# PART 70 OPERATING PERMIT

INDI ANA DEPARTMENT OF ENVIRONMENTA L

MANAGEMENT OFFICE OF AIR QU ALITY

and CITY OF INDI ANAPOLIS OFFICE OF ENVIRONMENTAL SERVICES

Rolls Royce Corporation Plant 8 - 2001 South Tibbs Avenue Plant 5 - 2355 South Tibbs Avenue Indianapolis, Indiana 46241

(herein known as the Permittee) is hereby authorized to operate subject to the conditions contained herein, the source described in Section A (Source Summary) of this permit. This permit is issued in accordance with 326 IAC 2 and 40 CFR Part 70 Appendix A and contains the conditions and provisions specified in 326 IAC 2-7 as required by 42 U.S.C. 7401, et. seq. (Clean Air Act as amended by the 1990 Clean Air Act Amendments), 40 CFR Part 70.6, IC 13-15, IC 13-17 and the Code of Indianapolis and Marion County, Chapter 511.

Operation Permit No.: T097-7238-00311 Issued by: Original Signed by

Janet G. McCabe, Assistant Commissioner Office of Air Quality

John B. Chavez, Administrator Office of Environmental Services Issuance Date: August 13, 2003

Expiration Date: August 13, 2008Rolls Royce Corporation Page 2 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy 

### TABLE OF CONTENTS

A SOURCE SUMMARY A.1 General Information [326 IAC 2-7-4(c)] [326 IAC 2-7-5(15)] [326 IAC 2-7-1(22)] A.2 Emission Units and Pollution Control Equipment Summary [326 IAC 2-7-4(c)(3)] A.3 Specifically Regulated Insignificant Activities [326 IAC 2-7-1(21)] [326 IAC 2-7-4(c)] [326 IAC 2-7-5(15)] A.4 Part 70 Permit Applicability [326 IAC 2-7-2]
B GENERAL CONDITIONS B.1 Definitions [326 IAC 2-7-1] B.2 Permit Term [326 IAC 2-7-5(2)] [326 IAC 2-1.1-9.5] B.3 Enforceability [326 IAC 2-7-7] B.4 Termination of Right to Operate [326 IAC 2-7-10] [326 IAC 2-7-4(a)] B.5 Severability [326 IAC 2-7-5(5)] B.6 Property Rights or Exclusive Privilege [326 IAC 2-7-5(6)(D)] B.7 Duty to Provide Information [326 IAC 2-7-5(6)(E)] B.8 Compliance with Permit Conditions [326 IAC 2-7-5(6)(A)] [326 IAC 2-7-5(6)(B)] B.9 Certification [326 IAC 2-7-4(f)] [326 IAC 2-7-6(1)] [326 IAC 2-7-5(3)(C)] B.10 Annual Compliance Certification [326 IAC 2-7-6(5)] B.11 Preventive Maintenance Plan [326 IAC 2-7-5(1),(3)and (13)][326 IAC 2-7-6(1)and(6)] [326 IAC 1-6-3] B.12 Emergency Provisions [326 IAC 2-7-16] B.13 Permit Shield [326 IAC 2-7-15] [326 IAC 2-7-20] [326 IAC 2-7-12] B.14 Prior Permits Superseded [326 IAC 2-1.1-9.5] B.15 Deviations from Permit Requirements and Conditions [326 IAC 2-7-5(3)(C)(ii)] B.16 Permit Modification, Reopening, Revocation and Reissuance, or Termination [326 IAC 2-7-5(6)(C)] [326 IAC 2-7-8(a)] [326 IAC 2-7-9] B.17 Permit Renewal [326 IAC 2-7-4] B.18 Permit Amendment or Modification [326 IAC 2-7-11][326 IAC 2-7-12] B.19 Permit Revision Under Economic Incentives and Other Programs [326 IAC 2-7-5(8)] [326 IAC 2-7-12(b)(2)] B.20 Operational Flexibility [326 IAC 2-7-20] [326 IAC 2-7-10.5] B.21 Source Modification Requirement [326 IAC 2-7-10.5] B.22 Inspection and Entry [326 IAC 2-7-6] [IC 13-14-2-2] [IC 13-30-3-1] B.23 Transfer of Ownership or Operational Control [326 IAC 2-7-11] B.24 Annual Fee Payment [326 IAC 2-7-19] [326 IAC 2-7-5(7)] [326 IAC 2-1.1-7] C SOURCE OPERATION CONDITIONS Emission Limitations and Standards [326 IAC 2-7-5(1)] C.1 Particulate Matter Emission Limitations For Insignificant Units [326 IAC 6-1-1] [326 IAC 6-1-2] C.2 Opacity [326 IAC 5-1] C.3 Open Burning [326 IAC 4-1] [IC 13-17-9] C.4 Incineration [326 IAC 4-2] [326 IAC 9-1-2] C.5 Fugitive Dust Emissions [326 IAC 6-4] C.6 Operation of Equipment [326 IAC 2-7-6(6)] C.7 Stack Height [326 IAC 1-7] C.8 Asbestos Abatement Projects [326 IAC 14-10] [326 IAC 18] [40 CFR 61, Subpart M] Testing Requirements [326 IAC 2-7-6(1)] C.9 Performance Testing [326 IAC 3-6]Rolls Royce Corporation Page 3 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy Compliance Requirements [326 IAC 2-1.1-11] C.10 Compliance Requirements [326 IAC 2-1.1-11] Compliance Monitoring Requirements [326 IAC 2-7-5(1)] [326 IAC 2-7-6(1)] C.11 Compliance Monitoring [326 IAC 2-7-5(3)] [326 IAC 2-7-6(1)] C.12 Monitoring Methods [326 IAC 3] [40 CFR 60] [40 CFR 63] C.13 Pressure Gauge and Other Instrument Specifications [326 IAC 2-1.1-11] [326 IAC 2-7- 5(3)] [326 IAC 2-7-6(1)] Corrective Actions and Response Steps [326 IAC 2-7-5] [326 IAC 2-7-6] C.14 Emergency Reduction Plans [326 IAC 1-5-2] [326 IAC 1-5-3] C.15 Risk Management Plan [326 IAC 2-7-5(12)] [40 CFR 68.215] C.16 Compliance Response Plan - Preparation, Implementation, Records, and Reports [326 IAC 2-7-5] [326 IAC 2-7-6] C.17 Actions Related to Noncompliance Demonstrated by a Stack Test [326 IAC 2-7-5] [326 IAC 2-7-6] Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19] C.18 Emission Statement [326 IAC 2-7-5(3)(C)(iii)] [326 IAC 2-7-5(7)] [326 IAC 2-7-19(c)] [326 IAC 2-6] C.19 General Record Keeping Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-6] C.20 General Reporting Requirements [326 IAC 2-7-5(3)(C)] [326 IAC 2-1.1-11] Stratospheric Ozone Protection C.21 Compliance with 40 CFR 82 and 326 IAC 22-1 Part 2 MACT Application Submittal Requirement C.22 Application Requirements for Section 112(j) of the Clean Air Act [40 CFR 63.52(e)] [40 CFR 63.56(a)] [40 CFR 63.9(b)] [326 IAC 2-7-12]
D.1 FACILITY OPERATION CONDITIONS - Boilers and Gas Turbines Emission Limitations and Standards [326 IAC 2-7-5(1)] D.1.1 Applicability [326 IAC 12-1-1][40 CFR 60, Subpart GG][40 CFR 60, Subpart A] D.1.2 Applicability [326 IAC 12-1-1] [40 CFR 60, Subpart GG] D.1.3 Standards of Performance for Stationary Gas Turbines [326 IAC 12-1-1][40 CFR 60, Subpart GG] D.1.4 Sulfur Content [326 IAC 12-1-1][40 CFR Part 60, Subpart GG] D.1.5 Oxides of Nitrogen (NOx) and Particulate Matter ten microns in aerodynamic diameter (PM10) emissions limits [326 IAC 2-7-5(1)] [326 IAC 2-7-5(1)] [326 IAC 2-2] [40 CFR 52.21] D.1.6 Marion County PM Limitation (PM) [326 IAC 6-1-12] D.1.7 Particulate Matter Emission Limitation (PM) [326 IAC 6-1-2(a)] D.1.8 Sulfur Dioxide Emission Limitation [326 IAC 7-4-2] D.1.9 Preventive Maintenance Plan [326 IAC 2-7-5(13)] Compliance Determination Requirements D.1.10 Sulfur Dioxide Emissions and Sulfur Content [326 IAC 3-6][326 IAC 3-7-4] [326 IAC 7-2-1] D.1.11 Testing Requirements [326 IAC 2-7-6(1),(6)][326 IAC 2-1.1-11] D.1.12 PM, PM-10, and NOx Emissions D.1.13 Sulfur ContentRolls Royce Corporation Page 4 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] D.1.14 Visible Emissions Notations Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19] D.1.15 Record Keeping Requirements D.1.16 Reporting Requirements
D.2 FACILITY OPERATION CONDITIONS -Surface Coating and Cleaning Emission Limitations and Standards [326 IAC 2-7-5(1)] D.2.1 General Provisions Relating to HAPs [326 IAC 20-1-1][40 CFR 63, Subpart A] D.2.2 Applicability [326 IAC 20-15-1] [40 CFR 63, Subpart GG] D.2.3 Standards for Cleaning Operations [40 CFR 63.744] D.2.4 Storage and Handling of Waste [326 IAC 20-15-1] [40 CFR 63, Subpart GG] D.2.5 Spray Gun Cleaning and Coating Operations [326 IAC 20-15-1] [40 CFR 63, Subpart GG] D.2.6 Primer and Topcoat Application Operations [326 IAC 20-15-1] [40 CFR 63, Subpart GG] D.2.7 Control Device Requirements [326 IAC 20-15-1] [40 CFR 63.748, Subpart GG] D.2.8 Compliance Monitoring Requirements for Aerospace Manufacturing and Rework Facilities [326 IAC 20-15] [40 CFR 63.751, Subpart GG] D.2.9 VOC Emissions [326 IAC 8-2-9] D.2.10 Particulate Matter Emissions [326 IAC 6-1-2(a)] D.2.11 Preventive Maintenance Plan [326 IAC 2-7-5(13)] Compliance Determination Requirements D.2.12 Compliance Testing and Procedures for Aerospace Manufacturing and Rework Facilities [326 IAC 20-15] [40 CFR 63.750, Subpart GG] Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19] D.2.13 Record Keeping Requirements D.2.14 Reporting Requirements
D.3 FACILITY OPERATION CONDITIONS - Degreasers Emission Limitations and Standards [326 IAC 2-7-5(1)] D.3.1 General Provisions Relating to HAPs [326 IAC 20-1-1][40 CFR 63, Subpart A] D.3.2 Applicability [326 IAC 20-6-1] [40 CFR Part 63, Subpart T] D.3.3 Halogenated Solvent Cleaning NESHAP [326 IAC 20-6-1][40 CFR Part 63, Subpart T] D.3.4 Halogenated Solvent Cleaning NESHAP [326 IAC 20-6-1][40 CFR Part 63, Subpart T] D.3.5 Degreasing Operations [326 IAC 8-3-2] D.3.6 Degreasing Operations [326 IAC 8-3-3] D.3.7 Degreasing Operations [326 IAC 8-3-5] D.3.8 Degreasing Operations [326 IAC 8-3-6] Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19] D.3.9 Record Keeping Requirements D.3.10 Reporting RequirementsRolls Royce Corporation Page 5 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy D.4 FACILITY OPERATION CONDITIONS - Shot Blasting, Grinding, Sanding and Blasting, and Woodworking Emission Limitations and Standards [326 IAC 2-7-5(1)] D.4.1 Particulate Matter (PM) [326 IAC 6-1-2(a)] D.4.2 General Operation
D.5 FACILITY OPERATION CONDITIONS -Gas Turbine Engines, Stack Heaters, Engine Test Cells Emission Limitations and Standards [326 IAC 2-7-5(1)] D.5.1 Particulate Matter (PM) [326 IAC 6-1-2(a)] D.5.2 Sulfur Dioxide (SO 2 ) [326 IAC 7-1.1-2(a)] D.5.3 PSD Minor NOx Limit [326 IAC 2-2][40 CFR 52.21] Compliance Determination Requirements D.5.4 Sulfur Dioxide Emissions and Sulfur Content Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19] D.5.5 Record Keeping Requirements D.5.6 Reporting Requirements
D.6 FACILITY OPERATION CONDITIONS -Hard Chromium Electroplating Operation Emission Limitations and Standards [326 IAC 2-7-5(1)] D.6.1 General Provisions Relating to HAPs [326 IAC 20-1-1][40 CFR Part 63, Subpart A] D.6.2 Applicability of the Chromium Electroplating and Anodizing NESHAP [326 IAC 20-8- 1][40 CFR Part 63.342] [40 CFR Part 63.344] D.6.3 Chromium Emission Limitation [326 IAC 20-8-1] [40 CFR Part 63, Subpart N] D.6.4 Work Practice Standards [326 IAC 20-8-1][40 CFR 63, Subpart N] D.6.5 Operation and Maintenance Plan [326 IAC 20-8-1][40 CFR 63, Subpart N] D.6.6 Monitoring to Demonstrate Continuous Compliance [326 IAC 20-8-1][40 CFR 63, Subpart N] Compliance Determination Requirements [ 326 IAC 2-1.1-11] [326 IAC 2-7-6(1) D.6.7 Performance Testing [326 IAC 2-1.1-11] [326 IAC 2-7-6(1)] [40 CFR 63.343(b)(2)] [40 CFR 63.7] [40 CFR 63.344] Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19] D.6.8 Record Keeping Requirements D.6.9 Reporting Requirements
D.7 FACILITY OPERATION CONDITIONS -Insignificant Activities Emission Limitations and Standards [326 IAC 2-7-5(1)] D.7.1 Applicability [326 IAC 12-1][40 CFR 60, Subpart Kb] D.7.2 Incinerators [40 CFR 52, Subpart P] D.7.3 Incinerators [326 IAC 4-2] D.7.4 Carbon Monoxide [40 CFR 52, Subpart P] D.7.5 Carbon Monoxide [326 IAC 9-1]Rolls Royce Corporation Page 6 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19] D.7.6 Record Keeping Requirements Certification Emergency Occurrence Report Semi Annual Natural Gas and Landfill Gas Fired Boiler Certification Quarterly Report (PM10) Quarterly Report (Jet Fuel Usage) Quarterly Report (NO x) Chromium Electroplating and Anodizing NESHAP Semi Annual Deviation and Compliance Monitoring Report Attachment A (state rules adopted by reference)Rolls Royce Corporation Page 7 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy SECTION A SOURCE SUMMARY This permit is based on information requested by the Indiana Department of Environmental Management (IDEM), Office of Air Quality (OAQ) and The Indianapolis Office of Environmental Services (OES). The information describing the source contained in conditions A.1 through A.3 is descriptive information and does not constitute enforceable conditions. However, the Permittee should be aware that a physical change or a change in the method of operation that may render this descriptive information obsolete or inaccurate may trigger requirements for the Permittee to obtain additional permits or seek modification of this permit pursuant to 326 IAC 2, or change other applicable requirementspresented in the permit application.
A.1 General Information [326 IAC 2-7-4(c)] [326 IAC 2-7-5(15)] [326 IAC 2-7-1(22)] The Permittee owns and operates a manufacturing and testing source for aerospace engines. Responsible Official: Chief Operating Officer Source Address: Plant 8 - 2001 South Tibbs Ave., Indianapolis, Indiana 46241 Plant 5 - 2355 South Tibbs Ave., Indianapolis, Indiana 46241 Mailing Address: P.O. Box 420 (N-23), Indianapolis, Indiana 46206-0420 Phone Number: 317-230-4141 SIC Code: 3724 County Location: Marion County Status: Attainment for all criteria pollutants Source Status: Part 70 Permit Program Major Source, under PSD; Major Source, Section 112 of the Clean Air Act
A.2 Emission Units and Pollution Control Equipment Summary [326 IAC 2-7-4(c)(3)] [326 IAC 2-7-5(15)] This stationary source consists of the following emission units and pollution control devices: (a) Ten (10) boilers identified below:
EU ID. Unit Identification MMBtu/hr Fuels Permitted to Use Stack Date constructed 0070-01 Babcock & Wilcox

Boiler 88 Natural Gas, Landfill Gas, No. 2 & No. 4 fuel oil 5-1 1942
0070-02 Babcock & Wilcox

Boiler 88 Natural Gas, Landfill Gas, No. 2 & No. 4 fuel oil 5-1 1942
0070-03 Babcock & Wilcox

Boiler 88 Natural Gas, Landfill Gas, No. 2 & No. 4 fuel oil 5-1 1942
0070-04 Babcock & Wilcox

Boiler 88 Natural Gas, Landfill Gas, No. 2 & No. 4 fuel oil 5-1 1942
0070-58 Babcock & Wilcox

Boiler 44 Natural Gas, Landfill Gas, No. 2, No. 4 & No. 6 fuel oil 8-3 1953
0070-59 Babcock & Wilcox

Boiler 44 Natural Gas, Landfill Gas, No. 2, No. 4, & No. 6 fuel oil 8-4 1953
0070-62 Combustion

Engineering Boiler 244 Natural Gas, Landfill Gas, No. 2, No. 4, & No. 6 fuel oil 8-5 1969

0070-63 Combustion

Engineering Boiler 244 Natural Gas, Landfill Gas, No. 2, No. 4, & No. 6 fuel oil 8-6 1969

0070-64 Combustion

Engineering Boiler 244 Natural Gas, Landfill Gas, No. 2, No. 4, & No. 6 fuel oil 8-7 1969
0070-65 Combustion

Engineering Boiler 244 Natural Gas, Landfill Gas, No. 2, No. 4, & No. 6 fuel oil 8-8 1969Rolls Royce Corporation Page 8 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy (b) Five (5) gas turbines identified below:
Emission Unit ID No. Unit Identification Maximum Capacity, MMBtu/hr Fuels Permitted to use Stack No. Date Constructed or last permitted 0070-76 Gas Turbine 51 Natural Gas, Landfill gas 5-22 1999 0070-79 Gas Turbine 48 Natural Gas, Landfill gas 8-79 1999 0070-80 Gas Turbine 68 Natural Gas, Landfill gas 8-80 1999 0070-81 Gas Turbine 80 Natural Gas, Landfill gas 8-81 pending 0070-71 Gas Turbine 35 Natural Gas 8-9 1999 (c) Six paint booths identified as emission units 0070-N56a and 0070-N56b, units 0070- 10a, 0070-10b, 0070-10c, and 0070-10d, controlled by dry filters, exhausting out stacks identified as SN56 a & b, 5-10a, 5-10b, 5-10c, and 5-10d respectively. These paint booths were installed prior to 1974 and modified in 1998 to comply with the aerospace NESHAPs. (d) Facility-wide wipe cleaning operations. (e) Degreasing operations, constructed prior to 1990, consisting of: (1) Two (2) Open Top Vapor Degreasers, identified as emission units 0070-13 and 0070-31, using perchloroethylene as the solvent, exhausting inside the building and reconstructed in 1997. (2) One (1) Open Top Vapor Degreasers, identified as emission units 0311-82 is permitted to use N-Propyl Bromide and Perchlorethylene as the solvent, exhausting inside the building and reconstructed in 2000. (3) Portable Cold Cleaner Degreasing Tanks, used for degreasing parts, identified as emission unit 0070-12, using mineral spirits as the solvent and exhausting into the building. (4) Spray cleaning booths, identified as emission unit 0070-14, using mineral spirts as the solvent and exhausting outside the building. (f) Miscellaneous sand and shot Blast Machines operations identified as: (1) Emission unit 0070-08, shot blasting, each controlled by a baghouse, exhausting out stack 5-8, constructed in 1964. (2) Emission unit 0070-N55, miscellaneous sanding and blasting, controlled by dust collector, exhausting out stack SN55, constructed in 1991. (3) Emission unit 0070-74, sand blasting, controlled by a baghouse, exhausting out stack 8-18, constructed prior to 1969. (g) Woodworking operations, prior to 1969, consisting of: (1) Emission unit 0070-72, controlled by dust collector, exhausting out stack 8-16, (2) Emission unit 0070-73, controlled by dust collector, exhausting out stack 8-17,Rolls Royce Corporation Page 9 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

(3) Emission unit 0070-05, controlled by dust collector, exhausting out stack 5-8. (h) Jet fueled turbine engines, constructed in 1955, identified as follows: (1) Two (2) emission units identified as 0070-66, with a maximum operating capacity of 107 million British thermal units per hour each, exhausting out stacks identified as 8-11A and 8-11B; (2) Twelve (12) emission units identified as 0070-67, with a maximum operating capacity of 27.2 million British thermal units per hour each, exhausting out stacks identified 8-13A through M respectively. (3) Ten (10) emission units identified as 0070-68, with a maximum operating capacity of 27.2 million British thermal units per hour each, exhausting out stacks identified as 8-12A through J. (4) Four (4) emission units identified as 0070-69, with a maximum operating capacity of 27.2 million British thermal per hour units each, exhausting out stacks identified as 8-14A through D. (i) Three (3) American Shack Heaters, identified as emission unit 0070-70, exhausting out stacks identified 8-6 A through C consisting of: (1) Two of the heaters are capable of being fired with distillate oil only and have a maximum heating put capacity of 93.4 million British thermal units per hour each; and (2) One of the heater is capable of being fired with either natural gas or distillate fuel and has a maximum heat input capacity of 90 million British thermal units per hour. (j) Fifty three (53) Engine test stand cells identified below. These test stand cells are used to test engines manufactured at the source. The engines tested are fueled by either Jet fuel, Diesel #2 or Natural Gas. All test stand cells were constructed prior to 1977. Engine Test Cells - Plant 5 Emission Unit ID No. Engine Test

Cell ID Maximum Test Cell

Capacity Type of Fuels Used Stack ID

0070-N3 109 5000 brake horsepower Jet fuel, Diesel SN3 0070-N4 111 10000 pounds of thrust Jet fuel SN4 0070-N5 113 10000 brake horsepower Jet fuel, Diesel & Natural Gas SN5

0070-N6 114 30000 pounds of thrust Jet fuel SN6 0070-N7 115 7000 brake horsepower Jet fuel, Diesel & Natural Gas SN7 0070-N8 116 5000 brake horsepower Jet fuel, Diesel SN8 0070-N9 117 5000 brake horsepower Jet fuel, Diesel SN9 0070-N10 118 5000 brake horsepower Jet fuel, Diesel SN10Rolls Royce Corporation Page 10 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

Engine Test Cells - Plant 5 Emission Unit ID No. Engine Test

Cell ID Maximum Test Cell

Capacity Type of Fuels Used Stack ID

0070-N11 119 5000 brake horsepower Jet fuel, Diesel & Natural Gas SN11 0070-N12 120 7000 brake horsepower Jet fuel, Diesel & Natural Gas SN12 0070-N13 121 10000 brake horsepower Jet fuel, Diesel SN13

0070-N14 122 9000 brake horsepower Jet fuel, Diesel SN14 0070-N15 123 5000 brake horsepower Jet fuel, Diesel & Natural Gas SN15 0070-N16 140 1500 brake horsepower Jet fuel SN16 0070-N17 141 750 brake horsepower Jet fuel SN17 0070-N18 142 800 brake horsepower Jet fuel SN18 0070-N19 143 750 brake horsepower Jet fuel SN19 0070-N20 144 750 brake horsepower Jet fuel SN20 0070-N21 145 750 brake horsepower Jet fuel SN21 0070-N22 146 1500 brake horsepower Jet fuel SN22 0070-N23 147 1500 brake horsepower Jet fuel SN23 0070-N24 148 1500 brake horsepower Jet fuel SN24 0070-N25 149 650 brake horsepower Jet fuel SN25 0070-N27 152 1500 brake horsepower Jet fuel SN27

Engine Test Cells - Plant 8

Emission Unit ID Engine

Test Cell Maximum Test Cell

Capacity Type of Fuels Used Stack ID

0070-N34 843 10000 brake horsepower Jet fuel SN34(A,B) 0070-N35 861 9000 pounds of thrust Jet fuel, Diesel SN35 0070-N36 862 6000 brake horsepower Jet fuel, Diesel SN36 0070-N37 871 15000 brake horsepower Jet fuel, Diesel & Natural Gas SN37(A,B) 0070-N38 872 9000 brake horsepower Jet fuel, Diesel & Natural Gas SN38(A,B) 0070-N39 873 6000 brake horsepower Jet fuel SN39(A,B,C)Rolls Royce Corporation Page 11 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

0070-N40 875 5000 brake horsepower Diesel SN40 0070-N41 881 10000 pounds of thrust Jet fuel SN41(A,B) 0070-N42 882 30000 pounds of thrust Jet fuel SN42(A,B,C,D,E,F) 0070-N43 883 2500 brake horsepower Jet fuel SN43(A,B) 0070-N44 884 2000 brake horsepower Jet fuel SN44 Engine Test Cells - Plant 8 Emission Unit ID Engine

Test Cell Maximum Test Cell

Capacity Type of Fuels Used Stack ID

0070-N45 885 800 brake horsepower Jet fuel, Diesel SN45(A,B) 0070-N46 886 30000 pounds of thrust Jet fuel, Diesel SN46(A,B,C,D) 0070-N47 893 500 pounds of thrust Diesel SN47 0070-N48 894 350 brake horsepower Diesel SN48 0070-N29 821 10 pounds/second air Jet fuel, Diesel & Natural Gas SN29(A,B) 0070- N29a 821 8 MMBtu/hr No. 2 Diesel fuel SN29C

0070-N30 822 50 pounds/second air Jet fuel, Diesel & Natural Gas SN30(A,B) 0070- N30a 822 8 MMBtu/hr No. 2 Diesel fuel SN30C

0070-N31 823 60 pounds/second air Jet fuel, Diesel & Natural Gas SN31(A,B) 0070- N31a 823 8 MMBtu/hr No. 2 Diesel fuel SN31C

0070-N32 824 90 pounds/second air Jet fuel, Diesel & Natural Gas SN32(A,B) 0070- N32a 824 8 MMBtu/hr No. 2 Diesel fuel SN32C

0070-N33 826 10 pounds/second air Jet fuel, Diesel SN33(A,B) 0070- N33a 826 8 MMBtu/hr No. 2 Diesel fuel SN33C

0070-54 8137 10 pounds/second air Jet fuel, Diesel & Natural Gas SN54 0070- N54a 8137 12.5 MMBtu/hr No. 2 Diesel fuel Not Available

0070-N55 8126 0.5 pounds/second air Jet fuel, Diesel & Natural Gas Not Available 0070-N56 8128 1 pounds/second air Jet fuel, Diesel & Natural Gas Not AvailableRolls Royce Corporation Page 12 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

(k) One (1) engine test cell, identified as emission unit 00311-83. The engines tested in this test cell have a operating capacity of 10,000 pounds of thrust and are fired with Jet A fuel. A maximum of six engines per day can be tested in this test cell. Emissions from this test cell are exhausted out stack 5-83 and are not controlled. This emission unit was initially constructed prior to 1970 and modified in 1999. (l) Chrome plating and anodizing line consisting of seven (7) chromium tanks (six hard chrome electroplating tanks and one anodizing tank), identified as 0070-99, with a common add-on air pollution control device with a maximum cumulative potential rectifier capacity of less than 60 million amp-hr/yr, controlled using a composite mesh pad system, identified as ID 253155, which exhausts out stack 5-99. This facility was installed October 6, 1997 consisting of: (1) Six (6) hard chrome electroplating tanks 1-11, 1-12, 1-13, 1-14, 1-15, 1-16 and (2) One (1) anodizing tank 2-20. A.3 Specifically Regulated Insignificant Activities [326 IAC 2-7-1(21)] [326 IAC 2-7-4(c)] [326 IAC 2-7-5(15)] This stationary source also includes the following insignificant activities which are specifically regulated, as defined in 326 IAC 2-7-1(21): Storage vessels, containing volatile organic liquid, identified as tank 1 through 6 and 9 through 20 at plant 5 and tanks 1 through 5 at plant 8. Each tank has a capacity greater than 40 cubic meters but less than 75 cubic meters and a construction date after July 23, 1984. [40 CFR 60, Subpart Kb] Classified documents incinerator with a maximum rated capacity of 125 pounds per two hour cycle. [40 CFR 52, Subpart P] [326 IAC 4-2] [326 IAC 9-1]
A.4 Part 70 Permit Applicability [326 IAC 2-7-2] This stationary source is required to have a Part 70 permit by 326 IAC 2-7-2 (Applicability) because: (a) It is a major source, as defined in 326 IAC 2-7-1(22); (b) It is a source in a source category designated by the United States Environmental Protection Agency (U.S. EPA) under 40 CFR 70.3 (Part 70 - Applicability).Rolls Royce Corporation Page 13 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy SECTION B GENERAL CONDITIONS
B.1 Definitions [326 IAC 2-7-1] Terms in this permit shall have the definition assigned to such terms in the referenced regulation. In the absence of definitions in the referenced regulation, the applicable definitions found in the statutes or regulations (IC 13-11, 326 IAC 1-2 and 326 IAC 2-7) shall prevail.
B.2 Permit Term [326 IAC 2-7-5(2)] [326 IAC 2-1.1-9.5] This permit is issued for a fixed term of five (5) years from the issuance date of this permit, as determined in accordance with IC 4-21.5-3-5(f) and IC 13-15-5-3. Subsequent revisions, modifications, or amendments of this permit do not affect the expiration date. B.3 Enforceability [326 IAC 2-7-7] (a) Unless otherwise stated, all terms and conditions in this permit, including any provisions designed to limit the source's potential to emit, are enforceable by IDEM and OES, the United States Environmental Protection Agency (U.S. EPA) and by citizens in accordance with the Clean Air Act. (b) The Indianapolis Air Pollution Control Board (IAPCB) has adopted by reference state rules listed in Attachment A of this permit. The version adopted by reference includes all amendments, additions and repeals filed with the Secretary of State through August 10, 1997 and published in the Indiana Register September 1, 1997, unless otherwise indicated in the adoption by reference. For the purposes of this permit, all state rules adopted by reference by the IAPCB are enforceable by OES using local enforcement procedures. Unless otherwise stated, all terms and conditions in this permit that are local requirements, including any provisions designed to limit the source's potential to emit, are enforceable by OES.
B.4 Termination of Right to Operate [326 IAC 2-7-10] [326 IAC 2-7-4(a)] The Permittee's right to operate this source terminates with the expiration of this permit unless a timely and complete renewal application is submitted at least nine (9) months prior to the date of expiration of the source’s existing permit, consistent with 326 IAC 2-7-3 and 326 IAC 2-7-4(a).
B.5 Severability [326 IAC 2-7-5(5)] The provisions of this permit are severable; a determination that any portion of this permit is invalid shall not affect the validity of the remainder of the permit. B.6 Property Rights or Exclusive Privilege [326 IAC 2-7-5(6)(D)] This permit does not convey any property rights of any sort or any exclusive privilege.
B.7 Duty to Provide Information [326 IAC 2-7-5(6)(E)] (a) The Permittee shall furnish to IDEM, OAQ, and OES within a reasonable time, any information that IDEM, OAQ, and OES may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit, or to determine compliance with this permit. The submittal by the Permittee does require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). Upon request, the Permittee shall also furnish to IDEM, OAQ, and OES copies of records required to be kept by this permit. (b) For information furnished by the Permittee to IDEM, OAQ, the Permittee may include a claim of confidentiality in accordance with 326 IAC 17.1. When furnishing copies of requested records directly to U. S. EPA, the Permittee may assert a claim of confidentiality in accordance with 40 CFR 2, Subpart B.Rolls Royce Corporation Page 14 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

B.8 Compliance with Permit Conditions [326 IAC 2-7-5(6)(A)] [326 IAC 2-7-5(6)(B)] (a) The Permittee must comply with all conditions of this permit. Noncompliance with any provisions of this permit, except those specifically designated as not federally enforceable, constitutes a violation of the Clean Air Act and is grounds for: (1) Enforcement action; (2) Permit termination, revocation and reissuance, or modification; or (3) Denial of a permit renewal application. (b) It shall not be a defense for the Permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit. (c) An emergency does constitute an affirmative defense in an enforcement action provided the Permittee complies with the applicable requirements set forth in Section B, Emergency Provisions. B.9 Certification [326 IAC 2-7-4(f)] [326 IAC 2-7-6(1)] [326 IAC 2-7-5(3)(C)] (a) Where specifically designated by this permit or required by an applicable requirement, any application form, report, or compliance certification submitted shall contain certification by a responsible official of truth, accuracy, and completeness. This certification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete. (b) One (1) certification shall be included, using the attached Certification Form, with each submittal requiring certification. (c) A responsible official is defined at 326 IAC 2-7-1(34). B.10 Annual Compliance Certification [326 IAC 2-7-6(5)] (a) The Permittee shall annually submit a compliance certification report which addresses the status of the source’s compliance with the terms and conditions contained in this permit, including emission limitations, standards, or work practices. The initial certification shall cover the time period from the date of final permit issuance through December 31 of the same year. All subsequent certifications shall cover the time period from January 1 to December 31 of the previous year, and shall be submitted in letter form no later than April 15 of each year to: Indiana Department of Environmental Management Compliance Data Section, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015
and Office of Environmental Services Air Quality Management Section, Data Compliance 2700 South Belmont Avenue Indianapolis, Indiana 46221Rolls Royce Corporation Page 15 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

and United States Environmental Protection Agency, Region V Air and Radiation Division, Air Enforcement Branch - Indiana (AE-17J) 77 West Jackson Boulevard Chicago, Illinois 60604-3590 (b) The annual compliance certification report required by this permit shall be considered timely if the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means, it shall be considered timely if received by IDEM, OAQ, and OES on or before the date it is due. (c) The annual compliance certification report shall include the following: (1) The appropriate identification of each term or condition of this permit that is the basis of the certification; (2) The compliance status; (3) Whether compliance was continuous or intermittent; (4) The methods used for determining the compliance status of the source, currently and over the reporting period consistent with 326 IAC 2-7-5(3); and (5) Such other facts, as specified in Sections D of this permit, as IDEM, OAQ, and OES may require to determine the compliance status of the source. The submittal by the Permittee does require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34).
B.11 Preventive Maintenance Plan [326 IAC 2-7-5(1),(3) and (13)] [326 IAC 2-7-6(1) and (6)] [326 IAC 1-6-3] (a) If required by specific condition(s) in Section D of this permit, the Permittee shall prepare and maintain Preventive Maintenance Plans (PMPs) within ninety (90) days after issuance of this permit, including the following information on each facility: (1) Identification of the individual(s) responsible for inspecting, maintaining, and repairing emission control devices; (2) A description of the items or conditions that will be inspected and the inspection schedule for said items or conditions; and (3) Identification and quantification of the replacement parts that will be maintained in inventory for quick replacement. If, due to circumstances beyond the Permittee’s control, the PMPs cannot be prepared and maintained within the above time frame, the Permittee may extend the date an additional ninety (90) days provided the Permittee notifies:Rolls Royce Corporation Page 16 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

