Facility DEC ID: 1472000911
PERMIT Under the Environmental Conservation Law (ECL) IDENTIFICATION INFORMATION Permit Type: Air State Facility Permit ID: 1-4720-00911/00007 Effective Date: 12/03/2001 Expiration Date: No expiration date Permit Issued To: ADVANCED COATING TECHNIQUES INC 313 WYANDANCH AVE NORTH BABYLON, NY 11703 Contact: ANTONIO GAITAN 313 WYANDANCH AVE NORTH BABYLON, NY 11703 (631) 643-4555 Facility: ADVANCED COATING TECHNIQUES INC 313 WYANDANCH AVE NORTH BABYLON, NY 11703 Contact: WILLIAM R STRONG 313 WYANDANCH AVE NORTH BABYLON, NY 11703 (631) 643-4555 Description: Advanced Coating Techniques Inc. is involved in chromium and sulfuric acid anodizing, cadmium, copper, and tin plating, and spray coating of aerosp ace aluminum and steel parts. The 3 Emission Units of the facility consist of spray coating and drying of coated parts in an oven, cleaning and anodizing of aluminum and aluminum-alloyed parts, and cleaning and electroplating of steel parts. The spray coating and drying unit consists of 4 Emission Points which are associated with three spray booths and one drying oven. The cleaning and anodizing unit consists of 2 Emission Points which are associated with emissions from chromic and sulfuric acid anodizing tanks. The cleaning and electroplating unit consists of 1 Emission Point which is associated with emissions from the plating area. The spray coating operations are subject to 6 NYCRR Part 228 (Surf ace Coating Processes) and 6 NYCRR Part 212 (General Process Emission Sources) regulations that require the utilization of compliant paints and emissions of toxics below the acceptable concentrations in the atmosphere. The facility conducts acid-based cleaning and uses chromic and sulfuric acids for its anodizing processes. Emissions from chromic acid anodizing are regulated under 40 CFR Part 63 Subpart N - National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks. Advanced Coating Techniques is also using cyanide-based solutions to conduct cadmium and copper plating of steel and aerospace parts and the emissions from these sources are regulated by 6 NYCRR Part 212.

FINALC ID: 1472000911 By acceptance of this permit, the permittee agrees that the permit is contingent upon strict compliance with the ECL, all applicable regulations, the General Conditions specified and any Special Conditions included as part of this permit. Permit Administrator: ROGER EVANS DIVISION OF ENVIRONMENTAL PERMITS SUNY CAMPUS, LOOP ROAD, BUILDING 40 STONY BROOK, NY 11790-2356 uth orized Signatur e: _________________________________ Date: ___ / ___ / _____

FINALFacility DEC ID: 1472000911 Notification of Other State Permittee Obligations
Item A: Permittee Accepts Legal Responsibility and Agrees to Indemnification The permittee expressly agrees to indemnify and hold harmless the Department of Environmental Conservation of the State of New York, its representatives, employees, and agents ("DEC") for all claims, suits, actions, and damages, to the extent attributable to the permittee's acts or omissions in connection with the permittee's undertaking of activities in connection with, or operation and maintenance of, the facility or facilities authorized by the permit whether in compliance or not in compliance with the terms and conditions of the permit. This indemnification does not extend to any claims, suits, actions, or damages to the extent attributable to DEC's own negligent or intentional acts or omissions, or to any claims, suits, or actions naming the DEC and arising under article 78 of the New York Civil Practice Laws and Rules or any citizen suit or civil rights provision under federal or state laws.

Item B: Permittee's Contractors to Comply with Permit The permittee is responsible for informing its independent contractors, employees, agents and assigns of their responsibility to comply with this permit, including all special conditions while acting as the permittee's agent w ith respect to the permitted activities, and such persons shall be subject to the same sanctions for violations of the Environmental Conservation Law as those prescribed for the permittee.

Item C: Permittee Responsible for Obtaining Other Required Permits The permittee is responsible for obtaining any other permits, approvals, lands, easements and rights-of-way that may be required to carry out the activities that ar e authorized by this permit.

Item D: No Right to Trespass or Interfere with Riparian Rights This permit does not convey to the permittee any right to trespass upon the lands or interfere with the riparian rights of others in order toperform the permitted work nor does it authorize the impairment of any rights, title, or interest in real or personal property held or vested in a rso n not a party to the perm it.

FINALFacility DEC ID: 1472000911 LIST OF CONDITIONS

DEC GENERAL CONDITIONS General Provisions Facility Inspection by the Department Relationship of this Permit to Other Department Orders and Determinations Applications for Permit Renewals and Modifications Permit Modifications, Suspensions, and Revocations by the Department Facility Level Submission of Applications for Permit Modification or Renewal-REGION 1 HEADQUARTERS

DEC Permit Conditions Page 1 of 3 FINALC ID: 1472000911 DEC GENERAL CONDITIONS **** General Provisions   GENERAL CONDITIONS - Apply to ALL Authorized Permits.

Condition 1: cility Inspection by the Department Applicable State Requirement: ECL 19-0305 Item 1.1: The permitted site or facility, including relevant records, is subject to inspection at reasonable hours and intervals by an authorized representative of the Department of Environmental Conservation (the Department) to determine whether the permittee is complying with this permit and the ECL. Such representative may order the work suspended pursuant to ECL 71-0301 and SAPA 401(3). Item 1.2: The permittee shall provide a person to accompany the Department's representative during an inspection to the permit area when requested by the Department. Item 1.3: A copy of this permit, including all referenced maps, drawings and special conditions, must be available for inspection by the Department at all times at the project site or facility. Failure to produce a copy of the permit upon request by a Department representative is a violation of this permit. Condition 2: Relationship of this Permit to Other Department Orders and Determinations Applicable State Requirement: ECL 3-0301.2(m) Item 2.1: Unless expressly provided for by the Department, issuance of this permit does not modify, supersede or rescind any order or determination previously issued by the Department or any of the terms, conditions or requirements contained in such order or determination. Condition 3: Applications for Permit Renewals and Modifications Applicable State Requirement: 6NYCRR 621.13(a) Item 3.1: The permittee must submit a separate written applicati on to the Department for renewal, modification or transfer of this permit. Such application must include any forms or supplemental information the Department requires. Any renewal, modification or transfer granted by the Department must be in writing. Item 3.2: The permittee must submit a renewal application at least 180 days before expiration of permits for T itle V Facility Permits, or at least 30 days before expiration of permits for State Facility Permits. Condition 4: Permit Modifications, Suspensions, and Revocations by the Department Applicable State Requirement: 6NYCRR 621.14

DEC Permit Conditions Page 2 of 3 FINALFacility DEC ID: 1472000911 Item 4.1: The Department reserves the right to modify, suspend, or revoke this permit. The grounds for modification, suspension or revocation include: a) the scope of the permitted ac tivity is exceeded or a violati on of any condition of the permit or provisions of the ECL and pertinent regulations is found; b) the permit was obtained by misrepresenta tion or failure to disclose relevant facts; c) new material information is discovered; or d) environmental conditions, relevant technology, or applicable law or regulation have materially changed since the permit was issued.

