~-VERMONT · • Keeping the nickel plating tanks covered with well-fitting lids when not in...

~-VERMONT State ofVermont AGENCYOFNATURALRESOURCES Department of Environmental Conservation Air Quality & Climate Division One National Life Drive Davis (North) Building 2nd Floor Montpelier, vr 05620-3802 (802)-828-1288

Donald Davis Precision Valley Finishing P.O. Box 480 Springfield, Vermont 05156

SUBJECT: Final Air Pollution Control Permit to Operate: #AQP-12-029

Dear Mr. Davis:

April 16, 2018

The Vermont Agency of Natural Resources, Department of Environmental Conservation, Air Quality & Climate Division ("Agency") has completed its review of Precision Valley Finishing's Operating Permit renewal application for the electroplating operations located in Springfield, Vermont. The Agency is now issuing a final renewed Air Pollution Control Permit to Construct and Operate.

Please note the renewed permit is valid for five (5) years and an application to renew the permit must be filed at least twelve ( 12) months prior to the date of expiration. The Agency revised the previous Hazardous Most Stringent Emission Rate (HMSER) determination which included only surface tension requirements for the chrome plating bath. The revised HMSER does not include chromium (VI) compounds since estimated actual emissions are below the established Action Level considering the enforceable surface tension requirements, amp-hour limitations and the scrubber control technology on the chromium electroplating tank.

However, actual estimated emissions of nickel continue to exceed the established Action Level for nickel compounds. Consequently, the renewed Permit includes an HMSER determination for nickel compounds that includes the following:

For Nickel Plating: • Keeping the nickel plating tanks covered with well-fitting lids when not in operation. • Maintaining a concentration of wetting agent/fume suppressant in each nickel plating tank

recommended by the manufacturer. • Complying with a combined annual 110,000 amp-hour limit.

(over)

Regional Offices - Barre/Essex Jct./Rutland/Springfield/St. Johnsbury

In the event the facility wishes to increase the amp-hour limitations established in this permit, the Agency will require evaluation of methods to provide additional reductions in nickel and/or chromium emissions. This may include but not be limited to evaluation and testing of the existing scrubber technology and the evaluation of the feasibility of capturing and directing the nickel plating emissions to the scrubber unit. Please feel free to contact me at (802) 272-3006, or by email at the address shown below, if I can be of any further assistance or if you have any questions or comments regarding this matter.

Sincerely,

Jay S. Hollingsworth Engineering Services Section Air Quality & Climate Division

JH:jh Y:\AP _Admin\StationaryFacilities\Precision Valley Finishing lnc\Permits\AOP-12-029 - Rutland

Regional Offices - Barre/Essex Jct./Rutland/Springfield/St. Johnsbury

#AOP-12-029 DEC# NS95-0182

Operating Permit Expiration Date: April 16, 2023

State of Vermont Agency of Natural Resources

Department of Environmental Conservation

Air Quality & Climate Division Montpelier, Vermont

AIR POLLUTION CONTROL PERMIT TO CONSTRUCT AND OPERATE

Date Permit Issued: April 16, 2018

Owner/Operator: Donald B. Davis Precision Valley Finishing, Inc. P.O. Box480 Springfield, Vermont 05156

Source: Electroplating of: Hexavalent Chromium and Other Metals Precision Valley Finishing, Inc. 135 Main Street Springfield, Vermont 05156

Precision Valley Finishing, Inc. - Springfield #AQP-12-029

FINDINGS OF FACT

(A) FACILITY DESCRIPTION

Precision Valley Finishing, Inc., formerly known as Springfield Electroplating (also referred to herein as "Permittee") owns and operates a metal electroplating facility on Main Street in the town of Springfield, Vermont (also referred to herein as "Facility"). Ownership of the Facility has been transferred from Springfield Electroplating to Precision Valley Finishing, Inc. in 2008. At the time of the transfer, some of the operations at the Facility had changed. The operations performed at the Facility are classified within Standard Industrial Classification Code 3471 (Electroplating, Plating, Polishing, Anodizing, and Coating).

The following is a list of metal plating operations that were previously permitted but will no longer be performed or permitted at the Facility upon issuance of this Permit. The Permittee would need to seek approval from the Agency of Natural Resources, Department of Environmental Conservation, Air Quality & Climate Division (hereinafter "Agency") prior to re-initiating any of the operations listed below:

• Barrel nickel line; ceased operation in 2010 ("nickel rack line" will now be designated as either "nickel electroplating line" or "nickel electroplating tank")

• Hard chrome plating line; ceased operation in 2009 • Spray booth associated with hard chrome plating line used for dip tank masking;

ceased operation in 2009.

The following is a list of equipment and operations currently performed and permitted at the Facility:

Metal Processing/Coating Lines:

• Decorative (Satin) Hexavalent Chromium Electroplating Tank Volume, gallons: 175 Temperature, degrees F: Ambient Line operates at 100-275 amps. 1,500 amp max. Annual Permit Limit: 440,000 amp-hours/yr Fume suppressant added and maintained in tank Perimeter lip vents (300 cfm) directed to centralized scrubber unit.

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Precision Valley Finishing, Inc. - Springfield #AOP-12-029

• Black Oxide Coating Line One (1) heated tank, 90% NaOH and 10% NaN03 solution heated to 292° F Alkaline soak tank Mesh pad mist eliminator system Volume, gallons: 200 Temperature, degrees F: 292 Line runs on 4 volts at 180 amps. No controls, internally vented. One (1) rust preventative tank containing Castrol oil Volume, gallons: 130 Temperature, degrees F: Ambient No controls, internally vented.

