00004 - NYSDEC - New York State

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Facility DEC ID: 7355400088

PERMIT Under the Environmental Conservation Law (ECL) IDENTIFICATION INFORMATION Permit Type: Air State Facility Permit ID: 7-3554-00088/00004 Mod 0 Effective Date: 06/26/2014 Expiration Date: 06/25/2024 Mod 1 Effective Date: 02/07/2018 Expiration Date: 06/25/2024

Permit Issued To:SOUTHERN GRAPHIC SYSTEMS LLC 626 WEST MAIN ST LOUISVILLE, KY 40202-4269 Contact:

VICTOR J BARANOWSKI SOUTHERN GRAPHIC SYSTEMS LLC 67 CO RTE 59 PHOENIX, NY 13135

Facility:

SOUTHERN GRAPHIC SYSTEMS LLC 67 CO RTE 59 PHOENIX, NY 13135

Description:

This modification authorizes the use of an existing packed bed scrubber (Control ID C0002) to control emissions from DeChrome Tank #2. By acceptance of this permit, the permittee agrees that the permit is contingent upon strict compliance with the ECL, all applicable regulations, the General Conditions specified and any Special Conditions included as part of this permit. Permit Administrator:

Authorized Signature:

ELIZABETH A TRACY 615 ERIE BLVD WEST SYRACUSE, NY 13204-2400 _________________________________

DEC Permit Conditions Mod 1/FINAL Page 1

Date: ___ / ___ / _____

Facility DEC ID: 7355400088

Notification of Other State Permittee Obligations Item A:

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

Item B:

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

Item C:

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

Item D:

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

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Facility DEC ID: 7355400088

LIST OF CONDITIONS

DEC GENERAL CONDITIONS General Provisions Facility Inspection by the Department Relationship of this Permit to Other Department Orders and Determinations Applications for permit renewals, modifications and transfers Applications for permit renewals, modifications and transfers Permit modifications, suspensions or revocations by the Department Facility Level Submission of application for permit modification or renewal-REGION 7 HEADQUARTERS

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Facility DEC ID: 7355400088

DEC GENERAL CONDITIONS **** General Provisions **** GENERAL CONDITIONS - Apply to ALL Authorized Permits.

Condition 1: Facility Inspection by the Department Applicable State Requirement: ECL 19-0305 Item 1.1: The permitted site or facility, including relevant records, is subject to inspection at reasonable hours and intervals by an authorized representative of the Department of Environmental Conservation (the Department) to determine whether the permittee is complying with this permit and the ECL. Such representative may order the work suspended pursuant to ECL 71-0301 and SAPA 401(3). Item 1.2: The permittee shall provide a person to accompany the Department's representative during an inspection to the permit area when requested by the Department. Item 1.3: A copy of this permit, including all referenced maps, drawings and special conditions, must be available for inspection by the Department at all times at the project site or facility. Failure to produce a copy of the permit upon request by a Department representative is a violation of this permit. Condition 2: Relationship of this Permit to Other Department Orders and Determinations Applicable State Requirement: ECL 3-0301 (2) (m) Item 2.1: Unless expressly provided for by the Department, issuance of this permit does not modify, supersede or rescind any order or determination previously issued by the Department or any of the terms, conditions or requirements contained in such order or determination. Condition 3: Applications for permit renewals, modifications and transfers Applicable State Requirement: 6 NYCRR 621.11 Item 3.1: The permittee must submit a separate written application to the Department for renewal, modification or transfer of this permit. Such application must include any forms or supplemental information the Department requires. Any renewal, modification or transfer granted by the Department must be in writing. Item 3.2: The permittee must submit a renewal application at least 180 days before expiration of permits for Title V Facility Permits, or at least 30 days before expiration of permits for State Facility Permits. Item 3.3: Permits are transferrable with the approval of the department unless specifically prohibited by the statute, regulation or another permit condition. Applications for permit transfer should be submitted prior to actual transfer of ownership. DEC Permit Conditions Mod 1/FINAL Page 4

Facility DEC ID: 7355400088

Condition 1-1: Applications for permit renewals, modifications and transfers Applicable State Requirement: 6 NYCRR 621.11

Item 1-1.1: The permittee must submit a separate written application to the Department for renewal, modification or transfer of this permit. Such application must include any forms or supplemental information the Department requires. Any renewal, modification or transfer granted by the Department must be in writing. Item1-1.2: The permittee must submit a renewal application at least 180 days before the expiration of permits for Title V and State Facility Permits. Item 1-1.3 Permits are transferrable with the approval of the department unless specifically prohibited by the statute, regulation or another permit condition. Applications for permit transfer should be submitted prior to actual transfer of ownership. Condition 4: Permit modifications, suspensions or revocations by the Department Applicable State Requirement: 6 NYCRR 621.13 Item 4.1: The Department reserves the right to exercise all available authority to modify, suspend, or revoke this permit in accordance with 6NYCRR Part 621. The grounds for modification, suspension or revocation include: a) materially false or inaccurate statements in the permit application or supporting papers; b) failure by the permittee to comply with any terms or conditions of the permit; c) exceeding the scope of the project as described in the permit application; d) newly discovered material information or a material change in environmental conditions, relevant technology or applicable law or regulations since the issuance of the existing permit; e) noncompliance with previously issued permit conditions, orders of the commissioner, any provisions of the Environmental Conservation Law or regulations of the Department related to the permitted activity.

**** Facility Level **** Condition 5: Submission of application for permit modification or renewal-REGION 7 HEADQUARTERS Applicable State Requirement: 6 NYCRR 621.6 (a) Item 5.1: Submission of applications for permit modification or renewal are to be submitted to: NYSDEC Regional Permit Administrator Region 7 Headquarters Division of Environmental Permits DEC Permit Conditions Mod 1/FINAL Page 5

Facility DEC ID: 7355400088

615 Erie Blvd West Syracuse, NY 13204-2400 (315) 426-7400

DEC Permit Conditions Mod 1/FINAL Page 6

Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

Permit Under the Environmental Conservation Law (ECL) ARTICLE 19: AIR POLLUTION CONTROL - AIR STATE FACILITY PERMIT IDENTIFICATION INFORMATION Permit Issued To:SOUTHERN GRAPHIC SYSTEMS LLC 626 WEST MAIN ST LOUISVILLE, KY 40202-4269

Facility:

SOUTHERN GRAPHIC SYSTEMS LLC 67 CO RTE 59 PHOENIX, NY 13135

Authorized Activity By Standard Industrial Classification Code: 2796 - PLATEMAKING SERVICES Mod 0 Permit Effective Date: 06/26/2014

Permit Expiration Date: 06/25/2024

Mod 1 Permit Effective Date: 02/07/2018

Permit Expiration Date: 06/25/2024

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

LIST OF CONDITIONS

FEDERALLY ENFORCEABLE CONDITIONS Facility Level 1-1 6 NYCRR 200.7: Maintenance of Equipment 1-2 6 NYCRR 200.7: Compliance Demonstration 1-3 6 NYCRR 200.7: Compliance Demonstration 1 6 NYCRR 211.1: Air pollution prohibited 1-4 6 NYCRR 212-1.6 (a): Compliance Demonstration 1-5 6 NYCRR 212-2.4 (b): Compliance Demonstration 1-6 6 NYCRR 228-1.3 (b) (2): Compliance Demonstration 1-7 40CFR 63.340(b), Subpart N: Compliance Demonstration 1-8 40CFR 63.342(b)(1), Subpart N: Standards apply during all tank operation 1-9 40CFR 63.342(c)(2)(vi), Subpart N: Compliance Demonstration 1-10 40CFR 63.342(f), Subpart N: Compliance Demonstration 1-11 40CFR 63.343(c)(1), Subpart N: Compliance Demonstration 1-12 40CFR 63.343(c)(4)(ii), Subpart N: Compliance Demonstration 1-13 40CFR 63.344, Subpart N: Compliance Demonstration 1-14 40CFR 63.344, Subpart N: Compliance Demonstration 1-15 40CFR 63.344(d), Subpart N: Compliance Demonstration 1-16 40CFR 63.345(b), Subpart N: Compliance Demonstration 1-17 40CFR 63.346, Subpart N: Compliance Demonstration 1-18 40CFR 63.347(a), Subpart N: Compliance Demonstration 1-19 40CFR 63.347(d), Subpart N: Compliance Demonstration 1-20 40CFR 63.347(f), Subpart N: Compliance Demonstration 1-21 40CFR 63.347(h), Subpart N: Compliance Demonstration Emission Unit Level EU=U-00001 1-23 40CFR 63.340(b), Subpart N: Part 63 General Provisions requirements 1-22 40CFR 63.347(e)(2), Subpart N: Required content for notification of compliance status STATE ONLY ENFORCEABLE CONDITIONS Facility Level 26 ECL 19-0301: Contaminant List 27 6 NYCRR 201-1.4: Malfunctions and start-up/shutdown activities 28 6 NYCRR Subpart 201-5: Emission Unit Definition 29 6 NYCRR 201-5.2 (c): Renewal deadlines for state facility permits 30 6 NYCRR 201-5.3 (c): Compliance Demonstration 31 6 NYCRR 211.2: Visible Emissions Limited 1-24 6 NYCRR 212-2.1: Compliance Demonstration 1-25 6 NYCRR 212-2.1: Compliance Demonstration 1-26 6 NYCRR 212-2.1: Compliance Demonstration 1-27 6 NYCRR 212-2.1: Compliance Demonstration 1-28 6 NYCRR 212-2.1 (a): Compliance Demonstration 1-29 6 NYCRR 212-2.1 (a): Compliance Demonstration Emission Unit Level 32 6 NYCRR Subpart 201-5: Emission Point Definition By Emission Unit 33 6 NYCRR Subpart 201-5: Process Definition By Emission Unit

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Permit ID: 7-3554-00088/00004

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

FEDERALLY ENFORCEABLE CONDITIONS **** Facility Level ****

NOTIFICATION OF GENERAL PERMITTEE OBLIGATIONS This section contains terms and conditions which are federally enforceable. Permittees may also have other obligations under regulations of general applicability Item A:

Sealing - 6 NYCRR 200.5 The Commissioner may seal an air contamination source to prevent its operation if compliance with 6 NYCRR Chapter III is not met within the time provided by an order of the Commissioner issued in the case of the violation. Sealing means labeling or tagging a source to notify any person that operation of the source is prohibited, and also includes physical means of preventing the operation of an air contamination source without resulting in destruction of any equipment associated with such source, and includes, but is not limited to, bolting, chaining or wiring shut control panels, apertures or conduits associated with such source. No person shall operate any air contamination source sealed by the Commissioner in accordance with this section unless a modification has been made which enables such source to comply with all requirements applicable to such modification. Unless authorized by the Commissioner, no person shall remove or alter any seal affixed to any contamination source in accordance with this section.