** ** Fac ility Level   Condition 5: Submission of Applications for Permit Modification or Renewal-REGION 1 HEADQUARTERS Applicable State Requirement: 6NYCRR 621.5(a) Item 5.1: Submission of applications for permit modifi cation or renewal are to be submitted to: NYSDEC Regional Permit Administrator Region 1 Headquarters Division of Environmental Permits pu s, Loop Road, Building 4 0 Stony Brook, NY 11790-2356 (631) 444-0365

DEC Permit Conditions Page 3 of 3 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 Permit Under the Environmental Conservation Law (ECL) ARTICLE 19: AIR POLLUTION CONTROL - AIR STATE FACILITY PERMIT IDENTIFICATION INFORMATION Permit Issued To: CE D COATING TECHNIQUES IN C 313 WYANDANCH AVE NORTH BABYLON, NY 11703
Facility: CE D COATING TECHNIQUES IN C 313 WYANDANCH AVE NORTH BABYLON, NY 11703 Authorized Activity By Standard Industrial Classification Code: 3471 -

Air Pollution Control Permit Conditions Page 1 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 LIST OF CONDITIONS

RCEABLE CONDITIONS Facility Level 13 6NYCRR 215: Open Fires Prohibited at I ndustrial and Commercial Sites 3 6NYCRR 200.7: Maintenance of equipment 6 6NYCRR 201-1.7: Recycling and Salvage 7 6NYCRR 201-1.8: Prohib ition of Reintroduction of Collected Contaminants to the Air 9 6NYCRR 201-3.2(a): Proof of Eligib ility 10 6NYCRR 201-3.3(a): Proof of Eligib ility 11 6NYCRR 202-1.1: Required emissions tests 12 6NYCRR 211.3: Visible emissions limited. 1 6NYCRR 200.5: Seali ng 2 6NYCRR 200.6: A cceptable ambient air quality 4 6NYCRR 201-1.2: Unperm itted Emission Sources 5 6NYCRR 201-1.5: Emergency Defense 8 6NYCRR 201-1.10(a): Public A ccess to Recordkeeping 14 6NYCRR 228.10: Compliance Demonstration Emission Unit Level EU=1-PAINT 15 6NYCRR 212.4(c): Compliance Demonstration 16 6NYCRR 212.4(c): Compliance Demonstration 17 6NYCRR 212.9(b): Compliance Demonstration 18 6NYCRR 228.3(a): Compliance Demonstration 19 6NYCRR 228.4: Compliance Demonstration 20 6NYCRR 228.5(a): Compliance Demonstration ID,Proc=AC2,ES=CANOD 21 40CFR 63.340(b), Subpart N: Compliance Demonstration 22 40CFR 63.342(f), Subpart N: Compliance Demonstration 23 40CFR 63.346(a), Subpart N: Compliance Demonstration 24 40CFR 63.346(b), Subpart N: Compliance Demonstration 25 40CFR 63.347(a), Subpart N: Compliance Demonstration 26 40CFR 63.347(h), Subpart N: Compliance Demonstration 27 40CFR 63.347(h)(2), Subpart N: Compliance Demonstration EU=2-0ACID,EP=00005,Proc=AC2,ES=CANOD 28 40CFR 63.342(d)(1), Subpart N: Compliance Demonstration EU=2-0ACID,EP=00006,Proc=AC3,ES=SANOD 29 6NYCRR 212.9(b): Compliance Demonstration EU=3-PLATE,EP=00007,Proc=PCD,ES=CEPLT

Air Pollution Control Permit Conditions Page 2 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 30 6NYCRR 212.9(b): Compliance Demonstration EU=3-PLATE,EP=00007,Proc=PCU,ES=CUPLT 31 6NYCRR 212.9(b): Compliance Demonstration RCEABLE CONDITIONS Facility Level 32 6NYCRR 201-1.4: Unavoidable noncompliance and violations 33 6NYCRR 201-5: General Provisions 34 6NYCRR 201-5: Permit Exclusion Provisions 35 6NYCRR 201-5: Emission Unit Defin ition 36 6NYCRR 201-5.3(b): Contaminant List 37 6NYCRR 211.2: Air pollution prohibited Emission Unit Level 38 6NYCRR 201-5: Emission Point Definition By Emission Unit 39 6NYCRR 201-5: Process Definition By Emission Unit ELECTROPLATING,POLISHING,ANODIZING, AND COLORING 3479 - METAL COATING AND ALLIED SERVICES,NEC

ve Date: 12/03/200 1 Permit Expiration Date: No expiration date.

Air Pollution Control Permit Conditions Page 3 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 FEDERALLY ENFORCEABLE CONDITIONS ** ** Fac ility Level  

Condition 13: Open Fires Prohibited at I ndustrial and Co mmercial Sites Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 215 Item 13.1: No person shall burn, cause, suffer, allow or permit the burning in an open fire of garbage, rubbish for salvage, or rubbish generated by industrial or commercial activities. Condition 3: Maintenance of equipment Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 200.7 Item 3.1: Any person who owns or operates an air contamination source which is equipped with an emission control device shall operate such device and keep it in a satisfactory state of maintenance and repair in accordance with ordinary and necessary practices, standards and procedures, inclusive of manufacturer's specifications, required to operate such device effectively. Condition 6: Recycling and Salvage Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 201-1.7 Item 6.1: Where practical, any person who owns or operates an air contamination source shall recycle or salvage air contaminants collected in an air cleaning device according to the requirements of 6 NYCRR. Condition 7: Prohibition of Reintroduction of Collected Contaminants to the Air Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 201-1.8 Item 7.1: No person shall unnecessarily remove, handle, or cause to be handled, collected air contaminants from an air cleaning device for recycling, salvage or disposal in a manner that would reintroduce them to the ou tdoor atmospher e. Condition 9: Proof of Eligibility Effective between the dates of 12/03/2001 and Permit Expiration Date