• Nickel Electroplating Tank (rack) Volume, gallons: 400 Temperature, degrees F: 130 Line operates on 3. 75 volts at 275 amps. 1,500 amp max. Annual Permit Limit: 110,000 amp-hours/yr Wetting agent fume suppressant added and maintained in tank Fume hood (300 cfm) exhausted to ambient atmosphere

• Copper Electroplating Tank Volume, gallons: 400 @ 30 percent nitric acid and 70 percent water Temperature, degrees F: Ambient Line runs on 1-3 volts at 10-25 amps. 1,500 amp max. No controls, internally vented.

• Passivation Line Volume, gallons: 110 30 percent nitric acid and 70% water Temperature, degrees F: Ambient No controls, internally vented.

• Chrome Conversion Line Volume, gallons: 180 Temperature, degrees F: Ambient No current No controls, internally vented. Wetting agent fume suppressant

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Precision Valley Finishing, Inc. - Springfield

• Sulfuric Acid Anodizing Line (clear or black) One (1) sulfuric acid anodizing tank Volume, gallons: 450 Temperature, degrees F: Ambient Line runs on 15 volts. 1,500 amp max. Additional tanks associated with the sulfuric acid anodizing line:

One (1) alkaline soap clean tank One (1) sodium hydroxide/water mix etch tank One (1) nitric acid tank One (1) de-oxidation/de-smut tank

• Electrolytic Electro-polishing Tank Volume, gallons: 180 Temperature, degrees F: Ambient Line runs on 1-5 volts at 1-450 amps. 1,500 amp max.

Bio-Clean Aqueous Degreasing Unit:

#AOP-12-029

The Facility operates a Bio-clean aqueous, air-sparged, degreasing unit that operates at approximately 130 degrees F. There are no solvents associated with this unit. This degreasing unit is not considered a emission source to the ambient atmosphere. The degreasing unit is uncontrolled and vents inside the Facility.

Grinding and Polishing Equipment: The Facility operates miscellaneous grinding, buffing and polishing wheels. These operations have no controls and are internally vented.

Evaporator Equipment: • One (1) atmospheric evaporator unit (PPC Corporation model ET-111-W).

Steam coil heated with 90 gallons per hour, maximum capacity Equipped with mesh pad mist eliminator Exhaust stack thirty (30) feet above grade.

Central Emission Control Equipment: • One (1) three-stage packed bed dry scrubber and a HEPA filter.

Minimum combined capture efficiency of 99.9 percent. Exhaust flow rate: 2,300 actual cubic feet per minute Exhaust stack thirty (30) feet above elevation.

Heating Equipment: The Facility operates one (1) 1.3 million thermal British units per hour maximum heat input capacity (MMBtu/hr), No.2 fuel oil-fired Columbia boiler, to provide process heat. The boiler exhausts to the ambient atmosphere through a stack at twenty-two (22) feet above grade.

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(8) FACILITY CLASSIFICATION

The Facility is classified as a source of air contaminants pursuant to Title 10 of the Vermont Statutes Annotated ("10 VSA") §555 and §5-401 (8) [Metal fabrication processes] of the Vermont Air Pollution Control Regulations (hereinafter "Regulations"). In addition, §5-101 of the Regulations defines a stationary source as any structure(s), equipment, installation(s), or operation(s), or combination thereof, which emit or may emit any air contaminant, which is located on one or more contiguous or adjacent properties and which is owned or operated by the same person or persons under common control. Based on this definition, all of the equipment, operations, and structures at the Facility are grouped together by the Agency as one stationary air contaminant source for purposes of review under the Regulations.

(C) PRIOR AGENCY ACTIONS/APPROVALS

The Facility does not currently operate under any prior "Permit to Construct" issued by the Agency pursuant to 10 VSA §556 and §§5-501 and/or 5-502 of the Regulations. However, the Facility has been issued the following "Permit to Operate" approvals pursuant to 10 VSA §556a and Subchapter X of the Regulations.

Date of Action

April 28, 1998

February 19, 2008

Prior Agency Permit Approvals and Actions

Description of Agency ApprovaUAction

#OP-95-096 - Initial "Permit to Operate" approval for Facility.

#AOP-07-004 - Operating permit renewal combined with application for transfer of ownership from Springfield Electroplating Co. to Precision Valley Finishing and some minor changes to existing plating lines.

(D) FACILITY PERMIT APPLICABILITY

As noted above, the Facility is classified as a source of air contaminants under §5-401 of the Regulations. Pursuant to 10 VSA §556a and Subchapter X of the Regulations a Permit to Operate is required for any air contaminant source with allowable emissions of all air contaminants combined of ten (10) tons per year ("tpy") or more or that is otherwise subject to Title 40 Code of Federal Regulations ("40 CFR') Part 70.

The Facility currently operates under a Permit to Construct and Operate issued on February 19, 2008. The Allowable Emissions from the Facility are estimated to be less than the ten (10) tpy combined threshold for applicability with Subchapter X of the Regulations, however, pursuant to Title 10 VSA §556a and §5-1003(a)(4) of the Regulations, the Agency is requiring the Permittee to maintain a Permit to Operate due to hazardous air contaminant emissions.