Indiana Department of Environmental Management Compliance Branch, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015
and Office of Environmental Services Air Quality Management Section, Data Compliance 2700 South Belmont Avenue Indianapolis, Indiana 46221 The PMP extension notification does not require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). (b) The Permittee shall implement the PMPs, including any required record keeping, as necessary to ensure that failure to implement a PMP does not cause or contribute to an exceedance of any limitation on emissions or potential to emit. (c) A copy of the PMPs shall be submitted to IDEM, OAQ, and OES upon request and within a reasonable time, and shall be subject to review and approval by IDEM, OAQ, and OES. IDEM, OAQ, and OES may require the Permittee to revise its PMPs whenever lack of proper maintenance causes or is the primary contributor to an exceedance of any limitation on emissions or potential to emit. The PMP does not require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). (d) To the extent the Permittee is required by 40 CFR Part 60/63 to have an Operation, Maintenance, and Monitoring (OMM) Plan for a unit, such Plan is deemed to satisfy the PMP requirements of 326 IAC 1-6-3 for that unit.
B.12 Emergency Provisions [326 IAC 2-7-16] (a) An emergency, as defined in 326 IAC 2-7-1(12), is not an affirmative defense for an action brought for noncompliance with a federal or state health-based emission limitation. (b) An emergency, as defined in 326 IAC 2-7-1(12), constitutes an affirmative defense to an action brought for noncompliance with a technology-based emission limitation if the affirmative defense of an emergency is demonstrated through properly signed, contemporaneous operating logs or other relevant evidence that describe the following: (1) An emergency occurred and the Permittee can, to the extent possible, identify the causes of the emergency; (2) The permitted facility was at the time being properly operated; (3) During the period of an emergency, the Permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards or other requirements in this permit; (4) For each emergency lasting one (1) hour or more, the Permittee notified IDEM, OAQ, and OES within four (4) daytime business hours after the beginning of the emergency, or after the emergency was discovered or reasonably should have been discovered;Rolls Royce Corporation Page 17 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

Telephone Number: 1-800-451-6027 (ask for Office of Air Quality, Compliance Section), or Telephone Number: 317-233-5674 (ask for Compliance Section) Facsimile Number: 317-233-5967 OES Telephone No.: 317-327-2234 (ask for Data Compliance) Facsimile No.: 317-327-2274 (5) For each emergency lasting one (1) hour or more, the Permittee submitted the attached Emergency Occurrence Report Form or its equivalent, either by mail or facsimile to: Indiana Department of Environmental Management Compliance Branch, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015
and Office of Environmental Services Air Quality Management Section, Data Compliance 2700 South Belmont Avenue Indianapolis, Indiana 46221 within two (2) working days of the time when emission limitations were exceeded due to the emergency. The notice fulfills the requirement of 326 IAC 2-7-5(3)(C)(ii) and must contain the following: (A) A description of the emergency; (B) Any steps taken to mitigate the emissions; and (C) Corrective actions taken. The notification which shall be submitted by the Permittee does not require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). (6) The Permittee immediately took all reasonable steps to correct the emergency. (c) In any enforcement proceeding, the Permittee seeking to establish the occurrence of an emergency has the burden of proof. (d) This emergency provision supersedes 326 IAC 1-6 (Malfunctions). This permit condition is in addition to any emergency or upset provision contained in any applicable requirement. (e) IDEM, OAQ, and/or OES may require that the Preventive Maintenance Plans required under 326 IAC 2-7-4-(c)(9) be revised in response to an emergency.Rolls Royce Corporation Page 18 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy (f) Failure to notify IDEM, OAQ, and OES by telephone or facsimile of an emergency lasting more than one (1) hour in accordance with (b)(4) and (5) of this condition shall constitute a violation of 326 IAC 2-7 and any other applicable rules. (g) If the emergency situation causes a deviation from a technology-based limit, the Permittee may continue to operate the affected emitting facilities during the emergency provided the Permittee immediately takes all reasonable steps to correct the emergency and minimize emissions. (h) The Permittee shall include all emergencies in the Quarterly Deviation and Compliance Monitoring Report. B.13 Permit Shield [326 IAC 2-7-15] [326 IAC 2-7-20] [326 IAC 2-7-12] (a) Pursuant to 326 IAC 2-7-15, the Permittee has been granted a permit shield. The permit shield provides that compliance with the conditions of this permit shall be deemed in compliance with any applicable requirements as of the date of permit issuance, provided that either the applicable requirements are included and specifically identified in this permit or the permit contains an explicit determination or concise summary of a determination that other specifically identified requirements are not applicable. The Indiana statutes from IC 13 and rules from 326 IAC, referenced in conditions in this permit, are those applicable at the time the permit was issued. The issuance or possession of this permit shall not alone constitute a defense against an alleged violation of any law, regulation or standard, except for the requirement to obtain a Part 70 permit under 326 IAC 2-7 or for applicable requirements for which a permit shield has been granted. This permit shield does not extend to applicable requirements which are promulgated after the date of issuance of this permit unless this permit has been modified to reflect such new requirements. (b) In addition to the nonapplicability determinations set forth in Sections D of this permit, the IDEM, OAQ has made the following determinations regarding this source: (1) None of the facilities listed in Section A, Emission Units and Pollution Control Equipment Summary are subject to the requirements of the following: (A) 40 CFR Part 63, Subpart JJ, Wood Furniture Surface Coating NESHAPs does not apply to the maintenance coating operations, since they do not manufacture wood furniture. (B) 40 CFR Part 63, Subpart KK, National Emission Standards for the Printing and Publishing Industry, does not apply to the print shop operations, since none of the operations is a publication rotogravure, product or packaging rotogravure, or a wide-web flexographic printing o peration. (C) 326 IAC 8-2-12, Wood Surface Coating, since the maintenance coating operations do not surface coat wood furnishings. (D) 326 IAC 8-1-6 does not apply to the printing and wood surface coating operations, since these operations were consyructed prior to January, 1980, and since each has a potential to emit less than 25 tons/year. (E) 326 IAC 6-5, Fugitive Dust Control Plan does not apply to this source, since the potential to emit from fugitive dust sources does not exceed 25 tons/year.Rolls Royce Corporation Page 19 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy (F) 40 CFR Part 60, Subpart Db, Standards of Performance for IndustrialCommercial-Institutional Steam Generating Units does not apply to Emission Units 0070-62, 0070-63,0070-64 and 0070-65, since these boilers were constructed prior to June 19, 1984. (G) 40 CFR Part 60, Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units does not apply to Emission Units0070-01, 0070-02, 0070-03, 0070-04, 0070-58, and 0070-59, since these boilers were constructed prior to June 9, 1989. (c) If, after issuance of this permit, it is determined that the permit is in nonconformance with an applicable requirement that applied to the source on the date of permit issuance, IDEM, OAQ, or OES shall immediately take steps to reopen and revise this permit and issue a compliance order to the Permittee to ensure expeditious compliance with the applicable requirement until the permit is reissued. The permit shield shall continue in effect so long as the Permittee is in compliance with the compliance order. (d) No permit shield shall apply to any permit term or condition that is determined after issuance of this permit to have been based on erroneous information supplied in the permit application. Erroneous information means information that the Permittee knew to be false, or in the exercise of reasonable care should have been known to be false, at the time the information was submitted. (e) Nothing in 326 IAC 2-7-15 or in this permit shall alter or affect the following: (1) The provisions of Section 303 of the Clean Air Act (emergency orders), including the authority of the U.S. EPA under Section 303 of the Clean Air Act; (2) The liability of the Permittee for any violation of applicable requirements prior to or at the time of this permit's issuance; (3) The applicable requirements of the acid rain program, consistent with Section 408(a) of the Clean Air Act; and (4) The ability of U.S. EPA to obtain information from the Permittee under Section 114 of the Clean Air Act. (f) This permit shield is not applicable to any change made under 326 IAC 2-7-20(b)(2) (Sections 502(b)(10) of the Clean Air Act changes) and 326 IAC 2-7-20(c)(2) (trading based on State Implementation Plan (SIP) provisions). (g) This permit shield is not applicable to modifications eligible for group processing until after IDEM, OAQ, or OES has issued the modifications. [326 IAC 2-7-12(c)(7)] (h) This permit shield is not applicable to minor Part 70 permit modifications until after IDEM, OAQ, or OES has issued the modification. [326 IAC 2-7-12(b)(8)]
B.14 Prior Permits Superseded [326 IAC 2-1.1-9.5] (a) All terms and conditions of previous permits issued pursuant to permitting programs approved into the state implementation plan have been either (1) incorporated as originally stated,Rolls Royce Corporation Page 20 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

(2) revised, or (3) deleted by this permit. (b) All previous registrations and permits are superseded by this permit. B.15 Deviations from Permit Requirements and Conditions [326 IAC 2-7-5(3)(C)(ii)] (a) Deviations from any permit requirements (for emergencies see Section B - Emergency Provisions), the probable cause of such deviations, and any response steps or preventive measures taken shall be reported to: Indiana Department of Environmental Management Compliance Data Section, Office of Air Quality 100 North Senate Avenue, P.O. Box 6015 Indianapolis, Indiana 46206-6015
and Office of Environmental Services Air Quality Management Section, Data Compliance 2700 South Belmont Avenue Indianapolis, Indiana 46221 using the attached Semi Annual Deviation and Compliance Monitoring Report, or its equivalent. A deviation required to be reported pursuant to an applicable requirement that exists independent of this permit, shall be reported according to the schedule stated in the applicable requirement and does not need to be included in this report. The Semi Annual Deviation and Compliance Monitoring Report does require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). (b) A deviation is an exceedance of a permit limitation or a failure to comply with a requirement of the permit. B.16 Permit Modification, Reopening, Revocation and Reissuance, or Termination [326 IAC 2-7-5(6)(C)] [326 IAC 2-7-8(a)] [326 IAC 2-7-9] (a) This permit may be modified, reopened, revoked and reissued, or terminated for cause. The filing of a request by the Permittee for a Part 70 permit modification, revocation and reissuance, or termination, or of a notification of planned changes or anticipated noncompliance does not stay any condition of this permit. [326 IAC 2-7-5(6)(C)] The notification by the Permittee does require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). (b) This permit shall be reopened and revised under any of the circumstances listed in IC 13-15-7-2 or if IDEM, OAQ, or OES determines any of the following: (1) That this permit contains a material mistake. (2) That inaccurate statements were made in establishing the emissions standards or other terms or conditions. (3) That this permit must be revised or revoked to assure compliance with an applicable requirement. [326 IAC 2-7-9(a)(3)]Rolls Royce Corporation Page 21 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

(c) Proceedings by IDEM, OAQ, or OES to reopen and revise this permit shall follow the same procedures as apply to initial permit issuance and shall affect only those parts of this permit for which cause to reopen exists. Such reopening and revision shall be made as expeditiously as practicable. [326 IAC 2-7-9(b)] (d) The reopening and revision of this permit, under 326 IAC 2-7-9(a), shall not be initiated before notice of such intent is provided to the Permittee by IDEM, OAQ, or OES at least thirty (30) days in advance of the date this permit is to be reopened, except that IDEM, OAQ, or OES may provide a shorter time period in the case of an emergency. [326 IAC 2-7-9(c)]
B.17 Permit Renewal [326 IAC 2-7-4] (a) The application for renewal shall be submitted using the application form or forms prescribed by IDEM, OAQ, and OES and shall include the information specified in 326 IAC 2-7-4. Such information shall be included in the application for each emission unit at this source, except those emission units included on the trivial or insignificant activities list contained in 326 IAC 2-7-1(21) and 326 IAC 2-7-1(40). The renewal application does require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). Request for renewal shall be submitted to: Indiana Department of Environmental Management Permits Branch, Office of Air Quality 100 North Senate Avenue, P.O. Box 6015 Indianapolis, Indiana 46206-6015
and Office of Environmental Services Air Quality Management Section, Permits 2700 South Belmont Avenue Indianapolis, Indiana 46221 (b) Timely Submittal of Permit Renewal [326 IAC 2-7-4(a)(1)(D)] (1) A timely renewal application is one that is: (A) Submitted at least nine (9) months prior to the date of the expiration of this permit; and (B) If the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means, it shall be considered timely if received by IDEM, OAQ, and OES on or before the date it is due. (2) If IDEM, OAQ, and OES, upon receiving a timely and complete permit application, fails to issue or deny the permit renewal prior to the expiration date of this permit, this existing permit shall not expire and all terms and conditions shall continue in effect, including any permit shield provided in 326 IAC 2-7-15, until the renewal permit has been issued or denied.Rolls Royce Corporation Page 22 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy (c) Right to Operate After Application for Renewal [326 IAC 2-7-3] If the Permittee submits a timely and complete application for renewal of this permit, the source’s failure to have a permit is not a violation of 326 IAC 2-7 until IDEM, OAQ, and OES, takes final action on the renewal application, except that this protection shall cease to apply if, subsequent to the completeness determination, the Permittee fails to submit by the deadline specified in writing by IDEM, OAQ, and OES, any additional information identified as being needed to process the application. (d) United States Environmental Protection Agency Authority [326 IAC 2-7-8(e)] If IDEM, OAQ, and OES fails to act in a timely way on a Part 70 permit renewal, the U.S. EPA may invoke its authority under Section 505(e) of the Clean Air Act to terminate or revoke and reissue a Part 70 permit. B.18 Permit Amendment or Modification [326 IAC 2-7-11] [326 IAC 2-7-12] (a) Permit amendments and modifications are governed by the requirements of 326 IAC 2- 7-11 or 326 IAC 2-7-12 whenever the Permittee seeks to amend or modify this permit. (b) Any application requesting an amendment or modification of this permit shall be submitted to: Indiana Department of Environmental Management Permits Branch, Office of Air Quality 100 North Senate Avenue, P.O. Box 6015 Indianapolis, Indiana 46206-6015
and Office of Environmental Services Air Quality Management Section, Permits 2700 South Belmont Avenue Indianapolis, Indiana 46221 Any such application should be certified by the “responsible official” as defined by 326 IAC 2-7-1(34). (c) The Permittee may implement administrative amendment changes addressed in the request for an administrative amendment immediately upon submittal of the request. [326 IAC 2-7-11(c)(3)] (d) No permit amendment or modification is required for the addition, operation or removal of a nonroad engine, as defined in 40 CFR 89.2. B.19 Permit Revision Under Economic Incentives and Other Programs [326 IAC 2-7-5(8)] [326 IAC 2-7-12 (b)(2)] (a) No Part 70 permit revision shall be required under any approved economic incentives, marketable Part 70 permits, emissions trading, and other similar programs or processes for changes that are provided for in a Part 70 permit. (b) Notwithstanding 326 IAC 2-7-12(b)(1) and 326 IAC 2-7-12(c)(1), minor Part 70 permit modification procedures may be used for Part 70 modifications involving the use of economic incentives, marketable Part 70 permits, emissions trading, and other similar approaches to the extent that such minor Part 70 permit modification procedures are explicitly provided for in the applicable State Implementation Plan (SIP) or in applicable requirements promulgated or approved by the U.S. EPA.Rolls Royce Corporation Page 23 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

B.20 Operational Flexibility [326 IAC 2-7-20] [326 IAC 2-7-10.5] (a) The Permittee may make any change or changes at the source that are described in 326 IAC 2-7-20(b), (c), or (e), without a prior permit revision, if each of the following conditions is met: (1) The changes are not modifications under any provision of Title I of the Clean Air Act; (2) Any preconstruction approval required by 326 IAC 2-7-10.5 has been obtained; (3) The changes do not result in emissions which exceed the emissions allowable under this permit (whether expressed herein as a rate of emissions or in terms of total emissions); (4) The Permittee notifies the: Indiana Department of Environmental Management Permits Branch, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015
and Office of Environmental Services Air Quality Management Section, Permits 2700 South Belmont Avenue Indianapolis, Indiana 46221
and United States Environmental Protection Agency, Region V Air and Radiation Division, Regulation Development Branch - Indiana (AR-18J) 77 West Jackson Boulevard Chicago, Illinois 60604-3590 in advance of the change by written notification at least ten (10) days in advance of the proposed change. The Permittee shall attach every such notice to the Permittee's copy of this permit; and (5) The Permittee maintains records on-site which document, on a rolling five (5) year basis, all such changes and emissions trading that are subject to 326 IAC 2-7-20(b), (c), or (e) and makes such records available, upon reasonable request, for public review. Such records shall consist of all information required to be submitted to IDEM, OAQ, and OES in the notices specified in 326 IAC 2-7-20(b)(1), (c)(1), and (e)(2). (b) The Permittee may make Section 502(b)(10) of the Clean Air Act changes (this term is defined at 326 IAC 2-7-1(36)) without a permit revision, subject to the constraint of 326 IAC 2-7-20(a). For each such Section 502(b)(10) of the Clean Air Act change, the required written notification shall include the following: (1) A brief description of the change within the source; (2) The date on which the change will occur;Rolls Royce Corporation Page 24 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

(3) Any change in emissions; and (4) Any permit term or condition that is no longer applicable as a result of the change. The notification which shall be submitted is not considered an application form, report or compliance certification. Therefore, the notification by the Permittee does not require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). (c) Emission Trades [326 IAC 2-7-20(c)] The Permittee may trade increases and decreases in emissions in the source, where the applicable SIP provides for such emission trades without requiring a permit revision, subject to the constraints of Section (a) of this condition and those in 326 IAC 2-7-20(c). (d) Alternative Operating Scenarios [326 IAC 2-7-20(d)] The Permittee may make changes at the source within the range of alternative operating scenarios that are described in the terms and conditions of this permit in accordance with 326 IAC 2-7-5(9). No prior notification of IDEM, OAQ, or U.S. EPA is required.
B.21 Source Modification Requirement [326 IAC 2-7-10.5] A modification, construction, or reconstruction is governed by the requirements of 326 IAC 2 and 326 IAC 2-7-10.5.
B.22 Inspection and Entry [326 IAC 2-7-6] [IC 13-14-2-2] [IC 13-30-3-1] Upon presentation of proper identification cards, credentials, and other documents as may be required by law, and subject to the Permittee’s right under all applicable laws and regulations to assert that the information collected by the agency is confidential and entitled to be treated as such, the Permittee shall allow IDEM, OAQ, OES, U.S. EPA, or an authorized representative to perform the following: (a) Enter upon the Permittee's premises where a Part 70 source is located, or emissions related activity is conducted, or where records must be kept under the conditions of this permit; (b) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, have access to and copy any records that must be kept under the conditions of this permit; (c) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, inspect any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this permit; (d) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, sample or monitor substances or parameters for the purpose of assuring compliance with this permit or applicable requirements; and (e) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, utilize any photographic, recording, testing, monitoring, or other equipment for the purpose of assuring compliance with this permit or applicable requirements. B.23 Transfer of Ownership or Operational Control [326 IAC 2-7-11] (a) The Permittee must comply with the requirements of 326 IAC 2-7-11 whenever the Permittee seeks to change the ownership or operational control of the source and no other change in the permit is necessary.Rolls Royce Corporation Page 25 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy (b) Any application requesting a change in the ownership or operational control of the source shall contain a written agreement containing a specific date for transfer of permit responsibility, coverage and liability between the current and new Permittee. The application shall be submitted to: Indiana Department of Environmental Management Permits Branch, Office of Air Quality 100 North Senate Avenue, P.O. Box 6015 Indianapolis, Indiana 46206-6015
and Office of Environmental Services Air Quality Management Section, Permits 2700 South Belmont Avenue Indianapolis, Indiana 46221 The application which shall be submitted by the Permittee does require the certification by the "responsible official" as defined by 326 IAC 2-7-1(34). (c) The Permittee may implement administrative amendment changes addressed in the request for an administrative amendment immediately upon submittal of the request. [326 IAC 2-7-11(c)(3)]
B.24 Annual Fee Payment [326 IAC 2-7-19] [326 IAC 2-7-5(7)] [326 IAC 2-1.1-7] (a) The Permittee shall pay annual fees to IDEM, OAQ, and OES within thirty (30) calendar days of receipt of a billing. Pursuant 326 IAC 2-7-19(b), if the Permittee does not receive a bill from IDEM, OAQ, or OES the applicable fee is due April 1 of each year. (b) Except as provided in 326 IAC 2-7-19(e), failure to pay may result in administrative enforcement action or revocation of this permit. (c) The Permittee may call the following telephone numbers: 1-800-451-6027 or 317-233- 4230 (ask for OAQ, I/M & Billing Section), to determine the appropriate permit fee.Rolls Royce Corporation Page 26 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy SECTION C SOURCE OPERATION CONDITIONS

Entire Source Emission Limitations and Standards [326 IAC 2-7-5(1)] C.1 Particulate Matter Emission Limitations for Insignificant Emission Units [326 IAC 6-1-1] [326 IAC 6-1-2] Pursuant to 326 IAC 6-1-1 and 326 IAC 6-1-2, emission units not already listed in the D Section of this permit, shall not emit particulate matter at levels above those limits listed in 326 IAC 6-1- 2. Unless, the allowable particulate matter emissions from the process is already regulated by 326 IAC 6-1-7 and 326 IAC 6-1-12 or any New Source Performance Standard. C.2 Opacity [326 IAC 5-1] Pursuant to 326 IAC 5-1-2 (Opacity Limitations), except as provided in 326 IAC 5-1-3 (Temporary Alternative Opacity Limitations), opacity shall meet the following, unless otherwise stated in this permit: (a) Opacity shall not exceed an average of thirty percent (30%) in any one (1) six (6) minute averaging period as determined in 326 IAC 5-1-4. (b) Opacity shall not exceed sixty percent (60%) for more than a cumulative total of fifteen (15) minutes (sixty (60) readings as measured according to 40 CFR 60, Appendix A, Method 9 or fifteen (15) one (1) minute nonoverlapping integrated averages for a continuous opacity monitor) in a six (6) hour period. C.3 Open Burning [326 IAC 4-1] [IC 13-17-9] The Permittee shall not open burn any material except as provided in 326 IAC 4-1-3, 326 IAC 4- 1-4 or 326 IAC 4-1-6. The previous sentence notwithstanding, the Permittee may open burn in accordance with an open burning approval issued by the Commissioner under 326 IAC 4-1-4.1. C.4 Incineration [326 IAC 4-2] [326 IAC 9-1-2] The Permittee shall not operate an incinerator or incinerate any waste or refuse except as provided in 326 IAC 4-2 and 326 IAC 9-1-2. 326 IAC 9-1-2 is not federally enforceable. C.5 Fugitive Dust Emissions [326 IAC 6-4] The Permittee shall not allow fugitive dust to escape beyond the property line or boundaries of the property, right-of-way, or easement on which the source is located, in a manner that would violate 326 IAC 6-4 (Fugitive Dust Emissions). 326 IAC 6-4-2(4) is not federally enforceable. C.6 Operation of Equipment [326 IAC 2-7-6(6)] Except as otherwise provided by statute or rule, or in this permit, all air pollution control equipment listed in this permit and used to comply with an applicable requirement shall be operated at all times that the emission units vented to the control equipment are in operation. C.7 Stack Height [326 IAC 1-7] The Permittee shall comply with the applicable provisions of 326 IAC 1-7 (Stack Height Provisions), for all exhaust stacks through which a potential (before controls) of twenty-five (25) tons per year or more of particulate matter or sulfur dioxide is emitted. The provisions of 326 IAC 1-7-2, 326 IAC 1-7-3(c) and (d), 326 IAC 1-7-4(d), (e), and (f), and 326 IAC 1-7-5(d) are not federally enforceable.Rolls Royce Corporation Page 27 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy C.8 Asbestos Abatement Projects [326 IAC 14-10] [326 IAC 18] [40 CFR 61, Subpart M] (a) Notification requirements apply to each owner or operator. If the combined amount of regulated asbestos containing material (RACM) to be stripped, removed or disturbed is at least 260 linear feet on pipes or 160 square feet on other facility components, or at least thirty-five (35) cubic feet on all facility components, then the notification requirements of 326 IAC 14-10-3 are mandatory. All demolition projects require notification whether or not asbestos is present. (b) The Permittee shall ensure that a written notification is sent on a form provided by the Commissioner at least ten (10) working days before asbestos stripping or removal work or before demolition begins, per 326 IAC 14-10-3, and shall update such notice as necessary, including, but not limited to the following: (1) When the amount of affected asbestos containing material increases or decreases by at least twenty percent (20%); or (2) If there is a change in the following: (A) Asbestos removal or demolition start date; (B) Removal or demolition contractor; or (C) Waste disposal site. (c) The Permittee shall ensure that the notice is postmarked or delivered according to the guidelines set forth in 326 IAC 14-10-3(2). (d) The notice to be submitted shall include the information enumerated in 326 IAC 14-10-3(3). All required notifications shall be submitted to: Indiana Department of Environmental Management Asbestos Section, Office of Air Quality 100 North Senate Avenue, P.O. Box 6015 Indianapolis, Indiana 46206-6015
and Office of Environmental Services Enforcement Section, Asbestos Program 2700 South Belmont Avenue Indianapolis, Indiana 46221 The notice shall include a signed certification from the owner or operator that the information provided in this notification is correct and that only Indiana licensed workers and project supervisors will be used to implement the asbestos removal project. The notifications do not require a certification by the "responsible official" as defined by 326 IAC 2-7-1(34). (e) Procedures for Asbestos Emission Control The Permittee shall comply with the applicable emission control procedures in 326 IAC 14-10-4 and 40 CFR 61.145(c). Per 326 IAC 14-10-1, emission control requirements are applicable for any removal or disturbance of RACM greater than three (3) linear feet on pipes or three (3) square feet on any other facility components or a total of at least 0.75 cubic feet on all facility components.Rolls Royce Corporation Page 28 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

(f) Demolition and renovation The Permittee shall thoroughly inspect the affected facility or part of the facility where the demolition or renovation will occur for the presence of asbestos pursuant to 40 CFR 61.145(a). (g) Indiana Accredited Asbestos Inspector The Permittee shall comply with 326 IAC 14-10-1(a) that requires the owner or operator, prior to a renovation/demolition, to use an Indiana Accredited Asbestos Inspector to thoroughly inspect the affected portion of the facility for the presence of asbestos. The requirement to use an Indiana Accredited inspector is not federally enforceable. Testing Requirements [326 IAC 2-7-6(1)] C.9 Performance Testing [326 IAC 3-6] (a) All testing shall be performed according to the provisions of 326 IAC 3-6 (Source Sampling Procedures), except as provided elsewhere in this permit, utilizing any applicable procedures and analysis methods specified in 40 CFR 51, 40 CFR 60, 40 CFR 61, 40 CFR 63, 40 CFR 75, or other procedures approved by IDEM, OAQ. A test protocol, except as provided elsewhere in this permit, shall be submitted to: Indiana Department of Environmental Management Compliance Data Section, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015
and Office of Environmental Services Air Quality Management Section, Data Compliance 2700 South Belmont Avenue Indianapolis, Indiana 46221 no later than thirty-five (35) days prior to the intended test date. The protocol submitted by the Permittee does not require certification by the "responsible official" as defined by 326 IAC 2-7-1(34). (b) The Permittee shall notify IDEM, OAQ of the actual test date at least fourteen (14) days prior to the actual test date. The notification submitted by the Permittee does not require certification by the "responsible official" as defined by 326 IAC 2-7-1(34). (c) Pursuant to 326 IAC 3-6-4(b), all test reports must be received by IDEM, OAQ and OES not later than forty-five (45) days after the completion of the testing. An extension may be granted by IDEM, OAQ, and OES if the source submits to IDEM, OAQ, a reasonable written explanation not later than five (5) days prior to the end of the initial forty-five (45) day period. Compliance Requirements [326 IAC 2-1.1-11] C.10 Compliance Requirements [326 IAC 2-1.1-11] The commissioner may require stack testing, monitoring, or reporting at any time to assure compliance with all applicable requirements by issuing an order under 326 IAC 2-1.1-11. Any monitoring or testing shall be performed in accordance with 326 IAC 3 or other methods approved by the commissioner or the U. S. EPA..Rolls Royce Corporation Page 29 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy Compliance Monitoring Requirements [326 IAC 2-7-5(1)] [326 IAC 2-7-6(1)] C.11 Compliance Monitoring [326 IAC 2-7-5(3)] [326 IAC 2-7-6(1)] Unless otherwise specified in this permit, all monitoring and record keeping requirements not already legally required shall be implemented within ninety (90) days of permit issuance. If required by Section D, the Permittee shall be responsible for installing any necessary equipment and initiating any required monitoring related to that equipment. If due to circumstances beyond its control, that equipment cannot be installed and operated within ninety (90) days, the Permittee may extend the compliance schedule related to the equipment for an additional ninety (90) days provided the Permittee notifies: Indiana Department of Environmental Management Compliance Branch, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015
and Office of Environmental Services Air Quality Management Section, Data Compliance 2700 South Belmont Avenue Indianapolis, Indiana 46221 in writing, prior to the end of the initial ninety (90) day compliance schedule, with full justification of the reasons for the inability to meet this date. The notification which shall be submitted by the Permittee does require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). Unless otherwise specified in the approval for the new emission unit(s), compliance monitoring for new emission units or emission units added through a source modification shall be implemented when operation begins. C.12 Monitoring Methods [326 IAC 3] [40 CFR 60] [40 CFR 63] Any monitoring or testing required by Section D of this permit shall be performed according to the provisions of 326 IAC 3, 40 CFR 60, Appendix A, 40 CFR 60 Appendix B, 40 CFR 63, or other approved methods as specified in this permit. C.13 Pressure Gauge and Other Instrument Specifications [326 IAC 2-1.1-11] [326 IAC 2-7-5(3)] [326 IAC 2-7-6(1)] (a) Whenever a condition in this permit requires the measurement of pressure drop across any part of the unit or its control device, the gauge employed shall have a scale such that the expected normal reading shall be no less than twenty percent (20%) of full scale and be accurate within plus or minus two percent ( ±2%) of full scale reading. (b) Whenever a condition in this permit requires the measurement of a temperature or flow rate, the instrument employed shall have a scale such that the expected normal reading shall be no less than twenty percent (20%) of full scale and be accurate within plus or minus two percent ( ±2%) of full scale reading.Rolls Royce Corporation Page 30 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy (c) The Preventive Maintenance Plan for the pH meter shall include calibration using known standards. The frequency of calibration shall be adjusted such that the typical error found at calibration is less than one pH point. (d) The Permittee may request the IDEM, OAQ approve the use of a pressure gauge or other instrument that does not meet the above specifications provided the Permittee can demonstrate an alternative pressure gauge or other instrument specification will adequately ensure compliance with permit conditions requiring the measurement of pressure drop or other parameters. Corrective Actions and Response Steps [326 IAC 2-7-5] [326 IAC 2-7-6]
C.14 Emergency Reduction Plans [326 IAC 1-5-2] [326 IAC 1-5-3] Pursuant to 326 IAC 1-5-2 (Emergency Reduction Plans; Submission): (a) The Permittee prepared and submitted written emergency reduction plans (ERPs) consistent with safe operating procedures on September 4, 1992. (b) Upon direct notification by IDEM, OAQ, and/or OES that a specific air pollution episode level is in effect, the Permittee shall immediately put into effect the actions stipulated in the approved ERP for the appropriate episode level. [326 IAC 1-5-3] C.15 Risk Management Plan [326 IAC 2-7-5(12)] [40 CFR 68.215] If a regulated substance, as defined in 40 CFR 68, is present at a source in more than a threshold quantity, the source must comply with the applicable requirements of 40 CFR 68. C.16 Compliance Response Plan - Preparation, Implementation, Records, and Reports [326 IAC 2-7- 5] [326 IAC 2-7-6] (a) The Permittee is required to prepare a Compliance Response Plan (CRP) for each compliance monitoring condition of this permit. The Operation, Maintenance and Monitoring Plan required for emission units 0070-13, 0070-31, and 311-82 under 40 CFR 63 shall be deemed to satisfy the requirements for a CRP for those compliance monitoring conditions. A CRP shall be submitted to IDEM, OAQ and OES upon request. The CRP shall be prepared within ninety (90) days after issuance of this permit by the Permittee, supplemented from time to time by the Permittee, maintained on site, and comprised of: (1) Reasonable response steps that may be implemented in the event that a response step is needed pursuant to the requirements of Section D of this permit; and an expected time frame for taking reasonable steps. (2) If, at any time, the Permittee takes reasonable response steps that are not set forth in the Permittee’s current Compliance Response Plan or Operation, Maintenance, and Monitoring (OMM) Plan and the Permittee documents such response in accordance with subsection (e) below, the Permittee shall amend its Compliance Response Plan or Operation, Maintenance, and Monitoring (OMM) Plan to include such response steps taken. The OMM Plan shall be submitted within the time frames specified by the applicable 40 CFR 63 requirement. (b) For each compliance monitoring condition of this permit, reasonable response steps shall be taken when indicated by the provisions of that compliance monitoring condition as follows:Rolls Royce Corporation Page 31 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

(1) Reasonable response steps shall be taken as set forth in the Permittee’s current Compliance Response Plan or Operation, Maintenance, and Monitoring (OMM) Plan; or (2) If none of the reasonable response steps listed in the Compliance Response Plan or Operation, Maintenance, and Monitoring (OMM) Plan is applicable or responsive to the excursion, the Permittee shall devise and implement additional response steps as expeditiously as practical. Taking such additional response steps shall not be considered a deviation from this permit so long as the Permittee documents such response steps in accordance with this condition. (3) If the Permittee determines that additional response steps would necessitate that the emissions unit or control device be shut down, the IDEM, OAQ and OES shall be promptly notified of the expected date of the shut down, the status of the applicable compliance monitoring parameter with respect to normal, and the results of the actions taken up to the time of notification. (4) Failure to take reasonable response steps shall be considered a deviation from the permit. (c) The Permittee is not required to take any further response steps for any of the following reasons: (1) A false reading occurs due to the malfunction of the monitoring equipment and prompt action was taken to correct the monitoring equipment. (2) The Permittee has determined that the compliance monitoring parameters established in the permit conditions are technically inappropriate, has previously submitted a request a minor permit modification to the permit, and such request has not been denied. (3) An automatic measurement was taken when the process was not operating. (4) The process has already returned or is returning to operating within “normal” parameters and no response steps are required. (d) When implementing reasonable steps in response to a compliance monitoring condition, if the Permittee determines that an exceedance of an emission limitation has occurred, the Permittee shall report such deviations pursuant to Section B-Deviations from Permit Requirements and Conditions. (e) The Permittee shall record all instances when, in accordance with Section D, response steps are taken. In the event of an emergency, the provisions of 326 IAC 2-7-16 (Emergency Provisions) requiring prompt corrective action to mitigate emissions shall prevail. (f) Except as otherwise provided by a rule or provided specifically in Section D, all monitoring as required in Section D shall be performed when the emission unit is operating, except for time necessary to perform quality assurance and maintenance activities.Rolls Royce Corporation Page 32 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy C.17 Actions Related to Noncompliance Demonstrated by a Stack Test [326 IAC 2-7-5] [326 IAC 2-7-6] (a) When the results of a stack test performed in conformance with Section C - Performance Testing, of this permit exceed the level specified in any condition of this permit, the Permittee shall take appropriate response actions. The Permittee shall submit a description of these response actions to IDEM, OAQ, within thirty (30) days of receipt of the test results. The Permittee shall take appropriate action to minimize excess emissions from the affected facility while the response actions are being implemented. (b) A retest to demonstrate compliance shall be performed within one hundred twenty (120) days of receipt of the original test results. Should the Permittee demonstrate to IDEM, OAQ that retesting in one-hundred and twenty (120) days is not practicable, IDEM, OAQ may extend the retesting deadline. (c) IDEM, OAQ reserves the authority to take any actions allowed under law in response to noncompliant stack tests. The response action documents submitted pursuant to this condition do require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19] C.18 Emission Statement [326 IAC 2-7-5(3)(C)(iii)] [326 IAC 2-7-5(7)] [326 IAC 2-7-19(c)] [326 IAC 2-6] (a) The Permittee shall submit an annual emission statement certified pursuant to the requirements of 326 IAC 2-6, that must be received by April 15 of each year and must comply with the minimum requirements specified in 326 IAC 2-6-4. The annual emission statement shall meet the following requirements: (1) Indicate estimated actual emissions of criteria pollutants from the source, in compliance with 326 IAC 2-6 (Emission Reporting); (2) Indicate estimated actual emissions of regulated pollutants as defined by 326 IAC 2-7-1(32) (“Regulated pollutant which is used only for purposes of Section 19 of this rule”) from the source, for purposes of Part 70 fee assessment. (b) The annual emission statement covers the twelve (12) consecutive month time period starting December 1 and ending November 30. The annual emission statement must be submitted to: Indiana Department of Environmental Management Technical Support and Modeling Section, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015
and Office of Environmental Services Air Quality Management Section, Data Compliance 2700 South Belmont Avenue Indianapolis, Indiana 46221Rolls Royce Corporation Page 33 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