Item B:

Acceptable Ambient Air Quality - 6 NYCRR 200.6 Notwithstanding the provisions of 6 NYCRR Chapter III, Subchapter A, no person shall allow or permit any air contamination source to emit air contaminants in quantities which alone or in combination with emissions from other air contamination sources would contravene any applicable ambient air quality standard and/or cause air pollution. In such cases where contravention occurs or may occur, the Commissioner shall specify the degree and/or method of emission control required.

Item C:

Maintenance of Equipment - 6 NYCRR 200.7 Any person who owns or operates an air contamination source which is equipped with an emission control device shall operate such device and keep it in a satisfactory state of maintenance and repair in accordance with ordinary and necessary practices, standards and procedures, inclusive of manufacturer's specifications,

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required to operate such device effectively. Item D:

Unpermitted Emission Sources - 6 NYCRR 201-1.2 If an existing emission source was subject to the permitting requirements of 6 NYCRR Part 201 at the time of construction or modification, and the owner and/or operator failed to apply for a permit for such emission source then the following provisions apply: (a) The owner and/or operator must apply for a permit for such emission source or register the facility in accordance with the provisions of Part 201. (b) The emission source or facility is subject to all regulations that were applicable to it at the time of construction or modification and any subsequent requirements applicable to existing sources or facilities.

Item E:

Recycling and Salvage - 6 NYCRR 201-1.7 Where practical, any person who owns or operates an air contamination source shall recycle or salvage air contaminants collected in an air cleaning device according to the requirements of 6 NYCRR.

Item F:

Prohibition of Reintroduction of Collected Contaminants to the Air - 6 NYCRR 201-1.8 No person shall unnecessarily remove, handle, or cause to be handled, collected air contaminants from an air cleaning device for recycling, salvage or disposal in a manner that would reintroduce them to the outdoor atmosphere.

Item G:

Proof of Eligibility for Sources Defined as Exempt Activities - 6 NYCRR 201-3.2 (a) The owner and/or operator of an emission source or unit that is eligible to be exempt, may be required to certify that it operates within the specific criteria described in 6 NYCRR Subpart 201-3. The owner or operator of any such emission source must maintain all required records on-site for a period of five years and make them available to representatives of the Department upon request. Department representatives must be granted access to any facility which contains emission sources or units subject to 6 NYCRR Subpart 201-3, during normal operating hours, for the purpose of determining compliance with this and any other state and federal air pollution control requirements, regulations, or law.

Item H:

Proof of Eligibility for Sources Defined as Trivial

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

Activities - 6 NYCRR 201-3.3 (a) The owner and/or operator of an emission source or unit that is listed as being trivial in 6 NYCRR Part 201 may be required to certify that it operates within the specific criteria described in 6 NYCRR Subpart 201-3. The owner or operator of any such emission source must maintain all required records on-site for a period of five years and make them available to representatives of the Department upon request. Department representatives must be granted access to any facility which contains emission sources or units subject to 6 NYCRR Subpart 201-3, during normal operating hours, for the purpose of determining compliance with this and any other state and federal air pollution control requirements, regulations, or law. Item I:

Required Emission Tests - 6 NYCRR 202-1.1 An acceptable report of measured emissions shall be submitted, as may be required by the Commissioner, to ascertain compliance or noncompliance with any air pollution code, rule, or regulation. Failure to submit a report acceptable to the Commissioner within the time stated shall be sufficient reason for the Commissioner to suspend or deny an operating permit. Notification and acceptable procedures are specified in 6 NYCRR Subpart 202-1.

Item J:

Open Fires Prohibitions - 6 NYCRR 215.2 Except as allowed by section 215.3 of 6 NYCRR Part 215, no person shall burn, cause, suffer, allow or permit the burning of any materials in an open fire.

Item K:

Permit Exclusion - ECL 19-0305 The issuance of this permit by the Department and the receipt thereof by the Applicant does not and shall not be construed as barring, diminishing, adjudicating or in any way affecting any legal, administrative or equitable rights or claims, actions, suits, causes of action or demands whatsoever that the Department may have against the Applicant for violations based on facts and circumstances alleged to have occurred or existed prior to the effective date of this permit, including, but not limited to, any enforcement action authorized pursuant to the provisions of applicable federal law, the Environmental Conservation Law of the State of New York (ECL) and Chapter III of the Official Compilation of the Codes, Rules and Regulations of the State of New York (NYCRR). The issuance of this permit also shall not in any way affect pending or future enforcement actions under the Clean Air Act brought by the United States or any person.

Item L:

Federally Enforceable Requirements - 40 CFR 70.6 (b)

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

All terms and conditions in this permit required by the Act or any applicable requirement, including any provisions designed to limit a facility's potential to emit, are enforceable by the Administrator and citizens under the Act. The Department has, in this permit, specifically designated any terms and conditions that are not required under the Act or under any of its applicable requirements as being enforceable under only state regulations.

FEDERAL APPLICABLE REQUIREMENTS The following conditions are federally enforceable.

Condition 1-1:

Maintenance of Equipment Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:6 NYCRR 200.7

Item 1-1.1: Any person who owns or operates an air contamination source which is equipped with an emission control device shall operate such device and keep it in a satisfactory state of maintenance and repair in accordance with ordinary and necessary practices, standards and procedures, inclusive of manufacturer's specifications, required to operate such device effectively. Condition 1-2:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:6 NYCRR 200.7

Item 1-2.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: U-00001 Process: P03

Emission Source: C0002

Emission Unit: U-00001 Process: P03

Emission Source: C0006

Emission Unit: U-00001 Process: P03

Emission Source: S0004

Emission Unit: U-00001 Process: P03

Emission Source: S0005

Emission Unit: U-00004 Process: P10

Emission Source: C0004

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

Emission Unit: U-00004 Process: P10

Emission Source: C0005

Emission Unit: U-00004 Process: P10

Emission Source: S0014

Emission Unit: U-00004 Process: P11

Emission Source: C0004

Emission Unit: U-00004 Process: P11

Emission Source: C0005

Emission Unit: U-00004 Process: P11

Emission Source: S0015

Item 1-2.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: This condition is not federally enforceable because 6 NYCRR 212 is not federally enforceable. When 6 NYCRR 212 is approved into the State Implementation Plan, this condition will be federally enforceable. 1. The owner or operator shall operate each control device whenever the associated process is in operation. 2. No later than 180 days after the effective date of this permit, the owner or operator shall submit to the DEC for approval an operation and maintenance plan for each control device at the facility. The plan shall include: a) a description of each emission source and each control device b) procedures to continuously measure and record scrubber flow recirculation rate, including procedures to calibrate the flow monitoring device c) operating ranges for scrubber recirculation flow d) operating ranges for scrubber pH e) procedures to monitor scrubber pressure drop. 3. No later than 180 days from the effective date of this permit, the owner shall comply with the operation and maintenance plan.

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Permit ID: 7-3554-00088/00004

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4. On an annual basis, the owner or operator shall state, in the annual certification report, whether he or she has complied with this request and the Operation and Maintenance Plan. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/2019. Subsequent reports are due every 12 calendar month(s). Condition 1-3:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:6 NYCRR 200.7

Item 1-3.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: U-00001 Process: P01

Emission Source: C001B

Emission Unit: U-00001 Process: P01

Emission Source: CME1B

Emission Unit: U-00001 Process: P01

Emission Source: CME2B

Emission Unit: U-00001 Process: P01

Emission Source: S001B

Emission Unit: U-00001 Process: P01

Emission Source: S002B

Item 1-3.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: 1. The owner or operator shall operate each control device whenever the associated process is in operation. 2. No later than 180 days after the effective date of this permit, the owner or operator shall submit to the DEC for approval an operation and maintenance plan for each control device at the facility. The plan shall include:

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

a) a description of each emission source and each control device b) procedures to continuously measure and record scrubber flow recirculation rate, including procedures to calibrate the flow monitoring device c) operating ranges for scrubber recirculation flow d) operating ranges for scrubber pH e) procedures to monitor scrubber pressure drop. 3. No later than 180 days from the effective date of this permit, the owner shall comply with the operation and maintenance plan. 4. On an annual basis, the owner or operator shall state, in the annual certification report, whether he or she has complied with this request and the Operation and Maintenance Plan. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/2019. Subsequent reports are due every 12 calendar month(s). Condition 1:

Air pollution prohibited Effective between the dates of 06/26/2014 and 06/25/2024 Applicable Federal Requirement:6 NYCRR 211.1

Item 1.1: No person shall cause or allow emissions of air contaminants to the outdoor atmosphere of such quantity, characteristic or duration which are injurious to human, plant or animal life or to property, or which unreasonably interfere with the comfortable enjoyment of life or property. Notwithstanding the existence of specific air quality standards or emission limits, this prohibition applies, but is not limited to, any particulate, fume, gas, mist, odor, smoke, vapor, pollen, toxic or deleterious emission, either alone or in combination with others.