In accordance with §5-1009 of the Regulations, the Agency is issuing the Permit to Construct and Operate herein as a renewal of the previous Permit, #AOP-07-004, for the Facility and the Permit herein supersedes all prior Permits for the Facility. The Allowable

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Emissions for the Facility are summarized below:

Allowable Air Contaminant Emissions (tons/year)1

co NOx HAP82

<1.0 <1.0 <1.0 <1.0 <1 <8/20

1 PM/PM10/PM2.5 - total particulate matter, total particulate matter of 10 micrometers in size or smaller and total particulate matter of 2.5 micrometers in size or smaller, respectively. Unless otherwise specified, all PM is assumed to be PM2.s; S02 - sulfur dioxide; NO, - oxides of nitrogen measured as N02 equivalent; CO - carbon monoxide; VOCs - volatile organic compounds; HAPs - hazardous air pollutants as defined in § 112 of the federal Clean Air Act.

2 A stationary source with potential emissions of 10 tons per year or greater of any single HAP or 25 tons per year or greater of all HAPs combined is considered a major source of HAPs under §112 of the federal Clean Air Act. Any stationary source with potential emissions of 8 tons per year or greater of any single HAP or 20 tons per year or greater of all HAPs combined is considered a synthetic minor source. The Facility is limited by the Permit herein to less than thresholds for a synthetic minor source. Actual total combined HAPs from the Facility are estimated at <1 tpy. This Permit does not explicitly authorize emissions up to this level since any increase in actual HAP emissions may be subject to §5-261 and 5-501 of the Regulations as applicable.

3 Commencing July 1, 2018 the allowed sulfur content of distillate fuel oils, No. 4 residual fuel oil and No. 6 residual fuel oils will decrease to 0.0015%, 0.25% and 0.5% by weight respectively, potentially further decreasing Facility allowed S02 emissions unless otherwise already restricted by the Permit herein

(E) REVIEW OF CRITERIA POLLUTANT EMISSIONS FOR THE PERMIT TO CONSTRUCT

(a) New Source Review Designation

The Permittee has not proposed any modifications to the Facility in conjunction with the review for this Permit to Operate and therefore is not subject to review under the New Source Review requirements in §5-501 or §5-502 of the Regulations at this time.

(b) Most Stringent Emission Rate

Pursuant to §5-502 of the Regulations, the owner/operator of each new major stationary source or major modification must apply control technology adequate to achieve the Most Stringent Emission Rate ("MSER") with respect to those air criteria pollutants for which there would be a major or significant actual emissions increase, respectively, but only for those currently proposed physical or operational changes which would contribute to the increased emissions.

The Permittee has not proposed any modifications to the Facility in conjunction with the review for this Permit to Operate and therefore is not subject to review under the MSER requirements in §5-502 of the Regulations at this time. In addition, there have been no prior MSER evaluations conducted for any of the previous modifications to the Facility.

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Precision Valley Finis hing, Inc. - Springfield #AOP-12-029

(c) Ambien t Air Quality Impact Evaluation

bient air quality impact evaluation for criteria pollutants is performed to An am demon of then air qua

strate whether or not a proposed project will cause or contribute to violations ational ambient air quality standards and/or significantly deteriorate existing lity for the regulated criteria pollutants.

rmittee has not proposed any modifications to the Facility in conjunction e review for this Permit to Operate and therefore is not subject to an air

The Pe with th quality there h of the p

impact analysis under §5-501 of the Regulations at this time. In addition, ave been no prior ambient air quality impact evaluations conducted for any revious modifications to the Facility.

(F) REVIEW OF C RITERIA POLLUTANT EMISSIONS FOR THE PERMIT TO OPERATE

(a) Applica ble Requirements

erations at the Facility are subject to the following state and federal laws The op and reg Permit.

ulations, the requirements of which are embodied in the conditions of this

(i) Vermont Air Pollution Control Regulations:

Applicable Requirements from the Vermont Air Pollution Control Regulations

Section 5-211(2) - Prohibition of Visible Air Contaminants, Installations Constructed Subsequent to April 30, 1970.

Section 5-221 (1) - Prohibition of Potentially Polluting Materials in Fuel, Sulfur Limitation in Fuel.

Section 5-231 (3) - Prohibition of Particulate Matter; Combustion Contaminants.

Section 5-241 - Prohibition of Nuisance and Odor.

Section 5-253.14 - Control of Volatile Organic Compounds from Solvent Metal Cleaning.

Section 5-261 (2) - Control of Hazardous Air Contaminants - Hazardous Most Stringent Emission Rate.

Section 5-402 - Written Reports When Requested.

Section 5-403 - Circumvention.

Section 5-404 - Methods for Sampling and Testing of Sources.

Section 5-405 - Required Air Monitoring.

Subchapter VIII - Registration of Air Contaminant Sources.

Subchapter X - Operating Permits.

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(ii) Reasonably Available Control Technology- §5-1010 of the Regulations

Pursuant to 1 O VSA §556a( d) and §5-1010 of the Regulations the Agency may establish and include within any Permit to Operate emission control requirements based on Reasonably Available Control Technology ("RACT"). Based on the Facility's existing levels of emissions and emission controls, the Agency has not imposed any further requirements on this Facility under this authority at this time.

(iii) Existing Air Pollution Control Permit to Construct and/or Operate

The Facility currently operates under the confines of a Permit to Operate issued on February 19, 2008 (#AQP-07-004). The conditions within that existing permit are considered applicable requirements pursuant to §5-1002 of the Regulations. The requirements of that permit which are not being modified herein are incorporated into this new Permit to Operate (#AOP-12-029).

