendations, at a minimum. d. Train operators in the pr oper operation of all such equipment and familiarize the operators with the wri tten operating procedures. T he permittee shall maintain records of the training provi ded including the names of trai nees, the date of training and the nature of the training. Records of maintenance and training shall be maintained on site for a period of five years and shall be made available to DEQ personnel upon request. (9 VAC 5-50-20 E)

22. Notification for Facility or C ontrol Equipment Malfunction - The permittee shall furnish notification to the Director, Southw est Regional Office, of malfunctions of theElectro Finishing, Inc. Registration Number 11200 October 2, 2008 Page 9

affected facility or related air pollution control equipment that may cause excess emissions for more than one hour, by facsimile transmission, telephone or telegraph. Such notification shall be made as soon as pr acticable but not later than four daytime business hours after the malfunction is di scovered. The permittee shall provide a written statement giving all pertinent fact s, including the estimated duration of the breakdown, within two weeks of discovery of the malfunction. When the condition causing the failure or malfunction has been corrected and the equipment is again in operation, the permittee shall notify the Directo r, Southwest Regional Office, in writing. (9 VAC 5-20-180 C and 9 VAC 5-80-1180)

23. Violation of Ambient Air Quality Standard - The permittee shall, upon request of the DEQ, reduce the level of operation or shut down a facility, as necessary to avoid violating any primary ambi ent air quality standard and shall not return to normal operation until such time as the ambient air quality standard will not be violated. (9 VAC 5-20-180 I and 9 VAC 5-80-1180)

24. Change of Ownership - In the case of a transfer of ownership of a stationary source, the new owner shall abide by any current permit issued to the previous owner. The new owner shall notify the Director, Sout hwest Regional Office of the change of ownership within 30 days of the transfer. (9 VAC 5-80-1240)

25. Permit Copy - The permittee shall keep a copy of this permit on the premises of the facility to which it applies. (9 VAC 5-170-160)