Condition 1-4:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:6 NYCRR 212-1.6 (a)

Item 1-4.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to:

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

Emission Unit: U-00001

Emission Point: E0002

Emission Unit: U-00001

Emission Point: E0010

Emission Unit: U-00002

Emission Point: E0004

Emission Unit: U-00002

Emission Point: E0005

Emission Unit: U-00002

Emission Point: E0006

Emission Unit: U-00002

Emission Point: E0007

Emission Unit: U-00004

Emission Point: E0008

Emission Unit: U-00004

Emission Point: E0009

Item 1-4.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description:

This condition is applicable to all process sources (not otherwise exempt under 6 NYCRR 212-1.4). 1. No facility owner or operator shall cause or allow emissions having an average opacity during any six consecutive minutes of 20 percent or greater from any process emission source or emission point, except for the emission of uncombined water. 2. Compliance shall be determined in accordance with a protocol approved by the Department and 6 NYCRR 202-1. Performance testing shall be conducted upon written request from the Department. Parameter Monitored: OPACITY Upper Permit Limit: 20 percent Reference Test Method: EPA Method 9 Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Averaging Method: 6-MINUTE AVERAGE (METHOD 9) Reporting Requirements: ONCE / BATCH OR MONITORING OCCURRENCE Condition 1-5:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:6 NYCRR 212-2.4 (b)

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

Item 1-5.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: U-00001

Emission Point: E0002

Emission Unit: U-00001

Emission Point: E0010

Emission Unit: U-00002

Emission Point: E0004

Emission Unit: U-00002

Emission Point: E0005

Emission Unit: U-00002

Emission Point: E0006

Emission Unit: U-00002

Emission Point: E0007

Emission Unit: U-00004

Emission Point: E0008

Emission Unit: U-00004

Emission Point: E0009

Regulated Contaminant(s): CAS No: 0NY075-00-0

PARTICULATES

Item 1-5.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description:

This condition is applicable to all process sources (not otherwise exempt under 6 NYCRR 212-1.4). 1. No facility owner or operator shall cause or allow emissions of particulate that exceed 0.050 grains per cubic foot of exhaust gas, expressed at standard conditions on a dry gas basis. 2. Compliance shall be determined in accordance with a protocol approved by the Department and 6 NYCRR 202-1. Performance testing shall be conducted upon written request from the Department. Parameter Monitored: PARTICULATES Upper Permit Limit: 0.05 grains per dscf Reference Test Method: EPA Methods 1 - 5 Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: ONCE / BATCH OR MONITORING OCCURRENCE

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Condition 1-6:

Facility DEC ID: 7355400088

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:6 NYCRR 228-1.3 (b) (2)

Item 1-6.1: The Compliance Demonstration activity will be performed for the Facility. Item 1-6.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: 1. This facility is not subject to 6 NYCRR 228-1 provided it (1) uses less than 55 gallons of coatings or (2) uses less than 400 pounds of VOC, each measured on a 12-month rolling total basis. 2. The facility must maintain records to demonstrate one of the criteria specified in Item 1 of this condition. If the facility demonstrates that it meets the exemption based on VOC usage, the facility must keep records documenting the amount of VOC containing materials used and the amount of VOC contained in those coatings. 3. All records used to demonstrate that the facility meets the exemption criteria must be maintained for five years. Parameter Monitored: VOC Upper Permit Limit: 400 pounds Monitoring Frequency: MONTHLY Averaging Method: 12-MONTH TOTAL, ROLLED MONTHLY Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 1-7:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:40CFR 63.340(b), Subpart N

Item 1-7.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: U-00001 Item 1-7.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Owners or operators of affected sources subject to 40 CFR

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

63 Subpart N must also comply with the requirements of Subpart A of Part 63, according to the applicability of Subpart A to such sources, as identified in Table 1 of Subpart N. Subpart A is the General Provisions for the NESHAP for Source Categories regulations. The General Provisions contain requirements for performance testing, monitoring, notification, recordkeeping, reporting, and control devices that may apply to the source. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 1-8:

Standards apply during all tank operation Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:40CFR 63.342(b)(1), Subpart N Replaces Condition(s) 6

Item 1-8.1: This Condition applies to: Emission Unit: U00001

Item 1-8.2: The emission limitations in this section apply during tank operation as defined in 40 CFR 63.341, and during periods of startup and shutdown as these are routine occurrences for affected sources subject to subpart N. In response to an action to enforce the standards set forth in subpart N, the owner or operator may assert a defense to a claim for civil penalties for violations of such standards that are caused by a malfunction, as defined in 40 CFR 63.2. Appropriate penalties may be assessed, however, if the owner or operator fails to meet the burden of proving all the requirements in the affirmative defense. The affirmative defense shall not be available for claims for injunctive relief. (i) To establish the affirmative defense in any action to enforce such a standard, the owner or operator must timely meet the reporting requirements of paragraph (ii), and must prove by a preponderance of evidence that: (A) The violation was caused by a sudden, infrequent, and unavoidable failure of air pollution control equipment, process equipment, or a process to operate in a normal and usual manner; and could not have been prevented through careful planning, proper design or better operation and maintenance practices; and did not stem from any activity or event that could have been foreseen and avoided, or planned for; and was not part of a recurring pattern indicative of inadequate design, operation, or maintenance; and (B) Repairs were made as expeditiously as possible when exceeded violation occurred. Off-shift and overtime labor were used, to the extent practicable to make these repairs; and (C) The frequency, amount and duration of the violation (including any bypass) were minimized to the maximum extent practicable; and

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(D) If the violation resulted from a bypass of control equipment or a process, then the bypass was unavoidable to prevent loss of life, personal injury, or severe property damage; and (E) All possible steps were taken to minimize the impact of the violation on ambient air quality, the environment, and human health; and (F) All emissions monitoring and control systems were kept in operation if at all possible, consistent with safety and good air pollution control practices; and (G) All of the actions in response to the violation were documented by properly signed, contemporaneous operating logs; and (H) At all times, the affected sources were operated in a manner consistent with good practices for minimizing emissions; and (I) A written root cause analysis was prepared, the purpose of which is to determine, correct, and eliminate the primary causes of the malfunction and the excess emissions resulting from the malfunction event at issue. The analysis shall also specify, using the best monitoring methods and engineering judgment, the amount of excess emissions that were the result of the malfunction. (ii) Report. The owner or operator seeking to assert an affirmative defense shall submit a written report to the Administrator with all necessary supporting documentation, that it has met the requirements set forth in paragraph (i). This affirmative defense report shall be included in the first periodic compliance, deviation report or excess emission report otherwise required after the initial occurrence of the violation of the relevant standard (which may be the end of any applicable averaging period). If such compliance, deviation report or excess emission report is due less than 45 days after the initial occurrence of the violation, the affirmation defense report may be included in the second compliance, deviation report or excess emission report due after the initial occurrence of the violation of the relevant standard.

Condition 1-9:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:40CFR 63.342(c)(2)(vi), Subpart N

Replaces Condition(s) 8 Item 1-9.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: U-00001 Process: P01

Emission Point: E0010 Emission Source: S001B

Emission Unit: U-00001 Process: P01

Emission Point: E0010 Emission Source: S002B

Regulated Contaminant(s): CAS No: 007440-47-3

CHROMIUM

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Item 1-9.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: Standards for enclosed hard chromium electroplating tanks that are new affected sources. During tank operation, each owner or operator shall control chromium emissions discharged to the atmosphere from an affected source by either: (1) Not allowing the concentration of total chromium in the exhaust gas stream discharged to the atmosphere to exceed 0.006 mg/dscm of ventilation air (2.6 × 10-6 gr/dscf) ; or (2) Not allowing the mass rate of total chromium in the exhaust gas stream discharged to the atmosphere to exceed the maximum allowable mass emission rate determined by using the calculation procedure in §63.344(f)(1)(iii). Upper Permit Limit: 0.006 milligrams per dry standard cubic meter Reference Test Method: EPA RM 306 or 306A Monitoring Frequency: SINGLE OCCURRENCE Averaging Method: Arithmetic average of stack test runs Reporting Requirements: ONCE / BATCH OR MONITORING OCCURRENCE Condition 1-10:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:40CFR 63.342(f), Subpart N

Replaces Condition(s) 9 Item 1-10.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: U-00001 Process: P01

Emission Source: S001B

Emission Unit: U-00001 Process: P01

Emission Source: S002B

Item 1-10.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: f) Operation and maintenance practices. (1)(i) At all times, including periods of startup,

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shutdown, and malfunction, owners or operators shall operate and maintain any affected source, including associated air pollution control devices and monitoring equipment, in a manner consistent with good air pollution control practices. (ii) Malfunctions shall be corrected as soon as practicable after their occurrence. (iii) Operation and maintenance requirements established pursuant to section 112 of the Act are enforceable independent of emissions limitations or other requirements in relevant standards. (2)(i) Determination of whether acceptable operation and maintenance procedures are being used will be based on information available to the Administrator, which may include, but is not limited to, monitoring results; review of the operation and maintenance plan, procedures, and records; and inspection of the source. (ii) Based on the results of a determination made under paragraph (f)(2)(i) of this section, the Administrator may require that an owner or operator of an affected source make changes to the operation and maintenance plan required by paragraph (f)(3) of this section for that source. Revisions may be required if the Administrator finds that the plan: (A) Does not address a malfunction that has occurred; (B) Fails to provide for the proper operation of the affected source, the air pollution control techniques, or the control system and process monitoring equipment during a malfunction in a manner consistent with good air pollution control practices; or (C) Does not provide adequate procedures for correcting malfunctioning process equipment, air pollution control techniques, or monitoring equipment as quickly as practicable. (3) Operation and maintenance plan. (i) The owner or operator of an affected source subject to paragraph (f) of this section shall prepare an operation and maintenance plan no later than the compliance date. The plan shall include the following elements: (A) The plan shall specify the operation and maintenance criteria for the affected source, the add-on air pollution

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control device (if such a device is used to comply with the emission limits), and the process and control system monitoring equipment, and shall include a standardized checklist to document the operation and maintenance of this equipment; (B) For sources using an add-on control device or monitoring equipment to comply with this subpart, the plan shall incorporate the operation and maintenance practices for that device or monitoring equipment, as identified in Table 1 of this section, if the specific equipment used is identified in Table 1 of this section; (C) If the specific equipment used is not identified in Table 1 of this section, the plan shall incorporate proposed operation and maintenance practices. These proposed operation and maintenance practices shall be submitted for approval as part of the submittal required under §63.343(d); (D) The plan shall specify procedures to be followed to ensure that equipment or process malfunctions due to poor maintenance or other preventable conditions do not occur; and (E) The plan shall include a systematic procedure for identifying malfunctions of process equipment, add-on air pollution control devices, and process and control system monitoring equipment and for implementing corrective actions to address such malfunctions. (F) The plan shall include housekeeping procedures, as specified in Table 2 of this section. (ii) If the operation and maintenance plan fails to address or inadequately addresses an event that meets the characteristics of a malfunction at the time the plan is initially developed, the owner or operator shall revise the operation and maintenance plan within 45 days after such an event occurs. The revised plan shall include procedures for operating and maintaining the process equipment, add-on air pollution control device, or monitoring equipment during similar malfunction events, and a program for corrective action for such events. (iii) Recordkeeping associated with the operation and maintenance plan is identified in §63.346(b). Reporting associated with the operation and maintenance plan is identified in §63.347 (g) and (h) and paragraph (f)(3)(iv) of this section.