The emission statement does require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). (c) The annual emission statement required by this permit shall be considered timely if the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means, it shall be considered timely if received by IDEM, OAQ, and OES on or before the date it is due. C.19 General Record Keeping Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-6] (a) Records of all required monitoring data, reports and support information required by this Permit shall be retained for a period of at least five (5) years from the date of monitoring sample, measurement, report, or application. These records shall be physically present or electronically accessible at the source location for a minimum of three (3) years. The records may be stored elsewhere for the remaining two (2) years as long as they are available upon request. If the Commissioner or Administrator of OES makes a request for records to the Permittee, the Permittee shall furnish the records to the Commissioner or OES within a reasonable time. (b) Unless otherwise specified in this permit, all record keeping requirements not already legally required shall be implemented within ninety (90) days of permit issuance. C.20 General Reporting Requirements [326 IAC 2-7-5(3)(C)] [326 IAC 2-1.1-11] (a) The source shall submit the attached Semi-Annual Deviation and Compliance Monitoring Report or its equivalent. Any deviation from permit requirements, the date(s) of each deviation, the cause of the deviation, and the response steps taken must be reported. This report shall be submitted within thirty (30) days of the end of the reporting period. The Semi-annual Deviation and Compliance Monitoring Report shall include the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). (b) The report required in (a) of this condition and reports required by conditions in Section D of this permit shall be submitted to: Indiana Department of Environmental Management Compliance Data Section, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015
and Office of Environmental Services Air Quality Management Section, Data Compliance 2700 South Belmont Avenue Indianapolis, Indiana 46221 (c) Unless otherwise specified in this permit, any notice, report, or other submission required by this permit shall be considered timely if the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means, it shall be considered timely if received by IDEM, OAQ, and OES on or before the date it is due.Rolls Royce Corporation Page 34 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

(d) Unless otherwise specified in this permit, all reports required in Section D of this permit shall be submitted within thirty (30) days of the end of the reporting period. All reports do require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). (e) The first report shall cover the period commencing on the date of issuance of this permit and ending on the last day of the reporting period. Reporting periods are based on calendar years. Stratospheric Ozone Protection
C.21 Compliance with 40 CFR 82 and 326 IAC 22-1 Pursuant to 40 CFR 82 (Protection of Stratospheric Ozone), Subpart F, except as provided for motor vehicle air conditioners in Subpart B, the Permittee shall comply with the standards for recycling and emissions reduction: (a) Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices pursuant to 40 CFR 82.156. (b) Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the standards for recycling and recovery equipment pursuant to 40 CFR 82.158. (c) Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved technician certification program pursuant to 40 CFR 82.161. Part 2 MACT Application Submittal Requirement
C.22 Application Requirements for Section 112(j) of the Clean Air Act [40 CFR 63.52(e) and 326 IAC 2-7-12] (a) The Permittee shall submit a Part 2 Maximum Achievable Control Technology (MACT) Application in accordance with 40 CFR 63.52(e)(1). The Part 2 MACT Application shall meet the requirements of 40 CFR 63.53(b). (b) Notwithstanding paragraph (a), the Permittee is not required to submit a Part 2 MACT Application if the Permittee no longer meets the applicability criteria of 40 CFR 63.50 by the application deadline in 40 CFR 63.52(e)(1). For example, the Permittee would not have to submit a Part 2 MACT Application if, by the application deadline: (1) The source is no longer a major source of hazardous air pollutants, as defined in 40 CFR 63.2; (2) The source no longer includes one or more units in an affected source category for which the U.S. EPA failed to promulgate an emission standard by May 15, 2002; or (3) The MACT standard or standards for the affected source categories included at the source are promulgated. (c) Notwithstanding paragraph (a), pursuant to 40 CFR 63.56(a), the Permittee shall comply with an applicable promulgated MACT standard in accordance with the scheduleRolls Royce Corporation Page 35 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

provided in the MACT standard if the MACT standard is promulgated prior to the Part 2 MACT Application deadline or prior to the issuance of a permit with a case-by-case Section 112(j) MACT determination. The MACT requirements include the applicable General Provisions requirements of 40 CFR 63, Subpart A. Pursuant to 40 CFR 63.9(b), the Permittee shall submit an initial notification not later than 120 days after the effective date of the MACT, unless the MACT specifies otherwise. The initial notification shall be submitted to: Indiana Department of Environmental Management Permits Branch, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015
and Office of Environmental Services Air Quality Management Section, Data Compliance 2700 South Belmont Avenue Indianapolis, Indiana 46221
and United States Environmental Protection Agency, Region V Air and Radiation Division, Regulation Development Branch - Indiana (AR-18J) 77 West Jackson Boulevard Chicago, Illinois 60604-3590Rolls Royce Corporation Page 36 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy SECTION D.1 FACILITY OPERATION CONDITIONS Facility Description [326 IAC 2-7-5(15)] (a) Ten (10) boilers identified below: Emission Unit ID No. Unit

Identification Maximum

Capacity, MMBtu/hr Fuels Permitted to Use Stack No. Date Constructed or Reconstructed 0070-01 Babcock &

Wilcox Boiler 88 Natural Gas, Landfill Gas, No. 2 & No. 4 fuel oil 5-1 1942

0070-02 Babcock &

Wilcox Boiler 88 Natural Gas, Landfill Gas, No. 2 & No. 4 fuel oil 5-1 1942

0070-03 Babcock &

Wilcox Boiler 88 Natural Gas, Landfill Gas, No. 2 & No. 4 fuel oil 5-1 1942

0070-04 Babcock &

Wilcox Boiler 88 Natural Gas, Landfill Gas, No. 2 & No. 4 fuel oil 5-1 1942

0070-58 Babcock &

Wilcox Boiler 44 Natural Gas, Landfill Gas, No. 2, No. 4 & No. 6 fuel oil 8-3 1953

0070-59 Babcock &

Wilcox Boiler 44 Natural Gas, Landfill Gas, No. 2, No. 4 & No. 6 fuel oil 8-4 1953

0070-62 Combustion

Engineering Boiler 244 Natural Gas, Landfill Gas, No. 2, No. 4 & No. 6 fuel oil 8-5 1969

0070-63 Combustion

Engineering Boiler 244 Natural Gas, Landfill Gas, No. 2, No. 4 & No. 6 fuel oil 8-6 1969

0070-64 Combustion

Engineering Boiler 244 Natural Gas, Landfill Gas, No. 2, No. 4 & No. 6 fuel oil 8-7 1969

0070-65 Combustion

Engineering Boiler 244 Natural Gas, Landfill Gas, No. 2, No. 4 & No. 6 fuel oil 8-8 1969

(b) Five (5) gas turbines identified below: Emission Unit ID No. Unit

Identification Maximum

Capacity, MMBtu/hr Fuels Permitted to Use Stack No. Date Constructed

0070-76 Gas Turbine 51 Natural Gas, Landfill gas 5-22 1999 0070-79 Gas Turbine 48 Natural Gas, Landfill gas 8-79 1999 0070-80 Gas Turbine 68 Natural Gas, Landfill gas 8-80 1999 0070-81 Gas Turbine 80 Natural Gas, Landfill gas 8-81 pending 0070-71 Gas Turbine 35 Natural Gas 8-9 1999 (The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.)Rolls Royce Corporation Page 37 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

Emission Limitations and Standards [326 IAC 2-7-5(1)]
D.1.1 Applicability [326 IAC 12-1-1][40 CFR 60, Subpart GG][40 CFR Part 60, Subpart A] The provisions of 40 CFR Part 60, Subpart A - General Provisions, which are incorporated by reference in 326 IAC 12-1, apply to the facility described in this section except when otherwise specified in 40 CFR Part 60, Subpart GG.
D.1.2 Applicability [326 IAC 12-1-1][40 CFR 60, Subpart GG] The emission standards contained in 40 CFR Part 60, Subpart GG, Standards of Performance for Stationary Gas Turbines are applicable to the five emission units, identified as 0070-71, 0070-76, 0070-79, 0070-80, and 0070-81, when combusting natural gas and/or landfill gas. D.1.3 Standards of Performance for Stationary Gas Turbines [326 IAC 12-1-1][40 CFR 60, Subpart GG] (a) Pursuant to 40 CFR 60.332(a)(2), nitrogen oxides emissions shall not be discharged into the atmosphere from any stationary gas turbine in excess of STD derived from the equation below:

STD 0.0150 (14.4) Y F = + where: STD = allowable NOx emissions (percent by volume at 15 percent oxygen and on a dry basis) Y = manufacturer’s rated heat rate at manufacturer’s rated peak load (kilojoules per watt

hour) or, actual measured heat rate based on lower heating value of fuel as measured at actual peak load for the facility. The value of Y shall not exceed 14.4 kilojoules per watt hour. F = NO x

emission allowance for fuel-bound nitrogen as defined in 40 CFR 60.332(a)(3); Pursuant to Emission Measurement Technical Information Center Guideline Document, “Determination of Fuel-Bound Nitrogen”, Recommendation: F = 0 in 60.332(a)(2) equation; and (b) Pursuant to 40 CFR 60.333(b) any fuel combusted in any stationary gas turbine which contains sulfur shall not exceed a sulfur content of 0.8 percent by weight.
D.1.4 Sulfur Content [326 IAC 12-1-1][40 CFR 60, Subpart GG] Pursuant to 40 CFR 60.334(b), the Permittee shall monitor sulfur content and nitrogen content of the fuel being fired in emission units 0070-71, 0070-76, 0070-79, 0070-80, and 0070-81. (a) Pursuant to 40 CFR 60.334(b)(2) a substantiated custom schedule was approved by the US EPA Region V on June 1, 2001 via an Approval letter (AE-17J) RE: Alternative fuel monitoring NSPS 40 CFR Part 60, Subpart GG. The custom schedule is as follows: (1) The Permittee is exempt from the nitrogen monitoring for both the landfill gas and the pipeline quality natural gas. (2) The Permittee shall be required to perform semi-annual testing of sulfur content. Should any semi annual sulfur analysis indicate noncompliance with the standard in Subpart GG, the Permittee shall notify the U.S. EPA immediately and this custom schedule shall be reexamined.Rolls Royce Corporation Page 38 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

(3) If there is a change in fuel supply, the Permittee shall notify the U.S. EPA of such change for re-examination of this schedule. A substantial change in fuel quality shall be considered as a change in fuel supply. D.1.5 Oxides of Nitrogen (NOx) and Particulate Matter ten microns in aerodynamic diameter (PM10) emissions limits [ 326 IAC 2-7-5(1)] [326 IAC 2-2] [40 CFR 52.21] Pursuant to condition 9 of CP-099-0311-01, issued on June 10, 1999 and amended by 097-11888-0311, issued August 17, 2000 the net increases of NOx and PM10 emissions from the modification are limited to less than the significance levels. The Permittee accepted emission limits on all units involved in the modification for NOx of 325.75 tons per year and PM10 of 130 tons per year to keep the net emissions of the modification below 40 tons per year. The following limits from CP-099-0311-01 and 097-11888-0311 apply: (a) NOx limitations (based on all boilers and turbines, Emission Units 01, 02, 03, 04, 58, 59, 62, 63, 64, 65, 71, 76, 79, 80 and 81): The input of natural gas and natural gas equivalents to the equipment covered in this permit shall be limited to less than 6205 MMCF natural gas per twelve (12) month consecutive period with compliance determined at the end of each month. This usage limitation is equivalent to a potential to emit of less than 325.74 tons per year, which keeps net emissions from the 1999 modification below 40 tons per year. (1) For the purposes of determining compliance every million cubic feet of natural gas shall be equivalent to the following:

Natural Gas Equivalents for Nitrogen Oxide Emissions

Emission Units MMCF per gal #4 oil MMCF per

gal #2 oil MMCF per

MMCF landfill gas MMCF per

MMCF natural gas MMCF

per gal #6 oil Boilers (Emission Unit ID 0070-01,02,03 and 04) 0.00023 0.00023 0.31928 N.A. N.A.

Boilers (Emission Unit ID 0070-58 and 59) 0.00023 0.00023 N.A. N.A. 0.00048

Boilers (Emission Unit ID 0070-62, 63, 64 and 65) N.A. 0.00023 0.31928 N.A. 0.00060

Turbine (Emission Unit ID 0070-80) N.A. N.A. 0.8257 3.90000 N.A.

Turbine (Emission Unit ID 81) N.A. N.A. 0.34130 3.90000 N.A.

Turbines (Emission Unit IDs 0070-71) N.A. N.A. 0.34130 4.50000 N.A.

Turbines (Emission Unit IDs 0070-76, 79) N.A. N.A. 0.34130 6.50000 N.A.

and (2) NOx emissions are limited to:Rolls Royce Corporation Page 39 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy (A) Boilers (Emission Unit ID 0070-01, 02, 03, 04, 62, 63, 64 and 65) shall be limited to 0.1 lbs/MMBtu when burning natural gas; (B) Boilers (Emission Unit ID 0070-01, 02, 03, 04, 58, 59, 62, 63, 64 and 65) shall be limited to 0.175 lbs/MMBtu when burning #2 fuel oil; (C) Boilers (Emission Unit ID 0070-01, 02, 03, 04, 62, 63, 64 and 65) shall be limited to 0.058 lbs/MMBtu when burning landfill gas; (D) Boilers (Emission Unit ID 0070-01,02,03,04,58 and 59) shall be limited to 0.175 lbs/MMBtu when burning #4 fuel oil; (E) Boilers (Emission Unit ID 0070-58 and 59) shall be limited to 0.336 lbs/MMBtu when burning #6 fuel oil; (F) Boilers (Emission Unit ID 0070-62, 63, 64 and 65)shall be limited to 0.447 lbs/MMBtu when burning #6 fuel oil; (G) Turbines (Emission Unit ID 0070-71, 76, 79, 80 and 81) shall be limited to 0.062 lbs/MMBtu when burning landfill gas. (H) Turbine (Emission Unit ID 0070-80) shall be limited to 0.15 lbs/MMBtu when burning landfill gas. (I) Turbines (Emission Unit ID 0070-80 and 81) are limited to 0.390 lbs/MMBtu when combusting natural gas. (J) Turbine (Emission Unit ID 0070-71) is limited to 0.450 lbs/MMBtu when combusting natural gas. (K) Turbines (Emission Unit ID 0070-76 and 79) are limited to 0.650 lbs/MMBtu when combusting natural gas. (b) PM10 limitation for Emission Unit ID 0070-01, 0070-02, 0070-03, 0070-04, 0070-58, 0070-59, 0070-62, 0070-63, 0070-64, 0070-65, 0070-71, 0070-76, 0070-79, 0070-80 and 0070-81: The input of No.4 oil and No. 4 oil equivalents shall be limited to 37,142,800 gallons of No.4 oil per twelve (12) month consecutive period with compliance determined at the end of each month. This usage limitation is equivalent to a potential to emit of 130 tons per year. (1) For the purposes of determining compliance every gallon of No.4 oil shall be equivalent to the following:

Fuel Oil Equivalents for PM-10 Emissions

Emission Units gal per gal #2 oil gal per CF

landfill gas gal per CF

natural gas gal per gal

#6 oil Boilers (Emission Unit ID 0070-01, 02, 03, 04, 62, 63, 64 and 65) 0.280 0.00116 0.00088 2.60Rolls Royce Corporation Page 40 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

Boilers (Emission Unit ID 0070- 58, 59) 0.280 N.A. 0.00088 2.60

Turbines (Emission Unit IDs 0070-76, 79, 80 and 81) N.A. 0.00132 0.00088 N.A.

and (2) PM10 emissions are limited to: (A) Boilers (Emission Unit ID 0070-01, 02, 03, 04, 62, 63, 64 and 65) shall be limited to 0.014 lbs/MMBtu when combusting landfill gas; and (B) Turbines (Emission Unit IDs 0070-76, 79, 80 and 81) shall be limited to 0.016 lbs/MMBtu when combusting landfill gas

D.1.6 Marion County PM Limitations [326 IAC 6-1-12] (a) Pursuant to 326 IAC 6-1-12(a) (Nonattainment Area Particulate Limitations: Marion County), the Permittee shall comply with the following emission limitations for Particulate Matter (PM):

Source NEDS

Plant ID Point Input ID Process Emission Limits tons per year Lbs/million

Btu

Rolls Royce Corporation 0311 01 Boilers 0070-01 thru 0070-04 130.0/yr 0.337

0311 02 Boilers 0070-58 and 0070-59 0.15 0311 03 Boilers 0070-62 thru 0070-65 0.15 (b) Pursuant to 326 IAC 6-1-12(b) this source shall be considered in compliance with the tons per year emissions limitation established in 326 IAC 6-1-12(a) if within 5% of the emission limit. (c) Pursuant to 326 IAC 6-1-12(f), the Permittee shall comply with the following: (1) Boilers 0070-01 thru 0070-04 shall use only #2 fuel oil, #4 fuel oil, natural gas or landfill gas as fuel. (2) Boilers 0070-58, 0070-59, and 0070-62 thru 0070-65 shall use only #6 fuel oil, #4 fuel oil, #2 fuel oil, natural gas or landfill gas as fuel. (3) Boilers 0070-01 thru 0070-04, 0070-58, 0070-59, and 0070-62 thru 0070-65 shall have the following limitations depending upon the fuel being used: (A) When using #4 fuel oil, the amount used for the listed boilers collectively shall not exceed thirty-seven million one hundred forty-two thousand eight hundred (37,142,800) gallons per year based on a three hundred sixty-five (365) day rolling figure. (B) When either #6 fuel oil, #2 fuel oil, natural gas or land fill gas is used, the limitation listed in clause (A) shall be adjusted as follows:Rolls Royce Corporation Page 41 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

(i) When using #6 fuel oil, the gallons per year of #4 fuel oil shall be reduced by two and six-tenths (2.6) gallon used. (ii) When using natural gas, the gallons per year of #4 fuel oil shall be reduced by eighty-eight hundred-thousandths (0.00088) gallon per cubic foot of natural gas burned. (iii) When using #2 fuel oil, the gallons per year of #4 fuel oil shall be reduced by twenty-eight hundredths (0.28) gallon per gallon used. (iv) When using landfill gas, the gallons per year of #4 fuel oil shall be reduced by one hundred sixteen hundred thousandths (0.00116) gallon per cubic foot of landfill gas burned.

D.1.7 PM Emissions Limitations [326 IAC 6-1-2(a)] Pursuant to 326 IAC 6-1-2(a)( Particulate Limitations), particulate matter (PM) emissions from emission units 0070-71, 0070-76, 0070-79, 0070-80 and 0070-81 shall be limited to 0.03 grain per dry standard cubic foot of exhaust air.

D.1.8 Sulfur Dioxide Emission Limitation [326 IAC 7-4-2] (a) Pursuant to 326 IAC 7-4-2(2), the Sulfur Dioxide (SO 2 ) emission from emission units 0070-01 through 0070-04 shall be each limited to 3.99 pounds per million Btu and 299.4 pounds per hour. (b) Pursuant to 326 IAC 7-4-2(28), the sulfur dioxide emissions from Boilers 0070-58, 0070- 59, and 0070-62 thru 0070-65 shall be limited as follows: (1) Boilers 0070-58, 0070-59, and 0070-62 thru 0070-65 shall be allowed to burn Natural gas at any time. (2) Babcock and Wilcox 0070-58 and 0070-59 and Combustion Engineering Boilers 0070-62 thru 0070-65 shall burn fuel oil with a sulfur content of two and one tenths (2.1) pounds per million Btu during periods when one of the following conditions are met: (A) Fuel oil is burned in no more than three (3) Babcock and Wilcox Boilers and fuel oil is not burned in any Combustion Engineering Boilers. (B) Fuel oil is burned in no more than two (2) Babcock and Wilcox Boilers and no more than two (2)Combustion Engineering Boilers (C) Fuel oil is burned in no more than one (1) Babcock and Wilcox Boilers and no more than three (3) Combustion Engineering Boilers. D.1.9 Preventive Maintenance Plan [326 IAC 2-7-5(13)] A Preventive Maintenance Plan, in accordance with Section B - Preventive Maintenance Plan, of this permit, is required for emission units 0070-01 through 0070-04, 0070-58, 0070-59, and 0070-62 through 0070-65 when burning fuel oil.Rolls Royce Corporation Page 42 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy Compliance Determination Requirements D.1.10 Sulfur Dioxide Emissions and Sulfur Content [326 IAC 3-6] [326 IAC 3-7-4] [326 IAC 7-2-1] Pursuant to 326 IAC 7-2-1 and 326 IAC 3-7-4 or 326 IAC 3-6. the Permittee shall demonstrate that the sulfur dioxide emissions from boilers 0070-01 thru 0070-04, 0070-58, 0070-59, and 0070-62 thru 0070-65 do not exceed the pounds per million Btu heat input limits in condition D.1.8. Compliance shall be determined utilizing one of the following options. (a) Providing vendor analysis of fuel delivered, if accompanied by a vendor certification, or; (b) Analyzing the oil sample to determine the sulfur content of the oil via the procedures in 40 CFR 60, Appendix A, Method 19. (1) Oil samples may be collected from the fuel tank immediately after the fuel tank is filled and before any oil is combusted; and (2) If a partially empty fuel tank is refilled, a new sample and analysis would be required upon filling. (c) Compliance may also be determined by conducting a stack test for sulfur dioxide emissions from 0070-01 through 0070-04, 0070-58, 0070-59, and 0070-62 thru 0070-65, using 40 CFR 60, Appendix A, Method 6 in accordance with the procedures in 326 IAC 3-6. A determination of noncompliance pursuant to any of the methods specified in (a), (b), or (c) above shall not be refuted by evidence of compliance pursuant to the other method.
D.1.11 Testing Requirements [326 IAC 2-7-6(1),(6)][326 IAC 2-1.1-11] (a) Within 60 days after achieving maximum production rate, but no later than 180 days after initial start-up, in order to demonstrate compliance with Condition D.1.5, the Permittee shall perform NOx testing utilizing methods approved by the Commissioner: (1) emission units 0070-76, 0070-79, 0070-80, and 0070-81 shall be tested when combusting landfill gas, and (2) emission unit 0070-71, 0070-76, 0070-79, 0070-80, and 0070-81 shall be tested when combusting natural gas. Testing shall be conducted in accordance with Section C- Performance Testing. (b) Within 60 days after achieving maximum production rate, but no later than 180 days after initial start-up, in order to demonstrate compliance with Condition D.1.5, the Permittee shall perform PM-10 testing utilizing methods approved by the Commissioner as follows: (1) emission units 0070-01 and 0070-62 when combusting landfill gas, and (2) emission unit 0070-76 when combusting landfill gas. PM-10 includes filterable and condensible PM-10. Testing shall be conducted in accordance with Section C- Performance Testing. (c) After the initial performance tests outlined in (a) and (b), this permit does not require the Permittee to perform repetitive testing on these units. However, IDEM or OES mayRolls Royce Corporation Page 43 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

require compliance testing when necessary to determine if the facility is in compliance. If testing is required by IDEM or OES, compliance with the PM and/or NOx limits specified in this permit shall be determined by a performance test conducted in accordance with Section C - Performance Testing.
D.1.12 PM, PM-10, and NOx Emissions Compliance with Condition D.1.5 and D.1.6 shall be demonstrated within 30 days of the end of each month based on the amount of fuel combusted for the most recent 365 day period. D.1.13 Sulfur Content Pursuant to 40 CFR 60.335(d) and 40 CFR 60.335(e), compliance with the sulfur content standard in 60.333(b) and the sulfur content monitoring requirements in 60.334(b) shall be determined as follows: ASTM D 2880-71 shall be used to determine the sulfur content of liquid fuels and ASTM D 1072-80, D 3031-81, D 4084-82, or D 3246-81 shall be used for the sulfur content of gaseous fuels (incorporated by reference -- see 60.17). The applicable ranges of some ASTM methods mentioned above are not adequate to measure the levels of sulfur in some fuel gases. Dilution of samples before analysis (with verification of the dilution ratio) may be used, subject to the approval of the Administrator

. Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)]
D.1.14 Visible Emissions Notations (a) Visible emission notations of the emission units 0070-01, 0070-02, 0070-03, 0070-04, 0070-58, 0070-59, 0070-62, 0070-63, 0070-64 and 0070-65 stack exhausts shall be performed once per shift during normal daylight operations when combusting fuel oil. A trained employee shall record whether emissions are normal or abnormal. (b) For processes operated continuously, "normal" means those conditions prevailing, or expected to prevail, eighty percent (80%) of the time the process is in operation, not counting startup or shut down time. (c) In the case of batch or discontinuous operations, readings shall be taken during that part of the operation that would normally be expected to cause the greatest emissions. (d) A trained employee is an employee who has worked at the plant at least one (1) month and has been trained in the appearance and characteristics of normal visible emissions for that specific process. (e) The Compliance Response Plan for this unit shall contain troubleshooting contingency and response steps for when an abnormal emission is observed. Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]
D.1.15 Record Keeping Requirements (a) To document compliance with condition D.1.6, the Permittee shall maintain records of the day and quantity of each type of fuel used in boilers, identified as emission units 0070-01, 0070-02, 0070-03,0070-04, 0070-58, 0070-59, 0070-62, 0070-63, 0070-64, and 0070-65, and its #4 fuel oil equivalence for PM. (b) To document compliance with Condition D.1.8 and D.1.10 , the Permittee shall maintain records in accordance with (1) through (6) below. (1) Calendar dates covered in the compliance determination period;Rolls Royce Corporation Page 44 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

(2) Actual fuel oil usage since last compliance determination period and equivalent sulfur dioxide emissions; (3) To certify compliance when burning natural gas only, the Permittee shall maintain records of fuel used. If the fuel supplier certification is used to demonstrate compliance, when burning alternate fuels and not determining compliance pursuant to 326 IAC 3-7-4, the following, as a minimum, shall be maintained: (4) Fuel supplier certifications; (5) The name of the fuel supplier; and (6) A statement from the fuel supplier that certifies the sulfur content of the fuel oil. The Permittee shall retain records of all recording/monitoring data and support information for a period of five (5) years, or longer if specified elsewhere in this permit, from the date of the monitoring sample, measurement, or report. Support information includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. (c) To document compliance with condition D.1.5, the Permittee shall maintain records of the day, amount and type of fuel combusted in emission units 0070-01, 0070-02, 0070- 03, 0070-04, 0070-58, 0070-59, 0070-62, 0070-63, 0070-64 and 0070-65 and the natural gas equivalence for NOx and PM-10. (d) To document compliance with condition D.1.3 and D.1.4, the Permittee shall, maintain records of semi-annual sulfur sampling when natural gas and/or landfill gas are combusted in emission Unit ID 0070-71, 0070-76, 0070-79, 0070-80 and 0070-81. (e) To document compliance with Condition D.1.14, the Permittee shall maintain records of daily visible emission notations of the stack exhaust for emission units 0070-01, 0070- 02, 0070-03, 0070-04, 0070-58, 0070-59, 0070-62, 0070-63, 0070-64, and 0070-65 when combusting fuel oil. (f) To document compliance with D.1.9, the Permittee shall maintain records of any additional inspections prescribed by the Preventive Maintenance Plan. (g) All records shall be maintained in accordance with Section C - General Record Keeping Requirements, of this permit. D.1.16 Reporting Requirements (a) The natural gas and landfill gas boiler certification shall be submitted to the address listed in Section C - General Reporting Requirements, of this permit, using the reporting forms located at the end of this permit, or its equivalent, within thirty (30) days after the end of the six (6) month period being reported. The natural gas and landfill gas fired boiler certification doesrequire the certification by the A responsible official @

as defined by 326 IAC 2-7-1(34). (b) A quarterly summary of the information to document compliance with condition D.1.5, D.1.6, and D.1.8, shall be submitted to the addresses listed in Section C - General Reporting Requirements of this permit, using the reporting forms located at the end of this permit, or their equivalent, within thirty (30) days after the end of the quarter being reported.Rolls Royce Corporation Page 45 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

SECTION D.2 FACILITY OPERATION CONDITIONS Facility Description [326 IAC 2-7-5(15)] (c) Six paint booths identified as emission units 0070-N56a and 0070-N56b, units 0070-10a, 0070-10b, 0070-10c, and 0070-10d, controlled by dry filters, exhausting out stacks identified as SN56 a & b, 5-10a, 5-10b, 5-10c, and 5-10d respectively. These paint booths were installed prior to 1974. (d) Facility-wide wipe cleaning operations. (The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.) Emission Limitations and Standards [326 IAC 2-7-5(1)]
D.2.1 General Provisions Relating to HAPs [326 IAC 20-1-1][40 CFR 63, Subpart A] The provisions of 40 CFR Part 63, Subpart A - General Provisions, which are incorporated as 326 IAC 20-1-1, apply to the facility described in this section except when otherwise specified in 40 CFR Part 63.743(a)(4) through (a)(10) and in Table 1 of 40 CFR 63, Subpart GG.
D.2.2 Applicability [326 IAC 20-15-1] [40 CFR 63, Subpart GG] The provisions of 40 CFR 63, Subpart GG and 326 IAC 20-15-1 which incorporates by reference 40 CFR 63, Subpart GG, National Emission Standards for Aerospace Manufacturing and Rework Facilities, apply to the facility described in this section. D.2.3 Standards for Cleaning Operations [40 CFR 63.744] (a) Pursuant to 40 CFR 63.744 (a), the Permittee shall comply with the housekeeping measures of 40 CFR 63.744(a), paragraphs (1) through (3) below, unless the cleaning solvent used is identified in Table 1 of 40 CFR 63.744, or contains HAP or VOC below the de-minimis levels specified in 63.741(f). (1) Pursuant to 40 CFR 63.744(a)(1) place cleaning solvent-laden cloth, paper, or other absorbent applicators used for cleaning in bags or other closed containers upon completing their use. Ensure that these bags and containers are kept closed at all times, except when depositing or removing these materials from the container. Use bags and containers of such design so as to contain the vapors of the cleaning solvent. Cotton tipped swabs used for very small cleaning operations are exempt from this requirement. (2) Pursuant to 40 CFR 63.744(a)(2) store fresh and spent cleaning solvents, except semi-aqueous solvent cleaners, used in aerospace cleaning operations in closed containers. (3) Pursuant to 40 CFR 63.744(a)(3) conduct the handling and transfer of cleaning solvents to or from enclosed systems, vats, waste containers, and other cleaning operation equipment that hold or store fresh or spent cleaning solvents in such a manner that minimizes spills. (b) Pursuant to 40 CFR 63.744(b) (Hand-wipe cleaning), the Permittee shall use cleaning solvents that meet (1) or (2) below. Cleaning solvents that contain HAP and VOC below the de minimis levels specified in 63.741(f) and cleaning operations described in 40 CFR 63.744(e) are exempt from these requirements.Rolls Royce Corporation Page 46 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

(1) Pursuant to 40 CFR 63.744(b)(1) meet one of the composition requirements in Table 1 of 40 CFR 63.744; or (2) Pursuant to 40 CFR 63.744(b)(2) have a composite vapor pressure of 45 mm Hg (24.1 in H 2 O) or less at 20 o C (68 o F). (c) Pursuant to 40 CFR 63.744(c) (Spray gun cleaning) when spray guns are cleaned, the Permittee shall use one of the techniques listed below in paragraphs (1) through (3) or their equivalent. Cleaning solvents that contain HAP and VOC below the de minimis levels specified in 63.741(f) are exempt from these requirements. (1) Pursuant to 40 CFR 63.744(c)(1) , Enclosed system, clean the spray gun in an enclosed system that is closed at all times except when inserting or removing the spray gun. Cleaning shall consist of forcing solvent through the gun. (2) Pursuant to 40 CFR 63.744(c)(2) , Nonatomized cleaning, clean the spray gun by placing cleaning solvent in the pressure pot and forcing the solvent through the spray gun with the atomizing cap in place. No atomizing air is to be used. Direct the cleaning solvent from the spray gun into a vat, drum or other waste container that is closed when not in use. (3) Pursuant to 40 CFR 63.744(c)(3) , Disassembled spray gun cleaning, clean the disassembled spray gun components by hand in a vat that shall remain closed at all times except when in use or by soaking in a vat that shall remain closed during the soaking period and when not inserting or removing components. (d) Pursuant to 40 CFR 63.744(d) (Flush Cleaning), the Permittee shall empty the used cleaning solvent each time aerospace parts or assemblies, or components of a coating unit (with the exception of spray guns) are flush cleaned into an enclosed container or collection system that is kept closed when not in use or into a system with equivalent emission control. This excludes those flush cleaning operations in which Table 1 or semi-aqueous cleaning solvents are used. (e) The requirements of 40 CFR 63.745 do not apply to the primer and topcoat operations since the Permittee is only using specialty coatings, adhesives, adhesive bonding primers, or sealants as defined in 40 CFR 63.741(f).