Air Pollution Control Permit Conditions Page 4 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 Applicable Federal Requirement: 6NYCRR 201-3.2(a) Item 9.1: The owner and/or operator of an emission source or unit that is eligible to be exempt, may be required to certify that it operates within the specific criteria described in 6 NYCRR Subpart 201-3. The owner or operator of any such emission source must maintain all required records on-site for a period of five years and make them available to representatives of the Department upon request. Department representatives must be granted access to any facility which contai ns emission sources or units subject to 6 NYCRR Subpart 201-3, during normal operating hours, for the purpose of determining compliance with this and any other state and federal air pollution control requirements, regulations, or law. Condition 10: Proof of Eligibility Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 201-3.3(a) Item 10.1: The owner and/or operator of an emission source or unit that is listed as being trivial in 6 NYCRR Part 201 may be required to certify that it operates within the specific criteria described in 6 NY CRR Subpart 201-3. The owner or operator of any such emission source must maintain all required records on-site for a period of five years and make them available to representatives of the Department upon request. Department representatives must be granted access toany facility which contains emission sources or units subject to 6 NYCRR Subpart 201-3, during normal operating hours, for the purpose of determining compliance with this and any other state and federal air pollution control requirements, regulations, or law. Condition 11: Required emissions tests Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 202-1.1 Item 11.1: An acceptable report of measured emissions shall be submitted, as may be required by the commissioner, to ascertain compliance or noncompliance with any air pollution code, rule, or regulation. Failure to submit a report acceptable to the commissioner within the time stated shall be sufficient reason for the commissioner to suspend or deny an operating permit. Notification and acceptable procedures are NY CRR Part 202- 1. Condition 12: Visible emissions limited. Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 211.3 Item 12.1: Except as permitted by a specific part of this Subchapter and for open fires for which a restricted burning permit has been issued, no person shall cause or allow any air contamination source to emit any material having an opacity equal to or greater than 20 percent (six minute average) except for one continuous six-

Air Pollution Control Permit Conditions Page 5 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 minute period per hour of not more than 57 percent opacity. Condition 1: Sealing Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 200.5 Item 1.1: (a) The commissioner may seal an air contamination source to prevent its operation if compliance with 6 NYCRR Chapter III is not met within the time provided by an order of the commissioner issued in the case of the violation. Sealing means labelling or tagging a source to notify any person that operation of the source is prohibited, and also includes physical means of preventing the operation of an air contamination source without resulting in destruction of any equipment associated with such source, and includes, but is not limited to, bolting, chaining or wiring shut control panels, apertures or conduits ted with such sourc e. (b) No person shall operate any air contamination source sealed by the commissioner in accordance with this section unless a modification has been ma de which enables such source to comply with all requirements applicable to such modification. (c) Unless authorized by the commissioner, no person shall remove or alter any seal affixed to any contamination source in accordance with this section Condition 2: Acceptable ambient air quality Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 200.6 Item 2.1: Notwithstanding the provisions of 6 NYCRR Chapter III, Subchapter A, no person shall allow or permit any air contamination source to emit air contaminants in quantities whic h alone or in combination with emissions from other air contamination sources woul d contravene any applicable ambient air quality standard and/or cause air pollution. In such cases where contravention occurs or may occur, the commissioner shall specify the degree and/or method of emission control required. Condition 4: Unpermitted Emission Sources Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 201-1.2 Item 4.1: If an existing emission source was subject to the permitting requirements of 6NYCRR Part 201 at the time of construction or modification, and the owner and/or operator failed to apply for a permit for such emission source then the following provisions apply: (a) The owner and/or operator must apply for a permit for such emission source or register the facility in accordance with the provisions of Part 201.

Air Pollution Control Permit Conditions Page 6 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911

(b) The emission source or facility is subject to all re gulations that were applicable to it at the time of construction or modification and any subsequent requirements applicable to existing sources or facilities. Condition 5: Emergency Defense Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 201-1.5 Item 5.1: An emergency constitutes an affirmative defense to an action brought for noncompliance with emissions limitations or permit conditions for all facilities in New York State. (a) The affirmative defense of emergency shall be demonstrated through properly signed, contemporaneous operating logs, or other relevant evidence that: (1) An emergency occurred and that the facility owner and/or operator can identify the s) of the emergenc y; (2) The equipment at the permitted facility cau sing the emergency was at the time being properly operated; (3) During the period of the emergency the facility owner and/or operator took all reasonable steps to minimize levels of emissions that exceeded the emission standards, or other ts in the permit; and (4) The facility owner and/or operator notified the Department within two working days after the event occurred. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. (b) In any enforcement pro ceeding, the facility owner and/or operator seeking to establish the occurrence of an emergency has the burden of proof. (c) This provision is in addition to any emergency or upset provision contained in any applicable requirement. Condition 8: Public Access to Recordkeeping Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 201-1.10(a) Item 8.1: Where emission source owners and/or operators keep records pursuant to compliance with the operational flexibility requirements of 6 NYCRR Subpart 201-5.4(b)(1) , and/or the emission capping requirements of 6 NYCRR Subparts 201-7.2(d), 201-7.3(f), 201-7.3(g), 201-7.3(h)(5), 201-7.3(i) and 201-7.3(j), the Department w ill make such records available to the public upon request in accordance

Air Pollution Control Permit Conditions Page 7 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 with 6 NYCRR Part 616 - Public A ccess to Records. Emission source owners and/or operators must submit the records required to comp ly with the request within sixty working days of written notification by the Department of receipt of the request. Condition 14: Compliance Demonstration Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 228.10 Item 14.1: The Compliance Demonstration activity will be performed for the Facility. Regulated Contaminant(s):

CAS No: 0NY998-00-0 VOC Item 14.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: No owner or operator of a facility subject to 6NYCRR Part 228 shall: 1. Use open containers to store or dispose of cloth or paper impregnated with VOC and/or solvents that are used for surface preparation, cleanup, or coating removal. 2. Store in open containers spent or fresh VOC and/or solvents to be used for surface preparation, cleanup, or coating removal. 3. Use VOC and/or solvents to cleanup spray equipment unless equipment is used to collect the cleaning compounds and to minimize their evaporation to the atmosphere. 4. Use open containers to store or dispose surface coating and/or inks unless production, sampling, maintenance, or inspection procedures require operational access. This provision does not apply to the actual device or equipment designed for the purpose of applying a coating material to a substrate. 5. Use open containers to store or dispose of spent surface coatings, spent VOC and/or solvents. 6. The facility shall be inspected daily to determine if

Air Pollution Control Permit Conditions Page 8 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 there are any open containers. Open containers, if found, shall be covered. Annual certification of this work practice is required.

onitoring Frequency: DAIL Y Reporting Requirements: ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period. The initial report is due 1/30/2002. Subsequent reports are due every 12 calendar month(s).