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(iv) If actions taken by the owner or operator during periods of malfunction are inconsistent with the procedures specified in the operation and maintenance plan required by paragraph (f)(3)(i) of this section, the owner or operator shall record the actions taken for that event and shall report by phone such actions within 2 working days after commencing actions inconsistent with the plan. This report shall be followed by a letter within 7 working days after the end of the event, unless the owner or operator makes alternative reporting arrangements, in advance, with the Administrator. (v) The owner or operator shall keep the written operation and maintenance plan on record after it is developed to be made available for inspection, upon request, by the Administrator 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 owner or operator 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 Administrator for a period of 5 years after each revision to the plan. (vi) To satisfy the requirements of paragraph (f)(3) of this section, the owner or operator may use applicable standard operating procedure (SOP) manuals, Occupational Safety and Health Administration (OSHA) plans, or other existing plans, provided the alternative plans meet the requirements of this section. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 1-11:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:40CFR 63.343(c)(1), Subpart N

Replaces Condition(s) 11 Item 1-11.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: U-00001 Process: P01

Emission Source: S001B

Emission Unit: U-00001 Process: P01

Emission Source: S002B

Item 1-11.2:

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Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: (C)(1) Continuous compliance for composite mesh-pad systems. (i) During the initial performance test, the owner or operator of an affected source, or a group of affected sources under common control, complying with the emission limitations in §63.342 through the use of a composite mesh-pad system shall determine the outlet chromium concentration using the test methods and procedures in §63.344(c), and shall establish as a site-specific operating parameter the pressure drop across the system, setting the value that corresponds to compliance with the applicable emission limitation, using the procedures in §63.344(d)(5). An owner or operator may conduct multiple performance tests to establish a range of compliant pressure drop values, or may set as the compliant value the average pressure drop measured over the three test runs of one performance test and accept ±2 inches of water column from this value as the compliant range. (ii) On and after the date on which the initial performance test is required to be completed under §63.7, the owner or operator of an affected source, or group of affected sources under common control, shall monitor and record the pressure drop across the composite mesh-pad system once each day that any affected source is operating. To be in compliance with the standards, the composite mesh-pad system shall be operated within ±2 inches of water column of the pressure drop value established during the initial performance test, or shall be operated within the range of compliant values for pressure drop established during multiple performance tests. (iii) The owner or operator of an affected source complying with the emission limitations in §63.343 through the use of a composite mesh-pad system may repeat the performance test and establish as a new site-specific operating parameter the pressure drop across the composite mesh-pad system according to the requirements in paragraphs (c)(1)(i) or (ii) of this section. To establish a new site-specific operating parameter for pressure drop, the owner or operator shall satisfy the requirements specified in paragraphs (c)(1)(iii)(A) through (D) of this section. (A) Determine the outlet chromium concentration using the test methods and procedures in §63.344(c);

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(B) Establish the site-specific operating parameter value using the procedures §63.344(d)(5); (C) Satisfy the recordkeeping requirements in §63.346(b)(6) through (8); and (D) Satisfy the reporting requirements in §63.347(d) and (f). (iv) The requirement to operate a composite mesh-pad system within the range of pressure drop values established under paragraphs (c)(1)(i) through (iii) of this section does not apply during automatic washdown cycles of the composite mesh-pad system.

Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 1-12:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:40CFR 63.343(c)(4)(ii), Subpart N

Item 1-12.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: U-00001 Process: P01

Emission Source: S001B

Emission Unit: U-00001 Process: P01

Emission Source: S002B

Item 1-12.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: (i) During the initial performance test, the owner or operator of an affected source, or group of affected sources under common control, complying with the emission limitations in §63.342 through the use of a fiber-bed mist eliminator shall determine the outlet chromium concentration using the procedures in §63.344(c), and shall establish as a site-specific operating parameter the pressure drop across the fiber-bed mist eliminator and the pressure drop across the control device installed upstream of the fiber bed to prevent plugging, setting the value that corresponds to compliance with the applicable

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emission limitation using the procedures in §63.344(d)(5). An owner or operator may conduct multiple performance tests to establish a range of compliant pressure drop values, or may set as the compliant value the average pressure drop measured over the three test runs of one performance test and accept ±1 inch of water column from this value as the compliant range. (ii) On and after the date on which the initial performance test is required to be completed under §63.7, the owner or operator of an affected source, or group of affected sources under common control, shall monitor and record the pressure drop across the fiber-bed mist eliminator, and the control device installed upstream of the fiber bed to prevent plugging, once each day that any affected source is operating. To be in compliance with the standards, the fiber-bed mist eliminator and the upstream control device shall be operated within ±1 inch of water column of the pressure drop value established during the initial performance test, or shall be operated within the range of compliant values for pressure drop established during multiple performance tests. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 1-13:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:40CFR 63.344, Subpart N

Replaces Condition(s) 16 Item 1-13.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: U-00001 Process: P01

Emission Point: E0010 Emission Source: S001B

Emission Unit: U-00001 Process: P01

Emission Point: E0010 Emission Source: S002B

Item 1-13.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: iii)(A) The owner or operator of an enclosed hard chromium electroplating tank that is a new source who chooses to meet the mass emission rate standard in §63.342(c)(2)(vii) shall determine compliance by not

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allowing the mass rate of total chromium in the exhaust gas stream discharged to the atmosphere to exceed the maximum allowable mass emission rate calculated using the following equation: MAMER = ESTA x K x 0.006 mg/dscm Where: MAMER = the alternative emission rate for enclosed hard chromium electroplating tanks in mg/hr. ESTA = the hard chromium electroplating tank surface area in square feet. K = a conversion factor, 425 dscm/(sq.ft. x hr). (B) Compliance with the alternative mass emission limit is demonstrated if the three-run average mass emission rate determined from testing using Method 306 or 306A of appendix A to part 63 is less than or equal to the maximum allowable mass emission rate calculated from the above equation. Reporting as per 40 CFR 63.347. Monitoring Frequency: SINGLE OCCURRENCE Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 1-14:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:40CFR 63.344, Subpart N

Replaces Condition(s) 15 Item 1-14.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: U-00001 Process: P01

Emission Point: E0010 Emission Source: S001B

Emission Unit: U-00001 Process: P01

Emission Point: E0010 Emission Source: S002B

Item 1-14.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Performance test requirements. Performance tests shall be conducted under such conditions as the Administrator specifies to the owner or operator based on representative performance of the affected source

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for the period being tested. Upon request, the owner or operator shall make available to the Administrator such records as may be necessary to determine the conditions of performance tests. Performance test results shall be documented in complete test reports that contain the information required by paragraphs (a)(1) through (9) of this section. The test plan to be followed shall be made available to the Administrator prior to the testing. Reporting as per §63.347. The testing and reporting requirements of 6 NYCRR Part 202-1 must also be met. (1) A brief process description; (2) Sampling location description(s); (3) A description of sampling and analytical procedures and any modifications to standard procedures; (4) Test results; (5) Quality assurance procedures and results; (6) Records of operating conditions during the test, preparation of standards, and calibration procedures; (7) Raw data sheets for field sampling and field and laboratory analyses; (8) Documentation of calculations; and (9) Any other information required by the test method.

Test methods. Each owner or operator subject to the provisions of this subpart and required by §63.343(b) to conduct an initial performance test shall use the test methods identified in this section to demonstrate compliance with the standards in §63.342. (1) Method 306 or Method 306A, “Determination of Chromium Emissions From Decorative and Hard Chromium Electroplating and Anodizing Operations,” appendix A of this part shall be used to determine the chromium concentration from hard or decorative chromium electroplating tanks or chromium anodizing tanks. The sampling time and sample volume for each run of Methods 306 and 306A, appendix A of this part shall be at least 120 minutes and 1.70 dscm (60 dscf), respectively. Methods 306 and 306A, appendix A of this part allow the measurement of either total chromium or hexavalent chromium emissions. For the purposes of this standard, sources using chromic acid baths must demonstrate compliance with the emission limits of §63.342 by measuring the total chromium. Monitoring Frequency: SINGLE OCCURRENCE Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION

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Condition 1-15:

Facility DEC ID: 7355400088

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:40CFR 63.344(d), Subpart N

Item 1-15.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: U-00001 Process: P01

Emission Source: S001B

Emission Unit: U-00001 Process: P01

Emission Source: S002B

Item 1-15.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Establishing site-specific operating parameter values. All monitoring equipment shall be installed such that representative measurements of emissions or process parameters from the affected source are obtained. For monitoring equipment purchased from a vendor, verification of the operational status of the monitoring equipment shall include execution of the manufacturer's written specifications or recommendations for installation, operation, and calibration of the system. (i) Specifications for differential pressure measurement devices used to measure velocity pressure shall be in accordance with section 2.2 of Method 2 (40 CFR part 60, appendix A). (ii) Specification for differential pressure measurement devices used to measure pressure drop across a control system shall be in accordance with manufacturer's accuracy specifications. The owner or operator of a source required to measure the pressure drop across the add-on air pollution control device in accordance with §63.343(c) (1) through (4) may establish the pressure drop in accordance with the following guidelines: (i) Pressure taps shall be installed at any of the following locations:

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(A) At the inlet and outlet of the control system. The inlet tap should be installed in the ductwork just prior to the control device and the corresponding outlet pressure tap should be installed on the outlet side of the control device prior to the blower or on the downstream side of the blower; (B) On each side of the packed bed within the control system or on each side of each mesh pad within the control system; or (C) On the front side of the first mesh pad and back side of the last mesh pad within the control system. (ii) Pressure taps shall be sited at locations that are: (A) Free from pluggage as possible and away from any flow disturbances such as cyclonic demisters. (B) Situated such that no air infiltration at measurement site will occur that could bias the measurement. (iii) Pressure taps shall be constructed of either polyethylene, polybutylene, or other nonreactive materials. (iv) Nonreactive plastic tubing shall be used to connect the pressure taps to the device used to measure pressure drop. (v) Any of the following pressure gauges can be used to monitor pressure drop: a magnehelic gauge, an inclined manometer, or a “U” tube manometer. (vi) Prior to connecting any pressure lines to the pressure gauge(s), each gauge should be zeroed. No calibration of the pressure gauges is required. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 1-16:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:40CFR 63.345(b), Subpart N

Item 1-16.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to:

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Emission Unit: U-00001 Process: P01

Emission Point: E0010 Emission Source: S001B

Emission Unit: U-00001 Process: P01

Emission Point: E0010 Emission Source: S002B

Item 1-16.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description:

Notification of new or reconstructed affected sources (1) No person may construct a new affected source or reconstruct an affected source subject to this subpart, or reconstruct a source such that it becomes an affected source subject to this subpart, without submitting a notification of construction or reconstruction to the Administrator. The notification shall contain the information identified in paragraphs (b) (2) and (3) of this section, as appropriate. (2) The notification of construction or reconstruction required under paragraph (b)(1) of this section shall include: (i) The owner or operator's name, title, and address; (ii) The address (i.e., physical location) or proposed address of the affected source if different from the owner's or operator's; (iii) A notification of intention to construct a new affected source or make any physical or operational changes to an affected source that may meet or has been determined to meet the criteria for a reconstruction as defined in §63.2; (iv) An identification of subpart N of this part as the basis for the notification; (v) The expected commencement and completion dates of the construction or reconstruction; (vi) The anticipated date of (initial) startup of the affected source; (vii) The type of process operation to be performed (hard

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or decorative chromium electroplating, or chromium anodizing); (viii) A description of the air pollution control technique to be used to control emissions from the affected source, such as preliminary design drawings and design capacity if an add-on air pollution control device is used; and (ix) An estimate of emissions from the source based on engineering calculations and vendor information on control device efficiency, expressed in units consistent with the emission limits of this subpart. Calculations of emission estimates should be in sufficient detail to permit assessment of the validity of the calculations. (3) If a reconstruction is to occur, the notification required under paragraph (b)(1) of this section shall include the following in addition to the information required in paragraph (b)(2) of this section: (i) A brief description of the affected source and the components to be replaced; (ii) A brief description of the present and proposed emission control technique, including the information required by paragraphs (b)(2) (viii) and (ix) of this section; (iii) An estimate of the fixed capital cost of the replacements and of constructing a comparable entirely new source; (iv) The estimated life of the affected source after the replacements; and (v) A discussion of any economic or technical limitations the source may have in complying with relevant standards or other requirements after the proposed replacements. The discussion shall be sufficiently detailed to demonstrate to the Administrator's satisfaction that the technical or economic limitations affect the source's ability to comply with the relevant standard and how they do so. (vi) If in the notification of reconstruction, the owner or operator designates the affected source as a reconstructed source and declares that there are no economic or technical limitations to prevent the source from complying with all relevant standards or requirements, the owner or operator need not submit the information required in paragraphs (b)(3) (iii) through (v) of this section.

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(4) The owner or operator of a new or reconstructed affected source that submits a notification in accordance with paragraphs (b) (1) through (3) of this section is not subject to approval by the Administrator. Construction or reconstruction is subject only to notification and can begin upon submission of a complete notification. The notification shall be submitted as soon as practicable before the construction or reconstruction is planned to commence. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 1-17:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:40CFR 63.346, Subpart N

Item 1-17.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: U-00001 Process: P01

Emission Source: S001B

Emission Unit: U-00001 Process: P01

Emission Source: S002B

Item 1-17.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Recordkeeping Requirements (a) The owner or operator of each affected source subject to these standards shall fulfill all recordkeeping requirements outlined in this section and in the General Provisions to 40 CFR part 63, according to the applicability of Subpart A of this part as identified in Table 1 of this subpart. (b) The owner or operator of an affected source subject to the provisions of this subpart shall maintain the following records for such source: (1) Inspection records for the add-on air pollution control device, if such a device is used, and monitoring equipment, to document that the inspection and maintenance

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required by the work practice standards of §63.342(f) and Table 1 of §63.342 have taken place. The record can take the form of a checklist and should identify the device inspected, the date of inspection, a brief description of the working condition of the device during the inspection, and any actions taken to correct deficiencies found during the inspection. (2) Records of all maintenance performed on the affected source, the add-on air pollution control device, and monitoring equipment, except routine housekeeping practices; (3) Records of the occurrence, duration, and cause (if known) of each malfunction of process, add-on air pollution control, and monitoring equipment; (4) Records of actions taken during periods of malfunction to minimize emissions in accordance with §63.342(a)(1), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation; (5) Other records, which may take the form of checklists, necessary to demonstrate consistency with the provisions of the operation and maintenance plan required by §63.342(f)(3); (6) Test reports documenting results of all performance tests; (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 §63.344(e); (8) Records of monitoring data required by §63.343(c) that are used to demonstrate compliance with the standard including the date and time the data are collected; (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; (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;

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Permit ID: 7-3554-00088/00004

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(11) The total process operating time of the affected source during the reporting period; (12) Records of the actual cumulative rectifier capacity of hard chromium electroplating tanks at a facility expended during each month of the reporting period, and the total capacity expended to date for a reporting period, if the owner or operator is using the actual cumulative rectifier capacity to determine facility size in accordance with §63.342(c)(2); (13) For sources using fume suppressants to comply with the standards, records of the date and time that fume suppressants are added to the electroplating or anodizing bath and records of the fume suppressant manufacturer and product name; (14) For sources complying with §63.342(e), records of the bath components purchased, with the wetting agent clearly identified as a bath constituent contained in one of the components; (15) Any information demonstrating whether a source is meeting the requirements for a waiver of recordkeeping or reporting requirements, if the source has been granted a waiver under §63.10(f); and (16) All documentation supporting the notifications and reports required by §63.9, §63.10, and §63.347. (c) All records shall be maintained for a period of 5 years in accordance with §63.10(b)(1). Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 1-18:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:40CFR 63.347(a), Subpart N

Item 1-18.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: U-00001 Process: P01

Emission Source: S001B

Emission Unit: U-00001 Process: P01

Emission Source: S002B

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

Item 1-18.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator of each affected source subject to these standards shall fulfill all reporting requirements outlined in this section and in the General Provisions to 40 CFR part 63, according to the applicability of subpart A as identified in Table 1 of this subpart. These reports shall be made to the Administrator at the appropriate address as identified in §63.13 or to the delegated State authority. (1) Reports required by subpart A of this part and this section may be sent by U.S. mail, fax, or by another courier. (i) Submittals sent by U.S. mail shall be postmarked on or before the specified date. (ii) Submittals sent by other methods shall be received by the Administrator on or before the specified date. (2) If acceptable to both the Administrator and the owner or operator of an affected source, reports may be submitted on electronic media. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 1-19:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:40CFR 63.347(d), Subpart N

Item 1-19.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: U-00001 Process: P01

Emission Source: S001B

Emission Unit: U-00001 Process: P01

Emission Source: S002B

Item 1-19.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

Monitoring Description: Notification of Performance Test (1) The owner or operator of an affected source shall notify the Administrator in writing of his or her intention to conduct a performance test at least 60 calendar days before the test is scheduled to begin to allow the Administrator to have an observer present during the test. Observation of the performance test by the Administrator is optional. (2) In the event the owner or operator is unable to conduct the performance test as scheduled, the provisions of §63.7(b)(2) apply. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 1-20:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:40CFR 63.347(f), Subpart N

Item 1-20.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: U-00001 Process: P01

Emission Point: E0010 Emission Source: S001B

Emission Unit: U-00001 Process: P01

Emission Point: E0010 Emission Source: S002B

Item 1-20.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Report of performance test results. (1) If the State has been delegated the authority, the owner or operator of an affected source should report performance test results to the appropriate authority. (2) Reports of performance test results shall be submitted no later than 90 days following the completion of the performance test (Note 6NYCRR Part 202-1 requires a final test report to be submitted within 60 days following test completion), and shall be submitted as part of the notification of compliance status required by paragraph

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

(e) of this section. (3) Within 60 days after the date of completing each performance test (defined in §63.2) as required by this subpart, you must submit the results of the performance tests, including any associated fuel analyses, required by this subpart to the EPA's WebFIRE database by using the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through the EPA's Central Data Exchange (CDX) (www.epa.gov/cdx). Performance test data must be submitted in the file format generated through use of the EPA's Electronic Reporting Tool (ERT) (see http://www.epa.gov/ttn/chief/ert/index.html). Only data collected using test methods on the ERT Web site are subject to this requirement for submitting reports electronically to WebFIRE. Owners or operators who claim that some of the information being submitted for performance tests is confidential business information (CBI) must submit a complete ERT file including information claimed to be CBI on a compact disk, flash drive or other commonly used electronic storage media to the EPA. The electronic media must be clearly marked as CBI and mailed to U.S. EPA/OAPQS/CORE CBI Office, Attention: WebFIRE Administrator, MD C404-02, 4930 Old Page Rd., Durham, NC 27703. The same ERT file with the CBI omitted must be submitted to the EPA via CDX as described earlier in this paragraph. At the discretion of the delegated authority, you must also submit these reports, including the confidential business information, to the delegated authority in the format specified by the delegated authority. For any performance test conducted using test methods that are not listed on the ERT Web site, the owner or operator shall submit the results of the performance test to the Administrator at the appropriate address listed in §63.13. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 1-21:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:40CFR 63.347(h), Subpart N

Item 1-21.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: U-00001 Process: P01