D.2.4 Storage and Handling of Waste [326 IAC 20-15-1] [40 CFR 63, Subpart GG] Pursuant to 40 CFR 63.748 and 63.741(e), unless exempt under 40 CFR 63.741(e), the Permittee shall conduct the handling and transfer of the waste that contains HAP to or from containers, tanks, vats, vessels, and piping systems in such a manner that minimizes spills. D.2.5 Spray Gun Cleaning and Coating Operations [326 IAC 20-15-1] [40 CFR 63, Subpart GG] (a) The Permittee shall comply with the Spray gun cleaning Enclosed system inspection and repair requirements below. (1) Pursuant to 40 CFR 63.751(a) visually inspect seals and other potential sources of leaks associated with each enclosed gun spray cleaner system at least once per month, while operating. (2) Pursuant to 40 CFR 63.744(c)(1)(ii) if a leak is found, repairs shall be made as soon as practicable, but no later than 15 days from detection. If the leak is not repaired by the 15 thday after detection, remove the cleaning solvent and shut down the enclosed cleaning system until the leak is repairedRolls Royce Corporation Page 47 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy D.2.6 Primer and Topcoat Application Operations [326 IAC 20-15-1] [40 CFR 63, Subpart GG] (a) All primers and topcoats shall be applied using one or more of the application techniques specified below unless the application is exempted in 40 CFR 63.745(f)(3) and shall be operated according to company procedures, and/or the manufacturers specifications, whichever is most stringent, at all times: (1) Flow/curtain coat application; (2) Dip coat application; (3) Roll coating; (4) Brush coating; (5) Cotton-tipped swab application; (6) Electrodeposition (dip) coating; (7) High volume low pressure (HVLP) spraying; (8) Electrostatic spray appliction; or (9) Other coating application methods that achieve emission reductions equivalent to HVLP or electrostatic spray application methods, as determined according to the requirements in 40 CFR 63.750(i). (b) Pursuant to 40 CFR 63.745(g)(1), primer or topcoat applications that are spray applied and contain inorganic HAP shall be applied in a booth or hangar in which air flow is directed downward onto or across the part of assembly being coated and exhausted through one or more outlets. (c) Pursuant to 40 CFR 63.745(g)(2), the Permittee must control the air stream from this operation by passing the air stream through a dry particulate filter system certified using the methods described in 40 CFR 63.750(o) to meet or exceed the efficiency data points in Table 1 and 2 of 40 CFR 63.745(g)(2). Pursuant to 40 CFR 63.745(g)(2)(iv), the following requirements shall be met for each dry particulate system used to comply with the primer and top coat inorganic HAP emissions standards in 40 CFR 63.745(g)(2)(i)(A): (1) maintain the system in good working order; (2) install a differential pressure gauge across the filter banks; (3) continuously monitor pressure drop across the filter and read and record the pressure drop across the filter once per shift; and (4) take corrective action when the pressure drop exceeds or falls below the filter manufacturer's recommended limit(s). (d) Pursuant to 40 CFR 63.745(g)(3), the Permittee shall comply with the requirements below. (1) If the pressure drop is outside of range, the permittee shall shut down the operation immediately and take corrective action. (2) If the booth maintenance procedures for the filter system have not been performed as scheduled, shut down the operation immediately and take corrective action. (3) The operation shall not be resumed until the pressure drop is returned within the specified range. (e) The requirements of 40 CFR 63.745(g)(1) through (3) do not apply to the situations listed in 40 CFR 63.745(g)(4).
D.2.7 Control Device Requirements [326 IAC 20-15-1] [40 CFR 63, Subpart GG] Pursuant to 40 CFR 63.743(b) dry particulate filter systems operated per the manufacturer's instructions are exempt from a startup, shutdown, and malfunction plan.Rolls Royce Corporation Page 48 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy D.2.8 Compliance Monitoring Requirements for Aerospace Manufacturing and Rework Facilities [326 IAC 20-15] [40 CFR 63.751, Subpart GG] The compliance monitoring requirements of 40 CFR 63.751 are applicable to the cleaning operations and dry particulate filter system. The Permittee shall perform monthly visual inspection requirements for enclosed spray gun cleaners pursuant to 40 CFR 63.751(a). The Permittee shall also continuously monitor, read and record the pressure drop once per shift pursuant to 40 CFR 63.751(c). D.2.9 VOC Emissions [326 IAC 8-2-9] Any change or modification to the facilities listed below which may increase the actuals before add-on controls shall obtain prior approval from the Office of Environmental Services (OES) and Office of Air Quality (OAQ). Current equipment operations are as follows: (a) paint booths identified as, N56a and N56b, VOC actual emissions before add-on controls of less than 15 pounds of VOC per day each; and (b) paint booths identified as, 0070-10a, 0070-10b, 0070-10c, and 0070-10d, VOC actual emissions before add-on controls of less than 15 pounds of VOC per day each. Compliance with this condition shall make the Miscellaneous Metal Parts Rule 326 IAC 8-2-9 not applicable. D.2.10 Particulate Matter Emissions [326 IAC 6-1-2(a)] Pursuant to 326 IAC 6-1-2(a) the PM emissions from each paint booth, identified as emission units 56Na, 56Nb, 0070-10a, 0070-10b, 0070-10c, and 0070-10d, shall not exceed 0.03 grains per dry standard cubic foot of exhaust air.
D.2.11 Preventive Maintenance Plan [326 IAC 2-7-5(13)] A Preventive Maintenance Plan, in accordance with Section B - Preventive Maintenance Plan, of this permit, is required for the dry filters and parametric monitoring associated with emission units N56a, N56b, 0070-10a, 0070-10b, 0070-10c, and 0070-10d. Compliance Determination Requirements

D.2.12 Compliance Testing and Procedures for Aerospace Manufacturing and Rework Facilities [326 IAC 20-15] [40 CFR 63.750, Subpart GG] The compliance test methods and procedures of 40 CFR 63.750 are to be used for demonstrating compliance with the cleaning operations. The specific requirements include the following: (a) The composition and vapor pressure requirements for cleaning operations shall be determined by the test methods and procedures specified in 40 CFR 63.750(a) and (b). (b) Dry particulate filters used to comply with 40 CFR 63.745(g)(2) must be certified by the filter manufacturer or distributor, paint/depainting booth supplier, and/or the facility owner or operator using method 319 in appendix A of subpart A of this part, to meet or exceed the efficiency data points found in Tables 1 and 2, or 3 and 4 of 40 CFR 63.745 for existing or new sources respectively as outlined in 40 CFR 63.750(o). Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]
D.2.13 Record Keeping Requirements (a) Pursuant to 40 CFR 63.752(a) and to demonstrate compliance with D.2.2, the Permittee shall fulfill all recordkeeping requirements specified in 40 CFR 63.10 (a), (b), (d), and (f).Rolls Royce Corporation Page 49 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy (b) Pursuant to 40 CFR 63.752(b)(1) Cleaning Operations: and to demonstrate compliance with D.2.2, record the following for each cleaning solvent used for the affected cleaning operations: (1) Name of the product; (2) The vapor pressure; and (3) Documentation showing the organic HAP constituents. (c) Pursuant to 40 CFR 63.752(b)(2) Hand-wipe Cleaning Operations : and to demonstrate compliance with D.2.2, record the following for each cleaning solvent used in hand wipe cleaning operations that complies with the composition requirements in 40 CFR 63.744(b)(1) or for semi-aqueous cleaning solvent used for flush cleaning operations: (1) name of each cleaning solvent used; (2) all data and calculations that demonstrate that the cleaning solvent complies with one of the composition requirements; and (3) annual records of the volume of each solvent used, from facility purchase or usage records. (d) Pursuant to 40 CFR 63.752(b)(3) and to demonstrate compliance with D.2.2, for each cleaning solvent used in hand-wipe cleaning operations that does not comply with the composition requirements in 40 CFR 63.744(b)(1), but does comply with the vapor pressure requirements in 40 CFR 63.744(b)(2): (1) The name of each cleaning solvent used; (2) The composite vapor pressure of each cleaning solvent used; (3) All vapor pressure test results, if appropriate, data, and calculations used to determine the composite vapor pressure of each cleaning solvent; and (4) The amount (in gallons) of each cleaning solvent used each month at each operation. (e) Pursuant to 40 CFR 63.752(b)(5) and to demonstrate compliance with D.2.2, record the following information for each leak identified from enclosed spray gun cleaners (1) source identification; and (2) date leak was discovered and repaired (f) Pursuant to 40 CFR 63.752(d) Primer and topcoat application operations--inorganic HAP emissions

and to demonstrate compliance with D.2.2, record the pressure drop across the dry filter system once each shift during which coating operations occur. The acceptable limit(s) of pressure drop, as specified by the filter manufacturer should be included in the log. (g) To document compliance with Condition D.2.8, the Permittee shall maintain records in accordance with (1) through (6) below. Records maintained for (1) through (6) shall be taken daily and shall be complete and sufficient to establish compliance with Condition D.2.8. (1) The VOC content of each coating material and solvent used. (2) The amount of coating material and solvent less water used on a daily basis. (A) Records shall include purchase orders, invoices, and material safety data sheets (MSDS) necessary to verify the type and amount used. (B) Solvent usage records shall differentiate between those added to coating and those used as cleanup solvents. (3) The weight of VOCs input each day.Rolls Royce Corporation Page 50 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy (h) To document compliance with Condition D.2.11, the Permittee shall maintain records of any additional inspections prescribed by the Preventive Maintenance Plan. (i) All records shall be maintained in accordance with Section C - General Record Keeping Requirements, of this permit.
D.2.14 Reporting Requirements (a) The Permittee shall submit a report that identifies the following information semi-annually unless otherwise specified. (1) Pursuant to 40 CFR 63.753(b) Cleaning operation (A) Any instance where a noncompliant cleaning solvent is used for a non-exempt hand-wipe cleaning operation (B) A list of any new cleaning solvents used for hand-wipe cleaning in the previous 6 months and, as appropriate, their composite vapor pressure or notification that they comply with the composition requirements specified in Sec. 63.744(b)(1) (C) Any instance where a noncompliant spray gun cleaning method is used (D) Any instance where a leaking enclosed spray gun cleaner remains unrepaired and in use for more than 15 days; and (E) If the operations have been in compliance for the semiannual period, a statement that the cleaning operations have been in compliance with the applicable standards. The Permittee shall also submit a statement of compliance signed by a responsible company official certifying that the facility is in compliance with all applicable requirements. (2) Pursuant to 40 CFR 63.753(c) Primer and topcoat application operations (A) All times when a primer or topcoat application operation was not immediately shut down when the pressure drop across a dry particulate filter system was outside the limit specified by the filter manufacturer (B) If the operations have been in compliance for the semiannual period, a statement that the operations have been in compliance with the applicable standards; and (C) Annual reports listing the number of times the pressure drop for each dry filter system was outside the limit specified by the filter manufacturer. (b) Pursuant to 40 CFR 63.9(j) any change in the information provided under 40 CFR 63.9 shall be reported to IDEM OAQ and OES in writing within 15 calendar days after the change. (c) All reports shall be submitted to the addresses listed in Section C - General Reporting Requirements, of this permit, using the reporting forms located at the end of this permit, or their equivalent, within thirty (30) days after the end of the calendar quarter being reported.Rolls Royce Corporation Page 51 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy SECTION D.3 FACILITY OPERATION CONDITIONS Facility Description [326 IAC 2-7-5(15)] (e) Degreasing operations, constructed prior to 1990, consisting of: (1) Two (2) Open Top Vapor Degreasers, identified as emission units 0070-13 and 0070- 31, using perchloroethylene as the solvent, reconstructed in 1997. (2) One (1) Open Top Vapor Degreasers, identified as emission units 0311-82 is permitted to use N-Propyl Bromide and Perchloroethylene as the solvent, reconstructed in 2000. (3) Portable Cold Cleaner Degreasing Tanks, used for degreasing parts, identified as emission unit 0070-12, using mineral spirits as the solvent exhausting into the building. (4) Spray cleaning booths, identified as emission unit 0070-14, using mineral spirts as the solvent exhausting outside the building. (The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.)

D.3.1 General Provisions Relating to HAPs [326 IAC 20-1-1] [40 CFR Part 63, Subpart A] The provisions of 40 CFR Part 63, Subpart A - General Provisions, which are incorporated as 326 IAC 20-1-1, apply to emission units 0070-13, 0070-31, and 0311-82, except when otherwise specified in 40 CFR Part 63, Subpart T. D.3.2 Applicability [326 IAC 20-6-1] [40 CFR Part 63, Subpart T] Facilities identified as 0070-13, 0070-31, and 0311-82 are subject to 40 CFR Part 63, Subpart T, (Halogenated Solvent Cleaning NESHAP), which is incorporated by reference as 326 IAC 20-6-1. Each of the following conditions apply to 0070-13, 0070-31, and 0311-82 except when otherwise specified. D.3.3 Halogenated Solvent Cleaning NESHAP [326 IAC 20-6-1] [40 CFR Part 63, Subpart T] (a) Pursuant to 40 CFR 63.463(a) each cleaning machine shall comply with the design requirements listed below: (1) Each cleaning machine shall have an idling and downtime mode cover, as described in 40 CFR 63.463(d)(1)(i), that may be readily opened or closed, that completely covers the cleaning machine openings when in place, and is free of cracks, holes, and other defects; (2) Each cleaning machine shall have a freeboard ratio of 0.75 or greater; (3) Each cleaning machine shall have an automated parts handling system capable of moving parts or parts baskets at a speed of 3.4 meters per minute (11 feet per minute) or less from the initial loading of parts through removal of cleaned parts; (4) Each vapor cleaning machine shall be equipped with a device that shuts off the sump heat if the sump liquid solvent level drops to the sump heater coils;Rolls Royce Corporation Page 52 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

(5) Each vapor cleaning machine shall be equipped with a vapor level control device that shuts off sump heat if the vapor level in the vapor cleaning machine rises above the height of the primary condenser; (6) Each vapor cleaning machine shall have a primary condenser; and (7) Each cleaning machine that uses a lip exhaust shall be designed and operated to route all collected solvent vapors through a properly operated and maintained carbon adsorber that meets the requirements of 40 CFR 63.463(e)(2)(vii). (b) Pursuant to 40 CFR 63.463(b) each batch vapor cleaning machine comply with the requirements listed below: (1) Pursuant to 40 CFR 63.463(b)(1)(i), emission units 0070-13 and 0311-82 shall employ the control combination of a freeboard refrigeration device and a freeboard ratio of 1.0. (2) Pursuant to 40 CFR 63.463(b)(2)(i), emission unit 0070-31 shall employ the control combination of a freeboard refrigeration device, reduced room draft, freeboard ratio of 1.0. (c) Pursuant to 40 CFR 63.463(d) each cleaning machine shall meet all of the work and operational practice requirements, for 0070-13, 0070-31, and 0311-82, listed below: (1) Cover(s) to each solvent cleaning machine shall be in place during the idling mode, and during the downtime mode unless either the solvent has been removed from the machine or maintenance or monitoring is being performed that requires the cover(s) to not be in place. (2) The parts baskets or the parts being cleaned in the cleaning machine shall not occupy more than 50 percent of the solvent/air interface area unless the parts baskets or parts are introduced at a speed of 0.9 meters per minute (3 feet per minute) or less. (3) Any spraying operations shall be done within the vapor zone or within a section of the solvent cleaning machine that is not directly exposed to the ambient air. (4) Parts shall be oriented so that the solvents drains from them freely. Parts having cavities or blind holes shall be tipped or rotated before being removed from any solvent cleaning machine unless an equally effective approach has been approved by the commissioner. (5) Parts baskets or parts shall not be removed from any solvent cleaning machine until dripping has stopped. (6) During startup of each vapor cleaning machine, the primary condenser shall be turned on before the sump heater. (7) During shutdown of each vapor cleaning machine, the sump heater shall be turned off and the solvent vapor layer allowed to collapse before the primary condenser is turned off.Rolls Royce Corporation Page 53 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

(8) When solvent is added or drained from any solvent cleaning machine, the solvent shall be transferred using threaded or other leak proof couplings and the end of the pipe in the solvent sump shall be located beneath the liquid solvent surface. (9) Each solvent cleaning machine and associated controls shall be maintained as recommended by the manufacturers of the equipment or using alternative maintenance practices that have been demonstrated to the commissioner’s satisfaction to achieve the same or better results as those recommended by the manufacturer. (10) Each operator of a solvent cleaning machine shall complete and pass the applicable sections of the test of solvent cleaning operating procedures in appendix B of 40 CFR 63, if requested during an inspection by the commissioner. (11) Waste solvents, still bottoms, and sump bottoms shall be collected and stored in closed containers. The closed containers may contain a device that would allow pressure relief, but would not allow liquid solvent to drain from the container. (12) Sponges, fabric, wood, and paper products shall not be cleaned. (d) Pursuant to 40 CFR 63.463(e) an exceedance has occurred if the following requirements are not met: (1) For Emission Unit 0070-31, if a reduced room draft is used to comply, the Permittee must establish and maintain the operating conditions under which the wind speed was demonstrated to be 15.2 meters per minute (50 feet per minute) or less as described in 40 CFR 63.466(d). (2) An exceedence occurs if the requirements, listed below, have not been met and are not corrected within 15 days of detection. Adjustments or repairs shall be made to the solvent cleaning system or control immediately upon adjustment or repair and demonstrated to be within required limits. (A) If a freeboard refrigeration device is used to comply with these standards, the owner or operator shall ensure that the chilled air blanket temperature (in deg.F), measured at the center of the air blanket, is no greater than 30 percent of the solvent's boiling point. (B) For Emission Unit 0070-31, if a reduced room draft is used to comply, the Permittee shall ensure that the flow or movement of air across the top of the freeboard area of the solvent cleaning machine or within the solvent cleaning machine enclosure does not exceed 15.2 meters per minute (50 feet per minute) at any time as measured using the procedures in 40 CFR 63.466(d). D.3.4 Halogenated Solvent Cleaning NESHAP [326 IAC 20-6-1] [40 CFR Part 63, Subpart T] (a) Pursuant to 40 CFR 63.466(a) and (a)(1), monitoring of equipment standards shall be conducted on a weekly basis using a thermometer or thermocouple to measure the temperature at the center of the air blanket during the idling mode for the freeboard refrigeration device. (b) Pursuant to 40 CFR 63.466(b) and (b)(1) the Permittee shall conduct monthly visual inspection to determine if the cover is opening and closing properly, completely coversRolls Royce Corporation Page 54 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

the cleaning machine openings when closed, and is free of cracks, holes, and other defects and record the results for the control devices (c) Pursuant to 40 CFR 63.466(c) and (c)(1) through (c)(4), the permittee shall monitor hoist speed monthly or quarterly monitoring, if one year of compliance without an exceedance is demonstrated. Monitoring shall determine the hoist speed by measuring the time it takes for the hoist to travel a measured distance. The speed is equal to the distance in meters divided by the time in minutes (meters per minute). D.3.5 Degreasing Operations [326 IAC 8-3-2] Pursuant to 326 IAC 8-3-2 (Cold Cleaner Operations), the Permittee shall ensure that the following control equipment requirements are met, unless more stringent requirements are applicable under 326 IAC 8-3-5 or 326 IAC 20-6 and 40 CFR 63 Subpart T: (a) Equip the cleaner with a cover; (b) Equip the cleaner with a facility for draining cleaned parts; (c) Close the degreaser cover whenever parts are not being handled in the cleaner; (d) Drain cleaned parts for at least fifteen (15) seconds or until dripping ceases; (e) Provide a permanent, conspicuous label summarizing the operation requirements; (f) Store waste solvent only in covered containers and not dispose of waste solvent or transfer it to another party, in such a manner that greater than twenty percent (20%) of the waste solvent (by weight) can evaporate into the atmosphere. D.3.6 Degreasing Operations [326 IAC 8-3-3] Pursuant to 326 IAC 8-3-3 (Open Top Vapor Degreasing Operations) the Permittee shall ensure that the following control equipment requirements are met, unless more stringent requirements are applicable under 326 IAC 8-3-6 or 326 IAC 20-6 and 40 CFR 63 Subpart T: (a) Equip the open top vapor degreaser with a cover that can be opened and closed easily without disturbing the vapor zone; (b) Keep the cover closed at all times except when processing workloads through the degreaser; (c) Minimize solvent carry-out by: (1) Racking parts to allow complete drainage; (2) Moving parts in and out of the degreaser at less than eleven (11) feet per minute; (3) Degreasing the workload in the vapor zone at least thirty (30) seconds or until condensation ceases; (4) Tipping out any pools of solvent on the cleaned parts before removal; (5) Allowing parts to dry within the degreaser for at least fifteen (15) seconds or until visually dry; (d) Not degrease porous or absorbent materials, such as cloth, leather, wood or rope; (e) Not occupy more than half of the degreaser’s open top area with the workload; (f) Not load the degreaser such that the vapor level drops more than fifty percent (50%) of the vapor depth when the workload is removed; (g) Never spray above the vapor level; (h) Repair solvent leaks immediately, or shut down the degreaser; (i) Store waste solvent only in covered containers and not dispose of waste solvent or transfer it to another party, such that greater than twenty percent (20%) of the waste solvent (by weight) can evaporate into the atmosphere;Rolls Royce Corporation Page 55 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy (j) Not use workplace fans near the degreaser opening; (k) Not allow visually detectable water in the solvent exiting the water separator; and (l) Provide a permanent, conspicuous label summarizing the operating requirements. D.3.7 Degreasing Operations [326 IAC 8-3-5] Pursuant to 326 IAC 8-3-5 (Cold Cleaner Degreaser Operation and Control) the Permittee shall ensure the following requirements are met, unless more stringent requirements are applicable under 326 IAC 8-3-2 or 326 IAC 20-6 and 40 CFR 63 Subpart T: (a) The Permittee shall ensure that the following operating requirements are met: (1) Equip the degreaser with a cover. The cover must be designed so that it can be easily operated with one (1) hand if: (A) The solvent volatility is greater than two (2) kiloPascals (fifteen (15) millimeters of mercury or three-tenths (0.3) pounds per square inch) measured at thirty-eight degrees Celsius (38 O C) (one hundred degrees Fahrenheit (100 O F)); (B) The solvent is agitated; or (C) The solvent is heated. (2) Equip the degreaser with a facility for draining cleaned articles. If the solvent volatility is greater than four and three-tenths (4.3) kiloPascals (thirty-two (32) millimeters of mercury) or six-tenths (0.6) pounds per square inch) measured at thirty-eight degrees Celsius (38 O C) (one hundred degrees Fahrenheit (100 O F)), then the drainage facility must be internal such that articles are enclosed under the cover while draining. The drainage facility may be external for applications where an internal type cannot fit into the cleaning system. (3) Provide a permanent, conspicuous label which lists the operating requirements outlined in subsection (b). (4) The solvent spray, if used, must be a solid, fluid stream and shall be applied at a pressure which does not cause excessive splashing. (5) Equip the degreaser with one (1) of the following control devices if the solvent volatility is greater than four and three-tenths (4.3) kiloPascals (thirty-two (32) millimeters of mercury) or six-tenths (0.6) pounds per square inch) measured at thirty-eight degrees Celsius (38 O C) (one hundred degrees Fahrenheit (100 O F)), or if the solvent is heated to a temperature greater than forty-eight and nine-tenths degrees Celsius (48.9 O C) (one hundred twenty degrees Fahrenheit (120 O F)): (A) A freeboard that attains a freeboard ratio of seventy-five hundredths (0.75) or greater. (B) A water cover when solvent used is insoluble in, and heavier than, water. (C) Other systems of demonstrated equivalent control such as a refrigerated chiller of carbon adsorption. Such systems shall be submitted to the U.S. EPA as a SIP revision.Rolls Royce Corporation Page 56 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy (b) The owner or operator of a cold cleaning facility shall ensure that the following operating requirements are met: (1) Close the cover whenever articles are not being handled in the degreaser. (2) Drain cleaned articles for at least fifteen (15) seconds or until dripping ceases. (3) Store waste solvent only in covered containers and prohibit the disposal or transfer of waste solvent in any manner in which greater than twenty percent (20%) of the waste solvent by weight could evaporate.
D.3.8 Degreasing Operations [326 IAC 8-3-6] Pursuant to 326 IAC 8-3-6 (Open top vapor degreaser operation and control requirements), for open top vapor degreasers existing as of July 1, 1990, emission units 0070-13, 0070-3, the Permittee shall ensure that the following control equipment requirements are met: (a) The Permittee shall ensure that the following control equipment requirements are met: (1) Equip the degreaser with a cover that can be opened and closed easily without disturbing the vapor zone. (2) Equip the degreaser with the following switches: (A) A condenser flow switch and thermostat which shuts off sump heat if condenser coolant stops circulating or becomes too warm. (B) A spray safety switch which shuts off spray pump if the vapor level drops more than ten (10) centimeters (four (4) inches). (3) Equip the degreaser with a permanent, conspicuous label which lists the operating requirements. (4) Equip the degreaser with one (1) of the following control devices: (A) A freeboard ratio of seventy-five hundredths (0.75) or greater and a powered cover if the degreaser opening is greater than one (1) square meter (ten and eight-tenths (10.8) square feet). (B) A refrigerated chiller. (C) An enclosed design in which the cover opens only when the article is actually entering or exiting the degreaser. (D) A carbon adsorption system with ventilation which, with the cover open, achieves a ventilation rate of greater than or equal to fifteen (15) cubic meters per minute per square meter (fifty (50) cubic feet per minute per square foot) of air to vapor interface area and an average of less than twenty-five (25) parts per million of solvent is exhausted over one (1) complete adsorption cycle. (E) Other systems of demonstrated equivalent or better control as those outlined in clauses (A) through (D). Such systems shall be submitted to the U.S. EPA as a SIP revision.Rolls Royce Corporation Page 57 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

(b) The Permittee shall ensure that the following operating requirements are met: (1) Keep the cover closed at all times except when processing workloads through the degreaser. (2) Minimize solvent carryout emissions by: (A) Racking articles to allow complete drainage; (B) Moving articles in and out of the degreaser at less than three and threetenths (3.3) meters per minute (eleven (11) feet per minute); (C) Degreasing the workload in the vapor zone at least thirty (30) seconds or until condensation ceases; (D) Tipping out any pools of solvent on the cleaned articles before removal; and (E) Allowing articles to dry within the degreaser for at least fifteen (15) seconds or until visually dry. (3) Prohibit the entrance into the degreaser of porous or absorbent materials such as, but not limited to, cloth, leather, wood, or rope. (4) Prohibit occupation of more than one-half (1/2) of the degreaser's open top area with the workload. (5) Prohibit the loading of the degreaser to the point where the vapor level would drop more than ten (10) centimeters (four (4) inches) when the workload is removed. (6) Prohibit solvent spraying above the vapor level. (7) Repair solvent leaks immediately or shut down the degreaser if leaks cannot be repaired immediately. (8) Store waste solvent only in covered containers and prohibit the disposal or transfer of waste solvent in any manner in which greater than twenty percent (20%) of the waste solvent by weight could evaporate. (9) Prohibit the exhaust ventilation rate from exceeding twenty (20) cubic meters per minute per square meter (sixty-five (65) cubic feet per minute per square foot) of degreaser open area unless a greater ventilation rate is necessary to meet Occupational Safety and Health Administration requirements. (10) Prohibit the use of workplace fans near the degreaser opening. (11) Prohibit visually detectable water in the solvent exiting the water separator.Rolls Royce Corporation Page 58 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]
D.3.9 Record Keeping Requirements (a) Pursuant to 40 CFR 63.467(a) the Permittee shall maintain records for emission units 0070-13, 0070-31, and 311-82, in written or electronic form for the life time of the machine as listed below: (1) Owners’s manuals or, if owners manual is not available, written maintenance and operating procedures, for the solvent cleaning machine and control equipment. (2) The date of installation of the solvent cleaning machine and all of its control devices. (3) Records of the halogenated HAP solvent content for each solvent used in a solvent cleaning machine subject to 40 CFR 63, Subpart T. (b) Pursuant to 40 CFR 63.467(b) the Permittee shall maintain records, for 0070-13, 0070- 31, and 311-82, in written or electronic form for a period of 5 years as listed below: (1) The results of control device monitoring required under 40 CFR63.466. (2) Information on the actions taken to comply with 40 CFR63.463(e). This information shall include records of written or verbal orders for replacement parts, a description of the repairs made, and additional monitoring conducted to demonstrate that monitored parameters have returned to accepted levels. (3) Estimates of annual solvent consumption for each solvent cleaning machine. D.3.10 Reporting Requirements (a) Pursuant to 40 CFR 63.468(f) the Permittee shall submit, for 0070-13, 0070-31, and 311- 82, an annual report by February 1 of each year following the one for which the reporting is being made. This report shall include the requirements as follows: (1) A signed statement from the facility owner or his designee stating that , “All operators of solvent cleaning machines have received training on the proper operation of solvent cleaning machines and their control devices sufficient to pass the test required in 40 CFR63.463(d)(10).” (2) An estimate of solvent consumption for each solvent cleaning machine during the reporting period. (b) Pursuant to 40 CFR 63.468(h), the Permittee shall submit an exceedance report for emission units 0070-13, 0070-31, and 311-82 to the US EPA, IDEM and OES semiannually except when, the Administrator of the US EPA determines on a case by case basis that more frequent reporting is necessary to accurately assess the compliance status of the source or an exceedance occurs. Once an exceedance has occurred the Permittee shall follow a quarterly reporting format until a request to reduce reporting frequency under paragraph 40 CFR 63.468(i) is approved. Exceedance reports shall be delivered or postmarked by the 30th day following the end of each calender half or quarter, as appropriate. The exceedance report shall include the applicable information as given below:Rolls Royce Corporation Page 59 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

(1) Information on the actions taken to comply with 40 CFR63. 463(e). This information shall include records of written or verbal orders for replacement parts, a description of the repairs made, and additional monitoring conducted to demonstrate that monitored parameters have returned to accepted levels. (2) If an exceedance has occurred, the reason for the exceedance and a description of the actions taken. (3) If no exceedances of a parameter have occurred, or a piece of equipment has not been inoperative, out of control, repaired, or adjusted, such information shall be stated in the report. (c) A summary of the information to document compliance with this Condition shall be submitted to the address listed in Section C - General Reporting Requirements, of this permit, and to the following address: United States Environmental Protection Agency, Region V Air and Radiation Division, Air Enforcement Branch - Indiana (AE-17J) 77 West Jackson Boulevard Chicago, Illinois 60604-3590Rolls Royce Corporation Page 60 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

SECTION D.4 FACILITY OPERATION CONDITIONS Facility Description [326 IAC 2-7-5(15)] (f) Miscellaneous sand and shot blast machines operations identified as: (1) Emission unit 0070-08, shot blasting, each controlled by a baghouse, exhausting out stack 5-8, constructed in 1964. (2) Emission unit 0070-N55, miscellaneous sanding and blasting, controlled by dust collector, exhausting out stack SN55, constructed in 1991. (3) Emission unit 0070-74, sand blasting, controlled by a baghouse, exhausting out stack 8-18, constructed prior to 1969. (g) Woodworking operations, prior to 1969, consisting of: (1) Emission unit 0070-72, controlled by dust collector, exhausting out stack 8-16, (2) Emission unit 0070-73, controlled by dust collector, exhausting out stack 8-17, (3) Emission unit 0070-05, controlled by dust collector, exhausting out stack 5-8. (The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.)

Emission Limitations and Standards [326 IAC 2-7-5(1)]
D.4.1 Particulate Matter (PM) [326 IAC 6-1-2(a)] Pursuant to 326 IAC 6-1-2(a)(Particulate Limitations), particulate matter (PM) emissions from emission units 0070-05, 0070-72, 0070-73, 0070-08, 0070-N55, and 0070-74 shall be limited to 0.03 grain per dry standard cubic foot of exhaust air.
D.4.2 General Operation Any change or modification which may increase potential emissions from the equipment covered in this permit shall obtain prior approval from the Office of Air Quality (OAQ).Rolls Royce Corporation Page 61 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy SECTION D.5 FACILITY OPERATION CONDITIONS Facility Description [326 IAC 2-7-5(15)] (h) Jet fueled turbine engines, constructed in 1955, identified as follows: (1) Two (2) emission units identified as 0070-66, with a maximum operating capacity of 107 million British thermal units per hour each, exhausting out stacks identified as 8- 11A and 8-11B; (2) Twelve (12) emission units identified as 0070-67, with a maximum operating capacity of 27.2 million British thermal units per hour each, exhausting out stacks identified 8- 13A through M respectively. (3) Ten (10) emission units identified as 0070-68, with a maximum operating capacity of 27.2 million British thermal units per hour each, exhausting out stacks identified as 8- 12A through J. (4) Four (4) emission units identified as 0070-69, with a maximum operating capacity of 27.2 million British thermal per hour units each, exhausting out stacks identified as 8- 14A through D. (The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.)

Facility Description [326 IAC 2-7-5(15)] (i) Three (3) American Shack Heaters, identified as emission unit 0070-70, exhausting out stacks identified 8-6A through C consisting of: (1) Two of the heaters are capable of being fired with distillate oil only and have a maximum heating put capacity of 93.4 million British thermal units per hour each; and (2) One of the heater is capable of being fired with either natural gas or distillate fuel and has a maximum heat input capacity of 90 million British thermal units per hour. (The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.)

Facility Description [326 IAC 2-7-5(15)] (j) Fifty three (53) Engine test stand cells identified below. These test stand cells are used to test engines manufactured at the source. The engines tested are fueled by either Jet fuel, Diesel #2 or Natural Gas. All test stand cells were constructed prior to 1977.