** ** Emission Unit Level   Condition 15: Compliance Demonstration Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 212.4(c) Item 15.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PAINT Regulated Contaminant(s):

CAS No: 0NY075-00-0 PARTICULATES Item 15.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: 1. Emissions of particulates from spray booths are limited to less than 0.05 grains per dry cubic foot of exhaust gas at standard conditions. 2. 98 percent or better particulate removal efficiencies shall be maintained in spray booths. 3. Compliance shall be based on monitoring the spray booths operational parameters, such as pressure drop across one or more filters, which justify the emission standard. 4. Performance testing to determine the parameter baseline or trigger value shall be conducted at the

Air Pollution Control Permit Conditions Page 9 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 discretion of the Department. 5. All values of baseline parameters over any 3-hour period that average more than 30 percent of average levels maintained to demonstrate comp liance shall be reported to the Department by a letter within seven (7) days and included in facility compliance reporting.
Mo nitored: PARTICULATE S Upper Permit Limit: 0.05 grains per dscf Reference Test Method: EPA Method 5 Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/2002. Subsequent reports are due every 12 calendar month(s). Condition 16: Compliance Demonstration Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 212.4(c) Item 16.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PAINT Regulated Contaminant(s):

CAS No: 0NY075-00-0 PARTICULATES Item 16.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Owner/operator of paint spray booths must periodically inspect the booths and the accompanying particulate control device(s) and record the inspections. Complete the following tasks on a weekly basis: 1. Inspect the spray booth's emission point for evidence of paint fallout and for presence of visible emissions. Presence of visible emissions indicates that the emission source may not be properly operating and that it may need

Air Pollution Control Permit Conditions Page 10 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 servicing. 2. Inspect and replace the spray booth's particulate control device (filter) according to the manufacturer's specifications. 3. Inspect and maintain the spray guns regularly as per manufacturer's specifications. 4. Record in an inspection log the date, name of individual performing inspection, and the inspection results after each inspection. Record the problem when discovered, the cause of the problem, and the corrective action taken to resolve the problem. The record log will be made available to the Department for review upon request. The problems must be immediately remedied. The dates of control device (filter) replacements, methods of manufacturer's recommendations used for this replacement, and a summary of the spray booth's maintenance log will be reported to the Department.

ito ring Frequency: WEEKL Y Reporting Requirements: ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period. The initial report is due 1/30/2002. Subsequent reports are due every 12 calendar month(s). Condition 17: Compliance Demonstration Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 212.9(b) Item 17.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PAINT Regulated Contaminant(s): CAS No: 007789-06-2 STRONTIUM CHROMATE Item 17.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: WORK PRACTICE INVOLVING SPECIFIC

Air Pollution Control Permit Conditions Page 11 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 OPERATIONS Monitoring Description: Coating/solvent usage records and 98% or better filtering requirements on spray booths will be maintained and emission factors or test methods employed which demonstrate that the strontium chromate emissions are kept below 10 pounds per year. Strontium chromate is a highly toxic compound and is thus assigned the environmental rating A. Its emission rate needs to be limited in order to avoid the installation of best available technology. Work Practice Type: PARAMETER OF PROCESS MATERIAL Process Material: PAINT Parameter Monitored: STRONTIUM CHROMATE Upper Permit Limit: 10 pounds per year Reference Test Method: EPA Method 301 Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION eth od: ARITHMETIC MEAN Reporting Requirements: ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/2002. Subsequent reports are due every 12 calendar month(s). Condition 18: Compliance Demonstration Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 228.3(a) Item 18.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PAINT Item 18.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: No coatings are allowed that exceed the allowable limits as specified in Table 1 and Table 2 of Part 228.7 and 228.8, respecively. Only compliant coatings are allowed, unless approved by the Department. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: ANNUALLY (CALENDAR)

Air Pollution Control Permit Conditions Page 12 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 Reports due 30 days after the reporting period. The initial report is due 1/30/2002. Subsequent reports are due every 12 calendar month(s). Condition 19: Compliance Demonstration Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 228.4 Item 19.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PAINT Item 19.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: 1. No person shall cause or allow emissions to the outdoor atmosphere having an opacity greater than 20 percent for any consecutive six-minute period from any emission point. 2. Compliance shall be based on monitoring the spray booths operational parameters, such as pressure drop across the filters, which justify the emission standard. 3. Performance testing to determine the parameter baseline or trigger value shall be conducted at the discretion of the Department. 4. All values of baseline parameters over any 3-hour period that average more than 30 percent of average levels maintained to demonstrate comp liance shall be reported by a letter within seven (7) days and included in facility compliance reporting. 5. The Department reserves the right to perform or require the performance of Method 9 opacity evaluation.

ameter Monitored: OPACIT Y pe r Permit Limit: 20 perce nt Reference Test Method: EPA Method 9 Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING

Air Pollution Control Permit Conditions Page 13 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 DESCRIPTION Averaging Method: 6-MINUTE AVERAGE (METHOD 9) Reporting Requirements: ONCE / BATCH OR MONITORING OCCURRENCE Condition 20: Compliance Demonstration Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 228.5(a) Item 20.1: The Compliance Demonstration activity will be performed for: Emission Unit: 1-PAINT Item 20.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: 1. Certification from the coating supplier/manufacturer which verify the parameters used to determine the actual VOC content of paints in all spray booths must be maintained and upon reques t made available to the Department. 2. Purchase and usage records of coatings, including solvents, shall be maintained at the facility for a period of 5 years. 3. Reporting of certification is required. Monitoring Frequency: PER BATCH OF PRODUCT/RAW MATERIAL CHANGE Reporting Requirements: ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/2002. Subsequent reports are due every 12 calendar month(s). Condition 21: Compliance Demonstration Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.340(b) , Subpart N Item 21.1: The Compliance Demonstration activity will be performed for: Emission Unit: 2-0ACID

Air Pollution Control Permit Conditions Page 14 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 Process: AC2 Emission Source: CANOD Item 21.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Owners or operators of affected sources subject to 40CFR63 Subpart N must also comply with the requirements of Subpart A of Part 63, according to the applicability of Subpart A to such sources, as identified in Table 1 of Subpart N. Subpart A is the General Provisions for the NESHAP for Source Categories regulations. The General Provisions contain requirements for performance testing, monitoring, notification, recordkeeping, reporting, and control devices that may apply to the source. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 22: Compliance Demonstration Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.342(f) , Subpart N Item 22.1: The Compliance Demonstration activity will be performed for: Emission Unit: 2-0ACID Process: AC2 Emission Source: CANOD Item 22.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Owner/operator is subject to the following work practice standards: 1. The owner/operator shall operate and maintain the affected source in a manner consistent with good air pollution control practices at all times (including during startups, shutdowns, and malfunctions). Malfunctions shall be corrected as soon as practicable. Operation and maintenance requirements established under section 112 of the Act are enforceable independent of emissions