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Emission Source: S001B

Air Pollution Control Permit Conditions Page 34 FINAL

Permit ID: 7-3554-00088/00004

Emission Unit: U-00001 Process: P01

Facility DEC ID: 7355400088

Emission Source: S002B

Item 1-21.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Ongoing compliance status reports for area sources. (1) The owner or operator of an affected source that is located at an area source site shall prepare a summary report to document the ongoing compliance status of the affected source. The report shall contain the information identified in paragraph (g)(3) of this section, shall be completed annually and retained on site, and made available to the Administrator upon request. The report shall be completed annually except as provided in paragraph (h)(2) of this section. (2) Reports of exceedances. (i) If either of the following conditions is met, semiannual reports shall be prepared and submitted to the Administrator: (A) The total duration of excess emissions (as indicated by the monitoring data collected by the owner or operator of the affected source in accordance with §63.343(c)) is 1 percent or greater of the total operating time for the reporting period; or (B) The total duration of malfunctions of the add-on air pollution control device and monitoring equipment is 5 percent or greater of the total operating time. (ii) Once an owner or operator of an affected source reports an exceedance as defined in paragraph (h)(2)(i) of this section, ongoing compliance status reports shall be submitted semiannually until a request to reduce reporting frequency under paragraph (h)(3) of this section is approved. (iii) The Administrator may determine on a case-by-case basis that the summary report shall be completed more frequently and submitted, or that the annual report shall be submitted instead of being retained on site, if these measures are necessary to accurately assess the compliance status of the source. (3) Request to reduce frequency of ongoing compliance

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

status reports. (i) An owner or operator who is required to submit ongoing compliance status reports on a semiannual (or more frequent) basis, or is required to submit its annual report instead of retaining it on site, may reduce the frequency of reporting to annual and/or be allowed to maintain the annual report onsite if all of the following conditions are met: (A) For 1 full year (e.g., 2 semiannual or 4 quarterly reporting periods), the ongoing compliance status reports demonstrate that the affected source is in compliance with the relevant emission limit; (B) The owner or operator continues to comply with all applicable recordkeeping and monitoring requirements of subpart A of this part and this subpart; and (C) The Administrator does not object to a reduced reporting frequency for the affected source, as provided in paragraphs (h)(3) (ii) and (iii) of this section. (ii) The frequency of submitting ongoing compliance status reports may be reduced only after the owner or operator notifies the Administrator in writing of his or her intention to make such a change, and the Administrator does not object to the intended change. In deciding whether to approve a reduced reporting frequency, the Administrator may review information concerning the source's previous performance history during the 5-year recordkeeping period prior to the intended change, or the recordkeeping period since the source's compliance date, whichever is shorter. Records subject to review may include performance test results, monitoring data, and evaluations of an owner or operator's conformance with emission limitations and work practice standards. Such information may be used by the Administrator to make a judgement about the source's potential for noncompliance in the future. If the Administrator disapproves the owner or operator's request to reduce reporting frequency, the Administrator will notify the owner or operator in writing within 45 days after receiving notice of the owner or operator's intention. The notification from the Administrator to the owner or operator will specify the grounds on which the disapproval is based. In the absence of a notice of disapproval within 45 days, approval is automatically granted. (iii) As soon as the monitoring data required by §63.343(c) show that the source is not in compliance with

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

the relevant emission limit, the frequency of reporting shall revert to semiannual, and the owner shall state this exceedance in the ongoing compliance status report for the next reporting period. After demonstrating ongoing compliance with the relevant emission limit for another full year, the owner or operator may again request approval from the Administrator to reduce the reporting frequency as allowed by paragraph (h)(3) of this section. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION

**** Emission Unit Level **** Condition 1-23:

Part 63 General Provisions requirements Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:40CFR 63.340(b), Subpart N

Item 1-23.1: This Condition applies to

Emission Unit: U-00001

Item 1-23.2: Owners or operators of affected sources subject to 40CFR63 Subpart N must also comply with the requirements of Subpart A of Part 63, according to the applicability of Subpart A to such sources, as identified in Table 1 of Subpart N. Subpart A is the General Provisions for the NESHAP for Source Categories regulations. The General Provisions contain requirements for performance testing, monitoring, notification, recordkeeping, reporting, and control devices that may apply to the source. Condition 1-22:

Required content for notification of compliance status Effective between the dates of 02/07/2018 and 06/25/2024 Applicable Federal Requirement:40CFR 63.347(e)(2), Subpart N

Item 1-22.1: This Condition applies to

Emission Unit: U-00001

Item 1-22.2: The notification of compliance status shall be submitted to the New York State Department of Environmental Conservation Regional Office. A copy shall also be sent to the United States Environmental Protection Agency Region II office. The notification shall list for each affected source: (i) The applicable emission limitation and the methods that were used to determine compliance with this limitation; (ii) If a performance test is required by Subpart N, the test report documenting the results of

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Facility DEC ID: 7355400088

the performance test, which contains the elements required by §63.344(a), including measurements and calculations to support the special compliance provisions of §63.344(e) if these are being followed; (iii) The type and quantity of hazardous air pollutants emitted by the source reported in mg/dscm or mg/hr if the source is using the special provisions of §63.344(e) to comply with the standards. (If the owner or operator is subject to the construction and reconstruction provisions of §63.345 and had previously submitted emission estimates, the owner or operator shall state that this report corrects or verifies the previous estimate.) For sources not required to conduct a performance test in accordance with §63.343(b), the surface tension measurement may fulfill this requirement; (iv) For each monitored parameter for which a compliant value is to be established under §63.343(c), the specific operating parameter value, or range of values, that corresponds to compliance with the applicable emission limit; (v) The methods that will be used to determine continuous compliance, including a description of monitoring and reporting requirements, if methods differ from those identified in this subpart; (vi) A description of the air pollution control technique for each emission point; (vii) A statement that the owner or operator has completed and has on file the operation and maintenance plan as required by the work practice standards in §63.342(f); (viii) If the owner or operator is determining facility size based on actual cumulative rectifier capacity in accordance with §63.342(c)(2), records to support that the facility is small. For existing sources, records from any 12-month period preceding the compliance date shall be used or a description of how operations will change to meet a small designation shall be provided. For new sources, records of projected rectifier capacity for the first 12-month period of tank operation shall be used; (ix) A statement by the owner or operator of the affected source as to whether the source has complied with the provisions of this subpart.

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

STATE ONLY ENFORCEABLE CONDITIONS **** Facility Level ****

NOTIFICATION OF GENERAL PERMITTEE OBLIGATIONS This section contains terms and conditions which are not federally enforceable. Permittees may also have other obligations under regulations of general applicability Item A:

Emergency Defense - 6 NYCRR 201-1.5 An emergency, as defined by subpart 201-2, constitutes an affirmative defense to penalties sought in an enforcement action brought by the Department for noncompliance with emissions limitations or permit conditions for all facilities in New York State. (a) The affirmative defense of emergency shall be demonstrated through properly signed, contemporaneous operating logs, or other relevant evidence that: (1) An emergency occurred and that the facility owner or operator can identify the cause(s) of the emergency; (2) The equipment at the permitted facility causing the emergency was at the time being properly operated and maintained; (3) During the period of the emergency the facility owner or operator took all reasonable steps to minimize levels of emissions that exceeded the emission standards, or other requirements in the permit; and (4) The facility owner or operator notified the Department within two working days after the event occurred. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. (b) In any enforcement proceeding, the facility owner or operator seeking to establish the occurrence of an emergency has the burden of proof. (c) This provision is in addition to any emergency or upset provision contained in any applicable requirement.

Item B:

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Public Access to Recordkeeping for Facilities With State Facility Permits - 6 NYCRR 201-1.10 (a) Where facility owners and/or operators keep records pursuant to compliance with the requirements of 6 NYCRR Subpart 201-5.4, and/or the emission capping requirements of 6 NYCRR Subpart 201-7, the Department will make such records available to the public upon request in accordance with 6 NYCRR Part 616 - Public Access to Records. Air Pollution Control Permit Conditions Page 39 FINAL

Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

Facility owners and/or operators must submit the records required to comply with the request within sixty working days of written notification by the Department. Item C:

General Provisions for State Enforceable Permit Terms and Condition - 6 NYCRR Part 201-5 Any person who owns and/or operates stationary sources shall operate and maintain all emission units and any required emission control devices in compliance with all applicable Parts of this Chapter and existing laws, and shall operate the facility in accordance with all criteria, emission limits, terms, conditions, and standards in this permit. Failure of such person to properly operate and maintain the effectiveness of such emission units and emission control devices may be sufficient reason for the Department to revoke or deny a permit. The owner or operator of the permitted facility must maintain all required records on-site for a period of five years and make them available to representatives of the Department upon request. Department representatives must be granted access to any facility regulated by this Subpart, during normal operating hours, for the purpose of determining compliance with this and any other state and federal air pollution control requirements, regulations or law.

STATE ONLY APPLICABLE REQUIREMENTS The following conditions are state only enforceable.

Condition 26:

Contaminant List Effective between the dates of 06/26/2014 and 06/25/2024 Applicable State Requirement:ECL 19-0301

Item 26.1: Emissions of the following contaminants are subject to contaminant specific requirements in this permit(emission limits, control requirements or compliance monitoring conditions). CAS No: 007440-47-3 Name: CHROMIUM CAS No: 007664-93-9 Name: SULFURIC ACID CAS No: 007705-08-0 Name: IRON(3+) CHLORIDE CAS No: 018540-29-9

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Air Pollution Control Permit Conditions Page 40 FINAL

Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

Name: CHROMIUM(VI) CAS No: 0NY075-00-0 Name: PARTICULATES Condition 27:

Malfunctions and start-up/shutdown activities Effective between the dates of 06/26/2014 and 06/25/2024 Applicable State Requirement:6 NYCRR 201-1.4

Item 27.1: (a) The facility owner or operator shall take all necessary and appropriate actions to prevent the emission of air pollutants that result in contravention of any applicable emission standard during periods of start-up, shutdown, or malfunction. (b) The facility owner or operator shall compile and maintain records of all equipment malfunctions, maintenance, or start-up/shutdown activities when they can be expected to result in an exceedance of any applicable emission standard, and shall submit a report of such activities to the department when requested to do so, or when so required by a condition of a permit issued for the corresponding air contamination source. Such reports shall state whether any violations occurred and, if so, whether they were unavoidable, include the time, frequency and duration of the maintenance and/or start-up/shutdown activities, and an estimate of the emission rates of any air contaminants released. Such records shall be maintained for a period of at least five years and made available for review to department representatives upon request. Facility owners or operators subject to continuous stack monitoring and quarterly reporting requirements need not submit additional reports for equipment maintenance or start-up/shutdown activities for the facility to the department. (c) In the event that emissions of air contaminants in excess of any emission standard in this Subchapter occur due to a malfunction, the facility owner or operator shall compile and maintain records of the malfunction and notify the department as soon as possible during normal working hours, but not later than two working days after becoming aware that the malfunction occurred. When requested by the department, the facility owner or operator shall submit a written report to the department describing the malfunction, the corrective action taken, identification of air contaminants, and an estimate of the emission rates. (d) The department may also require the owner or operator to include, in reports described under Subdivisions (b) and (c) of this Section, an estimate of the maximum ground level concentration of each air contaminant emitted and the effect of such emissions. (e) A violation of any applicable emission standard resulting from start-up, shutdown, or malfunction conditions at a permitted or registered facility may not be subject to an enforcement action by the department and/or penalty if the department determines, in its sole discretion, that such a violation was unavoidable. The actions and recordkeeping and reporting requirements listed above must be adhered to in such circumstances.