Emission Unit ID No. (s) Engine Test

Cell ID No.(s) Maximum Test Cell Capacity Type of Fuels Used Stack ID No. 0070-N3 109 5000 brake horsepower Jet fuel, Diesel SN3

0070-N4 111 10000 pounds of thrust Jet fuel SN4

0070-N5 113 10000 brake horsepower Jet fuel, Diesel & Natural Gas SN5Rolls Royce Corporation Page 62 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

SECTION D.5 FACILITY OPERATION CONDITIONS (Cont) Facility Description [326 IAC 2-7-5(15)] (j) (Cont)

Emission Unit ID No. (s) Engine Test

Cell ID No.(s) Maximum Test Cell Capacity Type of Fuels Used Stack ID No. 0070-N6 114 30000 pounds of thrust Jet fuel SN6

0070-N7 115 7000 brake horsepower Jet fuel, Diesel & Natural Gas SN7

0070-N8 116 5000 brake horsepower Jet fuel, Diesel SN8

0070-N9 117 5000 brake horsepower Jet fuel, Diesel SN9

0070-N10 118 5000 brake horsepower Jet fuel, Diesel SN10

0070-N11 119 5000 brake horsepower Jet fuel, Diesel & Natural Gas SN11

0070-N12 120 7000 brake horsepower Jet fuel, Diesel & Natural Gas SN12

0070-N13 121 10000 brake horsepower Jet fuel, Diesel SN13

0070-N14 122 9000 brake horsepower Jet fuel, Diesel SN14

0070-N15 123 5000 brake horsepower Jet fuel, Diesel & Natural Gas SN15

0070-N16 140 1500 brake horsepower Jet fuel SN16

0070-N17 141 750 brake horsepower Jet fuel SN17

0070-N18 142 800 brake horsepower Jet fuel SN18

0070-N19 143 750 brake horsepower Jet fuel SN19

0070-N20 144 750 brake horsepower Jet fuel SN20

0070-N21 145 750 brake horsepower Jet fuel SN21

0070-N22 146 1500 brake horsepower Jet fuel SN22

0070-N23 147 1500 brake horsepower Jet fuel SN23

0070-N24 148 1500 brake horsepower Jet fuel SN24

0070-N25 149 650 brake horsepower Jet fuel SN25

0070-N27 152 1500 brake horsepower Jet fuel SN27

0070-N34 843 10000 brake horsepower Jet fuel SN34(A, B)

0070-N35 861 9000 pounds of thrust Jet fuel, Diesel SN35

0070-N36 862 6000 brake horsepower Jet fuel, Diesel SN36

0070-N37 871 15000 brake horsepower Jet fuel, Diesel & Natural Gas SN37(A, B)

0070-N38 872 9000 brake horsepower Jet fuel, Diesel & Natural Gas SN38(A, B)

0070-N39 873 6000 brake horsepower Jet fuel SN39(A, B, C)Rolls Royce Corporation Page 63 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy SECTION D.5 FACILITY OPERATION CONDITIONS (Cont) Facility Description [326 IAC 2-7-5(15)] (j) (Cont)

Emission Unit ID No. (s) Engine Test

Cell ID No.(s) Maximum Test Cell Capacity Type of Fuels Used Stack ID No. 0070-N40 875 5000 brake horsepower Diesel SN40

0070-N41 881 10000 pounds of thrust Jet fuel SN41(A, B)

0070-N42 882 30000 pounds of thrust Jet fuel SN42 (A, B, C, D, E, F) 0070-N43 883 2500 brake horsepower Jet fuel SN43(A, B)

0070-N44 884 2000 brake horsepower Jet fuel SN44

0070-N45 885 800 brake horsepower Jet fuel, Diesel SN45(A, B)

0070-N46 886 30000 pounds of thrust Jet fuel, Diesel SN46 (A, B, C, D) 0070-N47 893 500 pounds of thrust Diesel SN47

0070-N48 894 350 brake horsepower Diesel SN48

0070-N29 821 10 pounds/second air Jet fuel, Diesel & Natural Gas SN29 (A, B)

0070-N29a 821 8 MMBtu/hr No. 2 Diesel fuel SN29C
0070-N30 822 50 pounds/second air Jet fuel, Diesel & Natural Gas SN30(A, B)

0070-N30a 822 8 MMBtu/hr No. 2 Diesel fuel SN30C
0070-N31 823 60 pounds/second air Jet fuel, Diesel & Natural Gas SN31(A, B)

0070-N31a 823 8 MMBtu/hr No. 2 Diesel fuel SN31C
0070-N32 824 90 pounds/second air Jet fuel, Diesel & Natural Gas SN32(A, B)

0070-N32a 824 8 MMBtu/hr No. 2 Diesel fuel SN32C
0070-N33 826 10 pounds/second air Jet fuel, Diesel SN33(A, B)

0070-N33a 826 8 MMBtu/hr No. 2 Diesel fuel SN33C
0070-N54 8137 10 pounds/second air Jet fuel, Diesel & Natural Gas SN54

0070-N54a 8137 12.5 MMBtu/hr No. 2 Diesel fuel Not Available

0070-N55 8126 0.5 pounds/second air Jet fuel, Diesel & Natural Gas Not Available

0070-N56 8128 1 pounds/second air Jet fuel, Diesel & Natural Gas Not Available (The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.)Rolls Royce Corporation Page 64 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy SECTION D.5 FACILITY OPERATION CONDITIONS(Cont.) Facility Description [326 IAC 2-7-5(15)] (k) One (1) engine test cell, identified as emission unit 00311-83. The engines tested in this test cell have a operating capacity of 10,000 pounds of thrust and are fired with Jet A fuel. A maximum of six engines per day can be tested in this test cell. Emissions from this test cell are exhausted out stack 5-83 and are not controlled. This emission unit was initially constructed prior to 1970 and modified in 1999. (The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.) Emission Limitations and Standards [326 IAC 2-7-5(1)]
D.5.1 Particulate Matter (PM) [326 IAC 6-1-2(a)] Pursuant to 326 IAC 6-1-2(a)(Particulate Limitations), particulate matter (PM) emissions from emission units 0070-66, 0070-67, 0070-68, 0070-69, 0070-70a, 0070-70b, 0070-70c, 0070- N3 through 0070- N54, and 00311-83 shall be limited to 0.03 grain per dry standard cubic foot of exhaust air. D.5.2 Sulfur Dioxide (SO 2 ) [326 IAC 7-1.1-2(a)] Pursuant to 326 IAC 7-1.1-2(a) (SO 2Emissions Limitations) the SO 2emissions from emission units 0070- 70a, 0070- 70b, 0070- 70c, 0070- N3 through 0070- N54, and 00311-83, shall not exceed five tenths (0.5) pounds per MMBtu heat input, when combusting distillate oil alone or simultaneous with any fuel permitted fuel

. D.5.3 PSD Minor NOx Limit [326 IAC 2-2] [40 CFR 52.21] Pursuant to Part 70 Significant Source Modification issued December 28, 1999, the NO x emissions from the Test Cell 00311-83 shall not exceed 0.1409 pounds per gallon or 62 pounds per hour and shall combust less than 567,779 gallons of Jet A fuel per twelve (12) month period with compliance determined at the end of each month. This fuel usage limitation is equivalent to 40 tons of NOx emissions per twelve (12) consecutive month period. Compliance with this limit makes 326 IAC 2-2 (Prevention of Significant Deterioration) and 40 CFR 52.21 not applicable. Compliance Determination Requirements D.5.4 Sulfur Dioxide Emissions and Sulfur Content Compliance shall be determined utilizing one of the following options. (a) Pursuant to 326 IAC 3-7-4, the Permittee shall demonstrate that the fuel oil sulfur content does not exceed five-tenths percent (0.5%) by weight by: (1) Providing vendor analysis of fuel delivered, if accompanied by a certification; (2) Analyzing the oil sample to determine the sulfur content of the oil via the procedures in 40 CFR 60, Appendix A, Method 19. (A) Oil samples may be collected from the fuel tank immediately after the fuel tank is filled and before any oil is combusted; and (B) If a partially empty fuel tank is refilled, a new sample and analysis would be required upon filling; orRolls Royce Corporation Page 65 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy (b) Compliance may also be determined by conducting a stack test for sulfur dioxide emissions from the thirteen (13) MMBtu per hour heater, fifty one (51) Engine test stand cells identified as emission units 0070-N3 through 0070-N54 , and Test Cell 00311-83 using 40 CFR 60, Appendix A, Method 6 in accordance with the procedures in 326 IAC 3- 6. A determination of noncompliance pursuant to either of the methods specified in (a) or (b) above shall not be refuted by evidence of compliance pursuant to the other method. Record Keeping and Reporting Requirement [326 IAC 2-7-5(3)] [326 IAC 2-7-19]
D.5.5 Record Keeping Requirements (a) To document compliance with condition D.5.3, the Permittee shall maintain records of the amount of Jet A fuel combusted in Test Cell 00311-83 on a monthly basis. (b) To document compliance with Condition D.5.2 and D.5.4, the Permittee shall maintain records in accordance with (1) through (6) below. (1) Calendar dates covered in the compliance determination period; (2) Actual fuel oil usage since last compliance determination period and equivalent sulfur dioxide emissions; (3) A certification, signed by the owner or operator, that the records of the fuel supplier certifications represent all of the fuel combusted during the period; and If the fuel supplier certification is used to demonstrate compliance, the following, as a minimum, shall be maintained: (4) Fuel supplier certifications; (5) The name of the fuel supplier; and (6) A statement from the fuel supplier that certifies the sulfur content of the fuel oil. The Permittee shall retain records of all recording/monitoring data and support information for a period of five (5) years, or longer if specified elsewhere in this permit, from the date of the monitoring sample, measurement, or report. Support information includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. (c) All records shall be maintained in accordance with Section C - General Record Keeping Requirements, of this permit. D.5.6 Reporting Requirements A quarterly summary of the information to document compliance with Condition D.5.3 shall be submitted to the addresses listed in Section C - General Reporting Requirements, of this permit, using the reporting forms located at the end of this permit, or their equivalent, within thirty (30) days after the end of the being reported.Rolls Royce Corporation Page 66 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy SECTION D.6 FACILITY OPERATION CONDITIONS Facility Description [326 IAC 2-7-5(15)] (l) Chrome plating and anodizing line consisting of seven (7) chromium tanks (six hard chrome electroplating tanks and one anodizing tank), identified as 0070-99, with a common add-on air pollution control device with a maximum cumulative potential rectifier capacity of less than 60 million amp-hr/yr, controlled using a composite mesh pad system, identified as ID 253155, which exhausts out stack 5-99. This facility was installed October 6, 1997 consisting of: (1) Six (6) hard chrome electroplating tanks 1-11, 1-12, 1-13, 1-14, 1-15, 1-16 and (2) One (1) anodizing tank 2-20. (The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.) Emission Limitations and Standards [326 IAC 2-7-5(1)]
D.6.1 General Provisions Relating to HAPs [326 IAC 20-1-1] [40 CFR Part 63, Subpart A] The provisions of 40 CFR Part 63, Subpart A - General Provisions, which are incorporated by reference as 326 IAC 20-1-1, apply to the facility described in this section except when otherwise specified in Table 1 of 40 CFR Part 63. The Permittee shall comply with the requirements of this condition on and after the compliance date for the tanks. D.6.2 Applicability of the Chromium Electroplating and Anodizing NESHAP [326 IAC 20-8-1][40 CFR Part 63, Subpart N] The provisions of 40 CFR 63, Subpart N - National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks, which are incorporated by reference as 326 IAC 20-8-1, apply to the tanks identified as 0070-99. The Permittee shall comply with the requirements of this condition on and after the compliance date for the tanks. The emission limitations apply during operation, start-up and shutdown. The emission limitations do not apply during periods of malfunction, but the work practice standards that address operation and maintenance and that are required by 40 CFR 63.342(f) must be followed during malfunctions. D.6.3 Chromium Emissions Limitation [326 IAC 20-8-1][40 CFR 63.342] [40 CFR 63.344] (a) Pursuant to 40 CFR 63.342(b)(1) the emission limitations in this section apply only during tank operation, and also apply during periods of startup and shutdown as these are routine occurrences for affected sources subject to this subpart. The emission limitations do not apply during periods of malfunction, but the work practice standards that address operation and maintenance must be followed during malfunctions. (b) Pursuant to 40 CFR 63.342(b)(2) If a Permittee is controlling a group of tanks with a common add-on air pollution control device, the emission limitations apply whenever any one affected source is operated. (c) Pursuant to 40 CFR 63.342(b)(2)(iii) The emission limitation shall be calculated according to Sec. 63.344(e)(4). (1) Pursuant to 40 CFR 63.344(e)(4) when multiple affected sources performing different types of operations are controlled by a common add-on air pollution control device that may or may not also be controlling emissions from sourcesRolls Royce Corporation Page 67 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy not affected by these standards, or if the affected sources controlled by the common add-on air pollution control device perform the same operation but are subject to different emission limitations (A) Based on the calculations set forth in 63.344(e) and the Notification of Compliance Status dated April 8, 1998, the Permittee shall not allow the concentration of total chromium in the exhaust gas stream discharged to the atmosphere from the control system, identified as 253155, to exceed: (i) 0.015 milligrams of total chromium per dry standard cubic meter (mg/dscm) of ventilation air [6.6 x 10 -6gr/dscf] for the six (6) hard chrome electroplating tanks, identified as 1-11, 1-12, 1-13, 1-14, 1-15, 1-16; and (ii) 0.010 mg/dscm [4.4 x 10 -6gr/dscf] for the one (1) anodizing tank, identified as, 2-20. (d) Pursuant to 40 CFR 63.344 (e)(6) these procedures shall be repeated if a tank is added or removed from the control system regardless of whether that tank is a nonaffected source. If the new nonaffected tank replaces an existing nonaffected tank of the same size and is connected to the control system through the same size inlet duct then this procedure does not have to be repeated. D.6.4 Work Practice Standards [326 IAC 20-8-1][40 CFR 63, Subpart N] The following work practice standards apply to the seven (7) chromium tanks: (a) Pursuant to 40 CFR 63.342(f)(1)(i), at all times, including periods of startup, shutdown, malfunction, the Permittee shall operate and maintain the seven (7) chromium tanks , including the composite mesh pad system, identified as ID 253155, and parametric monitoring equipment, in a manner consistent with good air pollution control practices, consistent with the Operation and Maintenance Plan (OMP). (b) Pursuant to 40 CFR 63.342(f)(1)(ii) , malfunctions shall be corrected as soon as practicable after their occurrence in accordance with the OMP. (c) Pursuant to 40 CFR 63.342(f)(1)(iii), these operation and maintenance requirements are enforceable independent of emissions limitations or other requirements in this section. (d) Pursuant to 40 CFR 63.342(f)(2)(i), determination of whether acceptable operation and maintenance procedures are being used will be based on information available to U.S. EPA, IDEM, OAQ, and OES, which may include, but is not limited to, monitoring results; review of the OMP, procedures, and records; and inspection of the source. (e) Pursuant to 40 CFR 63.342(f)(2)(ii) and based on the results of a determination made under paragraph (d) of this condition, U.S. EPA, IDEM, OAQ, and OES may require that the Permittee make changes to the OMP. Revisions may be required if U.S. EPA, IDEM, OAQ, and OES, finds that the plan: (1) Pursuant to 40 CFR 63.342(f)(2)(ii)(A), does not address a malfunction or period of excess emissions that has occurred; (2) Pursuant to 40 CFR 63.342(f)(2)(ii)(B), fails to provide for the operation of the seven (7) chromium tanks , the air pollution control techniques, or the composite mesh pad system, identified as ID 253155, and parametric monitoring equipment during a malfunction in a manner consistent with good air pollution control practices; orRolls Royce Corporation Page 68 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

(3) Pursuant to 40 CFR 63.342(f)(2)(ii)(C), does not provide adequate procedures for correcting malfunctioning tanks, air pollution control techniques, or parametric monitoring equipment as quickly as practicable. D.6.5 Operation and Maintenance Plan [326 IAC 20-8-1][40 CFR 63, Subpart N] (a) Pursuant to 63.342(f)(3)(i), the Permittee shall prepare an Operation and Maintenance Plan (OMP) to be implemented no later than the startup date of the seven (7) chromium tanks. The plan shall include the following elements: (1) Pursuant to 40 CFR 63.342(f)(3)(i)(A), the OMP shall specify the operation and maintenance criteria for the seven (7) chromium tanks , the composite mesh pad system, identified as ID 253155, and parametric monitoring equipment, and shall include a standardized checklist to document the operation and maintenance of this equipment; (2) Pursuant to 40 CFR 63.342(f)(3)(i)(B), the OMP shall incorporate the work practice standards as identified in Table 1 of 40 CFR 63.342. A summary of work practice standards for the Permittee’s composite mesh-pad system (CMP) from the Table is listed below: (A) Quarterly visual inspections of the device to ensure there is proper drainage, no chromic acid buildup on the pads, and no evidence of chemical attack on the structural integrity of the device. (B) Quarterly visual inspection of the back portion of the mesh pad closest to the fan to ensure there is no breakthrough of chromic acid mist. (C) Quarterly visual inspection of the duct work from the tank to the control device to ensure there are no leaks. (D) Perform washdown of the composite mesh-pads in accordance with manufacturers recommendations. (3) Pursuant to 40 CFR 63.342 (f)(3)(i)(D), the OMP shall specify procedures to be followed to ensure that equipment or process malfunctions due to poor maintenance or other preventable conditions do not occur

. (4) Pursuant to 40 CFR 63.342(f)(3)(i)(E), the OMP shall include a systematic procedure for identifying malfunctions of the seven (7) chromium tanks , the composite mesh pad system, identified as ID 253155, and parametric monitoring equipment and for implementing corrective actions to address such malfunctions. (b) Pursuant to 40 CFR 63.342(f)(3)(ii), if the OMP fails to address or inadequately addresses an event that meets the characteristics of a malfunction at the time the plan is initially developed, the Permittee shall revise the OMP within forty-five (45) days after such an event occurs. The revised plan shall include procedures for operating and maintaining the seven (7) chromium tanks , the composite mesh pad system, identified as ID 253155, or parametric monitoring equipment during similar malfunction events, and a program for corrective action for such events. (c) Pursuant to 40 CFR 63.342(f)(3)(iv), if actions taken by the Permittee during periods of malfunction are inconsistent with the procedures specified in the OMP, the Permittee shall record the actions taken for that event and shall report by phone such actions within two (2) working days after commencing actions inconsistent with the plan. This report shall beRolls Royce Corporation Page 69 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

followed by a letter within seven (7) working days after the end of the event, unless the Permittee makes alternative reporting arrangements, in advance, with U.S. EPA, IDEM, OAQ, and OES. (d) Pursuant to 40 CFR 63.342 (f)(3)(v), the Permittee shall keep the written operation and maintenance plan on record after it is developed to be made available for inspection, upon request, by the U.S. EPA, IDEM, OAQ, and OES, for the life of the affected source or until the source is no longer subject to the provisions of this subpart. In addition, if the operation and maintenance plan is revised, the Permittee shall keep previous (i.e., superseded) versions of the operation and maintenance plan on record to be made available for inspection, upon request, by the EPA, IDEM, OAQ, and OES, for a period of five (5) years after each revision to the plan. (e) Pursuant to 40 CFR 63.342(f)(3)(vi), to satisfy the OMP requirements, the Permittee may use applicable standard operating procedure (SOP) manuals, Occupational Safety and Health Administration (OHSA) plans, or other existing plans as the OMP, provided the alternative plan(s) meet the requirements in 40 CFR 63.342(f)(3). D.6.6 Monitoring to Demonstrate Continuous Compliance [326 IAC 20-8-1][40 CFR 63, Subpart N] Pursuant to 40 CFR 63.343(c)(1)(ii) the Permittee shall monitor and record the pressure drop across the composite mesh pad system once each day that any one or all of the seven (7) chromium tanks is in operation. To be in compliance with the standards, the composite mesh pad system pressure drop value shall be operated at 4.0 ± 1 inch of water column. Compliance Determination Requirements [326 IAC 2-1.1-11] [326 IAC 2-7-6(1)]
D.6.7 Performance Testing [326 IAC 2-1.1-11] [326 IAC 2-7-6(1)] [40 CFR 63.343(b)(2)] [40 CFR 63.7] [40 CFR 63.344] (a) Pursuant to 40 CFR 63.343(c)(1)(i), a performance test demonstrating initial compliance was performed on March 11, 1998 for the seven (7) chromium tanks, including the composite mesh pad system, identified as 253155, and parametric monitoring equipment. During the initial performance test, it was determined that the average pressure drop across the composite mesh pad system was 4.0 inches of water and the average outlet chromium concentration is 0.0037 mg/dscm. The compliant range was established as a result of an average pressure drop measured over the three test runs of one performance test. (b) The Permittee is not required to further test the seven (7) chromium tanks, including the composite mesh pad system, identified as 253155, by this permit. However, IDEM or OES may require testing when necessary to determine if the seven (7) chromium tanks, including the composite mesh pad system, identified as 253155, are in compliance. If testing is required by IDEM or OES, compliance with the limits specified in Condition D.6.3 shall be determined by a performance test conducted in accordance with 40 CFR 63.344 and Section C - Performance Testing. (c) Any change, modification, or reconstruction of the seven (7) chromium tanks, including the composite mesh pad system, identified as 253155, may require additional performance testing conducted in accordance with 40 CFR 63.344 and Section C - Performance Testing.Rolls Royce Corporation Page 70 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]
D.6.8 Record Keeping Requirements [326 IAC 2-7-5(3)] [40 CFR 63.346] Pursuant to 326 IAC 2-7-5(3)(B) and 40 CFR 63.346(a), (b), and (c) the Permittee shall maintain records to document compliance with Conditions D.6.3, D.6.4, D.6.5, and D.6.6 using the forms provided with this permit or their equivalent. These records shall be maintained in accordance with 40 CFR 63.346(c) and Section C - General Record Keeping Requirements of this permit and include a minimum of the following: (a) Pursuant to 40 CFR 63.346(b)(1), inspection records for the composite mesh pad system, identified as ID 253155, and parametric monitoring equipment to document that the inspection and maintenance required by Conditions D.6.4 and D.6.5 have taken place. The record can take the form of a checklist and should identify the following: (1) The device inspected; (2) The date of inspection; (3) A brief description of the working condition of the device during the inspection, and (4) Any actions taken to correct deficiencies found during the inspection. (b) Pursuant to 40 CFR 63.346(b)(2), records of all maintenance performed on the seven (7) chromium tanks , the composite mesh pad system, identified as ID 253155, and parametric monitoring equipment; (c) Pursuant to 40 CFR 63.346(b)(3), records of the occurrence, duration, and cause (if known) of each malfunction of the seven (7) chromium tanks , the composite mesh pad system, identified as ID 253155, and parametric monitoring equipment; (d) Pursuant to 40 CFR 63.346(b)(4), records of actions taken during periods of malfunction when such actions are inconsistent with the OMP; (e) Pursuant to 40 CFR 63.346(b)(5), other records, which may take the form of checklists, necessary to demonstrate consistency with the provisions of the OMP; (f) Pursuant to 40 CFR 63.346(b)(6) , test reports documenting results of all performance tests; (g) Pursuant to 40 CFR 63.346(b)(7), all measurements as may be necessary to determine the conditions of performance tests, including measurements necessary to determine compliance with the special compliance procedures of section 63.344(e); (h) Pursuant to 40 CFR 63.346(b)(8), records of monitoring data required by 40 CFR 63.343(c) that are used to demonstrate compliance with the standard including the date and time the data are collected; (i) Pursuant to 40 CFR 63.346(b)(9), 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;Rolls Royce Corporation Page 71 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy (j) Pursuant to 40 CFR 63.346(b)(10), 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; (k) Pursuant to 40 CFR 63.346(b)(11), the total process operating time of the seven (7) chromium tanks during the reporting period; (l) Pursuant to 40 CFR 63.346(b)(16), all documentation supporting the notifications and reports required by 40 CFR 63.9 and 40 CFR 63.10 and 40 CFR 63.347(Reporting Requirements). D.6.9 Reporting Requirements The notifications and reports required in this section shall be submitted to the US EPA, IDEM, OAQ, and OES using the addresses specified in Section C - General Reporting Requirements of this permit and to the following address: United States Environmental Protection Agency, Region V Air and Radiation Division, Air Enforcement Branch - Indiana (AE-17J) 77 West Jackson Boulevard Chicago, Illinois 60604-3590 (a) Notifications: (1) Initial Notifications The Permittee shall notify U.S. EPA, IDEM, OAQ, and OES in writing that the source is subject to 40 CFR Part 63, Subpart N. The notification shall be submitted no later than one hundred eighty (180) days after the compliance date and shall contain the information listed in 40 CFR 63.347(c)(1). (2) Pursuant to 40 CFR 63.347(e)(1) & (2) A Notification of Compliance Status (NCS) is required each time that the facility becomes subject to the requirements of 40 CFR Part 63, Subpart N. (A) The NCS shall be submitted to U. S. EPA, IDEM, OAQ, and OES, and shall list, for each tank, the information identified in 40 CFR 63.347(e)(2). (B) Pursuant to Agreed Order EPA-5-98-113(a)-IN-8, item No. 19 and 40 CFR 63.347(e)(1) & (2), the NCS for the seven (7) chromium tanks was submitted to U. S. EPA, IDEM, OAQ, and OES April 8, 1998. (3) Notification of Construction or Reconstruction Pursuant to 40 CFR 63.345(b)(1), no person may construct a new affected source or reconstruct an affected source subject to this subpart, or reconstruct a sourcesuch that it becomes an affected source subject to this subpart (including nonaffected tanks defined in 40 CFR 63.344(e)), without submitting a notification of construction or reconstruction to the US EPA, IDEM, OAQ, and OES. The notification shall contain the information pursuant to 40 CFR 63.345(b) paragraphs (2) and (3), as appropriate. (A) A change, modification, or reconstruction of this facility includes any change in the air pollution control techniques, the addition of add-on control devices, or the construction of duct work for the purpose of controlling both existing tanks and non-affected facilities by a common control technique or device (i.e. the addition of duct work to the CMP system).Rolls Royce Corporation Page 72 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy (B) A complete application to construct new chromium electroplating or chromium anodizing tanks serves as this notification. Likewise, the complete application to modify or reconstruct the seven (7) chromium tanks serves as this notification. (C) Pursuant to 326 IAC 2-1.1-2(a), permission must be received from IDEM, OAQ and OES before construction, modification, or reconstruction may commence. (b) Performance Test Results Pursuant to 40 CFR 63.344 (e)(6), the permittee shall repeat the compliance demonstration procedures, if a tank is added or removed from the control system regardless of whether that tank is a nonaffected source. If the new nonaffected tank replaces an existing nonaffected tank of the same size and is connected to the control system through the same size inlet duct then this procedure does not have to be repeated. The Permittee shall document results from future performance tests in a complete test report that contains the information required in 40 CFR 344(a) and (e). The Permittee shall submit reports of performance test results as part of the Notification of Compliance Status, described in 40 CFR 63.347(e), no later than forty-five (45) days following the completion of the performance test. (c) Ongoing Compliance Status Report Pursuant to 40 CFR 63.347(g)(1), the Permittee shall prepare summary reports to document the ongoing compliance status of the seven (7) chromium tanks , the composite mesh pad system, identified as ID 253155, and parametric monitoring equipment using the Ongoing Compliance Status Report form provided with this permit or its equivalent. This report shall contain the information specified in 40 CFR 63.347(g)(3). Because seven (7) chromium tanks located at a site that is a major source of hazardous air pollutants (HAPs), the Ongoing Compliance Status Report shall be completed and submitted according to the following schedule. (1) This report shall be submitted semiannually on a calendar year basis, unless otherwise directed by the US EPA, IDEM, OAQ, or OES. The report shall be submitted within thirty (30) days after the end of each reporting period (which ends June 30 and December 31 respectively). (2) Pursuant to 40 CFR 63.347(g)(1)(ii), if the monitoring data collected by the Permittee in accordance with 40 CFR 63.343(c) show that the emission limit has been exceeded, quarterly reports shall be submitted. Once the Permittee reports an exceedance as defined above, Ongoing Compliance Status Reports shall be submitted quarterly until a request to reduce reporting frequency in accordance with 40 CFR 63.347(g)(2) is approved. (3) Pursuant to 40 CFR 63.347(g)(1)(i), U.S. EPA, IDEM, OAQ, or OES may determine on a case-by-case basis that more frequent reporting is necessary to accurately assess the compliance status of this facility.Rolls Royce Corporation Page 73 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy SECTION D.7 FACILITY OPERATION CONDITIONS Facility Description [326 IAC 2-7-5(15)]: Insignificant activities Storage vessels, containing volatile organic liquid, identified as tank 1 through 6 and 9 through 20 at plant 5 and tanks 1 through 5 at plant 8. Each tank has a capacity greater than 40 cubic meters but less than 75 cubic meters and a construction date after July 23, 1984. Classified documents incinerator with a maximum rated capacity of 125 pounds per two hour cycle. (The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.) Emission Limitations and Standards [326 IAC 2-7-5(1)] [326 IAC 8-4][326 IAC 12]
D.7.1 Applicability [IAC 12-1-1][40 CFR 60, Subpart Kb] The emission standards contained in 40 CFR Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels are applicable to the storage vessels identified as tank 1 through 6 and 9 through 20 at plant 5 and tanks 1 through 5 at plant 8. Tanks 1 through 6 and 9 through 20 at plant 5 and tanks 1 through 5 at plant 8 are specifically regulated by applicability and designation of affected facility 60.110b(a) and (b).
D.7.2 Incinerators [40 CFR 52, Subpart P] Pursuant to 40 CFR 52, Subpart P, the confidential document incinerator shall: (a) consist of primary and secondary chambers or the equivalent; (b) be equipped with a primary burner unless burning wood products; (c) comply with 326 IAC 5-1 and 326 IAC 2; (d) be maintained properly as specified by the manufacturer and approved by the commissioner; (e) be operated according to the manufacturer’s recommendations and only burn waste approved by the commissioner; (f) comply with other state and/or local rules or ordinances regarding installation and operation of incinerators; (g) be operated so that emissions of hazardous material including, but not limited to, viable pathogenic bacteria, dangerous chemicals or gases, or noxious odors are prevented; (h) not emit particulate matter in excess of three-tenths (0.3) pounds of particulate matter per one thousand (1,000) pounds of dry exhaust gas at standard conditions corrected to fifty percent (50%) excess air. (i) not create a nuisance or a fire hazard. If any of the above result, the burning shall be terminated immediately. This condition will remain applicable until the revisions to 326 IAC 4-2 are approved into the SIP and the condition is modified in a subsequent permit action. D.7.3 Incinerators [326 IAC 4-2] Pursuant to 326 IAC 4-2, the confidential document incinerator shall: (a) Consist of primary and secondary chambers or the equivalent;Rolls Royce Corporation Page 74 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy (b) Be equipped with a primary burner; (c) Comply with 326 IAC 5-1 and 326 IAC 2; (d) Be maintained, operated and burn waste in accordance with : (1) manufacturers specifications; or (2) an operation and maintenance plan that complies with the following: (A) be designed to meet the PM emission limitation specified in subsection (a)(5) and include the following: procedures for receiving, handling and charging waste, procedures for incinerator startup and shutdown, procedures for responding to a malfunction, procedures for maintaining proper combustion air supply levels, procedures for operating the incinerator and associated air pollution control systems, procedures for handling ash, and a list of wastes that can be burned in the incinerator. (B) each incinerator operator shall review the plan before initial implementation of the operation and maintenance plan and annually thereafter. (C) be readily accessible to incinerator operators. (D) the owner or operator of the incinerator shall notify the department, in writing, thirty days after the operation and maintenance plan is initially developed pursuant to this section. (e) Not emit particulate matter in excess of three tenths (0.3) pound of particulate matter per one thousand (1,000) pounds of dry exhaust has under standard conditions corrected to fifty percent (50%) excess air. (f) The owner or operator of the incinerator must make the manufacturer’s specifications or the operation and maintenance plan available to the department upon request. If any of the requirements of (a) through (d) above are not met, then the owner or operator shall stop charging the incinerator until adjustments are made that address the underlying cause of the deviation. This condition is not federally enforceable.
D.7.4 Carbon Monoxide [40 CFR 52, Subpart P] Pursuant to 40 CFR 52, Subpart P, the confidential document incinerator shall not cause or allow the discharge of carbon monoxide from refuse incineration or burning equipment, unless the waste gas stream is burned in a direct-flame afterburner.
D.7.5 Carbon Monoxide [326 IAC 9-1] Pursuant to 326 IAC 9-1-2 (Carbon Monoxide Emission Limits, the incinerator shall not be operated unless the waste gas stream is burned in a direct-flame afterburner or a secondary chamber. This condition is not federally enforceable. Record Keeping and Reporting Requirements [326 IAC 2-8-4(3)] [326 IAC 2-8-16]
D.7.6 Record Keeping Requirements (a) Pursuant to 40 CFR 60.110(b), the record keeping requirements contained in 40 CFR 60.116(b) and (a) are applicable to the storage vessels identified as tank 1 through 6 and 9 through 20 at plant 5 and tanks 1 through 5 at plant 8. The Permittee is required to: (1) Keep readily accessible records showing the dimension of the storage vessel and an analysis showing the capacity of the storage vessel; (2) The records required in (1) above, shall be kept for the life of the source. (b) All records shall be maintained in accordance with Section C - General Record Keeping Requirements.Rolls Royce Corporation Page 75 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy 

## INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY COMPLIANCE DATA SECTION

and INDIANAPOLIS OFFICE OF ENVIRONMENTAL SERVICES

AIR QUALITY MANAGEMENT SECTION

DATA COMPLIANCE 

## PART 70 OPERATING PERMIT CERTIFICATION

Source Name: Rolls Royce Corporation Source Address: 2001 and 2355 S. Tibbs Avenue, Indianapolis, IN 46241 Mailing Address: P.O. Box 420 (N-23), Indianapolis, Indiana 46206-0420 Part 70 Permit No.: T097-7238-00311 This certification shall be included when submitting monitoring, testing reports/results or other documents as required by this permit. Please check what document is being certified:
9 Annual Compliance Certification Letter
9 Test Result (specify)
9 Report (specify)
9 Notification (specify)
9 Other (specify)

I certify that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.

Signature: Printed Name: Title/Position: Phone: Date:Rolls Royce Corporation Page 76 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY COMPLIANCE BRANCH P.O. Box 6015 100 North Senate Avenue Indianapolis, Indiana 46206-6015 Phone: 317-233-5674 Fax: 317-233-5967 and INDIANAPOLIS OFFICE OF ENVIRONMENTAL SERVICES

AIR QUALITY MANAGEMENT SECTION

DATA COMPLIANCE 2700 South Belmont Ave. Indianapolis Indiana 46221 Phone: 317-327-2234 Fax: 317-327-2274
PART 70 OPERATING PERMIT EMERGENCY OCCURRENCE REPORT Source Name: Rolls Royce Corporation Source Address: 2001 and 2355 S. Tibbs Avenue, Indianapolis, IN 46241 Mailing Address: P.O. Box 420 (N-23), Indianapolis, Indiana 46206-0420 Part 70 Permit No.: T097-7238-00311 This form consists of 2 pages Page 1 of 2 9 This is an emergency as defined in 326 IAC 2-7-1(12) C The Permittee must notify the Office of Air Quality (OAQ), within four ( 4 ) business hours (1-800-451-6027 or 317-233-5674, ask for Compliance Section); and C The Permittee must submit notice in writing or by facsimile within two ( 2 ) working days (Facsimile Number: 317-233-5967), and follow the other requirements of 326 IAC 2-7-16. If any of the following are not applicable, mark N/A Facility/Equipment/Operation:

Control Equipment:

Permit Condition or Operation Limitation in Permit:

Description of the Emergency:

Describe the cause of the Emergency:Rolls Royce Corporation Page 77 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy if any of the following are not applicable, mark N/A Page 2 of 2 Date/Time Emergency started:

Date/Time Emergency was corrected:

Was the facility being properly operated at the time of the emergency? Y N Describe:

Type of Pollutants Emitted: TSP, PM-10, SO 2 , VOC, NO X , CO, Pb, other:

Estimated amount of pollutant(s) emitted during emergency:

Describe the steps taken to mitigate the problem:

Describe the corrective actions/response steps taken:

Describe the measures taken to minimize emissions:

If applicable, describe the reasons why continued operation of the facilities are necessary to prevent imminent injury to persons, severe damage to equipment, substantial loss of capital investment, or loss of product or raw materials of substantial economic value:

Form Completed by: Title / Position: Date: Phone:Rolls Royce Corporation Page 78 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY COMPLIANCE DATA SECTION

and INDIANAPOLIS OFFICE OF ENVIRONMENTAL SERVICES

AIR QUALITY MANAGEMENT SECTION

DATA COMPLIANCE
PART 70 OPERATING PERMIT SEMI-ANNUAL NATURAL GAS AND LANDFILL GAS FIRED BOILER CERTIFICATION Source Name: Rolls Royce Corporation Source Address: 2001 and 2355 S. Tibbs Avenue, Indianapolis, IN 46241 Mailing Address: P.O. Box 420 (N-23), Indianapolis, Indiana 46206-0420 Part 70 Permit No.: T097-7238-00311

9 Natural Gas and Landfill Gas Only
9 Alternate Fuel burned From : To:



### I certify that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.
Signature: Printed Name: Title/Position: Phone: Date: A certification by the responsible official as defined by 326 IAC 2-7-1(34) is required for this report.Rolls Royce Corporation Page 79 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy 

### INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT, OFFICE OF AIR QUALITY, COMPLIANCE DATA SECTION and INDIANAPOLIS OFFICE OF ENVIRONMENTAL SERVICES, AIR QUALITY MANAGEMENT SECTION, DATA COMPLIANCE 

## Part 70 Quarterly Report Source Name: Rolls Royce Corporation Source Address: 2001 and 2355 S. Tibbs Avenue, Indianapolis, IN 46241 Mailing Address: P.O. Box 420 (N-23), Indianapolis, Indiana 46206-0420 Part 70 Permit No.: T097-7238-00311 Facility: Emission Unit D 0070-01, 02, 03, 04, 58, 59, 62, 63, 64, and 65 Parameter: PM10 Limit: 37,142,800 gal per twelve (12) consecutive month period of No. 4 oil and No.4 oil equivalents Permittee must submit this page for each 12 consecutive month period in the reporting period. Month: _________________ Year: ______________

Month No. 4 Oil

Usage (gal/month) No. 6 Oil

Usage (gal/day) Equivalent

No. 4 Oil (gal/month) Natural Gas

Usage MMCF/day Equivalent

No. 4 Oil (gal/month) No. 2 oil

Usage (gal/day) Equivalent

No. 4 Oil Usage (gal/month) Landfill gas

Usage MMCF/day Boiler Landfill Gas

Usage MMCF/day Turbine Equivalent

No. 4 Oil (gal/month) No. 4 Oil Usage and its

equivalent (gal/month)

TOTAL

9 No deviation occurred in this quarter.

9 Deviation/s occurred in this quarter. Deviation has been reported on: Submitted by: Date: Title / Position: Phone: Signature: Attach a signed certification to complete this report

.Rolls Royce Corporation Page 80 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy 

## INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY COMPLIANCE DATA SECTION

and INDIANAPOLIS OFFICE OF ENVIRONMENTAL SERVICES

AIR QUALITY MANAGEMENT SECTION

DATA COMPLIANCE 

## Part 70 Quarterl y Report

Source Name: Rolls Royce Corporation Source Address: 2355 South Tibb Avenue, Indianapolis Indiana Mailing Address: P.O. Box 420 (N-23), Indianapolis, Indiana 46206-0420 Part 70 Permit No.: T097-11121-00311 Facility: Test Cell 00311-83 Parameter: Jet Fuel Usage Limit: 567,779 gallons of Jet fuel per 12 consecutive month period.
YEAR:

Month Column 1 Column 2 Column 1 + Column 2 This Month Previous 11 Months 12 Month Total Month 1

Month 2

Month 3

9 No deviation occurred in this quarter.

9 Deviation/s occurred in this quarter. Deviation has been reported on: Submitted by: Title / Position: Signature:
Date: Phone:Rolls Royce Corporation Page 81 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy 

### INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT, OFFICE OF AIR QUALITY, COMPLIANCE DATA SECTION 

## and INDIANAPOLIS OFFICE OF ENVIRONMENTAL SERVICES, AIR QUALITY MANAGEMENT SECTION, DATA COMPLIANCE 

## Part 70 Quarterly Report Source Name: Rolls- Royce Corporation Source Address: 2001 and 2355 S. Tibbs Avenue, Indianapolis, IN 46241 Mailing Address: P.O. Box 420 (N-23), Indianapolis, Indiana 46206-0420 Part 70 Permit No.: T097-7238-00311 Facility: Emission Unit ID 0070-01, 02, 03, 04, 58, 62, 63, 64, 65, 71, 76, 79, 80, and 81 Parameter: Oxides of Nitrogen Limit: 6205 MMCF of natural gas and natural gas equivalents during the last 12 month consecutive period. Permittee must submit this page for each 12 consecutive month period in the reporting period.