Air Pollution Control Permit Conditions Page 15 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 limitations or other requirements in relevant standards. 2. The determination of whether the operation and maintenance procedures are acceptable will be based on information available to the Administrator, which may include, but is not limited to, monitoring results; review of the operation and maintenance plan, procedures, and records; and inspection of the source. Based on the results of this determination, the Administrator may require that the operation and maintenance plan be revised. Revisions may be required if it is found that the plan does not (a) address a malfunction that has occurred, (b) provide for the operation of the affected source, the air pollution control techniques, or the control system and process monitoring equipment during a malfunction in a manner consistent with good air pollution control practices, or (c) provide adequate procedures for correcting malfunctioning process equipment, air pollution control techniques, or monitoring equipment as quickly as practicable. 3. The owner/operator shall prepare an operation and maintenance (O&M) plan to be implemented no later than the compliance date. The plan sh all include the information found in 40CFR63. 342(f)(3)(i) (A) thr ough (E). If the O&M plan fails to address an event that meets the characteristics of a malfunction at the time the plan is initially developed, the owner/operator shall revise the O&M plan within 45 days toinclude procedures for operating and maintaining the process equipment, add-on air pollution control device, or monitoring equipment during similar malfunctions, and a program for corrective actions taken for such events. If actions taken by the owner/operator during periods of malfunction are inconsistent with the O&M plan, the actions taken shall be recorded and reported by phone within 2 working days after commencing actions inconsistent with the plan. This report shall be followed by a letter within 7 working days after the end of the event. The owner/operator shall keep the written O&M plan on record to be available for in spection by the Administrator until the source is no longer subject to Subpart N. In

Air Pollution Control Permit Conditions Page 16 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 addition, if the O&M plan is revised, previous versions shall be kept available for inspection for a period of 5 years. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/2002. Subsequent reports are due every 12 calendar month(s). Condition 23: Compliance Demonstration Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.346(a) , Subpart N Item 23.1: The Compliance Demonstration activity will be performed for: Emission Unit: 2-0ACID Process: AC2 Emission Source: CANOD Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 23.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator of the chrome anodizer source subject to 40CFR63 Subpart N shall fulfill all recordkeeping requirements outlined in section 40CFR63. 346 and in the General Provisions of 40CFR63 Subpart A. The records specified for Subpart N are listed as items numbered 1 through 16 in section 40CFR63. 346(b). Subpart A requirements are specified in Table 1 of Subpart N. All records shall be maintained for a period of 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. The data may be maintained on microfilm, in a computer, or on other storage media. Reports shall be submitted to the regional office of DEC. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION

Air Pollution Control Permit Conditions Page 17 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 24: Compliance Demonstration Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.346(b) , Subpart N Item 24.1: The Compliance Demonstration activity will be performed for: Emission Unit: 2-0ACID Process: AC2 Emission Source: CANOD Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 24.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/ operator of the chromium anodizing tank subject to the provisions of 40CFR 63.342(d)(1) (not allowing the concentration of total chromium in the exhaust gas stream discharged to the atmosphere to exceed 0.01 mg/dscm) shall maintain the following records for such a source: 1. Records of all maintenance performed on the affected source, the add-on air pollution control device, and monitoring equipment. 2. Records of the occurrence, duration, and cause (if known) of each malfunction of process, add-on air pollution control, and monitoring equipment. 3. Records of actions taken during periods of malfunction when such actions are inconsistent with the operation and maintenance plan. 4. Other records, which may take the form of checklists, necessary to demonstrate consistency with the provisions of the operation and maintenance plan required by 40CFR63.342(f)(3). 5. Records of monitoring date required by 40CFR63.343(c) that are used to demonstrate compliance with the standard

Air Pollution Control Permit Conditions Page 18 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 including the date and time the data are collected. 6. The specific identification (i.e. the date and time of commencement and completion) of each period of excess emissions, as indicated by monitoring data, that occurs during malfunction of the process, add-on air pollution control, or monitoring equipment. 7. The specific identification (i.e. the date and time of commencement and completion) of each period of excess emissions, as indicated by monitoring data, that occurs during periods other than malfunction of the process, add-on air pollution control, or monitoring equipment. 8. The total process operating time of the affected source during the reporting period. 9. For sources using fume suppressants to comply with the standards, records of the date and time that fume suppressants are added to the electroplating or anodizing bath. 10. All documentation supporting the notification and reports required by 40CFR63.9, 40CFR63.10, and 40CFR63.347. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/2002. Subsequent reports are due every 12 calendar month(s). Condition 25: Compliance Demonstration Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.347(a) , Subpart N Item 25.1: The Compliance Demonstration activity will be performed for: Emission Unit: 2-0ACID Process: AC2 Emission Source: CANOD Item 25.2: Compliance Demonstration shall include the following monitoring:

Air Pollution Control Permit Conditions Page 19 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911
Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator of each affected source subject to 40CFR63 Subpart N shall fulfill all reporting requirements as outlined in section 40CFR63. 347 and in the General Provisions of 40CFR63. General Provisions requirements are identified in Table 1 of Subpart N. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 26: Compliance Demonstration Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.347(h) , Subpart N Item 26.1: The Compliance Demonstration activity will be performed for: Emission Unit: 2-0ACID Process: AC2 Emission Source: CANOD Item 26.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator of the affected source that is located at an area source site shall submit a summary report to document the ongoing compliance status of the affected source. The report shall contain the information identified below and shall be submitted annually, except as provided in paragraph 40CFR63.347(h)(2). 1. The company name and address of the affected source. 2. An identification of the operating parameter that is being monitored for compliance determination, as required by 40CFR63.343(c). 3. The relevant emission limitation for the affected source, and the operating parameter value, or range of values, that correspond to compliance with this emission limitation as specified in the notification of compliance

Air Pollution Control Permit Conditions Page 20 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 status required vy 40CFR63.347(e). 4. The beginning and ending dates of the reporting period. 5. A description of the type of process performed in the affected source. 6. The total operating time of the affected source during the reporting period. 7. If the affected source is a hard chromium electroplating tank and the owner or operator is limiting the maximum cumulative rectifier capacity in accordance with 40CFR63.342(c)(2), the actual cumulative rectifier capacity expended during the reporting period, on a month-by-month basis. 8. A summary of operating parameter values, including the total duration of excess emissions during the reporting period as indicated by those values, the total duration of excess emissions expressed as a percent of the total source operating time during the reporting period, and a breakdown of the total duration of excess emissions during the reporting period into thos e that are due to process upsets, control equipment malfunctions, other known causes, and unknown causes. 9. A certification by a responsible official, as defined in 40CFR63.2, that the work practice standards in 40CFR63.342(f) were followed in accordance with the operation and maintenance plan for the source. 10. If the operation and maintenance plan required by 40CFR63.342(f)(3) was not followed, an explanation of the reasons for not following the provisions, an assessment of whether any excess emission and/or parameter monitoring exceedances are believed to have occurred, and a copy of the report(s) required by 40CFR63.342(f)(3)(iv) documenting that the operation and maintenance plan was not followed. 11. A description of any changes in monitoring, processes, or control since the last reporting period. 12. The name, title, and signature of the responsible official who is certifying the accuracy of the

Air Pollution Control Permit Conditions Page 21 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 report. 13. The date of the report. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/2002. Subsequent reports are due every 12 calendar month(s). Condition 27: Compliance Demonstration Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.347(h)(2 ), Subpart N Item 27.1: The Compliance Demonstration activity will be performed for: Emission Unit: 2-0ACID Process: AC2 Emission Source: CANOD Item 27.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: (i) If both the following conditions are met, semiannual reports shall be prepared and submitted to the Administrator. (A) The total duration of excess emissions (as indicated by the monitoring data collected by the owner or operator of the affected source in accordance with 40CFR63. 343(c)) is 1 percent or greater of the total operating time for the reporting period; and (B) The total duration of malfunctions of the add-on air pollution control device and monitoring equipment is 5 percent or greater of the total operating time. (ii) Once the owner or operator reports an exceedance as defined in item (i) of this condition, ongoing compliance status reports shall be submitted semiannually until a request to reduce reporting frequency under 40CFR63.347(h)(3) is approved.