Condition 28:

Emission Unit Definition Effective between the dates of 06/26/2014 and 06/25/2024 Applicable State Requirement:6 NYCRR Subpart 201-5

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

Item 28.1(From Mod 1): The facility is authorized to perform regulated processes under this permit for: Emission Unit: U-00001 Emission Unit Description: Chrome operations consisting of chrome electroplating and chrome stripping. Building(s): BLDG1 Item 28.2(From Mod 1): The facility is authorized to perform regulated processes under this permit for: Emission Unit: U-00002 Emission Unit Description: This unit consists of a Copperstar alkaline copper plating unit and three Copperstar acid copper plating units. Building(s): BLDG1 Item 28.3(From Mod 1): The facility is authorized to perform regulated processes under this permit for: Emission Unit: U-00004 Emission Unit Description: This unit contains operations associated with the laser engraving process (including cleaning & decoating, spray coating, and spray etching. Building(s): BLDG1 Condition 29:

Renewal deadlines for state facility permits Effective between the dates of 06/26/2014 and 06/25/2024 Applicable State Requirement:6 NYCRR 201-5.2 (c)

Item 29.1: The owner or operator of a facility having an issued state facility permit shall submit a complete application at least 180 days, but not more than eighteen months, prior to the date of permit expiration for permit renewal purposes. Condition 30:

Compliance Demonstration Effective between the dates of 06/26/2014 and 06/25/2024 Applicable State Requirement:6 NYCRR 201-5.3 (c)

Item 30.1: The Compliance Demonstration activity will be performed for the Facility. Item 30.2: Compliance Demonstration shall include the following monitoring:

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Air Pollution Control Permit Conditions Page 42 FINAL

Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Any reports or submissions required by this permit shall be submitted to the Regional Air Pollution Control Engineer (RAPCE) at the following address: Division of Air Resources NYS Dept. of Environmental Conservation Region 7 615 Erie Blvd West Syracuse, NY 13204 Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 31:

Visible Emissions Limited Effective between the dates of 06/26/2014 and 06/25/2024 Applicable State Requirement:6 NYCRR 211.2

Item 31.1: Except as permitted by a specific part of this Subchapter and for open fires for which a restricted burning permit has been issued, no person shall cause or allow any air contamination source to emit any material having an opacity equal to or greater than 20 percent (six minute average) except for one continuous six-minute period per hour of not more than 57 percent opacity. Condition 1-24:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable State Requirement:6 NYCRR 212-2.1

Item 1-24.1: The Compliance Demonstration activity will be performed for the Facility. Item 1-24.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: No owner or operator shall allow emissions of toxic contaminants from the facility's Part 212-regulated emission sources in excess of the thresholds in 6 NYCRR 212-2.2, Table 2, or for any other contaminant in excess of 100 pounds per year, at a rate that results in predicted ambient impacts in excess of the short-term guideline concentration and/or annual guideline concentration or at a rate in excess of the reduction efficiencies stated in 6 NYCRR 212-2.3(b), Table 4. On an annual basis, the owner or operator shall state whether he or she has complied with this condition. Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

DESCRIPTION Reporting Requirements: ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/2019. Subsequent reports are due every 12 calendar month(s). Condition 1-25:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable State Requirement:6 NYCRR 212-2.1

Item 1-25.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: U-00004 Process: P10

Emission Point: E0008 Emission Source: S0014

Regulated Contaminant(s): CAS No: 007705-08-0

IRON(3+) CHLORIDE

Item 1-25.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: 1. Emissions of ferric chloride from the spray etcher shall not exceed 0.11 pounds per hour. 2. Compliance shall be determined through a stack test conducted in accordance with a protocol approved by the Department and 6 NYCRR 202-1. 3. Testing shall be conducted upon request from the Department.

Parameter Monitored: IRON(3+) CHLORIDE Upper Permit Limit: 0.11 pounds per hour Reference Test Method: EPA Method 29 Monitoring Frequency: UPON REQUEST OF REGULATORY AGENCY Averaging Method: Arithmetic average of stack test runs Reporting Requirements: ONCE / BATCH OR MONITORING OCCURRENCE Condition 1-26:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable State Requirement:6 NYCRR 212-2.1

Item 1-26.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to:

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

Emission Unit: U-00001 Process: P01

Emission Source: S001B

Emission Unit: U-00001 Process: P01

Emission Source: S002B

Emission Unit: U-00001 Process: P03

Emission Source: S0004

Emission Unit: U-00001 Process: P03

Emission Source: S0005

Emission Unit: U-00002 Process: P06

Emission Source: S0008

Emission Unit: U-00002 Process: P06

Emission Source: S0009

Emission Unit: U-00002 Process: P06

Emission Source: S0010

Regulated Contaminant(s): CAS No: 007664-93-9

SULFURIC ACID

Item 1-26.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description:

1. Facility-wide emissions of sulfuric acid shall not exceed 100 pounds per year for any 12 consecutive month period. 2. Emissions shall be computed as the product of the emission rate, in pounds per hour, and the number of hours of operation. Alternatively, emissions shall be computed as the product of an emission factor, in units of pounds per unit, multiplied by the number of units processed. 3. The emission rate (or emission factor) shall be the emission rate (or factor) measured during the most recent stack test. 4. The facility shall maintain records of the hours of operation and the results of each stack test for a period of five years.

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

5. Emissions tests shall be conducted at least once every five years (starting from the effective date of this permit) in accordance with a protocol approved by the Department and 6 NYCRR 202-1. 6. On an annual basis, the owner or operator shall submit, in an annual report, the amount of sulfuric acid emitted for each 12 consecutive month period, and a statement of whether he or she has complied with this condition. Parameter Monitored: SULFURIC ACID Upper Permit Limit: 100 pounds per year Monitoring Frequency: MONTHLY Averaging Method: 12-MONTH TOTAL, ROLLED MONTHLY Reporting Requirements: ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/2019. Subsequent reports are due every 12 calendar month(s). Condition 1-27:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable State Requirement:6 NYCRR 212-2.1

Item 1-27.1: The Compliance Demonstration activity will be performed for the Facility. Item 1-27.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Operational Flexibility Protocol - New Construction of general process emission sources; modifications to existing sources The owner or operator may install a new general process air contamination source or modify an existing emission source, provided that criteria pollutants, hazardous air pollutants, and pollutants emitted from such device for which an annual guideline concentration (AGC) and/or short term guideline concentration (SGC) exist, meet all of the following conditions: 1. The device will not result in the emission of any A-rated contaminant with an emission rate potential equal to or greater than 0.1 pound/hr. 2. The device will not result in the emission of any non-VOC contaminant, not given an A-rating, with an emission rate potential equal to or greater than 10

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

pounds/hr. 3. The device shall not emit particulate matter in excess of 0.05 gr/dscf. The owner or operator shall conduct emissions testing upon written request of the DEC in accordance with 6 NYCRR 202. 4. The device shall not cause or allow emissions having an average opacity during any six consecutive minutes of 20 percent or greater, except only the emission of uncombined water. The owner or operator shall conduct emissions testing upon written request of the DEC in accordance with 6 NYCRR 202. 5. The owner or operator must identify all potential pollutants that could be emitted, including A-rated contaminants, hazardous air pollutants, High Toxicity Air Contaminants, VOCs, and non-VOC pollutants. For this facility, A-rated contaminants are those contaminants listed with a "high" toxicity in the Department's most recent DAR-1 (Air Guide 1) guidance document, and any other contaminants that may be A-rated by the Department. All other pollutants are B-rated, unless otherwise rated by the Department. 6. A facility-wide DAR-1 analysis must be performed and demonstrate that there are no predicted off-site ambient concentrations in excess of the AGC or SGC for each contaminant. This analysis shall include all emissions of such pollutant, facility-wide. The owner or operator shall maintain the results of all DAR-1 analyses on-site for a period of at least five years. 7. No facility-wide emissions cap shall be exceeded; and 8. The installation does not render the facility subject to any additional requlations of requirements. Notification of Permitting Procedures If the installation or modification results in the emission of any pollutant not previously authorized or emitted at this site in accordance with this permit, the owner or operator shall submit to the DEC a notice of the intention to install a new air contamination source or modify an existing source. Such notice shall be submitted no later than 30 days prior to the proposed installation. The DEC reserves the right to require a permit modification to impose special conditions if DEC determines the proposed change may have a significant air

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

quality impact. In such cases, upon receipt of any notice submitted by the owner or operator to the DEC as required in this permit, the DEC will respond within 15 days of receipt of such notice, and may require that the owner not undertake the proposed change without a permit modification. When a new emission point, emission source and/or process is proposed to be added, the owner or operator must submit to DEC an application using the format prescribed by DEC (on forms available from the DEC). Reporting A summary of all activities conducted under this operational flexibility condition shall be reported to the DEC in the facility's annual capping report required pursuant to 6 NYCRR 201-7. The annual compliance certifications shall also (1) include compliance certifications for all devices added pursuant to this condition since permit issuance; (2) include a statement that records are maintained on site documenting that exempt and trivial emissions sources continue to satisfy the criteria of 6 NYCRR 201-3.2 and 3.3, and (3) identify any new equipment that was installed without a permit that was not exempt pursuant to 6 NYCRR 201-3.2 or 3.3 and did not comply with the operational flexibility terms of this condition.