Month Natural Gas Usage (MMCF/month) No. 6 oil Usage No. 4 Oil usage (gal/month) No. 2 oil

usage (gal/month) Landfill Gas usage Natural Gas Usage and its equivalent (MMCF/month) boilers Turbine ID Number (gal/month) (MMCF/month)

0070-80 0070-71 0070-76 0070-79 boilers turbines

Total QUARTER: YEAR:

9 No deviation occurred in this quarter. 9 Deviation/s occurred in this quarter. Deviation has been reported on: Submitted by: Date: Title / Position: Phone: Signature: Attach a signed certification to complete this report 

### .Rolls Royce Corporation Page 82 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy 

# ONGOING COMPLIANCE STATUS REPORT Applicable Rule: 40 CFR Part 63, Subpart N National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks. Page 1 of 2 1. Plant Identification Number: 97-00311(Old ID 00070) Owner : Rolls-Royce Corporation Street Address : 2355 S. Tibbs Avenue City : IndianapolisState : IndianaZip Code : 46241 Plant Phone Number : (317) 230-3591 Plant Fax Number : (317) 230-6047 Plant Contact : Pravin Patel

2.

Tank ID # Type of Tank Applicable emission limit Type of control

technique Control

system ID # Operating

parameter monitored Acceptable value

of the monitored parameter Total

operating time (hours) 1-11 Hard chrome

plating 0.015 mg/dscm Composite meshpad 253155 pressure drop 4 in. w.c. ±1 in

1-12 Hard chrome

plating 0.015 mg/dscm Composite meshpad 253155 pressure drop 4 in. w.c. ±1 in
1-13 Hard chrome

plating 0.015 mg/dscm Composite meshpad 253155 pressure drop 4 in. w.c. ±1 in

1-14 Hard chrome

plating 0.015 mg/dscm Composite meshpad 253155 pressure drop 4 in. w.c. ±1 in
1-15 Hard chrome

plating 0.015 mg/dscm Composite meshpad 253155 pressure drop 4 in. w.c. ±1 in
1-16 Hard chrome

plating 0.015 mg/dscm Composite meshpad 253155 pressure drop 4 in. w.c. ±1 in
2-20 Chrome

anodizing 0.010 mg/dscm Composite meshpad 253155 pressure drop 4 in. w.c. ±1 in



### 3. Identify the beginning and ending dates of the reporting period: Beginning EndingRolls Royce Corporation Page 83 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy 

### Page 2 of 2 4. Excess Emissions/Malfunction

Tank ID # Type of

malfunction Hours of

malfunction Tank Hours of

operation during malfunction % of Total operating time

1-11 None 0 0 0 1-12 None 0 0 0 1-13 None 0 0 0 1-14 None 0 0 0 1-15 None 0 0 0 1-16 None 0 0 0 2-20 None 0 0 0



### 5. Monitoring Data : Attached

6. During this reporting period, the pressure drop was within the range.

7. Any changes in monitoring, process or controls since the last reporting period : None
8. Responsible official certification :
Name : Title :

I certify that the information contained in this report is accurate and true to the best of my knowledge.

(Signature of responsible official) (Date)Rolls Royce Corporation Page 84 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF Air Quality COMPLIANCE DATA SECTION

and INDIANAPOLIS OFFICE OF ENVIRONMENTAL SERVICES

AIR QUALITY MANAGEMENT SECTION

DATA COMPLIANCE

PART 70 OPERATING PERMIT SEMI-ANNUAL DEVIATION AND COMPLIANCE MONITORING REPORT

Source Name: Rolls Royce Corporation Source Address: 2001 and 2355 S. Tibbs Avenue, Indianapolis, IN 46241 Mailing Address: P.O. Box 420 (N-23), Indianapolis, Indiana 46206-0420 Part 70 Permit No.: T097-7238-00311 Months: ___________ to ____________ Year: ______________ Page 1 of 2 This report shall be submitted semi-annually based on a calendar year. Any deviation from therequirements, the date(s) of each deviation, the probable cause of the deviation, and the response steps taken must be reported. Deviations that are required to be reported by an applicable requirement shall be reported according to the schedule stated in the applicable requirement and do not need to be included in this report. Additional pages may be attached if necessary. If no deviations occurred, please specify in the box marked “No deviations occurred this reporting period”. 

### 9 NO DEVIATIONS OCCURRED THIS REPORTING PERIOD. 

### 9 THE FOLLOWING DEVIATIONS OCCURRED THIS REPORTING PERIOD Permit Requirement(specify permit condition #) Date of Deviation: Duration of Deviation: Number of Deviations: Probable Cause of Deviation:

Response Steps Taken:

Permit Requirement(specify permit condition #) Date of Deviation: Duration of Deviation: Number of Deviations: Probable Cause of Deviation:

Response Steps Taken:Rolls Royce Corporation Page 85 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy Page 2 of 2 Permit Requirement(specify permit condition #) Date of Deviation: Duration of Deviation: Number of Deviations: Probable Cause of Deviation:

Response Steps Taken:

Permit Requirement(specify permit condition #) Date of Deviation: Duration of Deviation: Number of Deviations: Probable Cause of Deviation:

Response Steps Taken:

Permit Requirement(specify permit condition #) Date of Deviation: Duration of Deviation: Number of Deviations: Probable Cause of Deviation :

Response Steps Taken:

Form Completed By: Title/Position:
Date: Phone: Attach a signed certification to complete this report.Rolls Royce Corporation Page 86 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy 

## Attachment A The following state rule have been adopted by reference by the Indianapolis Air Pollutant Control Board and are enforceable by Indianapolis Office of Environmental Services (OES) using local enforcement procedures. (1) 326 IAC 1-1-1 through 1-1-3 and 1-1-5; (2) 326 IAC 1-2-1 through 1-2-91 (In addition, the IAPCB has adopted several local definitions); (3) 326 IAC 1-3-1 through 1-3-4; (4) 326 IAC 1-4-1 (The IAPCB added to the adoption by reference a citation to 61 FR 58482 (November 15, 1996)); (5) 326 IAC 1-5-1 through 1-5-5; (6) 326 IAC 1-6-1 through 1-6-6; (7) 326 IAC 1-7-1 through 1-7-5 (8) 326 IAC 2-3-1 through 2-3-5; (9) 326 IAC 2-4-1 through 2-4-6; (10) 326 IAC 2-6-1 through 2-6-4; (11) 326 IAC 2-7-1 through 2-7-18, 2-7-20 through 2-7-25; (12) 326 IAC 2-8-1 through 2-8-15, 2-8-17 through 2-8-10; (13) 326 IAC 2-9-1 through 2-9-14; (14) 326 IAC 2-10-1 through 2-10-5 (The IAPCB adoption adds the language “state or local” immediately after the word “federal” in 326 IAC 2-10-1); (15) 326 IAC 2-11-1, 2-11-3 and 2-11-4 (The IAPCB adoption adds the language “federal, state or local” immediately after the word “by” in 326 IAC 2-11-1); (16) 326 IAC 3-1.1-1 through 3-1.1-5; (17) 326 IAC 3-2.1-1 through 3-2.1-5; (18) 326 IAC 3-3-1 through 3-3-5; (19) 326 IAC 4-2-1 through 4-2-2; (20) 326 IAC 5-1-1 (a), (b) and c) (5), 5-1-2 (1), (2)(A), (2)c) (4), 5-1-3 through 5-1-5, 5-1-7; (21) 326 IAC 7-1.1-1 and 7-1.1-2; (22) 326 IAC 7-2-1; (23) 326 IAC 7-3-1 and 7-3-2; (24) 326 IAC 7-4-2(28) through (31) (Instead of adopting by reference 7-4-2(1) through (27), the IAPCB regulation substitutes the same requirements listed in a format in which the companies are alphabetized and emission points known to no longer exist have been deleted); (25) 326 IAC 8-1-0.5 except (b), 8-1-1 through 8-1-2, 8-1-3 except c), (g) and (i), 8-1-5 through 8-1-12; (26) 326 IAC 8-2-1 through 8-2-12 (The IAPCB adoption by reference of 8-2- 5 adds additional language specific to Zimmer Paper Products, Incorporated as subpart c); (27) 326 IAC 8-3-1 through 8-3-7; (28) 326 IAC 8-4-1 through 8-4-5, 8-4-6 (a)(6), (a)(8) and (a)(14) and 8-4-6(b)(1), (b)(3) and 8-4-6c) (In place of 8-4-6(b)(2), which was not adopted, the IAPCB adopted language requiring a pressure relief valve set to release at no less than four and eight-tenths (4.8) Kilo Pascals (seven-tenths (0.7) pounds per square inch)), 8-4-7 except (e), 8-4-8 and 8-4-9; (29) 326 IAC 8-5-1 through 8-5-4, 8-5-5 except (a)(3) and (d)(3); (30) 326 IAC 8-6-1 and 8-6-2; (31) 326 IAC 9-1-1 and 9-1-2; (32) 326 IAC 11-1-1 through 11-1-2; (33) 326 IAC 11-2-1 through 11-2-3; (34) 326 IAC 11-3-1 through 11-3-6; (35) 326 IAC 14-1-1 through 14-1-4;
Attachment A continued (36) 326 IAC 14-2-1 except 40 CFR 61.145; (37) 326 IAC 14-3-1;Rolls Royce Corporation Page 87 of 87

Indianapolis, Indiana T097-7238-00311 Permit Reviewer: Amanda Hennessy (38) 326 IAC 14-4-1; (39) 326 IAC 14-5-1; (40) 326 IAC 14-6-1; (41) 326 IAC 14-7-1; (42) 326 IAC 14-8-1 through 14-8-5; (43) 326 IAC 15-1-1, 15-1-2(a)(1), (a)(2) and (a)(8), 15-1-3 and 15-1-4; (44) 326 IAC 20-1-1 through 20-1-4 (In 20-1-3(b)(2) the adoption states that “permitting authority” means the commissioner of IDEM or the administrator of OES, whichever is applicable); (45) 326 IAC 20-2-1; (46) 326 IAC 20-3-1; (47) 326 IAC 20-4-1; (48) 326 IAC 20-5-1; (49) 326 IAC 20-6-1; (50) 326 IAC 20-7-1; (51) 326 IAC 20-8-1; (52) 326 IAC 20-9-1; (53) 326 IAC 20-14-1; (54) 326 IAC 20-15-1; (55) 326 IAC 20-16-1; (56) 326 IAC 20-17-1; (57) 326 IAC 20-18-1; (58) 326 IAC 20-19-1; (59) 326 IAC 20-20-1; (60) 326 IAC 20-21-1; (61) 326 IAC 21-1-1 (The adoption states that “or the administrator of OES” is added in (b)); (62) 326 IAC 22-1-1 (The adoption states that “or the administrator of OES” is added in (b)).Page 1 of 32



## Indiana Department of Environmental Management

Office of Air Quality

and 

## Indianapolis Office of Environmental Services

Addendum to the Technical Support Document for a Part 70 Operating Permit

Source Name: Rolls Royce Corporation Source Location: Plant 8 - 2001 South Tibbs Ave., Indianapolis, Indiana 46241 Plant 5 - 2355 South Tibbs Ave., Indianapolis, Indiana 46241 County: Marion SIC Code: 3724 Operation Permit No.: T097-7238-00311 Permit Reviewer: Amanda Hennessy

On January 10, 2003, the Office of Air Quality (OAQ) and the City of Indianapolis Office of Environmental Services (OES) had a notice published in the Indianapolis Star, Indianapolis, Indiana, stating that Rolls Royce Corporation had applied for a Part 70 Operating Permit to operate a manufacturing and testing source for aerospace engines. The notice also stated that OAQ and OES proposed to issue a permit for this operation and provided information on how the public could review the proposed permit and other documentation. Finally, the notice informed interested parties that there was a period of thirty (30) days to provide comments on whether or not this permit should be issued as proposed. The following changes to the draft Title V Permit will be made. The TSD will remain as it originally appeared when published. OAQ and OES prefer that the Technical Support Document reflect the permit that was on public notice. Changes to the permit or technical support material that occur after the permit has been published are documented in this Addendum to the Technical Support Document. This accomplishes the desired result of ensuring that these types of concerns are documented and part of the record regarding this permit decision. The Permit Table of Contents has been updated to reflect changes where necessary without being included in the response to comments and formatting changes have been made that do not change the meaning, intent or language of the permit. The summary of the changes made by IDEM and OES, public comments, and responses to comments follows with strikeout showing deleted text and boldshowing new text. IDEM and OES have made the following changes: Condition B.7 has changed as follows:
B.7 Duty to Supplement and Provide Information [326 IAC 2-7-4(b)] [326 IAC 2-7-5(6)(E)] [326 IAC 2-7-6(6)] (a) The Permittee, upon becoming aware that any relevant facts were omitted or incorrect information was submitted in the permit application, shall promptly submit such supplementary facts or corrected information to:Page 2 of 32 Indiana Department of Environmental Management Permits Branch, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015
and Office of Environmental Services (OES) Air Quality Management Section 2700 South Belmont Avenue Indianapolis, IN 46221 The submittal by the Permittee does require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). ( b a ) The Permittee shall furnish to IDEM, OAQ, and OES within a reasonable time, any information that IDEM, OAQ, and OES may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit, or to determine compliance with this permit. The submittal by the Permittee does require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). Upon request, the Permittee shall also furnish to IDEM, OAQ, and OES copies of records required to be kept by this permit. ( c b ) For information furnished by the Permittee to IDEM, OAQ and OES, the Permittee may include a claim of confidentiality in accordance with 326 IAC 17.1. When furnishing copies of requested records directly to U. S. EPA, the Permittee may assert a claim of confidentiality in accordance with 40 CFR 2, Subpart B. Conditions B.11(b), (c) and (d) have changed as follows:
B.11 Preventive Maintenance Plan [326 IAC 2-7-5(1),(3) and (13)] [326 IAC 2-7-6(1) and (6)] [326 IAC 1-6-3] (b) The Permittee shall implement the PMPs , including any required record keeping, as necessary to ensure that failure to implement a PMP does not cause or contribute to a violation an exceedanceof any limitation on emissions or potential to emit. (c) A copy of the PMPs shall be submitted to IDEM, OAQ, and OES upon request and within a reasonable time, and shall be subject to review and approval by IDEM, OAQ, and OES. IDEM, OAQ, and OES may require the Permittee to revise its PMPs whenever lack of proper maintenance causes or contributes is the primary contributorto any violation an exceedance of any limitation on emissions or potential to emit . The PMP does not require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). (d) Records of preventive maintenance shall be retained for a period of at least five (5) years. These records shall be kept at the source location for a minimum of three (3) years. The records may be stored elsewhere for the remaining two (2) years as long as they are available upon request. If the Commissioner or OES makes a request for records to the Permittee, the Permittee shall furnish the records to the Commissioner and/or OES within a reasonable time. To the extent the Permittee is required by 40 CFR Part 60/63 to have an Operation, Maintenance, and Monitoring (OMM) Plan for a unit, such Plan is deemed to satisfy the PMP requirements of 326 IAC 1-6-3 for that unit.Page 3 of 32

Condition B.18(d) has been added: B.18 Permit Amendment or Modification [326 IAC 2-7-11] [326 IAC 2-7-12] (d) No permit amendment or modification is required for the addition, operation or removal of a nonroad engine, as defined in 40 CFR 89.2

. Condition B.22 has changed as follows:
B.22 Inspection and Entry [326 IAC 2-7-6] [IC 13-14-2-2][IC 13-30-3-1] Upon presentation of proper identification cards, credentials, and other documents as may be required by law, and subject to the Permittee’s right under all applicable laws and regulations to assert that the information collected by the agency is confidential and entitled to be treated as such, the Permittee shall allow IDEM, OAQ, OES, U.S. EPA, or an authorized representative to perform the following: (a) Enter upon the Permittee's premises where a Part 70 source is located, or emissions related activity is conducted, or where records must be kept under the conditions of this permit; (b) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30- 3-1, H h ave access to and copy any records that must be kept under the conditions of this permit; (c) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30- 3-1,I i nspect any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this permit; (d) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30- 3-1, S s ample or monitor substances or parameters for the purpose of assuring compliance with this permit or applicable requirements; and (e) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30- 3-1, U u tilize any photographic, recording, testing, monitoring, or other equipment for the purpose of assuring compliance with this permit or applicable requirements. Condition C.8(f) and (g) has changed as follows: C.8 Asbestos Abatement Projects [326 IAC 14-10] [326 IAC 18] [40 CFR 61, Subpart M] (f) Demolition and renovation The Permittee shall thoroughly inspect the affected facility or part of the facility where the demolition or renovation will occur for the presence of asbestos pursuant to 40 CFR 61.145(a). (g) Indiana Accredited Asbestos Inspector The Permittee shall comply with 326 IAC 14-10-1(a) that requires the owner or operator, prior to a renovation/demolition, to use an Indiana Accredited Asbestos Inspector to thoroughly inspect the affected portion of the facility for the presence of asbestos. The requirement that the inspector be accredited, pursuant to the provisions of 40 CFR 61, Subpart M, is federally enforceable. The requirement to use an Indiana Accredited Asbestos inspector is not federally enforceable.Page 4 of 32

Condition C.15 has changed as follows: C.15 Risk Management Plan [326 IAC 2-7-5(12)] [40 CFR 68.215] If a regulated substance, subject to as defined in 40 CFR 68, is present at a source in more than a threshold quantity, 40 CFR 68 is an applicable requirement and the Permittee shall submit: the source must comply with the applicable requirements of 40 CFR 68. (a) A compliance schedule for meeting the requirements of 40 CFR 68; or (b) As a part of the annual compliance certification submitted under 326 IAC 2-7- 6(5), a certification statement that the source is in compliance with all the requirements of 40 CFR 68, including the registration and submission of a Risk Management Plan (RMP); and (c) A verification to IDEM, OAQ, and OES that a RMP or a revised plan was prepared and submitted as required by 40 CFR 68. All documents submitted pursuant to this condition shall include the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). Condition C.16 has been changed as follows: C.16 Compliance Response Plan - Preparation, Implementation, Records, and Reports [326 IAC 2-7- 5] [326 IAC 2-7-6] (a) The Permittee is required to prepare a Compliance Response Plan (CRP) for each compliance monitoring condition of this permit. The Operation, Maintenance and Monitoring Plan required for emission units 0070-13, 0070-31, and 311-82 under 40 CFR 63 shall be deemed to satisfy the requirements for a CRP for those compliance monitoring conditions.A CRP shall be submitted to IDEM, OAQ and OES upon request. The CRP shall be prepared within ninety (90) days after issuance of this permit by the Permittee, supplemented from time to time by the Permittee, maintained on site, and comprised of: (1) Reasonable response steps that may be implemented in the event that a response step is needed pursuant to the requirements of Section D of this permit; and an expected time frame for taking reasonable steps. (2) If, at any time, the Permittee takes reasonable response steps that are not set forth in the Permittee’s current Compliance Response Plan or Operation, Maintenance, and Monitoring (OMM) Planand the Permittee documents such response in accordance with subsection (e) below, the Permittee shall amend its Compliance Response Plan and Operation, Maintenance, and Monitoring (OMM) Planto include such response steps taken. The OMM Plan shall be submitted within the time frames specified by the applicable 40 CFR 63 requirement. (b) For each compliance monitoring condition of this permit, reasonable response steps shall be taken when indicated by the provisions of that compliance monitoring condition as follows: (1) Reasonable response steps shall be taken as set forth in the Permittee’s current Compliance Response Plan or Operation, Maintenance, and Monitoring (OMM) Plan ; orPage 5 of 32 (2) If none of the reasonable response steps listed in the Compliance Response Plan or Operation, Maintenance, and Monitoring (OMM) Planis applicable or responsive to the excursion, the Permittee shall devise and implement additional response steps as expeditiously as practical. Taking such additional response steps shall not be considered a deviation from this permit so long as the Permittee documents such response steps in accordance with this condition. (3) If the Permittee determines that additional response steps would necessitate that the emissions unit or control device be shut down, the IDEM, OAQ and OES shall be promptly notified of the expected date of the shut down, the status of the applicable compliance monitoring parameter with respect to normal, and the results of the actions taken up to the time of notification. (4) Failure to take reasonable response steps shall constitute a violation be considered a deviation from of the permit. (c) The Permittee is not required to take any further response steps for any of the following reasons: (1) A false reading occurs due to the malfunction of the monitoring equipment and prompt action was taken to correct the monitoring equipment. (2) The Permittee has determined that the compliance monitoring parameters established in the permit conditions are technically inappropriate, has previously submitted a request a minor permit modification to the permit, and such request has not been denied. (3) An automatic measurement was taken when the process was not operating. (4) The process has already returned or is returning to operating within “normal” parameters and no response steps are required. (d) When implementing reasonable steps in response to a compliance monitoring condition, if the Permittee determines that an exceedance of an emission limitation has occurred, the Permittee shall report such deviations pursuant to Section B-Deviations from Permit Requirements and Conditions. (e) The Permittee shall record all instances when, in accordance with Section D, response steps are taken. In the event of an emergency, the provisions of 326 IAC 2-7- 16 (Emergency Provisions) requiring prompt corrective action to mitigate emissions shall prevail. (f) Except as otherwise provided by a rule or provided specifically in Section D, all monitoring as required in Section D shall be performed when the emission unit is operating, except for time necessary to perform quality assurance and maintenance activities. Condition C.17 has changed as follows: C.17 Actions Related to Noncompliance Demonstrated by a Stack Test [326 IAC 2-7-5] [326 IAC 2-7-6] (a) When the results of a stack test performed in conformance with Section C - Performance Testing, of this permit exceed the level specified in any condition of this permit, the Permittee shall take appropriate response actions. The Permittee shall submit a description of these response actions to IDEM, OAQ, within thirty (30) days of receipt of the test results. The Permittee shall takePage 6 of 32 appropriate action to minimize excess emissions from the affected facility while the response actions are being implemented. (b) A retest to demonstrate compliance shall be performed within one hundred twenty (120) days of receipt of the original test results. Should the Permittee demonstrate to IDEM, OAQ that retesting in one-hundred and twenty (120) days is not practicable, IDEM, OAQ may extend the retesting deadline. (c) IDEM, OAQ reserves the authority to take any actions allowed under law in response to noncompliant stack tests.
The response action documents submitted pursuant to this condition do require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). Condition C.18 has changed as follows: C.18 Emission Statement [326 IAC 2-7-5(3)(C)(iii)] [326 IAC 2-7-5(7)] [326 IAC 2-7-19(c)] [326 IAC 2-6] [326 IAC 2-7-19 (e)] (a) The Permittee shall submit an annual emission statement certified pursuant to the requirements of 326 IAC 2-6, that must be received by April 15 of each year and must comply with the minimum requirements specified in 326 IAC 2-6-4. The annual emission statement shall meet the following requirements and be used for the purpose of a Part 70 fee assessment: (1) Indicate estimated actual emissions of criteria pollutants from the source; (2) Indicate estimated actual emissions of other regulated pollutants ( as defined by 326 IAC 2-7-1 (32) (“Regulated pollutant which is used only for purposes of Section 19 of this rule” ) from the source, for purposes of Part 70 fee assessment. Condition C.19 has changed as follows: C.19 General Record Keeping Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-6] (a) Records of all required monitoringdata, reports and support information required by this Permitshall be retained for a period of at least five (5) years from the date of monitoring sample, measurement, report, or application. These records shall be kept physically present or electronically accessibleat the source location for a minimum of three (3) years. The records may be stored elsewhere for the remaining two (2) years as long as they are available upon request. If the Commissioner or Administrator of OES makes a request for records to the Permittee, the Permittee shall furnish the records to the Commissioner or OES within a reasonable time. Condition C.22 has changed as follows: (d) Notwithstanding paragraph (a), pursuant to 40 CFR 63.56(a), the Permittee shall comply with an applicable promulgated MACT standard in accordance with the schedule provided in the MACT standard if the MACT standard is promulgated prior to the Part 2 MACT Application deadline or prior to the issuance of a permit with a case-by-case Section 112(j) MACT determination. The MACT requirements include the applicable General Provisions requirements of 40 CFR 63, Subpart A. Pursuant to 40 CFR 63.9(b), the Permittee shall submit an initial notification not later than 120 days after the effective date of the MACT, unless the MACT specifies otherwise. The initial notification shall be submitted to:Page 7 of 32

Indiana Department of Environmental Management Permits Branch, Office of Air Quality 100 North Senate Avenue, P. O. Box 6015 Indianapolis, Indiana 46206-6015
and Office of Environmental Services Air Quality Management Section, Data Compliance 2700 South Belmont Avenue Indianapolis, Indiana 46221
and United States Environmental Protection Agency, Region V Air and Radiation Division, Regulation Development Branch - Indiana (AR-18J) 77 West Jackson Boulevard Chicago, Illinois 60604-3590 Condition D.1.6 is being changed because the PM limitations from 326 IAC 6-1-12(a) have been approved by EPA and are now federally enforceable: D.1.6 Marion County PM Limitations [326 IAC 6-1-12] (a) Pursuant toLSA Document #99-218, final August 1, 2001, 326 IAC 6-1-12(a) nonattainment area particulate limitations of PM from emission units 0070-01 through 0070-04, 0070-58, 0070-59, and 0070-62 thru 0070-65 is limited and enforceable by the state, but the limits are subject to comment and approval by EPA prior to federal enforceability. Federal enforceability is necessary to issue the final Title V permit as follows: (Nonattainment Area Particulate Limitations: Marion County), the Permittee shall comply with the following emission limitations for Particulate Matter (PM):

Source NEDS

Plant ID Point Input ID Process Emission Limits tons per year Lbs/million

Btu

Rolls Royce Corporation 0311 01 Boilers 0070-01 thru 0070-04 130.0/yr 0.337

0311 02 Boilers 0070-58 and 0070-59 0.15 0311 03 Boilers 0070-62 thru 0070-65 0.15

Condition D.1.12 shall be corrected as follows:
D.1.12 PM, PM-10, and NOx Emissions Compliance with Condition D.1.5 and D.1.6 shall be demonstrated within 30 days of the end of each month based on the amount of fuel combusted for the most recent 365 day period.Page 8 of 32

Condition D.1.14 is being changed because the visible emission notations should be performed once per shift rather than once daily:
D.1.14 Visible Emissions Notations (a) Visible emission notations of the emission units 0070-01, 0070-02, 0070-03, 0070-04, 0070-58, 0070-59, 0070-62, 0070-63, 0070-64 and 0070-65 stack exhausts shall be performed once daily per shiftduring normal daylight operations when combusting fuel oil. A trained employee shall record whether emissions are normal or abnormal. The following change is being made to Condition D.1.15 to complete the change made to Condition B.11: D.1.15 Record Keeping Requirements

(f) To document compliance with D.1.9, the Permittee shall maintain records of any additional inspections prescribed by the Preventive Maintenance Plan. (vii) All records shall be maintained in accordance with Section C - General Record Keeping Requirements, of this permit. The Environmental Resource Management Division is now the Office of Environmental Services. The following change has been made to Condition D.2.8 (Per Response to Comment (1)(b) the Condition is now Condition D.2.9):
D.2. 8 9 VOC Emissions [326 IAC 8-2-9] Any change or modification to the facilities listed below which may increase the actuals before add-on controls shall obtain prior approval from theEnvironmental Resource Management Division Office of Environmental Services(OES) and Office of Air Quality (OAQ). Current equipment operations are as follows: (a) paint booths identified as, N56a and N56b, VOC actual emissions before add-on controls of less than 15 pounds of VOC per day each; and (b) paint booths identified as, 0070-10a, 0070-10b, 0070-10c, and 0070-10d, VOC actual emissions before add-on controls of less than 15 pounds of VOC per day each. Compliance with this condition shall make the Miscellaneous Metal Parts Rule 326 IAC 8-2-9 not applicable. Condition D.2.12 is being deleted because it is not necessary. Actual emissions from these units are less than 15 pounds per day.
D.2.12 VOC Emissions Compliance with condition D.2.8 shall be demonstrated at the end of each day based on the daily VOC usage. The following change is being made to Condition D.2.13 to complete the change made to Condition B.11: D.2.13 Record Keeping Requirements

(h) To document compliance with Condition D.2.11, the Permittee shall maintain records of any additional inspections prescribed by the Preventive Maintenance Plan.Rolls Royce Corporation

Indianapolis, Indiana OP No. T097-7238-00311 Permit Reviewer: A. Hennessy Page 9 of 32

(i) All records shall be maintained in accordance with Section C - General Record Keeping Requirements, of this permit. On February 10, 2003, Rolls Royce Corporation submitted comments on the proposed Part 70 permit. The summary of the comments and responses to comments follows. Comment (1) 

### : Incorporation of National Emission Standards for Hazardous Air Pollutants (NESHAPs) requirements. We continue to believe that it is preferable to incorporate the requirements of the NESHAPs regulations into the Part 70 permit, rather than writing the specific provisions that pertain to our specific operations. Incorporating the requirements by reference ensures that we will not be subject to provisions that may be amended, abridged or modified from the actual requirements of the rule. It is our understanding that the approach of incorporating the specific provisions into the permit by section may be acceptable to the state. We have attached alternative language for the D Sections that contain the NESHAPs requirements for Aerospace Surface Coating, Halogenated Solvent Cleaning Operations and Chrome Plating for your consideration as an alternative to the proposed permit language. We believe these alternative sections fully incorporate the NESHAPs requirements consistent with our current operations. More specifically our concern is that the sections as drafted do not completely or accurately reflect the requirements of these standards. Some specific examples of this concern are listed as follows: Aerospace NESHAP (a) Condition D.2.5(b)(2): The paint booth pressure drop should not be limited to 1.14 inches of water. The NESHAP standard allows us to use EPA approved filters, which will have different pressure drops depending on the specific manufacturer. The current pressure drop limits eliminates the flexibility allowed in the NESHAP. (b) Condition D.2.5: This section does not include the use of different painting application equipment use as allowed in 63.745(f). (c) The permit conditions do not include the exemption allowed in the NESHAP 63.745(g)(4). (d) Condition D.2.7: The compliance monitoring requirements for paint booth pressure drop is not listed in permit. (e) Condition D.2.13(g): The requirements of subsections 3, 4, and 6 should be deleted as they are not applicable to our facility. (f) Condition D.2.14(b) and (d): Under the NESHAP, only recordkeeping and not reporting of the VOCs is required. Halogenated Solvent NESHAP (g) Condition D.3.3(d)(1), (2), and (3): These conditions are not included as part of the NESHAP regulation, and, therefore, should be deleted from the permit condition. (h) Conditions D.3.6(e) and D.3.8(b)(4): Inclusion of these requirements eliminates the flexibility allowed in the NESHAP. Chrome Plating NESHAP (i) Condition D.6 Descriptions: The facility should be revised to identify 6 chrome plating tanks and one anodizing tank consistent with the equipment we have at the site and the types of tanks specified in the NESHAP. (j) Condition D.6.6: The pressure drop limit in the draft permit is 4 ± 1. EPA has a proposed draft revision to 40 CFR 63.343(c)(1)(I), which allow 4 ± 2. By incorporating the requirements of the NESHAP rule by reference we will be subject to the revised specificiation upon final adoption by EPA, rather than requiring that we amend the Part 70 permit once the rule is finalized. (k) Condition D.6.7(b): This condition should refer to 7 tanks rather than 97.Rolls Royce Corporation

Indianapolis, Indiana OP No. T097-7238-00311 Permit Reviewer: A. Hennessy Page 10 of 32

Response to Comment (1): IDEM and OES disagree that the alternative sections provided by the Permittee fully incorporate the NESHAP requirements. Pursuant to 326 IAC 2-7-5, IDEM and OES must incorporate all applicable requirements into a source’s Part 70 permit. The USEPA has issued guidance to clarify what is meant by this. IDEM and OES permit language is consistent with this EPA guidance. Response to Comment (1)(a), (b), and (c): (a) IDEM and OES agree that the NESHAP only specifies that a differential pressure gauge be installed. (b) IDEM and OES agree. The Permittee must use one of the painting applications listed in 40 CFR 63.745(f). A new condition D.2.6 has been generated to insert this requirement. In addition, D.2.5(b) has been moved into the new condition (D.2.6) for Primer and Topcoat Application Operations and the wording has changed to more accurately reflect the requirements of 40 CFR 63.745(g). All subsequent conditions have been renumbered. (c) The exemptions listed in 40 CFR 63.745(g)(4) have been added to the new Condition at the request of the Permittee. Condition D.2.5 has been modified as follows: D.2.5 Spray Gun Cleaning and Coating Operations [326 IAC 20-15-1] [40 CFR 63, Subpart GG] (a) The Permittee shall comply with the Spray gun cleaning Enclosed system inspection and repair requirements below. (1) Pursuant to 40 CFR 63.751(a) visually inspect seals and other potential sources of leaks associated with each enclosed gun spray cleaner system at least once per month, while operating. (2) Pursuant to 40 CFR 63.744(c)(1)(ii) if a leak is found, repairs shall be made as soon as practicable, but no later than 15 days from detection. If the leak is not repaired by the 15 thday after detection, remove the cleaning solvent and shut down the enclosed cleaning system until the leak is repaired
D.2.6 Primer and Topcoat Application Operations [326 IAC 20-15-1] [40 CFR 63, Subpart GG] (a) All primers and topcoats shall be applied using one or more of the application techniques specified below unless the application is exempted in 40 CFR 63.745(f)(3) and shall be operated according to company procedures, and/or the manufacturers specifications, whichever is most stringent, at all times: (1) Flow/curtain coat application; (2) Dip coat application; (3) Roll coating; (4) Brush coating; (5) Cotton-tipped swab application; (6) Electrodeposition (dip) coating; (7) High volume low pressure (HVLP) spraying; (8) Electrostatic spray appliction; or (9) Other coating application methods that achieve emission reductions equivalent to HVLP or electrostatic spray application methods, as determined according to the requirements in 40 CFR 63.750(i).Rolls Royce Corporation