Air Pollution Control Permit Conditions Page 22 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 28: Compliance Demonstration Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 40CFR 63.342(d)(1 ), Subpart N Item 28.1: The Compliance Demonstration activity will be performed for: Emission Unit: 2-0ACID Emission Point: 00005 Process: AC2 Emission Source: CANOD Regulated Contaminant(s): CAS No: 007440-47-3 CHROMIUM Item 28.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: 1. Chromium emissions from the anodizing tank shall be maintained below 0.01 mg/dscm by maintaining the pressure drop between 1.4 and 3.4 inches of water column across the composite mesh-pad scrubber system. 2. The pressure drop shall be monitored by taking pressure gage readings at least once every 3 hours of tank operation and the average daily value shall be recorded and reported. 3. An exceedance in chromium emissions is defined as the pressure drop across the mesh-pad which falls outside of compliance limits. Manufacturer Name/Model Number: Kimre/B-gon composite mesh pad eter Monitored: PRESSURE Lower Permit Limit: 1.4 inches of water Upper Permit Limit: 3.4 inches of water Reference Test Method: EPA Method 306 Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Averaging Method: RANGE - NOT TO FALL OUTSIDE OF STATED RANGE AT ANY TIME

Air Pollution Control Permit Conditions Page 23 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 Reporting Requirements: ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/2002. Subsequent reports are due every 12 calendar month(s). Condition 29: Compliance Demonstration Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 212.9(b) Item 29.1: The Compliance Demonstration activity will be performed for: Emission Unit: 2-0ACID Emission Point: 00006 Process: AC3 Emission Source: SANOD Regulated Contaminant(s): CAS No: 007664-93-9 SULFURIC ACID Item 29.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: The sulfuric acid is a toxic compound and its emission rate potential for this emission point (before control) was estimated at 0.2 pounds per hour. The polypropylene balls two layers thick floating on the surface of the tank are estimated to control about 50% of these emissions. With this control the emi ssions are below the ambient guideline concentration listed in guidance document DAR-1 and it is not necessary to install the best available control technology to control the emissions. If inspections offer reasons to doubt that the sulfuric acid emissions exceed the allowable concentration, the Department reserves the right to request a performance test pursuant to 6NYCRR Part 202-1. The test must show that the actual emission rate is less than 0.1 pounds per hour.

o nitored: SULFURIC ACID Upper Permit Limit: 0.10 pounds per hour Reference Test Method: EPA Method 8 Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION eth od: ARITHMETIC MEAN

Air Pollution Control Permit Conditions Page 24 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 Reporting Requirements: ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/2002. Subsequent reports are due every 12 calendar month(s). Condition 30: Compliance Demonstration Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 212.9(b) Item 30.1: The Compliance Demonstration activity will be performed for: Emission Unit: 3-PLATE Emission Point: 00007 Process: PCD

Emission Source: CEPLT Regulated Contaminant(s): CAS No: 000057-12-5 CYANIDE Item 30.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: The cyanide is a toxic compound and its emission rate potential for this emission source (before control) was estimated at 0.1 pounds per hour. The polypropylene balls two layers thick floating on the surface of the tank are estimated to control about 50% of these emissions. With this control the emissions ar e below the ambient guideline concentration listed in guidance document DAR-1 and it is not necessary to install the best available control technology to control the emissions. If inspections offer reasons to doubt that the cyanide emissions exceed the allowable concentration, the Department reserves the right to request a performance test pursuant to 6NYCRR Part 202-1. The test must show that the actual emission rate is less than 0.05 pounds per hour.

me ter Monitored: CYANID E Upper Permit Limit: 0.05 pounds per hour Reference Test Method: EPA Method 301 Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION eth od: ARITHMETIC MEAN

Air Pollution Control Permit Conditions Page 25 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 Reporting Requirements: ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/2002. Subsequent reports are due every 12 calendar month(s). Condition 31: Compliance Demonstration Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable Federal Requirement: 6NYCRR 212.9(b) Item 31.1: The Compliance Demonstration activity will be performed for: Emission Unit: 3-PLATE Emission Point: 00007 Process: PCU

Emission Source: CUPLT Regulated Contaminant(s): CAS No: 000057-12-5 CYANIDE Item 31.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: Cyanide is a toxic compound and its emission rate potential for this emission source (before control) was estimated at 0.1 pounds per hour. The polypropylene balls two layers thick floating on the surface of the tank are estimated to control about 50% of these emissions. With this control the emissions ar e below the ambient guideline concentration listed in guidance document DAR-1 and it is not necessary to install the best available control technology to control the emissions. If inspections offer reasons to doubt that cyanide emissions exceed the allowable concentration, the Department reserves the right to request a performance test pursuant to 6NYCRR Part 202-1. The test must show that the actual emission rate is less than 0.05 pounds per hour.

me ter Monitored: CYANID E Upper Permit Limit: 0.05 pounds per hour Reference Test Method: EPA Method 301 Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION eth od: ARITHMETIC MEAN

Air Pollution Control Permit Conditions Page 26 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 Reporting Requirements: ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/2002. Subsequent reports are due every 12 calendar month(s).

Air Pollution Control Permit Conditions Page 27 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911