(iv) Federal Requirements:

Applicable Requirements from Federal Regulations and the Clean Air Act

40 CFR Part 63, Subpart N - Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks: §63.342 Standards for Chromium; §63.343 Compliance Provisions; §63.346 Recordkeeping Requirements. Applicable to all facilities performing hard chromium electroplating and all major source facilities performing decorative chromium electroplating or chromium anodizing.

Vermont has taken full delegation of this rule and is the implementing authority and is responsible for determining applicability of this regulation. The Facility performs decorative hexava/ent chromium electroplating. Accordingly, Subpart N applies to the Facility's chromium electroplating operation at this time.

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#AQP-12-029

40 CFR Part 63, Subpart JJJJJJ - National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial and Institutional Boilers. Applies to new and existing fuel oil and solid fuel fired boilers located at area sources (major sources are subject to Subpart DDDDD). Natural gas or propane fired boilers are not subject. This gas exemption allows use of backup fuel during gas curtailments and up to 48 hours of elective use. Oil fired hot water boilers less than 1.6 MMBtu/hr are not subject. The rule requires a tune-up for each boiler once every two years except boilers with oxygen trim and oil boilers less than 5 MMBtu/hr must conduct tune-ups every five years. New boilers greater than 10 MMBtu/hr are subject to PM emission limits. Boilers that commenced construction on or before June 4, 2010 are considered an existing source.

Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation.

Subpart JJJJJJ is not anticipated to apply to the Columbia boiler at the Facility since the boiler is below the 1. 6 MMBtu/hr heat input threshold. Since the Facility is not a major source of HAPs, the Facility is not subject to Subpart DDDDD.

40 CFR Part 63, Subpart HHHHHH - National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources. Applies to: paint stripping operations that involve the use of chemical strippers that contain methylene chloride (MeCI), autobody refinishing operations, and spray application of coatings containing compounds of chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd) to any part or product made of metal or plastic. The regulation excludes: activities on sites owned and operated by the military (including state National Guard sites), activities performed by individuals on their personal property, activities for research and laboratory activities, and quality control activities. Existing affected sources that commenced operation prior to September 17, 2007 have a compliance date of January 11, 2011.

Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation. The Facility does not perform paint stripping that contains methylene chloride, auto body refinishing or spray application containing compounds of chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd). Consequently, Subpart HHHHHH is not anticipated to apply to the operations at the Facility at this time.

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#AQP-12-029

40 CFR Part 63, Subpart WWW - National Emission Standards for Hazardous Air Pollutants for Chemical Manufacturing Area Sources. This regulation will apply to chemical manufacturing area sources (CMAS) with chemical manufacturing process units (CMPU) that use, produce or generate hazardous air pollutants defined in Table 1 of this regulation (Table 1 HAP) in concentrations greater than 0.10% for carcinogens and 1.0% for non-carcinogens. The regulation requires notification implementation of management practices and semi-annual reporting requirements. Emissions reductions will be required for facilities that emit Table 1 HAP in excess of specified thresholds.

Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation. Based on the SIC codes for applicability of Subpart VVVVVV, and the SIC codes that describe the Facility, Subpart VVVVVV is not anticipated to apply to the operations at the Facility.

40 CFR Part 63, WV\/WN\/VW-National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Plating and Polishing Operations: Applies to operations that involve plating and polishing utilizing Cadmium, Chromium, Manganese, Nickel and Lead.

Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation. Subpart WWWWWW is anticipated to apply to the Facility's nickel electroplating tank due to the presence of materials in the tank containing greater than 0. 1 percent nickel by weight.

In addition, Subpart WWWWWW is anticipated to apply to the Facility's dry mechanical polishing equipment due to the equipment emitting nickel and chromium metal HAPs.

40 CFR Part 63, XXXXXX-National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Nine Metal Fabrication and Finishing Source Categories. Applies to area sources that are primarily engaged in one of nine source categories and which conduct dry abrasive blasting, dry grinding and dry polishing with machines, machining, spray painting and coating, and welding operations, which use or emit any of five air toxics: cadmium, chromium, lead, manganese, and nickel.

Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation. While the Facility does conduct some of the applicable operations, Subpart XXXXXX is not anticipated to apply to the Facility since it is not primarily engaged in one of the source categories.

40 CFR Part 63, GG-National Emission Standards for Aerospace Manufacturing and Rework Facilities. Applies to major HAP sources that are engaged, either in part or in whole, in the manufacture or rework of commercial, civil, or military aerospace vehicles or components.

The Facility may conduct worl< on aerospace components but is not a major source of HAPs therefore Subpart GG is not anticipated to apply at this time.

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#AOP-12-029

Control Technology Guidance for - Control of Volatile Organic Compound Emissions from Coating Operations at Aerospace Manufacturing and Rework Operations. Applies to facilities with greater than 25 tons per year of VOCs. Requires control of VOC emissions from coatings and solvents used in the aerospace industry.

The Facility's VOC emissions have been restricted to less than one (1) ton per year therefore this CTG is not anticipated to apply to the Facility at this time.

(b) Non-Applicable Requirements

Pursuant to §5-1015(a)(14) of the Regulations, an owner or operator of a Facility may request a permit shield from specific state or federally enforceable regulations and standards which are not applicable to the source. The applicant has not requested such a permit shield in accordance with the requirements of §5-1015( a)(14) of the Regulations.