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(b) Primer and topcoat operations emitting Inorganic HAP - monitoring of emission controls compliance shall be determined as follows: (1) Pursuant to 40 CFR 63.745(g)(2)(iv) the following requirements shall be met for each dry particulate system used to comply with the primer and top coat inorganic HAP emissions standards in 40 CFR 63.745(g)(2)(i)(A): (A) maintain the system in good working order (B) continuously monitor pressure drop across the filter and read and record the pressure drop across the filter once per shift; and (C) take corrective action when the pressure drop exceeds or falls below the filter manufacturer's recommended limit(s). (2) Pursuant to Notification of Compliance Status, submitted by Rolls Royce Pressure drop range shall be between 0.14 to 1.14 inches of water (3) Pursuant to 40 CFR 63.745(g)(3), the Permittee shall comply with the requirements below. (A) if the pressure drop is outside of range, the permittee shall shut down the operation immediately and take corrective action. (B) If the booth maintenance procedures for the filter system have not been performed as scheduled, shut down the operation immediately and take corrective action. (C) The operation shall not be resumed until the pressure drop is returned within the specified range. (b) Pursuant to 40 CFR 63.745(g)(1), primer or topcoat applications that are spray applied and contain inorganic HAP shall be applied in a booth or hangar in which air flow is directed downward onto or across the part of assembly being coated and exhausted through one or more outlets. (c) Pursuant to 40 CFR 63.745(g)(2), the Permittee must control the air stream from this operation by passing the air stream through a dry particulate filter system certified using the methods described in 40 CFR 63.750(o) to meet or exceed the efficiency data points in Table 1 and 2 of 40 CFR 63.745(g)(2). Pursuant to 40 CFR 63.745(g)(2)(iv), the following requirements shall be met for each dry particulate system used to comply with the primer and top coat inorganic HAP emissions standards in 40 CFR 63.745(g)(2)(i)(A): (1) maintain the system in good working order; (2) install a differential pressure gauge across the filter banks; (3) continuously monitor pressure drop across the filter and read and record the pressure drop across the filter once per shift; and (4) take corrective action when the pressure drop exceeds or falls below the filter manufacturer's recommended limit(s). (d ) Pursuant to 40 CFR 63.745(g)(3), the Permittee shall comply with the requirements below. (A) If the pressure drop is outside of range, the permittee shall shut down the operation immediately and take corrective action. (B) If the booth maintenance procedures for the filter system have not been performed as scheduled, shut down the operation immediately and take corrective action. (C) The operation shall not be resumed until the pressure drop is returned within the specified range.Rolls Royce Corporation

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(e) The requirements of 40 CFR 63.745(g)(1) through (3) do not apply to the situations listed in 40 CFR 63.745(g)(4). Response to Comment (1)(d): IDEM and OES agree that Condition D.2.7 is not complete. The following change has been made to Condition D.2.7 (Per Response to Comment (1)(b), this condition is now Condition D.2.8):
D.2. 7 8 Compliance Monitoring Requirements for Aerospace Manufacturing and Rework Facilities [326 IAC 20-15] [40 CFR 63.751, Subpart GG] The compliance monitoring requirements of 40 CFR 63.751 are applicable to the cleaning operations and dry particulate filter system . The Permittee shall perform monthly visual inspection requirements for enclosed spray gun cleaners pursuant to 40 CFR 63.751(a). The Permittee shall also continuously monitor, read and record the pressure drop once per shift pursuant to 40 CFR 63.751(c). Response to Comment (1)(e): Condition D.2.13(g) is recordkeeping relative to Condition D.2.8 (now Condition D.2.9). Condition D.2.8 (now D.2.9) relates to the non-applicability of 326 IAC 8-2-9. IDEM and OES require records to ensure that actual emissions are less than 15 pounds per day. A change has been made to this Condition in Response to Comment (8). This condition is not related to the Aerospace NESHAP. Recordkeeping for the Aerospace NESHAP is addressed in Condition D.2.13(a) through (f). Response to Comment (1)(f): Condition D.2.14(b) is reporting relative to Condition D.2.8 (now Condition D.2.9) which is related to the non-applicability of 326 IAC 8-2-9. Condition D.2.14(b) has been removed under Response to Comment (9) since reporting should not be required in this situation. Condition D.2.14(b) in the public notice version of the permit is not related to the Aerospace NESHAP. Reporting for the Aerospace NESHAP is addressed in Condition D.2.14(a). Response to Comment 1(g): IDEM and OES feel that Conditions D.3.3(d)(1), (2) and (3) are included in the NESHAP regulation and should not be deleted from the permit condition. However, the Permittee will not be using a working mode cover, idling mode cover or carbon adsorber to comply with this rule. Emission Units 0070-13 and 0311-82 will comply with the rule by employing the control combination of a freeboard refrigeration device and a freeboard ratio of 1.0. and Emission Unit 0070-31 will comply with the rule by employing the control combination of a freeboard refrigeration device, reduced room draft, and a freeboard ratio of 1.0. Therefore, IDEM and OES agree that the condition needs to be corrected to match the compliance options of the Permittee. Condition D.3.3(d) has been changed as follows: (d) Pursuant to 40 CFR 63.463(e) an exceedance has occurred if the following requirements are not met: (1) Ensure that the cover opens only for part entrance and removal and completely covers the cleaning machine openings when closed. For Emission Unit 0070- 31, if a reduced room draft is used to comply, the Permittee must establish and maintain the operating conditions under which the wind speed was demonstrated to be 15.2 meters per minute (50 feet per minute) or less as described in 40 CFR 63.466(d). (2) Ensure that the cover is in place whenever parts are not in the solvent cleaning machine and completely covers the cleaning machine openings when in place.Rolls Royce Corporation

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(3) Ensure that the lip exhaust is located above the solvent cleaning machine cover so that the cover closes below the lip exhaust level. (4 2 ) An exceedence occurs if the requirements, listed below, have not been met and are not corrected within 15 days of detection. Adjustments or repairs shall be made to the solvent cleaning system or control immediately upon adjustment or repair and demonstrated to be within required limits. (A) If a freeboard refrigeration device is used to comply with these standards, the owner or operator shall ensure that the chilled air blanket temperature (in deg.F), measured at the center of the air blanket, is no greater than 30 percent of the solvent's boiling point. (B) Ensure that the working-mode cover is maintained free of cracks, holes, and other defects. For Emission Unit 0070-31, if a reduced room draft is used to comply, the Permittee shall ensure that the flow or movement of air across the top of the freeboard area of the solvent cleaning machine or within the solvent cleaning machine enclosure does not exceed 15.2 meters per minute (50 feet per minute) at any time as measured using the procedures in 40 CFR 63.466(d). (C) Ensure that the idling-mode cover is maintained free of cracks, holes, and other defects. Response to Comment (1)(h): The requirements in Conditions D.3.6(e) and D.3.8(b)(4) are requirements under 326 IAC 8-3-3 and 326 IAC 8-3-6. Therefore, they must remain in the permit unless they are streamlined through the process outlined in 326 IAC 2-7-24. When streamlining pursuant to 326 IAC 2-7-24, the streamlined requirements must be at least as stringent as the requirements that are being subsumed and must ensure compliance with all applicable requirements. Response to Comment (1)(i): The facility consists of six (6) hard chrome electroplating tanks and one anodizing tank. Conditions A.2(l) and D.6 Facility Description have been changed as follows: (l) Seven (7) chromium plating tanks each with a maximum cumulative potential rectifier capacity less than 60 million amp-hr/yr, identified as 0070-99 Chrome plating and anodizing line consisting oftwenty tanks and seven (7) chromium tanks (six hard chrome electroplating tanks and one anodizing tank) , identified as 0070-99, with a common add-on air pollution control device with a maximum cumulative potential rectifier capacity of less than 60 million amp-hr/yr , controlled using a composite mesh pad system, identified as ID 253155, which exhausts out stack 5-99. This facility was installed October 6, 1997 consisting of: (1) Six (6) hard chrome electroplating tanks 1-11, 1-12, 1-13, 1-14, 1-15, 1-16 and (2) One (1) anodizing tank 2-20. andRolls Royce Corporation

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Facility Description [326 IAC 2-7-5(15)] (l) Chrome plating and anodizing line consisting of twenty tanks and seven (7) chromium tanks (six hard chrome electroplating tanks and one anodizing tank) , identified as 0070-99, with a common add-on air pollution control device with a maximum cumulative potential rectifier capacity of less than 60 million amp-hr/yr, controlled using a composite mesh pad system, identified as ID 253155, which exhausts out stack 5-99. This facility was installed October 6, 1997 consisting of: (1) Six (6) hard chrome electroplating tanks 1-11, 1-12, 1-13, 1-14, 1-15, 1-16 and (2) One (1) anodizing tank 2-20. (The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.) Response to Comment (1)(j): IDEM and OES must include all operating parameters into a source’s Part 70 permit. Referencing cannot be used to incorporate operating parameters. The permit must include the NESHAP requirements that are applicable at the time of the Part 70 issuance. If the EPA finalizes a change to operating parameters in the NESHAP, the Permittee shall apply for a permit modification to reflect the new parameters. Response to Comment (1)(k): IDEM and OES agree. The typographical error in Condition D.6.7 has been corrected as follows: (b) The Permittee is not required to further test the seven ( 9 7) chromium tanks, including the composite mesh pad system, identified as 253155, by this permit. However, IDEM or OES may require testing when necessary to determine if the seven (7) chromium tanks, including the composite mesh pad system, identified as 253155, are in compliance. If testing is required by IDEM or OES, compliance with the limits specified in Condition D.6.3 shall be determined by a performance test conducted in accordance with 40 CFR 63.344 and Section C - Performance Testing. Comment (2): Condition A.1, General Information. We would request that the Responsible Official be revised to identify the “Chief Operating Officer,” rather than the “Executive Vice President of Operations.” Response to Comment (2): IDEM and OES agree. The Chief Operating Officer meets the definition of Responsible Official as defined in 326 IAC 2-7-1(34)(A)(vi). Therefore, the following change has been made:
A.1 General Information [326 IAC 2-7-4(c)] [326 IAC 2-7-5(15)] [326 IAC 2-7-1(22)] The Permittee owns and operates a manufacturing and testing source for aerospace engines. Responsible Official: Executive Vice President of Operations Chief Operating Officer Source Address: Plant 8 - 2001 South Tibbs Ave., Indianapolis, Indiana 46241 Plant 5 - 2355 South Tibbs Ave., Indianapolis, Indiana 46241 Mailing Address: P.O. Box 420 (N-23), Indianapolis, Indiana 46206-0420 Phone Number: 317-230-4141 SIC Code: 3724Rolls Royce Corporation

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County Location: Marion County Status: Attainment for all criteria pollutants Source Status: Part 70 Permit Program Major Source, under PSD; Major Source, Section 112 of the Clean Air Act Comment (3): Condition A.2, Emission Units and Pollution Control Equipment Summary. Emission unit 0070- 58 exhausts through stack 8-3 rather than stack 8-1. Similarly, emission unit 0070-59 exhausts through stack 8-4 rather than stack 8-1. The construction dates for Emission Unit 0070-62, 0070-63, 0070-64 and 0070-65 should be 1969 rather than 1953. Emission unit 0070-81 was not constructed in 1999. Construction of this unit is still pending. Please make appropriate revisions to Sections A.2 and D.1 of the permit. Response to Comment (3): IDEM and OES agree. These changes do not affect any applicability determination, therefore the changes above have been made in Condition A.2(a) and (b) and D.1.
A.2 Emission Units and Pollution Control Equipment Summary [326 IAC 2-7-4(c)(3)] [326 IAC 2-7-5(15)] (a) Ten (10) boilers identified below:
EU ID. Unit Identification MMBtu/hr Fuels Permitted to Use Stack Date constructed 0070-01 Babcock & Wilcox

Boiler 88 Natural Gas, Landfill Gas, No. 2 & No. 4 fuel oil 5-1 1942
0070-02 Babcock & Wilcox

Boiler 88 Natural Gas, Landfill Gas, No. 2 & No. 4 fuel oil 5-1 1942
0070-03 Babcock & Wilcox

Boiler 88 Natural Gas, Landfill Gas, No. 2 & No. 4 fuel oil 5-1 1942
0070-04 Babcock & Wilcox

Boiler 88 Natural Gas, Landfill Gas, No. 2 & No. 4 fuel oil 5-1 1942
0070-58 Babcock & Wilcox

Boiler 44 Natural Gas, Landfill Gas, No. 2, No. 4 & No. 6 fuel oil 8- 1 3 1953
0070-59 Babcock & Wilcox

Boiler 44 Natural Gas, Landfill Gas, No. 2, No. 4, & No. 6 fuel oil 8- 1 4 1953
0070-62 Combustion

Engineering Boiler 244 Natural Gas, Landfill Gas, No. 2, No. 4, & No. 6 fuel oil 8-5 19531969

0070-63 Combustion

Engineering Boiler 244 Natural Gas, Landfill Gas, No. 2, No. 4, & No. 6 fuel oil 8-6 1953 1969

0070-64 Combustion

Engineering Boiler 244 Natural Gas, Landfill Gas, No. 2, No. 4, & No. 6 fuel oil 8-7 1953 1969 0070-65 Combustion

Engineering Boiler 244 Natural Gas, Landfill Gas, No. 2, No. 4, & No. 6 fuel oil 8-8 1953 1969

(b) Five (5) gas turbines identified below:
Emission Unit ID No. Unit Identification Maximum Capacity, MMBtu/hr Fuels Permitted to use Stack No. Date Constructed or last permitted 0070-76 Gas Turbine 51 Natural Gas, Landfill gas 5-22 1999 0070-79 Gas Turbine 48 Natural Gas, Landfill gas 8-79 1999 0070-80 Gas Turbine 68 Natural Gas, Landfill gas 8-80 1999 0070-81 Gas Turbine 80 Natural Gas, Landfill gas 8-81 1999 pending 0070-71 Gas Turbine 35 Natural Gas 8-9 1999Rolls Royce Corporation

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and SECTION D.1 FACILITY OPERATION CONDITIONS Facility Description [326 IAC 2-7-5(15)] (a) Ten (10) boilers identified below: Emission Unit ID No. Unit Identification Maximum Capacity, MMBtu/hr Fuels Permitted to Use Stack No. Date Constructed or Reconstructed 0070-01 Babcock & Wilcox

Boiler 88 Natural Gas, Landfill Gas, No. 2 & No. 4 fuel oil 5-1 1942

0070-02 Babcock & Wilcox

Boiler 88 Natural Gas, Landfill Gas, No. 2 & No. 4 fuel oil 5-1 1942

0070-03 Babcock & Wilcox

Boiler 88 Natural Gas, Landfill Gas, No. 2 & No. 4 fuel oil 5-1 1942

0070-04 Babcock & Wilcox

Boiler 88 Natural Gas, Landfill Gas, No. 2 & No. 4 fuel oil 5-1 1942

0070-58 Babcock & Wilcox

Boiler 44 Natural Gas, Landfill Gas, No. 2, No. 4 & No. 6 fuel oil 8- 1 3 1953

0070-59 Babcock & Wilcox

Boiler 44 Natural Gas, Landfill Gas, No. 2, No. 4 & No. 6 fuel oil 8- 1 4 1953

0070-62 Combustion

Engineering Boiler 244 Natural Gas, Landfill Gas, No. 2, No. 4 & No. 6 fuel oil 8-5 1953 1969

0070-63 Combustion

Engineering Boiler 244 Natural Gas, Landfill Gas, No. 2, No. 4 & No. 6 fuel oil 8-6 1953 1969

0070-64 Combustion

Engineering Boiler 244 Natural Gas, Landfill Gas, No. 2, No. 4 & No. 6 fuel oil 8-7 1953 1969

0070-65 Combustion

Engineering Boiler 244 Natural Gas, Landfill Gas, No. 2, No. 4 & No. 6 fuel oil 8-8 1953 1969

(b) Five (5) gas turbines identified below: Emission Unit ID No. Unit Identification Maximum Capacity, MMBtu/hr Fuels Permitted to Use Stack No. Date Constructed

0070-76 Gas Turbine 51 Natural Gas, Landfill gas 5-22 1999 0070-79 Gas Turbine 48 Natural Gas, Landfill gas 8-79 1999 0070-80 Gas Turbine 68 Natural Gas, Landfill gas 8-80 1999 0070-81 Gas Turbine 80 Natural Gas, Landfill gas 8-81 1999 pending 0070-71 Gas Turbine 35 Natural Gas 8-9 1999 (The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.)Rolls Royce Corporation

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Comment (4): Condition B.11, Preventive Maintenance Plan. We would request that a statement be included in this condition indicating that if the emission unit is required to have an Operation and Maintenance (O&M) plan by one of the NESHAPs regulations that the O&M plan would also satisfy the requirement for a Preventive Maintenance Plan. This will eliminate the duplicative requirements posted by these two separate regulations. Response to Comment (4): IDEM and OES agree. In the Technical Support Document, IDEM and OES outline that the O & M Plan required in the Halogenated Organic Solvent NESHAP satisfies the requirement to have a PMP, therefore, no requirement for a PMP was included in the Permit for these emission units. The following change has been made to Condition B.11(d): (d) Records of preventive maintenance shall be retained for a period of at least five (5) years. These records shall be kept at the source location for a minimum of three (3) years. The records may be stored elsewhere for the remaining two (2) years as long as they are available upon request. If the Commissioner or OES Administrator makes a request for records to the Permittee, the Permittee shall furnish the records to the Commissioner or OES within a reasonable time. To the extent Permittee is required by 40 CFR Part 60/63 to have an OMM Plan, such Plan is deemed to satisfy the PMP requirements of 326 IAC 1-6-3 for such unit and, otherwise, the OMM Plan requirements for such unit shall be the applicable requirements for maintenance. Comment (5): Condition B.13, Permit Shield. We request that paragraph (b)(2) of this condition be replaced with a statement that this permit supercedes all previously issued construction and operating permits. By listing only a portion of one previously issued permit it implies that other portions of that permit or other permits may still be applicable. Response to Comment (5): IDEM and OES partially agree. Condition B.13(b)(2) has been deleted. It is not necessary to replace the condition with the statement that this permit supercedes all previously issued construction and operating permits because Condition B.14 states this. Condition B.13 has been changed as follows:

B.13 Permit Shield [326 IAC 2-7-15] [326 IAC 2-7-20] [326 IAC 2-7-12] (b)(2) The requirement from CP 950070-01, issued October 13, 1995, Condition 3 and 4, listing requirements as follows:

3. Allowable Emissions-The Permittee shall not release emissions in excess of the amounts

shown above. (i) #4 Fuel Oil-The short term allowable TSP emissions (lbs/MMBtu) are listed

pursuant to 326 IAC 6-1-2(b)(4) and IAPCB Reg II-1. The short term allowable SO2 emissions (lb/MMBtu) are listed pursuant to 326 IAC 7-1.1-2(a)(2). Long term TSP and SO2 emissions (tons/yr) are based on the applicable short term allowable limits, maximum operating capacity and combusting no more than 7,405,195 gallons of #4 Fuel oil for all three boilers combined such that Emissions Offset Regulation 326 IAC 2-3 is not triggered for TSP. (ii) #2 Fuel oil-the short term allowable TSP emissions (lbs/ MMBtu) are listed

pursuant to 326 IAC 6-1-2(b)(4) and IAPCB RegII-1. The short term allowable SO2 emissions (lbs/MMBtu)are listed pursuant to 326 IAC 7-1.1-2(a)(3).Rolls Royce Corporation

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Long term TSP emissions (tons/yr) are based on the applicable short term allowable limit, and the combustion of no more than 8,324,088 gallons of #2 Fuel oil for all three boilers combined such that the Emissions Offset Regulation 326 IAC 2-3 is not triggered for TSP. (iii) Natural Gas-The short term allowable TSP emissions (gr/dscf) are listed

pursuant to 326 IAC 6-1-2(b)(5) and IAPCB Reg II-1. The short term allowable SO2 emissions (lbs/MMBtu) are listed pursuant to IAPCB Reg IV-4. The short term allowable Nox emission limits are based on an emission factor from AP-42 tables 1.4-1,2,3 and the maximum firing rate for each boiler. Long term NOx emissions are based on the applicable short term allowable limit, and the combustion of no more than 2,364,070,536 cubic feet for all three boilers such that the Prevention of Significant Deterioration Regulation 326 IAC 2-2 is not triggered for Nox.
4. The Potential to Emit TSP, and SO2 at the same as the long term allowable emissions for

#4 Fuel Oil combustion given in 3(i). The potential to emit NOx is the same as the long term allowable limits for natural gas combustion give in condition 3(iii). The potential to emit for CO and VOC are based on AP-42 emissions factor for natural gas combustion, and restrictions on the amount of natural gas combusted per condition 3(iii). The potential to emit PM-10 is based on AP-42 emissions factor for Fuel oil combustion, and restrictions on the amount of #4 Fuel oil combusted per condition 3(i). These conditions are not applicable because IDEM, OAQ and OES have determined that the old permit should not have been required. There was an overall decrease in emissions when the boilers were modified to combust natural gas and fuel oil only rather than coal and fuel oil. In addition, the actual to potential analysis showed the modification to existing equipment was not significant. However, limits were set at 40 ton per year of allowable TSP (current air rules refer to as PM and or PM-10) and NOx to satisfy concerns of an increase in production due to the fuel switch. This assumption was in error because potential emissions would not have increased due to increases in production. Per a 1993 U.S. EPA Region V Policy for converting dirty fuel (coal) to clean fuels (natural gas), the conversion should have been allowed without limits. Further, this source modified the boilers in 1999 to include landfill gas as a fuel. The fuel addition was not significant for NOx and PM-10. New limits were established for the boilers previously modified in 1995. The intent of CP-099-0311-01, issued June 6, 1999 was to modify or supercede past CPs. In addition, 62 FR 18521, published April 16, 1997 and IDEM memo, dated April 12, 1998 stating “TSP nonattainment designations can be eliminated as long as rules controlling emissions of particulate are not relaxed.” The PM and PM10 limits controlling particulate emissions have not been relaxed. Therefore, the long term TSP (current air rules refer to as PM and or PM-10), which limited the source below the applicability threshold for 326 IAC 2-3 Emission Offset Regulation, has been removed. Comment (6): Condition C.15(b)(4), Compliance Response Plan - Preparation, Implementation, Records and Reports. This section of the condition indicates that failure to take reasonable response steps shall constitute a violation of the permit. Not all excursions from a compliance monitoring condition would result in a violation of an underlying applicable emission limit. As such, failure to take a response step should not be considered a violation per se, without evidence that theRolls Royce Corporation

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underlying applicable emission limit has been exceeded. As such, we would request that this condition be eliminated from the permit, or in the alternative, state that “Failure to take reasonable response steps shall constitute a violation of the permit if such failure causes an exceedance of an applicable emission limit.” Response to Comment (6):IDEM and OES disagree. The OAQ and OES believe that responding promptly to compliancerelated information is necessary to the compliance status of the source. 326 IAC 2-7-5(1) requires that all Title V permits contain operational requirements and limitations that assure compliance with all applicable requirements. 326 IAC 2-7-5(3) requires that all Title V permits contain monitoring and related record keeping requirements which assure that all reasonable information is provided to evaluate continuous compliance with applicable requirements. 326 IAC 2-7-5(3)(A)(ii) requires that, at a minimum, the periodic monitoring requirements must be sufficient to yield reliable data from the relevant time period that are representative of the source = s compliance, even where the applicable requirement does not require periodic testing or instrumental monitoring. The requirement that the permit contain operational requirements and limitations that assure compliance with all applicable requirements, coupled with the rule requirements for compliance monitoring, provides all the necessary authority for this permit requirement. Therefore, the IDEM, OAQ and OES disagree with your position that Condition C.16(b)(4) be eliminated. There has been no change to this Condition. Comment (7): Condition D.1.6(c)(3)(B)(ii), Marion County PM Limits. We request that the limit in paragraph (c)(3)(B)(ii) be amended by eliminating the last 8 in the numeric limit to read as follows: “0.00088". This is consistent with the applicable requirement. Response to Comment (7): IDEM and OES agree. The typographical error has been corrected as follows:

(ii) When using natural gas, the gallons per year of #4 fuel oil shall be reduced by eighty-eight hundred-thousandths (0.00088 8 ) gallon per cubic foot of natural gas burned. Comment (8): Condition D.2.13(g), Recordkeeping Requirements. We request that subparagraphs (3), (4) and (6) be eliminated from this condition, since this information is not required to demonstrate compliance with the 15 pound per day limit found in Condition 2.8 and/or is redundant of other records required by the condition. Response to Comment (8): IDEM and OES agree. Condition D.2.13(g)(3), (4), and (5) are unnecessary or repetitive. In response to this change, (6) will also be reworded. The condition will be changed as follows: (g) To document compliance with Condition D.2.8, the Permittee shall maintain records in accordance with (1) through (6) below. Records maintained for (1) through (6) shall be taken daily and shall be complete and sufficient to establish compliance with Condition D.2.8. (1) The VOC content of each coating material and solvent used. (2) The amount of coating material and solvent less water used on a daily basis. (A) Records shall include purchase orders, invoices, and material safety data sheets (MSDS) necessary to verify the type and amount used.Rolls Royce Corporation

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(B) Solvent usage records shall differentiate between those added to coating and those used as cleanup solvents. (3) The volume weighted VOC content of the coatings used for each day; (4) The cleanup solvent usage for each day; (5) The total VOC usage for each day; and (6) The weight of VOCsinput emitted for each day compliance period

. Comment (9): Condition D.2.14(b), Reporting Requirements. We would request that this condition and the associated reporting form be eliminated from the permit. Given the very small size of the emission unit, we do not believe that routine reporting is warranted. We believe that keeping the records on file at the facility for review by the department should be sufficient to allow for an adequate review of compliance with this requirement. Response to Comment (9): IDEM and OES agree that reporting does not need to be required in this instance. Recordkeeping, as outlined in Condition D.2.13(g) is sufficient to show compliance with Condition D.2.8. No reporting form was provided for this requirement, therefore it is not necessary to remove the associated reporting form. The reporting condition has changed as follows:
D.2.14 Reporting Requirements (b) A summary of the information to document compliance with Condition D.2.8 and D.2.13(g) shall be submitted quarterly. ( c b ) Pursuant to 40 CFR 63.9(j) any change in the information provided under 40 CFR 63.9 shall be reported to IDEM OAQ and OES in writing within 15 calendar days after the change. ( d c ) All reports shall be submitted to the addresses listed in Section C - General Reporting Requirements, of this permit, using the reporting forms located at the end of this permit, or their equivalent, within thirty (30) days after the end of the calendar quarter being reported. Comment (10): Condition D.3.6 and D.3.8, Degreasing Operations. These two rules are redundant as they both apply to open top vapor degreasing operations and contain many of the same requirements. The requirements of 326 IAC 8-3-6 as reflected in condition D.3.8 are more stringent and apply to facilities in Marion County. This condition should be retained, but we would request that condition D.3.6 be deleted from the permit as it is not applicable and is a duplication of other requirements. Response to Comment (10): As outlined in the Technical Support Document, the open top vapor degreasers (emission unit 0070-13 and 0070-31) are regulated under 326 IAC 8-3-3 and 326 IAC 8-3-6. Emission units 0070-13 and 0070-31 were new facilities after January 1, 1980, performing organic solvent degreasing operations. Therefore, 326 IAC 8-3 section 3 applies. Emission units 0070-13, 0070-31, 0311-82, 0070-12, and 0070-14 were either existing in Marion County prior to July 1, 1990 or constructed after July 1, 1990 and each consisted of a type described in 326 IAC 8-3- 1(b)(1)(B). Therefore 326 IAC 8-3 section 6 applies. 326 IAC 8-3-3 and 326 IAC 8-3-6 have limits applicable to the open top vapor degreasing operations. Since both rules are applicable, both requirements must be outlined in the permit. There has been no change made to the permit.Rolls Royce Corporation

Indianapolis, Indiana OP No. T097-7238-00311 Permit Reviewer: A. Hennessy Page 21 of 32

Comment (11): Semi-Annual Natural Gas Fired Boiler Certification. This form should be removed from the permit as it is not required by any specific condition in the D sections of the permit. Under section D.1 we are required to maintain detailed records of the fuels combusted in our boilers and this form would appear to serve no useful purpose beyond the recordkeeping and reporting requirements found in D.1 of the permit. Response to Comment (11): IDEM and OES disagree. Combustion of natural gas and landfill gas results in negligible PM emissions and, therefore, no visible emissions monitoring is required. Certifying when natural gas and landfill gas are used allows the source to account for the time that visible emissions monitoring is not performed. Visible emissions monitoring is required while combusting fuel oil. The reporting of the fuel usage is to ensure that the source is not exceeding permitted limits. The Reporting Condition D.1.16 has been changed to include the requirement to submit the natural gas and landfill gas certification and the natural gas certification has been changed to include landfill gas: D.1.16 Reporting Requirements (a) The natural gas and landfill gas boiler certification shall be submitted to the address listed in Section C - General Reporting Requirements, of this permit, using the reporting forms located at the end of this permit, or its equivalent, within thirty (30) days after the end of the six (6) month period being reported. The natural gas and landfill gas fired boiler certification doesrequire the certification by the A responsible official @

as defined by 326 IAC 2-7-1(34). (b) A quarterly summary of the information to document compliance with condition D.1.5, D.1.6, and D.1.8, shall be submitted to the addresses listed in Section C - General Reporting Requirements of this permit, using the reporting forms located at the end of this permit, or their equivalent, within thirty (30) days after the end of the quarter being reported.

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY COMPLIANCE DATA SECTION

and INDIANAPOLIS OFFICE OF ENVIRONMENTAL SERVICES

AIR QUALITY MANAGEMENT SECTION

DATA COMPLIANCE
PART 70 OPERATING PERMIT SEMI-ANNUAL NATURAL GAS AND LANDFILL GAS FIRED BOILER CERTIFICATION Source Name: Rolls Royce Corporation Source Address: 2001 and 2355 S. Tibbs Avenue, Indianapolis, IN 46241 Mailing Address: P.O. Box 420 (N-23), Indianapolis, Indiana 46206-0420 Part 70 Permit No.: T097-7238-00311Rolls Royce Corporation

Indianapolis, Indiana OP No. T097-7238-00311 Permit Reviewer: A. Hennessy Page 22 of 32

9 Natural Gas and Landfill GasOnly
9 Alternate Fuel burned From : To:



### I certify that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.
Signature: Printed Name: Title/Position: Phone: Date: A certification by the responsible official as defined by 326 IAC 2-7-1(34) is required for this report. Comment (12): Chromium Electroplating and Anodizing NESHAP Compliance Status Report Form. We would request that the following modifications be made to this form to more accurately reflect the rule requirements:

• Instead of listing the specific parametric monitoring value at the top of the form please include a reference to 40 CFR 63.343(c)(1)(I). Since this specification may be changed in the near future, including the rule reference will eliminate any confusion over the specific value.

• Delete the rectifier capacity requirements as they do not apply to our facility.

• We have attached a copy of our current report format. We would request that our format be used to replace the proposed form. Response to Comment (12): IDEM and OES agree. The draft form has been replaced with the current report format that the source is submitting. The inspector for this source has indicated that the current report format meets the requirements of the rule. Comment (13): PM10 and NO x

Report Form. We have attached a copy of our current report format for reporting on the PM10 and NO x

based fuel usage limits. We would request that this format be used instead of the format in the forms attached to the proposed permit. We have found that this is a more suitable form for our reports. In lieu of replacing these forms, a statement could be added to the forms indicating that alternative forms may be used to report this information.Rolls Royce Corporation

Indianapolis, Indiana OP No. T097-7238-00311 Permit Reviewer: A. Hennessy Page 23 of 32

Response to Comment (13): IDEM and OES wish to clarify that the reporting conditions indicate that the Permittee shall submit the required data “using the reporting forms located at the end of this permit, or their equivalent.” The Permittee may use the forms provided or an equivalent form. The Oxides of Nitrogen form submitted by the Permittee is equivalent to the first page of the draft reporting form. The second page is a summary of emissions for each twelve month period in the reporting period. The second page of the draft reporting form will be deleted and instructions to submit the first page for each 12 month period in the reporting period will be added to the first page. The PM10 form submitted by the Permittee is equivalent to the first page of the draft reporting form, but is organized slightly different. The second page of the draft reporting form is a summary of emissions for each 12 month period in the reporting period. The second page of the draft reporting for will be deleted, instructions to submit the first page for each 12 month period in the reporting period will be added to the first page and the table organization will be changed to reflect the Permittee’s current reporting form. The forms have been changed as follows:Rolls Royce Corporation

Indianapolis, Indiana OP No. T097-7238-00311 Permit Reviewer: A. Hennessy Page 24 of 32



### INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT, OFFICE OF AIR QUALITY, COMPLIANCE DATA SECTION and INDIANAPOLIS OFFICE OF ENVIRONMENTAL SERVICES, AIR QUALITY MANAGEMENT SECTION, DATA COMPLIANCE 

## Part 70 Quarterly Report

Source Name: Rolls Royce Corporation Source Address: 2001 and 2355 S. Tibbs Avenue, Indianapolis, IN 46241 Mailing Address: P.O. Box 420 (N-23), Indianapolis, Indiana 46206-0420 Part 70 Permit No.: T097-7238-00311 Facility: Emission Unit D 0070-01, 02, 03, 04, 58, 59, 62, 63, 64, and 65 Parameter: PM10 Limit: 37,142,800 gal per year twelve (12) consecutive month period of No. 4 oil and No.4 oil equivalents Permittee must submit this page for each 12 consecutive month period in the reporting period. Page 1 of 2 Month: _________________ Year: ______________

Month No. 4 Oil

Usage (gal/day) Equivalent No. 4 Oil (gal/mo.) Equivalent No. 4 Oil (gal/mo.) Equivalent No. 4 Oil (gal/mo.) Equivalent No. 4 Oil (gal/mo.) Total No.4 Oil Usage and its Equivalents (gal/mo.) No. 6 Usage (gal/day) Equivalency

Multiple by 2.6 Natural Gas

Usage MMCF/day Equivalency

Multiply gallon conversion by 0.00088 No. 2 oil

Usage (gal/day) Equivalency

multiply by 0.28 Landfill gas

Usage MMCF/day Boiler Equivalency multi.

conv. by 0.00116gal/CF landfill gas Landfill Gas

Usage MMCF/day Turbine Equivalency multi.

conv. by 0.00132gal/CF landfill gas Month 1 Month 2 Month 3

Month No. 4 Oil

Usage (gal/month ) No. 6 Oil

Usage (gal/day) Equivalent

No. 4 Oil (gal/month) Natural Gas

Usage MMCF/day Equivalent

No. 4 Oil (gal/month) No. 2 oil

Usage (gal/day) Equivalent

No. 4 Oil Usage (gal/month) Landfill gas

Usage MMCF/day Boiler Landfill Gas

Usage MMCF/day Turbine Equivalent

No. 4 Oil (gal/month) No. 4 Oil Usage and

its equivalent (gal/month)

TOTALRolls Royce Corporation

Indianapolis, Indiana OP No. T097-7238-00311 Permit Reviewer: A. Hennessy Page 25 of 32 

## INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT, OFFICE OF

AIR QUALITY, COMPLIANCE DATA SECTION and 

## INDIANAPOLIS OFFICE OF ENVIRONMENTAL SERVICES, AIR QUALITY

MANAGEMENT SECTION, DATA COMPLIANCE

Part 70 Quarterly Report
Source Name: Rolls Royce Corporation Source Address: 2001 and 2355 S. Tibbs Avenue, Indianapolis, IN 46241 Mailing Address: P.O. Box 420 (N-23), Indianapolis, Indiana 46206-0420 Part 70 Permit No.: T097-7238-00311 Facility: Emission Unit D 0070-01, 02, 03, 04, 58, 59, 62, 63, 64, 65, 71, 76, 79, 80, & 81 Parameter: PM10 Limit: 37,142,800 gal per year of No. 4 oil and No.4 oil equivalents Page 2 of 2
Fuel Oil Equivalents for PM-10 Emissions Emission Units gal per gal #2 oil gal per CF

landfill gas gal per CF

natural gas gal per gal

#6 oil Boilers (Emission Unit ID 0070-01, 02, 03, 04, 62, 63, 64 and 65) 0.280 0.00116 0.00088 2.60

Boilers (Emission Unit ID 0070- 58, 59) 0.280 N.A. 0.00088 2.60 Turbines (Emission Unit IDs 0070-76, 79, 80 and 81) N.A. 0.00132 0.00088 N.A.