STATE ONLY ENFORCEABLE CONDITIONS ** ** Fac ility Level  

Condition 32: Unavoidable noncompliance and violations Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable State Requirement: 6NYCRR 201-1.4 Item 32.1: At the discretion of the commissioner a violation of any applicable emission standard for necessary scheduled equipment maintenance, start-up/shutdown conditions and malfunctions or upsets may be excused if such violations are unavoidable. The following actions and recordkeeping and reporting requirements must be adhered to in such circumstances. (a) The facility owner and/or operator shall comp ile and maintain records of all equipment maintenance or start-up/shutdown activities when they can be expected to resu lt in an exceed ance of any applicable emission standard, and shall submit a report of such activities to the commissioner's representative when requested to do so in writing or when so required by a condition of a permit issued for the corresponding air contamination source except where conditions elsewhere in this permit which contain more stringent reporting and notification provisions for an applicable requirement, in which case they supercede those stated here. Such reports shall describe why the violation was unavoidable and shall include the time, frequency and dur ation of the maintenance and/or start-up/shutdown activities and the identification of air contaminants, and the estimated emission rates. If a facility owner and/or operator is subject to continuous stack monitoring and quarterly reporting requirements, he need not submit reports for equipment maintenance or start-up/shutdown for the facility to the co mmissioner's representative. (b) In the event that emissions of air contaminants in excess of any emission standard in 6 NYCRR Chapter III Subchapter A occur due to a malfunction, the facility owner and/or operator shall report such malfunction by telephone to the commissioner's representative as soon as possible during normal working hours, but in any event not later than two working days after becoming aware that the malfunction occurred. Within 30 days thereafter, when requeste d in writing by the commissi oner's representative, the facility owner and/or operator shall submit a wr itten report to the commissioner's representative describing the malfunction, the corrective action taken, identification of air contaminants, and an estimate of the emission rates. These reporting requirements are superceded by conditions elsewhere in this permit which contain reporting and notification provisions for applicable requirements more stringent than those above. (c) The Department may also require the owner and/or operator to include in reports described under (a) and (b) above an estimate of the maximum ground level concentration of each air contaminant emitted and the effect of such emissions dependi ng on the deviation of the malfunction and the air ont aminants emitte d. (d) In the event of maintenance, start-up/shutdown or malfunction conditions which result in emissions exceeding any applicable emission standard , the facility owner and/oroperator shall take appropriate action to prevent emissions which will resu lt in contravention of any applicable ambient air

Air Pollution Control Permit Conditions Page 28 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 quality standard. Reasonably available control technology, as determined by the commissioner,. shall be applied during any maintenance, start-up/shutdown or malfunction condition subject to this paragraph. (e) In order to have a violation of a federal regulation (such as a new source performance standard or national emissions standard for hazardous air pollutant s) excused, the specific federal regulation must provide for an affirmative defense during start-up, shutdowns, malfunctions or upsets. Condition 33: General Provisions Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable State Requirement: 6NYCRR 201-5 Item 33.1: This section contains terms and c onditions that are not federally enforceable and are not required under the Act or under any of its applicable requirements. Terms and conditions so designated are not subject to the requirements of Section 201-6.4 of Part 201. Item 33.2: Any person who owns and/or operates stationary sources shall operate and maintain all emission units and any required emission control devices in complian ce with all applicable Parts of this Chapter and existing laws, and shall operate the facility in accordance with all criteria, emission limits, terms, conditions, and standards in this pe rmit. Failure of such person to properly operate and maintain the effectiveness of such emission units and emission control devices may be sufficient reason for the Department to revoke or deny a permit. Item 33.3: The owner or operator of the permitted facility must maintain all required records on-site for a period of five years and make them available to representatives of the Department upon request. Department representatives must be granted acce ss to any facility regulated by this Subpart, during normal operating hours, for the purpose of determining compliance with this and any other state and federal air pollution control requirements, regulations or law. Condition 34: Permit Exclusion Provisions Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable State Requirement: 6NYCRR 201-5 Item 34.1: The issuance of this permit by the Department and the receipt thereof by the Applicant does not and shall not be construed as barring, diminishing, adjudicating or in any way affecting any currently pending or future legal, administrative or equitable rights or claims, actions, suits, causes of action or demands whatsoever that the Department may have agains t the Applicant including, but not limited to, any enforcement action authorized pursuant to the provisions of applicable federal law, the Environmental Conservation Law of the State of New York (ECL) and Chapter III of the Official Compilation of the Codes, Rules and Regulations of the State of New York (NYCRR). The issuance of this permit by the Department and the receipt thereof by the Applicant does not

Air Pollution Control Permit Conditions Page 29 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 supercede, revoke or rescind an order or modification thereof on consent or determination by the Commissioner issued heretofore by the Department or any of the terms, conditions or requirements contained in such order or modification thereof unless specifically intended by this permit. The issuance of this permit by the Department and the receipt thereof by the Applicant does not and shall not be construed as barring, diminishing, adjudicating or in any way affecting the right of the Department to bring any future action, or pursue any pending action, either administrative or judicial, to required remediation, contribution for costs incurred or funds expended, for any violations, past, present or future, known or unknown, of applicable federal law, the ECL, or the rules and regulations promulgated thereunder, or conditions contained in any other licenses or permits issued to the Applicant and not res sed in this perm it. The issuance of this permit by the Department and the receipt thereof by the Applicant does not and shall

not be construed as barring, diminishing, adjudicating or in any way affecting the right of the Department to pursue any claims for natural resource damages against the Applicant. Condition 35: Emission Unit Definition Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable State Requirement: 6NYCRR 201-5 Item 35.1: The facility is authorized to perform regulated processes under this permit for: Emission Unit: 1-PAINT E mission Unit Descriptio n: The Emission Unit consists of a paint mixing booth, three spray booths where the metal parts are coated with compliant paints, and one drying oven where the parts are dried. The emissions from spray booths and drying oven are exhausted through 4 Emission Points. The emissions from the paint mixing booth are exempted under 6 NYCRR Part 201-3.2(c)(42), b ecause the paints stored at this location are kept in closed containers when not in use. Building(s): HDQ Item 35.2: The facility is authorized to perform regulated processes under this permit for: Emission Unit: 2-0ACID E mission Unit Descriptio n: The Emission Unit consists of alkaline cleaning, etching, and dioxidation of aluminum and aluminum-alloyed metal parts before anodizing. The cleaned parts are anodized in chromic and sulfuric acid baths and subsequently sealed and chromated. The emissions from chromic acid bath are controlled by a composite mesh pad scrubber prior to being discharged through the Emission Point 5. The emissions

Air Pollution Control Permit Conditions Page 30 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 from sulfuric acid bath are discharged through the Emission Point 6 and are not being controlled. Building(s): HDQ Item 35.3: The facility is authorized to perform regulated processes under this permit for: Emission Unit: 3-PLATE E mission Unit Descriptio n: The Emission Unit consists of alkaline electrocleaning, acid pickling, chromating, and cadmium, tin and copper plating of steel parts. The parts cleaning, plating, and sealing area includes the Emission Point 7. Mixing of chemicals and paints takes place in an adjacent room. Building(s): HDQ Condition 36: Contaminant List Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable State Requirement: 6NYCRR 201-5.3(b) Item 36.1: Emissions of the following contaminants are subject to contaminant specific requirements in this permit(emission limits, control requirements or compliance monitoring conditions). CAS No: 007440-47-3 Name: CHROMIUM CAS No: 000057-12-5 Name: CYANIDE CAS No: 0NY075-00-0 Name: PARTICULATES

CAS No: 007789-06-2 ST RONTIUM CHROMAT E CAS No: 007664-93-9 Name: SULFURIC ACID

CAS No: 0NY998-00-0 Name: VOC Condition 37: Air pollution prohibited Effective between the dates of 12/03/2001 and Permit Expiration Date

Air Pollution Control Permit Conditions Page 31 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 Applicable State Requirement: 6NYCRR 211.2 Item 37.1: No person shall cause or allow emissions of air contaminants to the outdoor atmosphere of such quantity, characteristic or duration which are injurious to human , plant or animal life or to property, or which unreasonably interfere with the comfortable enjoyment of life or property. Notwithstanding the existence of specific air quality standards or emission limits, this prohibition applies, but is not limited to, any particulate, fume, gas, mist, odor, smoke, vapor, pollen, toxic or deleterious emission, either alone or in bin ation with othe rs.