Monitoring Frequency: AS REQUIRED - SEE PERMIT MONITORING DESCRIPTION Reporting Requirements: ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/2019. Subsequent reports are due every 12 calendar month(s). Condition 1-28:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable State Requirement:6 NYCRR 212-2.1 (a)

Item 1-28.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: U-00001 Process: P01

Emission Source: S001B

Emission Unit: U-00001 Process: P01

Emission Source: S002B

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Air Pollution Control Permit Conditions Page 48 FINAL

Permit ID: 7-3554-00088/00004

Regulated Contaminant(s): CAS No: 018540-29-9

Facility DEC ID: 7355400088

CHROMIUM(VI)

Item 1-28.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: 1. Facility-wide emissions of chromium (VI) compounds shall not exceed 0.10 pounds per year for any 12 consecutive month period (12 month rolling basis). 2. Emissions shall be computed as the product of the emission rate, in pounds per hour, and the number of hours of operation. Alternatively, emissions shall be computed as the product of an emission factor, expressed in pounds per unit, multiplied by the number of units processed. 3. The emission rate (or emission factor) shall be the emission rate (or factor) measured during the most recent stack test. 4. The facility shall maintain records of the hours of operation and the results of each stack test for a period of five years. 5. Emissions tests shall be conducted at least once every five years (starting from the effective date of this permit) in accordance with a protocol approved by the Department and 6 NYCRR 202-1. 6. On an annual basis, the owner or operator shall submit, in an annual report, the amount of chromium (VI) compounds emitted for each 12 consecutive month period, and a statement of whether he or she has complied with this condition. Parameter Monitored: CHROMIUM(VI) Upper Permit Limit: 0.10 pounds per year Monitoring Frequency: MONTHLY Averaging Method: 12-MONTH TOTAL, ROLLED MONTHLY Reporting Requirements: ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/2019. Subsequent reports are due every 12 calendar month(s). Condition 1-29:

Compliance Demonstration Effective between the dates of 02/07/2018 and 06/25/2024 Applicable State Requirement:6 NYCRR 212-2.1 (a)

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

Item 1-29.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: U-00001 Process: P01

Emission Source: S001B

Emission Unit: U-00001 Process: P01

Emission Source: S002B

Emission Unit: U-00001 Process: P03

Emission Source: S0004

Emission Unit: U-00001 Process: P03

Emission Source: S0005

Emission Unit: U-00004 Process: P10

Emission Source: S0014

Regulated Contaminant(s): CAS No: 007440-47-3

CHROMIUM

Item 1-29.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description:

1. Facility-wide emissions of chromium compounds shall not exceed 250 pounds per year for any 12 consecutive month period (12 month rolling basis). 2. Emissions shall be computed as the product of the emission rate, in pounds per hour, and the number of hours of operation. Alternatively, emissions shall be computed as the product of an emission factor, in units of pounds per unit, multiplied by the number of units processed. 3. The emission rate (or emission factor) shall be the emission rate (or factor) measured during the most recent stack test. 4. The facility shall maintain records of the hours of operation and the results of each stack test for a period of five years. 5. Emissions tests shall be conducted at least once every five years (starting from the effective date of this

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

permit) in accordance with a protocol approved by the Department and 6 NYCRR 202-1. 6. On an annual basis, the owner or operator shall submit, in an annual report, the amount of chromium compounds emitted for each 12 consecutive month period, and a statement of whether he or she has complied with this condition. Parameter Monitored: CHROMIUM Upper Permit Limit: 250 pounds per year Monitoring Frequency: MONTHLY Averaging Method: 12-MONTH TOTAL, ROLLED MONTHLY Reporting Requirements: ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/2019. Subsequent reports are due every 12 calendar month(s).

**** Emission Unit Level **** Condition 32:

Emission Point Definition By Emission Unit Effective between the dates of 06/26/2014 and 06/25/2024 Applicable State Requirement:6 NYCRR Subpart 201-5

Item 32.1(From Mod 1): The following emission points are included in this permit for the cited Emission Unit: Emission Unit:

U-00001

Emission Point: E0002 Height (ft.): 22 Diameter (in.): 12 NYTMN (km.): 4789.414 NYTME (km.): 393.589

Building: BLDG1

Emission Point: E0010 Height (ft.): 24 Diameter (in.): 10 NYTMN (km.): 4789.414 NYTME (km.): 393.589

Building: BLDG1

Item 32.2(From Mod 1): The following emission points are included in this permit for the cited Emission Unit: Emission Unit:

U-00002

Emission Point: E0004 Height (ft.): 18 Diameter (in.): 8 NYTMN (km.): 4789.414 NYTME (km.): 393.589

Building: BLDG1

Emission Point: E0005 Height (ft.): 18 Diameter (in.): 8 NYTMN (km.): 4789.414 NYTME (km.): 393.589

Building: BLDG1

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

Emission Point: E0006 Height (ft.): 17 Diameter (in.): 8 NYTMN (km.): 4789.414 NYTME (km.): 393.589

Building: BLDG1

Emission Point: E0007 Height (ft.): 18 Diameter (in.): 8 NYTMN (km.): 4789.414 NYTME (km.): 393.589

Building: BLDG1

Item 32.3(From Mod 1): The following emission points are included in this permit for the cited Emission Unit: Emission Unit:

U-00004

Emission Point: E0008 Height (ft.): 18 Diameter (in.): 6 NYTMN (km.): 4789.414 NYTME (km.): 393.589

Building: BLDG1

Emission Point: E0009 Height (ft.): 19 Diameter (in.): 6 NYTMN (km.): 4789.414 NYTME (km.): 393.589

Building: BLDG1

Condition 33:

Process Definition By Emission Unit Effective between the dates of 06/26/2014 and 06/25/2024 Applicable State Requirement:6 NYCRR Subpart 201-5

Item 33.1(From Mod 1): This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: U-00001 Process: P01 Source Classification Code: 3-09-010-06 Process Description: Chrome electroplating process: A prepared cylinder is placed in one of two vertical electroplating tanks. Cylinders are electroplated in a chromic acid bath until the appropriate plating thickness is achieved. Air emissions from each unit are directed to mist eliminators. The emissions from both units are directed to a common composite mesh pad mist eliminator, after which the emissions are exhausted through Emission Point E0010.

Emission Source/Control: C001B - Control Control Type: COMPOSITE MESH-PAD Emission Source/Control: CME1B - Control Control Type: MIST ELIMINATOR Emission Source/Control: CME2B - Control Control Type: MIST ELIMINATOR

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

Emission Source/Control: S001B - Process Emission Source/Control: S002B - Process Item 33.2(From Mod 1): This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: U-00001 Process: P03 Source Classification Code: 3-09-010-06 Process Description: Chrome stripping process: Acidic cleaning solution is used to strip existing plate layers from used cylinders. Once stripped, the cylinders are cleaned with a solution prior to the next step. Air emissions from each tank are directed to a common scrubber, after which the emissions are exhausted through Emission Point E0002. Emission Source/Control: C0002 - Control Control Type: SCRUBBER - PACKED BED Emission Source/Control: C0006 - Control Control Type: MIST ELIMINATOR Emission Source/Control: S0004 - Process Emission Source/Control: S0005 - Process Item 33.3(From Mod 1): This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: U-00002 Process: P05 Source Classification Code: 3-09-010-04 Process Description: Copperstar Alkaline Copper Plating: A cylinder is placed in an alkaline bath to provide an initial copper electroplating layer to a cylinder at 50% submersion. Air emissions from the alkaline copper plating unit are exhausted through Emission Point E0004. Emission Source/Control: S0007 - Process Item 33.4(From Mod 1): This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: U-00002 Process: P06 Source Classification Code: 3-09-010-04 Process Description: Copperstar Acid Copper Plating: A cylinder is placed in one of three high speed copper electroplating machines at 50% submersion. Cylinders are coated with copper until the appropriate plating thickness is achieved. Air emissions from plating units 1 - 3 are exhausted through Emission

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

Pointsb E0005, E0006, and E0007, respectively. Emission Source/Control: S0008 - Process Emission Source/Control: S0009 - Process Emission Source/Control: S0010 - Process Item 33.5(From Mod 1): This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: U-00004 Process: P08 Source Classification Code: 4-02-025-01 Process Description: Spray Coating: The spray coating machine applies a black lacquer coating in order to prepare the cylinders and sleeves for the laser. Air emissions from the unit are exhausted through Emission Point E0008. Emission Source/Control: S0012 - Process Item 33.6(From Mod 1): This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: U-00004 Process: P10 Source Classification Code: 3-09-010-06 Process Description: Spray Etching: In the spray etching machine, the screen dots, which were opened by the laser engraving, are etched with a ferric chloride solution. Air emissions are directed to a scrubber and mist eliminator, after which the emissions are exhausted through Emission Point E0009. Emission Source/Control: C0004 - Control Control Type: SCRUBBER - PACKED BED Emission Source/Control: C0005 - Control Control Type: MIST ELIMINATOR Emission Source/Control: S0014 - Process Item 33.7(From Mod 1): This permit authorizes the following regulated processes for the cited Emission Unit: Emission Unit: U-00004 Process: P11 Source Classification Code: 4-02-025-02 Process Description: Cleaning & Decoating: The cleaning and decoating unit is required for cleaning and degreasing the cylinders before being coated. The unit is also used for decoating the cylinders after the spray etching process. Air emissions are directed to a scrubber and mist eliminator after which

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Permit ID: 7-3554-00088/00004

Facility DEC ID: 7355400088

the emissions are exhausted through Emission Point E0009. Emission Source/Control: C0004 - Control Control Type: SCRUBBER - PACKED BED Emission Source/Control: C0005 - Control Control Type: MIST ELIMINATOR Emission Source/Control: S0015 - Process

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00004 - NYSDEC - New York State

Facility DEC ID: 7355400088 PERMIT Under the Environmental Conservation Law (ECL) IDENTIFICATION INFORMATION Permit Type: Air State Facility Permit I...

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