YEAR:

Month Column 1 Column 2 Column 1 + Column 2 This Month Previous 11 Months 12 Month Total Month 1

Month 2

Month 3

9 No deviation occurred in this quarter. 9 Deviation/s occurred in this quarter.

Deviation has been reported on: Date: Phone:

Title/Position: Submitted by: Signature: Attach a signed certification to complete this report.Rolls Royce Corporation

Indianapolis, Indiana OP No. T097-7238-00311 Permit Reviewer: A. Hennessy Page 26 of 32 

### INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT, OFFICE OF AIR QUALITY, COMPLIANCE DATA SECTION and INDIANAPOLIS OFFICE OF ENVIRONMENTAL SERVICES, AIR QUALITY MANAGEMENT SECTION, DATA COMPLIANCE Part 70 Quarterly Report Page 1 of 2 Source Name: Rolls- Royce Corporation Source Address: 2001 and 2355 S. Tibbs Avenue, Indianapolis, IN 46241 Mailing Address: P.O. Box 420 (N-23), Indianapolis, Indiana 46206-0420 Part 70 Permit No.: T097-7238-00311 Facility: Emission Unit ID 0070-01, 02, 03, 04, 58, 62, 63, 64, 65, 71, 76, 79, 80, and 81 Parameter: Oxides of Nitrogen Limit: 6205 MMCF of natural gas and natural gas equivalents during the last 12 month consecutive period. Permittee must submit this page for each 12 consecutive month period in the reporting period.

Month Natural Gas Usage (MMCF/month) No. 6 oil Usage No. 4 Oil usage (gal/month) No. 2 oil

usage (gal/month) Landfill Gas usage Natural Gas Usage and its equivalent (MMCF/month) boilers Turbine ID Number (gal/month) (MMCF/month)

0070-80 0070-71 0070-76 0070-79 boilers turbines

Total

QUARTER: YEAR:Rolls Royce Corporation

Indianapolis, Indiana OP No. T097-7238-00311 Permit Reviewer: A. Hennessy Page 27 of 32 

### INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT, OFFICE OF AIR QUALITY, COMPLIANCE DATA SECTION

and INDIANAPOLIS OFFICE OF ENVIRONMENTAL SERVICES, AIR QUALITY MANAGEMENT SECTION, DATA COMPLIANCE Part 70 Quarterly Report Page 2 of 2 Source Name: Rolls- Royce Corporation Source Address: 2001 and 2355 S. Tibbs Avenue, Indianapolis, IN 46241 Mailing Address: P.O. Box 420 (N-23), Indianapolis, Indiana 46206-0420 Part 70 Permit No.: T097-7238-00311 Facility: Emission Unit ID 0070-01, 02, 03, 04, 58, 62, 63, 64, 65, 71, 76, 79, 80, and 81 Parameter: Oxides of Nitrogen Limit: 6205 MMCF of natural gas and natural gas equivalents during the last 12 month consecutive period.

Natural Gas Equivalents for Nitrogen Oxide Emissions Emission Units MMCF per gal #4 oil MMCF per

gal #2 oil MMCF per MMCF

landfill gas MMCF per MMCF

natural gas MMCF per

gal #6 oil Boilers (Emission Unit ID 0070-01,02,03 and 04) 0.00023 0.00023 0.31928 N.A. N.A. Boilers (Emission Unit ID 0070-58 and 59) 0.00023 0.00023 N.A. N.A. 0.00048 Boilers (Emission Unit ID 0070-62, 63, 64 and 65) N.A. 0.00023 0.31928 N.A. 0.00060 Turbines (Emission Unit IDs 0070-80 and 81) N.A. N.A. 0.34130 3.90000 N.A. Turbines (Emission Unit IDs 0070-71) N.A. N.A. 0.34130 4.50000 N.A. Turbines (Emission Unit IDs 0070-76, 79) N.A. N.A. 0.34130 6.50000 N.A. 

### QUARTER: YEAR:

Month Column 1 Column 2 Column 1 + Column 2

This Month Previous 11 Months 12 Month Total Month 1

Month 2

Month 3

9 No deviation occurred in this quarter.

9 Deviation/s occurred in this quarter. Deviation has been reported on: 

### Submitted by: Title /Position: Signature: Date: Phone: Attach a signed certification to complete this report.Rolls Royce Corporation

Indianapolis, Indiana OP No. T097-7238-00311 Permit Reviewer: A. Hennessy Page 28 of 32

Comment (14) : TSD - Enforcement Issue: This section of the TSD indicates that IDEM and OES are aware that equipment has been constructed prior to receiving proper permits, and that the subject equipment is listed in the TSD under a section entitled “ Unpermitted Emission Units and Pollution Control Equipment ”. We are unaware of any such issue and do not find the referenced section of the TSD. Please clarify that there is no such enforcement issue regarding unpermitted emission units or control equipment. Response to Comment (14): The “Unpermitted Emission Units and Pollution Control Equipment” section begins at the bottom of page 3 of the TSD and continues to the top of page 6. The equipment listed in this section is unpermitted. However, all emission units in this section qualify for the relief provided in the IDEM policy titled Implementing and Supplementing Title 5 Compliance Transition Program per I.C. 13-10-4-1 . In addition the “modification” to the paint booths 0070-56a and 0070-56b to comply with the aerospace NESHAP lowered potential emissions and therefore, did not require a permit. Comment (15): TSD - Insignificant Activities: We have previously informed your offices that we have a small incinerator to destroy classified documents. This small unit may be considered a “trivial activity” as it is an office rather than production related activity. However, if it is not considered a “trivial activity” we would request that it be included in the listing of insignificant activities in the TSD. Response to Comment (15): Additional information on the classified document incinerator was provided by the source upon request. Potential emissions are below insignificant [326 IAC 2-7-1(21)] and exempt from permitting requirements [326 IAC 2-1.1-3(d)] levels. Therefore, the Permittee did not need a permit prior to construction or installation and 326 IAC 2-2 did not apply. The insignificant activity has been incorporated into the Title V permit in both Section A and Section D.7 as follows:
A.3 Specifically Regulated Insignificant Activities [326 IAC 2-7-1(21)] [326 IAC 2-7-4(c)] [326 IAC 2-

7-5(15)] This stationary source also includes the following insignificant activities which are specifically regulated, as defined in 326 IAC 2-7-1(21): Storage vessels, containing volatile organic liquid, identified as tank 1 through 6 and 9 through 20 at plant 5 and tanks 1 through 5 at plant 8. Each tank has a capacity greater than 40 cubic meters but less than 75 cubic meters and a construction date after July 23, 1984. Classified documents incinerator with a maximum rated capacity of 125 pounds per two hour cycle. [40 CFR 52, Subpart P] [326 IAC 4-2] [326 IAC 9-1] and SECTION D.7 FACILITY OPERATION CONDITIONS Facility Description [326 IAC 2-7-5(15)]: Insignificant activities Storage vessels, containing volatile organic liquid, identified as tank 1 through 6 and 9 through 20 at plant 5 and tanks 1 through 5 at plant 8. Each tank has a capacity greater than 40 cubic meters but less than 75 cubic meters and a construction date after July 23, 1984. Classified documents incinerator with a maximum rated capacity of 125 pounds per two hour cycle. (The information describing the process contained in this facility description box is descriptive information and does not constitute enforceable conditions.)Rolls Royce Corporation

Indianapolis, Indiana OP No. T097-7238-00311 Permit Reviewer: A. Hennessy Page 29 of 32

Emission Limitations and Standards [326 IAC 2-7-5(1)] [326 IAC 8-4][326 IAC 12]

D.7.2 Incinerators [40 CFR 52, Subpart P]

Pursuant to 40 CFR 52, Subpart P, the confidential document incinerator shall: (b) consist of primary and secondary chambers or the equivalent; (c) be equipped with a primary burner unless burning wood products; (d) comply with 326 IAC 5-1 and 326 IAC 2; (e) be maintained properly as specified by the manufacturer and approved by the commissioner; (f) be operated according to the manufacturer’s recommendations and only burn waste approved by the commissioner; (g) comply with other state and/or local rules or ordinances regarding installation and operation of incinerators; (h) be operated so that emissions of hazardous material including, but not limited to, viable pathogenic bacteria, dangerous chemicals or gases, or noxious odors are prevented; (i) not emit particulate matter in excess of three-tenths (0.3) pounds of particulate matter per one thousand (1,000) pounds of dry exhaust gas at standard conditions corrected to fifty percent (50%) excess air. (j) not create a nuisance or a fire hazard. If any of the above result, the burning shall be terminated immediately. This condition will remain applicable until the revisions to 326 IAC 4-2 are approved into the SIP and the condition is modified in a subsequent permit action.
D.7.3 Incinerators [326 IAC 4-2]

Pursuant to 326 IAC 4-2, the confidential document incinerator shall: (a) Consist of primary and secondary chambers or the equivalent; (b) Be equipped with a primary burner; (c) Comply with 326 IAC 5-1 and 326 IAC 2; (d) Be maintained, operated and burn waste in accordance with : (1) manufacturers specifications; or (2) an operation and maintenance plan that complies with the following: (A) be designed to meet the PM emission limitation specified in subsection (a)(5) and include the following: procedures for receiving, handling and charging waste, procedures for incinerator startup and shutdown, procedures for responding to a malfunction,Rolls Royce Corporation

Indianapolis, Indiana OP No. T097-7238-00311 Permit Reviewer: A. Hennessy Page 30 of 32

procedures for maintaining proper combustion air supply levels, procedures for operating the incinerator and associated air pollution control systems, procedures for handling ash, and a list of wastes that can be burned in the incinerator. (B) each incinerator operator shall review the plan before initial implementation of the operation and maintenance plan and annually thereafter. (C) be readily accessible to incinerator operators. (D) the owner or operator of the incinerator shall notify the department, in writing, thirty days after the operation and maintenance plan is initially developed pursuant to this section. (e) Not emit particulate matter in excess of three tenths (0.3) pound of particulate matter per one thousand (1,000) pounds of dry exhaust has under standard conditions corrected to fifty percent (50%) excess air. (f) The owner or operator of the incinerator must make the manufacturer’s specifications or the operation and maintenance plan available to the department upon request. If any of the requirements of (a) through (d) above are not met, then the owner or operator shall stop charging the incinerator until adjustments are made that address the underlying cause of the deviation. This condition is not federally enforceable.

D.7.4 Carbon Monoxide [40 CFR 52, Subpart P]

Pursuant to 40 CFR 52, Subpart P, the confidential document incinerator shall not cause or allow the discharge of carbon monoxide from refuse incineration or burning equipment, unless the waste gas stream is burned in a direct-flame afterburner


### . D.7.5 Carbon Monoxide [326 IAC 9-1] Pursuant to 326 IAC 9-1-2 (Carbon Monoxide Emission Limits, the incinerator shall not be operated unless the waste gas stream is burned in a direct-flame afterburner or a secondary chamber. This condition is not federally enforceable. Record Keeping and Reporting Requirements [326 IAC 2-8-4(3)] [326 IAC 2-8-16]
D.7. 2 6 Record Keeping Requirements (a) Pursuant to 40 CFR 60.110(b), the record keeping requirements contained in 40 CFR 60.116(b) and (a) are applicable to the storage vessels identified as tank 1 through 6 and 9 through 20 at plant 5 and tanks 1 through 5 at plant 8. The Permittee is required to: (1) Keep readily accessible records showing the dimension of the storage vessel and an analysis showing the capacity of the storage vessel; (2) The records required in (1) above, shall be kept for the life of the source. (b) All records shall be maintained in accordance with Section C - General Record Keeping Requirements.Rolls Royce Corporation

Indianapolis, Indiana OP No. T097-7238-00311 Permit Reviewer: A. Hennessy Page 31 of 32

On April 1, 2003, Rolls Royce Corporation submitted a request to update the NOx emission factors and fuel equivalencies for Emission Unit ID 0070-80 based on recently completed NOx emission testing. IDEM and OES agree with the request and the following changes have been made to Condition D.1.5(a): (a) NOx limitations (based on all boilers and turbines, Emission Units 01, 02, 03, 04, 58, 59, 62, 63, 64, 65, 71, 76, 79, 80 and 81): The input of natural gas and natural gas equivalents to the equipment covered in this permit shall be limited to less than 6205 MMCF natural gas per twelve (12) month consecutive period with compliance determined at the end of each month. This usage limitation is equivalent to a potential to emit of less than 325.74 tons per year, which keeps net emissions from the 1999 modification below 40 tons per year. (1) For the purposes of determining compliance every million cubic feet of natural gas shall be equivalent to the following:

Natural Gas Equivalents for Nitrogen Oxide Emissions

Emission Units MMCF per gal #4 oil MMCF per

gal #2 oil MMCF per

MMCF landfill gas MMCF per

MMCF natural gas MMCF

per gal #6 oil Boilers (Emission Unit ID 0070-01,02,03 and 04) 0.00023 0.00023 0.31928 N.A. N.A.

Boilers (Emission Unit ID 0070-58 and 59) 0.00023 0.00023 N.A. N.A. 0.00048

Boilers (Emission Unit ID 0070-62, 63, 64 and 65) N.A. 0.00023 0.31928 N.A. 0.00060

Turbines (Emission Unit ID 0070-80) N.A. N.A. 0.8257 3.90000 N.A.

Turbine s(Emission Unit ID s 0070-80 and 81) N.A. N.A. 0.34130 3.90000 N.A.

Turbines (Emission Unit IDs 0070-71) N.A. N.A. 0.34130 4.50000 N.A.

Turbines (Emission Unit IDs 0070-76, 79) N.A. N.A. 0.34130 6.50000 N.A.

and (2) NOx emissions are limited to: (A) Boilers (Emission Unit ID 0070-01, 02, 03, 04, 62, 63, 64 and 65) shall be limited to 0.1 lbs/MMBtu when burning natural gas; (B) Boilers (Emission Unit ID 0070-01, 02, 03, 04, 58, 59, 62, 63, 64 and 65) shall be limited to 0.175 lbs/MMBtu when burning #2 fuel oil; (C) Boilers (Emission Unit ID 0070-01, 02, 03, 04, 62, 63, 64 and 65) shall be limited to 0.058 lbs/MMBtu when burning landfill gas; (D) Boilers (Emission Unit ID 0070-01,02,03,04,58 and 59) shall be limited to 0.175 lbs/MMBtu when burning #4 fuel oil;Rolls Royce Corporation

Indianapolis, Indiana OP No. T097-7238-00311 Permit Reviewer: A. Hennessy Page 32 of 32

(E) Boilers (Emission Unit ID 0070-58 and 59) shall be limited to 0.336 lbs/MMBtu when burning #6 fuel oil; (F) Boilers (Emission Unit ID 0070-62, 63, 64 and 65)shall be limited to 0.447 lbs/MMBtu when burning #6 fuel oil; (G) Turbines (Emission Unit ID 0070-71, 76, 79, 80and 81) shall be limited to 0.062 lbs/MMBtu when burning landfill gas. (H) Turbine (Emission Unit ID 0070-80) shall be limited to 0.15 lbs/MMBtu when burning landfill gas. ( H I) Turbines (Emission Unit ID 0070-80 and 81) are limited to 0.390 lbs/MMBtu when combusting natural gas. ( I J) Turbine (Emission Unit ID 0070-71) is limited to 0.450 lbs/MMBtu when combusting natural gas. ( J K) Turbines (Emission Unit ID 0070-76 and 79) are limited to 0.650 lbs/MMBtu when combusting natural gas.TSD App. A page 1 of 8

Emission Unit ID 0070-66

Emission Unit Description Two Turbines model J-71, Test facility 841 Maximum Capacity (MMBtu/hr) 107 Fuel Jet Fuel HorsePower (Mechanical) 42024.25 Max Firing Rate 0.91 Stack ID 8-11a, 8-11b Stack Flowrate 81700 Stack Temp 600 Control None Date Installed 1955 Steps Point 811 Heat Content (Jet Fuel) 118232 Sulfur Content (Jet Fuel) 0.05 

### Emission Factors Pollutant Source Factor Units CO 1999 Steps 116.8 lbs/1000 gal SO2 1999 Steps 13 lbs/1000 gal VOC 1999 Steps 86 lbs/1000 gal NOx 1999 Steps 67.8 lbs/1000 gal PM 1999 Steps 24.3 lbs/1000 gal PM-10 1999 Steps 11.3 lbs/1000 gal 

### Potential Emissions Emissions Unit 0070-66a Emissions Unit 0070-66b Pollutant (lbs/hr) (tons/yr) (lbs/hr) (tons/yr) CO 105.70 462.98 105.70 462.98 SO2 11.77 51.53 11.77 51.53 VOC 77.83 340.90 77.83 340.90 NOx 61.36 268.75 61.36 268.75 PM 21.99 96.32 21.99 96.32 PM-10 10.23 44.79 10.23 44.79 

### Limited Potential To Emit Equivalent Emissions Emission Unit Pollutant Regulation Limit (lbs/hr) (tons/yr) 0070-66a PM 326 IAC 6-1-2(a) 0.03gr/dscf 21.01 92.02 0070-66a SO2 326 IAC 7-1 0.5 lbs/MMBtu 53.50 234.33 0070-66b PM 326 IAC 6-1-2(a) 0.03gr/dscf 21.01 92.02 0070-66b SO2 326 IAC 7-1 0.5 lbs/MMBtu 53.50 234.33TSD app. A page 2 of 8

Emission Unit ID 0070-72 0072-73 0070-05 Emission Unit Description

Plant 8 Pattern Shop Plant 8 Carpenter

Shop Plant 5 Carpenter

Shop Maximum Capacity (ton/hr) 1 1 1 Stack ID 8-16 8-17 5-8 Stack Flowrate 9500 6500 10000 Control Rotoclone Cyclone Cyclone Date Installed 1956 1956 1969 Steps Point 816 817 13

Pollutant SCC Number Emission Factor Unit PM 30700808 2 lbs/hr PM-10 30700808 0.8 lbs/hr

Potential Emissions Pollutant Emission Unit lbs/hr tons/yr PM 0070-72 2 8.76 PM-10 0070-72 0.8 3.504 PM 0072-73 2 8.76 PM-10 0072-73 0.8 3.504 PM 0070-05 2 8.76 PM-10 0070-05 0.8 3.504

Limited Potential to Emit Unit Pollutant Regulation Limit Unit Equivalent (lbs/hr) Equivalent (tons/yr) 0070-72 PM 326 IAC 6-1-2(a) 0.03 gr/dscf 2.44 10.70 0072-73 PM 326 IAC 6-1-2(a) 0.03 gr/dscf 1.67 7.32 0070-05 PM 326 IAC 6-1-2(a) 0.03 gr/dscf 2.57 11.26TSD App. A page 3 of 8

Emission Unit ID 0070-70a 0070-70b 0070-70c Emission Unit Description American Shack Heater American Shack

Heater American Shack

Heater Maximum Capacity (MMBtu/hr) 93.4 93.4 90 Max Firing Rate for Dist. 0.67 0.67 0.64 (1000 gal/hr) Max Firing Rate for NG NA NA 0.09 (MMcf/hr) Stack ID 8-6a 8-6b 8-6c Stack Flowrate 63000 63000 63000 (Based on Steps) Control None None None Date Installed 1956 1956 1956 Steps Point 815 815 815

Fuel Distillate Distillate Natual Gas and Distillate Heat Content (Distillate) 140000 140000 140000 Heat Content (Natural Gas) 1000 1000 1000 Sulfur Content (Distillate) 0.5 0.5 0.5 

### Emission Factors Distillate Fuel OiL (AP-42 Sect. 1-3) Natural Gas (AP-42 Sect. 1-4) Pollutant Emission Factor Units Emission Factor Units PM (filterable) 2 lbs/1000 gal 1.9 lbs/MMCF PM-10 1 lbs/1000 gal 7.6 lbs/MMCF NOx 20 lbs/1000 gal 100 lbs/MMCF CO 5 lbs/1000 gal 84 lbs/MMCF VOC 0.2 lbs/1000 gal 5.5 lbs/MMCF SO2 71 lbs/1000 gal 0.6 lbs/MMCF 

### Potential to Emit - Distillate Fuel OIL Emission Unit 0070-70a Emission Unit 0070-70b Emission Unit 0070-70c Pollutant (lbs/hr) (tons/yr) (lbs/hr) (tons/yr) (lbs/hr) (tons/yr) PM 1.33 5.84 1.33 5.84 1.29 5.63 PM-10 0.67 2.92 0.67 2.92 0.64 2.82 NOx 13.34 58.44 13.34 58.44 12.86 56.31 CO 3.34 14.61 3.34 14.61 3.21 14.08 VOC 0.13 0.58 0.13 0.58 0.13 0.56 SO2 47.37 207.47 47.37 207.47 45.64 199.92 

### Potential to Emit - Natural Gas Emission Unit 0070-70c Pollutant (lbs/hr) (tons/yr) PM 0.17 0.75 PM-10 0.68 3.00 NOx 9.00 39.42 CO 7.56 33.11 VOC 0.50 2.17 SO2 0.05 0.24



### Limited Potential To Emit Equivalent Emissions Emission Unit Pollutant Regulation Limit (lbs/hr) (tons/yr) 0070-70a PM 326 IAC 6-1-2(a) 0.03 gr/dscf 16.2 70.96 0070-70a SO2 3276 IAC 7-1 0.5% S by WT. 47.37 207.47 0070-70b PM 326 IAC 6-1-2(a) 0.03 gr/dscf 16.2 70.96 0070-70b SO2 3276 IAC 7-1 0.5% S by WT. 47.37 207.47 0070-70c PM 326 IAC 6-1-2(a) 0.03 gr/dscf 16.2 70.96 0070-70c SO2 3276 IAC 7-1 0.5% S by WT. 45.64 199.92TSD App. A page 4 of 8

Emission Unit ID 0070-01 0070-02 0070-03 0070-04 0070-58 0070-59 Description Boiler 1 Boiler 2 Boiler 3 Boiler 4 Boiler 3 Boiler 4 Location Plant 5 Plant 5 Plant 5 Plant 5 Plant 8 Plant 8 Maximum Capacity (mmBtu/hr) 88 88 88 88 44 44 Stack I.D. No. 5-1 5-1 5-1 5-1 8-1 8-2 Fuel Types Cable of Firing NG, & #2#4#6 FO NG, & #2#4#6 FO NG, & #2#4#6 FOCoal, & #2#4#6 FONG, & #2#4#6 FO NG, & #2#4#6 FO Date Installed 1942 1942 1942 1942 1953 1953 Date Modified 1996* & 1999** 1996* & 1999** 1996* & 1999** 1999** NA NA

Emission Unit ID 0070-60 0070-61 0070-62 0070-63 0070-64 0070-65 Description Boiler 5 Boiler 6 Boiler 7 Boiler 8 Boiler 9 Boiler 10 Location Plant 8 Plant 8 Plant 8 Plant 8 Plant 8 Plant 8 Maximum Capacity (mmBtu/hr) 88 88 244 244 244 244 Stack I.D. No. 8-3 8-4 8-5 8-6 8-7 8-8 Fuel Types Cable of Firing NG, & #2#4#6 FO NG, & #2#4#6 FO NG, & #2#4#6 FO NG, & #2#4#6 FO NG, & #2#4#6 FO NG, & #2#4#6 FO Date Installed 1953 1953 1956 1956 1956 1956 Date Modified NA NA 1999** 1999** 1999** 1999**

Emission Unit ID 0070-71 0070-76 0070-79 0070-80 0070-81 Description 2.5MW GasTurb. 5MW GasTurb. 5MW GasTurb. 5MW GasTurb. 7.7MW GasTurb. Location Plant 5 Plant 5 Plant 5 Plant 5 Plant 8 Maximum Capacity (mmBtu/hr) 88 88 244 244 244 Stack I.D. No. 8-9 5-22 8-79 8-80 8-81 Fuel Types Cable of Firing NG & LG NG & LG NG & LG NG & LG NG & LG Date Installed 1978 1999** 1999** 1999** 1999** Date Modified 1999** NA NA NA NA

*Converted from coal to fuel oil and natrual gas.

Fuel Precent Sulfur by weight Precent Ash by

weight Fuel (Btu/gal or

Btu/mmcf or Btu/lb) Natural Gas NA NA 1000 Landfill Gas Coal (Bituminus) 7.64 1.68 11517 #2 Fuel Oil 1.8 NA 139000 #4 Fuel Oil 1.8 0.84 139000 #6 Fuel Oil 1.8 1.12(S)+0.37 156441

Pollutant PM (Filterable) PM-10 SO2 NOx VOC CO #2 Fuel Oil (lb/Kgal) 2 1 142(S) 24.0 0.20 5.0 #4 Fuel Oil (lb/Kgal) 7 7.17(A) 150(S) 47.0 0.20 5.0 #6 Fuel Oil (lb/Kgal) 10 7.17(A) 157(S) 47.0 0.28 5.0 Natrual Gas (lb/MMcf) 7.6 7.6 0.6 100.0 5.5 84.0

Methodology Normal Firing Emission Factors were used. 1 gallon of #5 Fuel oil has a heating value of 139,000 Btu 1 gallon of #6 Fuel oil has a heating value of 150,000 Btu 1 gallon of No. 2 Fuel Oil has a heating value of 140,000 Btu Potential Throughput #2 Fuel Oil (kgals/year) = Heat Input Capacity (MMBtu/hr) x 8,760 hrs/yr x 1kgal per 1000 gallon x 1 gal per 0.139 MM Btu Potential Throughput #5 Fuel Oil (kgals/year) = Heat Input Capacity (MMBtu/hr) x 8,760 hrs/yr x 1kgal per 1000 gallon x 1 gal per 0.140 MM Btu Potential Throughput #6 Fuel Oil (kgals/year) = Heat Input Capacity (MMBtu/hr) x 8,760 hrs/yr x 1kgal per 1000 gallon x 1 gal per 0.150 MM Btu Potential Throughput Natural Gas (MMCF) = Heat Input Capacity (MMBtu/hr) x 8,760 hrs/yr x 1 MMCF/1,000 MMBtu Emission Factors for #5 and #6 Fuel Oil are from AP42 Tables 1.3-1, 1.3-2 and 1.3-3 (SCC 1-01-004-01/02/03 and 1-01-004-05 and 1-02-004-04) (AP-42 Supplement E 9/98) Emission Factors for #2 Fuel Oil are from AP 42, Tables 1.3-1, 1.3-2, and 1.3-3 (SCC 1-02-005-01/02/03) Supplement E 9/98 Emission Factors Nautral Gas are from AP 42, Chapter 1.4, Tables 1.4-1, 1.4-2, 1.4-3, SCC #1-02-006-02, 1-01-006-02, 1-03-006-02, and 1-03-006-03 (Supplement D 3/98)

PM Emissions are Condensible and Filterable PM Emission From Fuel Oil Comb. (tons/yr) = Throughput (kgals/ yr) x Emission Factor (lb/kgal)/2,000 lb/ton Emission From Natrual Gas Comb. (tons/yr) = Throughput (MMCF/yr) x Emission Factor (lb/MMCF)/2,000 lb/tonEmission Unit ID 0070-67 TSD App A page 5 of 8

Emission Unit Description Twelve Turbines model T-56, Test facility D-2, 873 Maximum Capacity (MMBtu/hr) 27.2 Fuel Jet Fuel HorsePower (Mechanical) 10682.8 Max Firing Rate 0.23 Stack ID 8-13a - m Stack Flowrate 63310 Stack Temp 900 Control None Date Installed 1955 Steps Point 811 Heat Content (Jet Fuel) 118232 Sulfur Content (Jet Fuel) 0.05 

### Emission Factors Pollutant Source Factor Units CO 1999 Steps 23.82 lbs/1000 gal SO2 1999 Steps 6.2 lbs/1000 gal VOC 1999 Steps 6.7 lbs/1000 gal NOx 1999 Steps 67.8 lbs/1000 gal PM 1999 Steps 24.3 lbs/1000 gal PM-10 1999 Steps 4.8 lbs/1000 gal 

### Potential Emissions Emissions Unit 0070-67 (each) Emissions Unit 0070-67 (all) Pollutant (lbs/hr) (tons/yr) (lbs/hr) (tons/yr) CO 5.48 24.00 65.76 288.03 SO2 1.43 6.25 17.12 74.97 VOC 1.54 6.75 18.50 81.01 NOx 15.60 68.32 187.17 819.82 PM 5.59 24.49 67.08 293.83 PM-10 1.10 4.84 13.25 58.04 

### Limited Potential To Emit Equivalent Emissions Emission Unit Pollutant Regulation Limit (lbs/hr) (tons/yr) 0070-67(each) PM 326 IAC 6-1-2(a) 0.03gr/dscf 16.28 71.31Emission Unit ID 0070-68 TSD App A page 6 of 8

Emission Unit Description Ten Turbines model T-56, Test facility D-3, dept 873 Maximum Capacity (MMBtu/hr) 27.2 Fuel Jet Fuel HorsePower (Mechanical) 10682.8 Max Firing Rate 0.23 Stack ID 8-12a -j Stack Flowrate 63310 Stack Temp 900 Control None Date Installed 1955 Steps Point 811 Heat Content (Jet Fuel) 118232 Sulfur Content (Jet Fuel) 0.05 

### Emission Factors Pollutant Source Factor Units CO 1999 Steps 23.82 lbs/1000 gal SO2 1999 Steps 6.2 lbs/1000 gal VOC 1999 Steps 6.7 lbs/1000 gal NOx 1999 Steps 67.8 lbs/1000 gal PM 1999 Steps 24.3 lbs/1000 gal PM-10 1999 Steps 4.8 lbs/1000 gal 

### Potential Emissions Emissions Unit 0070-68 (each) Emissions Unit 0070-68 (all) Pollutant (lbs/hr) (tons/yr) (lbs/hr) (tons/yr) CO 5.48 24.00 54.80 240.02 SO2 1.43 6.25 14.26 62.47 VOC 1.54 6.75 15.41 67.51 NOx 15.60 68.32 155.98 683.18 PM 5.59 24.49 55.90 244.86 PM-10 1.10 4.84 11.04 48.37 

### Limited Potential To Emit Equivalent Emissions Emission Unit Pollutant Regulation Limit (lbs/hr) (tons/yr) 0070-68(each) PM 326 IAC 6-1-2(a) 0.03gr/dscf 16.28 71.31Emission Unit ID 0070-69 TSD App A page 7 of 8

Emission Unit Description Four Turbines model T-56, Test facility D-4, dept 873 Maximum Capacity (MMBtu/hr) 27.2 Fuel Jet Fuel HorsePower (Mechanical) 10682.8 Max Firing Rate 0.23 Stack ID 8-12a -d Stack Flowrate 63310 Stack Temp 900 Control None Date Installed 1955 Steps Point 811 Heat Content (Jet Fuel) 118232 Sulfur Content (Jet Fuel) 0.05 

### Emission Factors Pollutant Source Factor Units CO 1999 Steps 23.82 lbs/1000 gal SO2 1999 Steps 6.2 lbs/1000 gal VOC 1999 Steps 6.7 lbs/1000 gal NOx 1999 Steps 67.8 lbs/1000 gal PM 1999 Steps 24.3 lbs/1000 gal PM-10 1999 Steps 4.8 lbs/1000 gal 

### Potential Emissions Emissions Unit 0070-69 (each) Emissions Unit 0070-69 (all) Pollutant (lbs/hr) (tons/yr) (lbs/hr) (tons/yr) CO 5.48 24.00 54.80 240.02 SO2 1.43 6.25 14.26 62.47 VOC 1.54 6.75 15.41 67.51 NOx 15.60 68.32 155.98 683.18 PM 5.59 24.49 55.90 244.86 PM-10 1.10 4.84 11.04 48.37 

### Limited Potential To Emit Equivalent Emissions Emission Unit Pollutant Regulation Limit (lbs/hr) (tons/yr) 0070-69(each) PM 326 IAC 6-1-2(a) 0.03gr/dscf 16.28 71.31TSD App A page 8 of 8

Emission Unit ID 0070-08 0070-N55 0070-74 Emission Unit Description ShotBlast Machine Plt 5 Misc. Sanding and Blasting Sand Blasting

Dept 0862 Plt 8 Maximum Capacity (ton/hr) 0.024 0.2 0.002 (Taken from 1999 Steps) Stack ID 5-8 SN55 8-18 Stack Flowrate 20000 9000 16000 (Taken from 1999 Steps) Control Baghouse Dust Collector Baghouse Date Installed 1964 1991 1969 Steps Point 17 855 818 (Taken from 1999 Steps)



### Emission Factors

Abrasive lb PM /lb abrasive lb PM10 /lb PM Sand 0.027 0.01 AP-42 Sect 13.2 Steel Shot 0.860 0.004

Potential Emissions Before Control Unit 0070-N55 Unit 0070-74 Unit 0070-08 Pollutant lbs/hr tons/yr lbs/hr tons/yr lbs/hr tons/yr PM 10.800 47.304 0.108 0.473 41.280 180.806 PM-10 5.200 22.776 0.05 0.228 0.19 0.84

Potential Emissions After Control Unit 0070-N55 Unit 0070-74 Unit 0070-08 Pollutant lbs/hr tons/yr lbs/hr tons/yr lbs/hr tons/yr PM 0.108 0.473 0.001 0.005 0.413 1.808 PM-10 0.052 0.228 0.001 0.002 0.002 0.008 

### Limited Potential To Emit Equivalent Emissions Pot. After Control Emission Unit Pollutant Regulation Limit (lbs/hr) (tons/yr) (lbs/hr) 0070-N55 PM 326 IAC 6-1-2(a) 0.03gr/dscf 2.31 10.14 0.108 0070-74 PM 326 IAC 6-1-2(a) 0.03gr/dscf 4.11 18.02 0.001 0070-08 PM 326 IAC 6-1-2(a) 0.03gr/dscf 5.14 22.53 0.413