(G) CONTROL OF HAZARDOUS AIR CONTAMINTANTS

Pursuant to §5-261 of the Regulations, any stationary source subject to the rule1 with current or proposed actual emissions of a hazardous air contaminant (HAC) equal to or greater than the respective Action Level (found in Appendix C of the Regulations) shall be subject to the Regulation and shall achieve the Hazardous Most Stringent Emission Rate (HMSER) for the respective HAC. HMSER is defined as a rate of emissions which the Secretary, on a case-by-case basis, determines is achievable for a stationary source based on the lowest emission rate achieved in practice by such a category of source and considering economic impact and cost. HMSER may be achieved through application o1 pollution control equipment, production processes or techniques, equipment design, work practices, chemical substitution, or innovative pollution control techniques.

The decorative hexavalent chromium electroplating tank and the nickel electroplating tank have the potential to emit hexavalent chromium and nickel at levels greater than the established respective Action Levels. However, the Facility controls emissions from both plating processes with fume suppressants, vents the chrome plating operation to a dry scrubber and complies with the amp-hour limitations established in this Permit. With these controls in place, actual chromium emissions are estimated to below the chromium Action Level. However, actual nickel emissions are estimated to remain above the nickel Action Level. Consequently, an HMSER evaluation was only required for the Facility's nickel electroplating operations. The table below outlines previous and current HMSER determinations that were established for the Facility.

1 APCR §5-261 (1 )(c)(ii) provides that solid fuel burning equipment (not including incinerators installed or constructed prior to January 1, 1993, and all fuel burning equipment which combus1 virgin liquid or gaseous fuel shall not be subject to the requirements of §5-261.

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Hazardous Most Stringent EmlQton Rate Detennlnatlons •

Permit#

Initial determination

#QP-95-096

#AOP-07-004

#AOP-12-029

Pollutant

hexavalent chromium

nickel

Description of HMSER

• The Agency determined HMSER to be an emission rate from the chromium electroplating exhaust not to exceed 8.6x10·8 grains per dry standard cubic foot or 1.6x1 o-e pounds per hour.

• An emission rate from the chromium electroplating exhaust not to exceed 8.6x1 o.a grains per dry standard cubic foot or 1.6x10-e pounds per hour.

• A surface tension of the electroplating bath shall not exceed 45 dynes per centimeter (dynes/cm) (3.1 x 10-3 pound-force per foot (lbf/ft)} as measured by a stalagmometer or 35 dynes/cm (2.4 x 10-3 lbf/ft) as measured by a tensiometer at any time during operation of the tank; and

• Continued operation of the existing three-stage packed bed dry scrubber and HEPA filter.

• Keeping the nickel plating tank covered with well-fitting lid when not in operation.

• Maintaining a concentration of wetting agent I fume suppressant in the nickel plating tank recommended by the manufacturer.

• Complying with the 110,000 annual amp-hour limit.

• The initial1998 HMSER evaluation was based on test data that represented total chromium for the simultaneous operation of,:·the hard and decorative chrome plating operations with emissions controlled through the operation of a three-stage packed bed dry scrubber and HEPA filter. Regardless of the removal of the hard chromium electroplating process, the Agency will continue to require operation of the existing controls because the capital investment has already been made and the controls are in place and operational.

As mentioned above, the Agency has determined that the Facility will have emissions of nickel in excess of its Action Level, the Agency has considered whether or not an Air Quality Impact Evaluation should be required. The Agency has reviewed several factors relating to this Facility, including, but not limited to those listed in §5-261 (3)(a)-(c) of the Regulations and the level of emissions typical for this category of emission source. Based on this review, the Agency is not requiring the Facility to conduct an air quality impact evaluation pursuant to §5-261 (3) of the Regulations at this time.

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Based on the Agency's review of the Facility's application and the above Findings of Fact, the Agency concludes that the Facility, subject to the following Permit conditions, complies with all applicable state and federal air pollution control laws and regulations or is subject to an acceptable schedule of compliance. Therefore, pursuant to 10 VSA §§556 and 556a, as amended, the Agency hereby issues a Permit approving the Facility, as described in the above Findings of Fact, subject to the following:

PERMIT CONDITIONS

- Construction and Equipment Specifications -

(1) The Permittee shall construct and operate the Facility in accordance with the plans and specifications submitted to the Agency and in accordance with the conditions set forth herein, including the equipment specifications as listed in Findings of Fact (A) or their equivalent as approved by the Agency. [10 v.s.A. §§556(c) and 556a(d)J [§5-501(1) of the Regulations] [Applications for #QP-95-096, #AOP-07-004 and #AOP-12-029]

(2) Scrubber and HEPA Filter: The Permittee shall control emissions from the hexavalent chromium electroplating tank by operating and maintaining a three-stage packed bed dry scrubber and a HEPA filter or a similar device capable of achieving equivalent emission reductions if approved in writing by the Agency.