** ** Emission Unit Level **** Condition 38: Emission Point Definition By Emission Unit Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable State Requirement: 6NYCRR 201-5 Item 38.1: The following emission points are included in this permit for the cited Emission Unit: Emission Unit: 1-PAINT Emission Point: 00001 Height (ft.): 21 Diameter (in.): 24 NYTMN (km.): 4511.4 NYTME (km.): 638.6 Building: HDQ Emission Point: 00002 Height (ft.): 21 Diameter (in.): 24 NYTMN (km.): 4511.4 NYTME (km.): 638.6 Building: HDQ Emission Point: 00003 Height (ft.): 21 Diameter (in.): 24 NYTMN (km.): 4511.4 NYTME (km.): 638.6 Building: HDQ Emission Point: 00004 Height (ft.): 21 Diameter (in.): 7 NYTMN (km.): 4511.4 NYTME (km.): 638.6 Building: HDQ Item 38.2: The following emission points are included in this permit for the cited Emission Unit: Emission Unit: 2-0ACID Emission Point: 00005 Height (ft.): 19 Diameter (in.): 15

Air Pollution Control Permit Conditions Page 32 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 NYTMN (km.): 4511.4 NYTME (km.): 638.6 Building: HDQ Emission Point: 00006 Height (ft.): 18 Diameter (in.): 12 NYTMN (km.): 4511.4 NYTME (km.): 638.6 Building: HDQ Item 38.3: The following emission points are included in this permit for the cited Emission Unit: Emission Unit: 3-PLATE Emission Point: 00007 Height (ft.): 20 Diameter (in.): 12 NYTMN (km.): 4511.4 NYTME (km.): 638.6 Building: HDQ Condition 39: Process Definition By Emission Unit Effective between the dates of 12/03/2001 and Permit Expiration Date Applicable State Requirement: 6NYCRR 201-5 Item 39.1: This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: 1-PAINT Process: SP0 Source Classification Code: 4-02-025-01 Process Description: Compliant coatings are applie d to metal parts in three (3) spray booths. The parts are then dried in one (1) curing oven. The paints are mixed in a booth adjacent to spray booths. Emission Source/Control: PSB01 - Control e: MAT OR PANEL FILTE R Emission Source/Control: PSB02 - Control e: MAT OR PANEL FILTE R Emission Source/Control: PSB03 - Control e: MAT OR PANEL FILTE R Emission Source/Control: PSMR1 - Process Emission Source/Control: PSOV1 - Process Item 39.2: This permit authorizes the following regulated processes for the cited Emission Unit:

Air Pollution Control Permit Conditions Page 33 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 Emission Unit: 2-0ACID Process: AC1 Source Classification Code: 3-09-011-01 Process Description: Alkaline cleaning at 150 F, etching at 140 F, and deoxidizing at 70 F in desmutter. The process involves non-electrical activity and produces non-agitation of air. Emission Source/Control: ACALK - Process Item 39.3: This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: 2-0ACID Process: AC2 Source Classification Code: 3-09-011-03 Process Description: Chromic acid anodizing of aluminum and aluminum-alloyed parts at 100 F. The process i nvolves electrical activity and produces air agitation. Emission Source/Control: CANOD - Process Item 39.4: This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: 2-0ACID Process: AC3 Source Classification Code: 3-09-011-03 Process Description: Sulfuric acid anodizing of Aluminum and Aluminum-alloyed parts at 80 F. The process involves electrical activity and produces air agitation. Emission Source/Control: SANOD - Process Item 39.5: This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: 2-0ACID Process: AC4 Source Classification Code: 3-09-011-99 Process Description: Dichromate and dilute chromic acid sealing of Aluminum and Aluminum-alloyed parts at about 200 F. The process involves non-electrical activity and produces non-agitation of air. Emission Source/Control: DSHSL - Process

Air Pollution Control Permit Conditions Page 34 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911 Item 39.6: This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: 2-0ACID Process: AC5 Source Classification Code: 3-09-011-03 Process Description: Hard coat anodizing of Aluminum and Aluminum-alloyed parts in sulfuric and oxalic acids. The process involves electrical activity and produces agitation of air. Emission Source/Control: HANOD - Process Item 39.7: This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: 3-PLATE Process: PAE Source Classification Code: 3-09-011-01 Process Description: Alakaline electrocleaning of parts prior to plating at about 100 F. The process i nvolves electrical activity and produces air agitation. Emission Source/Control: AECLG - Process Item 39.8: This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: 3-PLATE Process: PAP Source Classification Code: 3-09-011-02 Process Description: Acid pickling of steel parts in muriatic acid at ambient temperature. The process involves non-electrical activity and produces non-agitation of air. Emission Source/Control: APICK - Process Item 39.9: This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: 3-PLATE Process: PCC Source Classification Code: 3-09-011-99 Process Description: Chromating at ambient conditions after anodizing and plating. The process involves non-electrical activity and produces non-agitation of air. Emission Source/Control: CHRMT - Process

Air Pollution Control Permit Conditions Page 35 of 36 FINAL-4720-00911/00007 Facility DEC ID: 1472000911

Item 39.10: This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: 3-PLATE Process: PCD Source Classification Code: 3-09-010-52 Process Description: Cadmium plating of steel parts using sodium cyanide, sodium hydroxide, and sodium carbonate baths at ambient conditions. The process involves electrical activity and produces non-agitation of air. Emission Source/Control: CEPLT - Process Item 39.11: This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: 3-PLATE Process: PCM Source Classification Code: 3-01-014-01 Process Description: Mixing of chemicals and paints in a storage room. Emission Source/Control: PCMRM - Process Item 39.12: This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: 3-PLATE Process: PCU Source Classification Code: 3-09-010-42 Process Description: Copper plating at about 150 F in copper cyanide, sodium cyanide, sodium carbonate, rochelle salts, and sodium hydroxide solutions. The process involves electrical activity and produces non-agitation of air. Emission Source/Control: CUPLT - Process Item 39.13: This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: 3-PLATE Process: PTN Source Classification Code: 3-09-010-97 Process Description: Tin plating at ambient conditions in stannate and sulfuric acid baths. The process involves electrical activity and produces non-agitation of air. Emission Source/Control: TEPLT - Process

Air Pollution Control Permit Conditions Page 36 of 36 FINAL