Further, all elements of these air pollution control system(s) shall be maintained in good working order at all times and shall be operated in accordance with the manufacturer's operation and maintenance recommendations. Each air pollution control system shall be in operation whenever the respective emission sources are in operation. [10 v.s.A. §§556(c) and 556a(d)] (§§5-261, 5-501, and 5-1015(a)(1 ), (3) and (4) of the Regulations] [Application for #QP-95-096]

(3) Scrubber and HEPA Filter (Pressure Gauges): The Permittee shall equip each stage of the packed bed scrubber and the HEPA filter with its own pressure gauge to measure the pressure drop across each device. [10 v.s.A. §§556(c) and 556a(d)J [§§5-261 and 5-1015(a)(1), (3) and (4) of the Regulations] (Application for #QP-95-096]

(4) Hexavalent Chromium Electroplating Tank (Fume Suppressant): The Permittee shall control chromium emissions from its chromium electroplating tank by using a chemical fume suppressant containing a wetting agent and not allowing the surface tension of the electroplating baths to exceed 40 dynes per centimeter at any time during the preparation of the tank. The use of the fume suppressant shall also be in accordance with 40 CFR §§63.342, 63.343 and in accordance with the manufacturer's recommendations. (§5-261 o the Regulations and 40 CFR Part 60 Subpart NJ

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(5) Nickel Electroplating Tank [Wetting Agent I Fume Suppressant]: The Permittee shall control nickel emissions from its nickel electroplating tank by using a wetting agent I fume suppressant in the amounts recommended by the manufacturer for the specific type of electrolytic process. In addition, the Permittee shall add wetting agent I fume suppressant in proportion to the other bath chemistry ingredients that are added to replenish the tank bath, as in the original make-up of the tank. The use of an alternate emission control shall be approved by the Agency, in writing, prior to implementation and in accordance with 40 CFR Part 63 Subpart W\/INNVWW. [10 V.S.A. §§556(c) and 556a(d)J [§5-261(2) of the Regulations and 40 CFR Part 63 Subpart INWWIJV,NIN)

(6) Hexavalent Chromium Electroplating Tank [Amp-hour Meter]: The Permittee shall equip the hexavalent chromium electroplating tank with a non-resettable amp-hour meter to measure the amperage of the electrical current being applied to the plating bath and the cumulative hours of rectifier usage or equip the tank with an amp-hour meter designed for momentary measurement of amperage. [10 v.s.A. §§556(c) and 556a(d)J [§§ 5-261 and 5-405(1) of the Regulations] [Application for #QP-95-096]

(7) Nickel Electroplating Tank [Amp-hour Meter]: The Permittee shall equip the nickel electroplating tank with a non-resettable amp-hour meter to measure the amperage of the electrical current being applied to the plating bath and the cumulative hours of rectifier usage or equip the tank with an amp-hour meter designed for momentary measurement of amperage. [1 o v. S.A. §§556(c) and 556a(d)J [§§ 5-261 (2) and 5-405(1) of the Regulations] [Application for #AOP-12-029]

(8) Hexavalent Chromium Electroplating Tank [Fume Suppressant]: The Permittee shall control chromium emissions from its chromium electroplating tank by using a chemical fume suppressant containing a wetting agent and not allowing the surface tension of the electroplating bath to exceed 40 dynes per centimeter (dynes/cm) (2.8 x 10-3 pound-force per foot (lbt/ft)) as measured by a stalagmometer or 33 dynes/cm (2.3 x 10-3 lbtlft) as measured by a tensiometer at any time during operation of the tank. The use of the fume suppressant shall also be in accordance with 40 CFR §§63.342, 63.343 and in accordance with the manufacturer's recommendations. [§5-261 of the Regulations and 40 CFR Part 60 Subpart NJ [Application for permit #QP-95-096]

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(9) Stack Heights: The exhaust gases from the following emission sources shall be vented vertically through a stack(s) of the configuration noted below. Where stack heights are noted in Findings of Fact A such stacks shall be configured accordingly. The stack(s) shall not be equipped with any device that may obstruct the upward discharge of the exhaust gases such as a fixed rain cap of a type that has not been approved by the Agency.

Stack Height and Configuration

Emission source

Evaporator Unit, PPC Corp. Model ET-111-W

Three-stage packed bed dry scrubber unit

Oil-fired Columbia boiler

Maximum stack diameter, feet

Not specified

Not specified

Not specified

Minimum stack height above stack grade, feet

30

30

22

For all other non-fugitive emission points at the Facility, the Agency recommends that they each be exhausted vertically through a stack(s) which extend a minimum of four (4) feet above the roof where the stack penetrates the roof and that they not be equipped with any device that may obstruct the upward discharge of the exhaust gases such as a fixed rain cap of a type that has not been approved by the Agency. The Agency may require the Permittee to increase the stack height, remove a rain cap, or conduct a dispersion analysis to verify compliance with ambient air quality standards for any stack at the Facility if, in the judgment of the Agency, adequate dispersion cannot be maintained at the current stack configuration. Adequacy may in part be based on the actual emission rate of air contaminants, the characteristics of the current stack configuration, or inspections of the Facility that indicate poor dispersion or that confirm significant visible emissions or nuisance or odor beyond the property line. 11 o v.s.A. §§556(c} and 556a(d)J [§5-406 of the Regulations] [Application for #QP-95-096]

(10) Facility Wide Process Tanks: The Permittee shall cover all tank baths with covers whenever the associated line is not in operation and reduce process bath temperatures, whenever possible, to minimize volatilization and emissions when they are not in use. 110 V.S.A. §§556(c} and 556a(d}]

- Operational Limitations -

(11) Hexavalent Chromium Electroplating Tank [Amp-hr Limit]: The Permittee shall ensure operation of the hexavalent chromium electroplating tank shall not exceed the annual 440,000 amp-hr limit per calendar year. 110 vs.A. §§556(c) and 556a(d)J [§5-261 of the Regulations [Application for #AQP-12-029]

(12) Nickel Electroplating Tank [Amp-hr Limit]: The Permittee shall ensure operation of the nickel electroplating tank shall not exceed the annual 110,000 amp-hr limit per calendar year. [1 O V.S.A. §§556(c) and 556a(d)] [§5-261 (2) of the Regulations] [Application for permit #AQP-12-029]

Page 15 of 27


(13) Solvent Metal Cleaning Station: The Permittee shall operate the cold, solvent metal cleaning units (parts cleaners) in accordance with the following requirements and shall only use a solvent with a vapor pressure equal to or less than 0.3 pounds per square inch measured at 100°F, which includes but is not limited to the Safety-Kleen 105 hydrocarbon solvent. Prior to the Permittee using any solvent with a maximum true vapor pressure greater than 0.3 psi or using a solvent that is heated, the Permittee shall notify the Agency and comply with any additional applicable requirements of §5-253.14 of the Regulations.

(a) Provide a permanent, legible, conspicuous label, summarizing the operating requirements;

(b) Store waste solvent in covered containers; (c) Close the cover whenever parts are not being handled in the cleaner; (d) Drain the cleaned parts until dripping ceases; (e) Supply a solvent spray, if used, that ensures a solid fluid stream at a pressure that

does not exceed ten (10) pounds per square inch gauge; (f) Degrease only materials that are neither porous nor absorbent; and (g) Cease operation of the unit upon the detection of any visible solvent leak until such

solvent leak is repaired.

(10 V.S.A. §§556(c) and 556a(d}]

(14) Boiler: Only No.2 fuel oils, or lighter grade fuel oils, with a maximum sulfur content not to exceed 0.05 percent by weight may be used as fuel in the boiler unless the Permittee obtains prior written approval from the Agency to use another type of fuel. Commencing on July 1, 2018, the sulfur content of No.2 and lighter distillate oils shall not exceed 0.0015 percent by weight. (10 V.S.A. §§556(c) and 556a(d)] (§§5-501 and 5-1015(a)(1) of the Regulations] [§5-221(1)(a) of the Regulations] [Application for #QP-95-096]

Page 16 of 27


- Emission Limitations -

(15) HAC Emission Limits: Emissions hexavalent chromium and nickel shall not exceed the following limits from each respective piece of equipment:

Equipment

Decorative Hexavalent Chromium Electroplating Tank

Equipment

Nickel Electroplating Tank

HAC Emission Limitations

Pollutant

Hexavalent Chromium

Pollutant

Nickel

Emission Limitations 1

lb/hr

1.60E-6

Emission Limitations 1

gr/amp-hr

0.63

1 Hexavalent chrome: Emission limit based on test data of 1.60E-6 lb/hr.

lb/8-hr

2.34E-8

lb/8-hr

9.04E-4

Nickel: Emission limit based on typical amperage of the plating tank (275 amps), the AP-42 emission factor for nicke plating (0.63 gr/amp-hr), 90 percent control efficiency from the fume suppressant. 0.63 gr/amp-hr * 275 amps * 40C hr/yr* (1 lb/7,000gr) * (1 yr/8, 760hr) * (1-0.9) *8-hr = 9.04E-4 lb Ni/8-hr.

Any emission testing conducted to demonstrate compliance with the above emission limits shall be performed in accordance with Title 40 Code of Federal Regulations Part 60, Appendix A, Reference Method 26 for sulfuric acid and Method 29 for nickel and hexavalent chromium or an equivalent method approved in writing by the Agency. (10 v.s.A. §556a(d)] (§5-261 (2) and 5-404 of the Regulations]

(16) Particulate Matter: Emissions of particulate matter ("PM") from any fossil fuel burning device, except motorized vehicles, with a heat input rating of less than ten (10) million British Thermal Units per hour ("MMBtu/hr") shall not exceed 0.5 pounds per MMBtu.

Any emission testing conducted to demonstrate compliance with the above emission limi shall be performed in accordance with 40 CFR Part 60, Appendix A, Reference Method f and Part 51, Appendix M, Reference Method 202, or equivalent methods approved ir writing by the Agency. [10 V.S.A. §§556(c) and 556a(d)] (§§5-231 (3)(a)(i) and 5-404 of the Regulations]

(17) Visible Emissions [Facility Wide): Emissions of visible air contaminants from an) installation at the Facility, except where otherwise noted in this Permit, shall not exceec twenty (20) percent opacity for more than a period or periods aggregating six (6) minutes in any hour and at no time shall visible emissions exceed sixty (60) percent opacity.

Any emission testing conducted to demonstrate compliance with the above emission limit~ shall be performed in accordance with 40 CFR Part 51, Appendix M, Methods 2038 anc 203C, respectively, or equivalent methods approved in writing by the Agency. (10 v.s.A §§556(c) and 556a(d)] [§§5-211 (2), 5-211 (3) and 5-404 of the Regulations]

Page 17 of 27


(18) Volatile Organic Compounds: Emissions of volatile organic compounds from the Facility shall not equal or exceed one (1) ton per calendar year. r10 vs.A §§556(c) and 556a(d)J [§5-502 of the Regulations]

( 19) Hazardous Air Pollutants: Emission of federally regulated hazardous air pollutants (HAPs) from the Facility shall not equal or exceed eight (8) tons per year of any single HAP or twenty (20) tons per year of all HAPs combined per calendar year This condition does not explicitly authorize emissions up to this level since any increase in actual HAP emissions may be subject to §5-261 and 5-501 of the Regulations as applicable. r10 v.s.A. §§556(c) and 556a(d)) [§§5-261 and 5-501 of the Regulations) [40 CFR Part 63)

(20) Hazardous Air Contaminants: Emissions of state hazardous air contaminants (HACs) from the applicable operations at the Facility shall not equal or exceed their respective Action Level (found in Appendix C of the Regulations) unless the Agency has reviewed and approved such HAC emission under §5-261 (2) of the Regulations. r10 v.s.A. §§556(c) and 556a(d)] [§5-261 of the Regulations]

(21) Nuisance and Odor: The Permittee shall not discharge, cause, suffer, allow, or permit from any source whatsoever such quantities of air contaminants, or odors beyond the property line of a premises, which will cause injury, detriment, nuisance or annoyance to any considerable number of people or to the public or which endangers the comfort, repose, health or safety of any such persons or the public or which causes or has a natural tendency to cause injury or damage to business or property. r10 v.s.A. §§556(c) and 556a(d)J [§5-241 ( 1) of the Regulations]

- Fume Suppressant Monitoring -

(22) Hexavalent Chromium Electroplating Tank [Fume Suppressant]: The Permittee shall test the surface tension of the hexavalent chromium electroplating tank at least once during every forty (40) hours of operation of the tank including at least once each day the tank is used. If results are consistently below 40 dynes/cm, the frequency of testing can be reduced according to the chrome plating operating and maintenance plan submitted by the Permittee to the Agency and approved by the Agency. Said testing shall be conducted in accordance with Method 3068 of 40 CFR Part 63, Appendix A. If the surface tension is found to exceed 40 dynes per centimeter (dynes/cm) (2.8 x 10-3 pound-force per foot (lbtlft)) as measured by a stalagmometer or 33 dynes/cm (2.3 x 10-3 lbtlft) as measured by a tensiometer during a test, the Permittee shall take action to reduce the surface tension in accordance with the submitted operation and maintenance plan and test the surface tension once every four (4) hours of operation thereafter until the surface tension is found to be consistently less than the limits outlined in this Condition. r10 v.s.A. §§556(c) and 556a(d)J [§5-261 of the Regulations] [40 CFR Part 63 Subpart NJ

Page 18 of 27


- Compliance Testing and Monitoring -

(23) Operation and Maintenance Plan [Chrome Electroplating and Air Pollution Control Equipment]: The Permittee shall develop and submit to the Agency, within 120 days of the date of issuance of this Permit, an operation and maintenance ("O&M") plan for its decorative chrome electroplating equipment and air pollution control system. Said O&M plan shall include, but not be limited to, routine and preventive maintenance procedures, frequency of inspections, and procedures for correcting malfunctions. Said O&M plan shall also identify the pressure drops across the dry scrubber beds and HEPA filter that correspond to compliance with the emission limit. The Permittee shall revise this plan at the Agency's request or on its own motion to reflect equipment or operational changes. The plan shall be made available for inspection and kept for the life of the chromium electroplating equipment and air pollution control system. If the O&M plan is revised, the Permittee shall keep the superseded version(s) on record for a period of five (5) years after revision. [40 CFR Part 60 Subpart NJ [Permit #OP-95-096J

(24) The Permittee shall observe the pressure drop across each stage of its three-stage packed bed scrubber at least once per day during the operation of the air pollution control system. If the pressure drop across any of the stages increases above the levels listed in Table A, the Permittee shall initiate wash-down of those stages. Following wash-down, i1 the pressure drop increase remains, the Permittee shall perform appropriate maintenance, including but not limited to, replacement of the packing material to reduce the pressure drop into the proper range. If the pressure drop across the entire scrubber is less than 1. 7 inches of water, the Permittee shall take appropriate steps, in accordance with the operation and maintenance plan referenced in this Permit, to verify that the scrubber is functioning properly. [40 CFR Part 60 Subpart NJ

Table A: Maximum Pressure Drop for Scrubber Stages

Stage Preaaure Drop (lnchea of water)

0.86

2 1.75

3 0.85

(25) The Permittee shall observe the pressure drop across its HEPA filter unit at least once per day during the operation of the air pollution control system. If the pressure drop across the HEPA filter unit exceeds two inches of water column, the Permittee shall replace the filters. If the pressure drop across the HEPA filter unit drops below 0.5 inches of water column, the Permittee shall take appropriate steps, in accordance with the operation and maintenance plan referenced in this Permit, to verify that the unit is functioning properly. [40 CFR Part 60 Subpart NJ [Permit #QP-95-096J

Page 19 of 27

Precisi on Valley Finishing, Inc. - Springfield #AQP-12-029

(26) The Permittee shall follow the work practice standards listed in Tables B and C for each respective air pollution control system. [40 CFR Part so Subpart NJ [Permit #QP-95-0961

Table B: Work Practice Standard• for Three-Stage Packed Bed Scrubber

Work Practice Standard Frequency

1. Visually inspect device to ensure there is proper drainage, no chromic acid buildup on the

Once per quarter packed beds, and no evidence of chemical attack on the structural integrity of the device.

2. Visually inspect back portion of scrubber to ensure there is no breakthrough of chromic acid Once per quarter mist.

3. Visually inspect ductwork from electroplating tanks to the scrubber to ensure there are no Once per quarter leaks.

4. Perform washdown or more intensive cleaning of each packed bed in accordance with the Per manufacturer and Table A of this Permit manufacturer's recommendations.

5. Visually inspect spray nozzles to ensure that spray pattern is uniform and covers a full 360E

Once per month arc. Visually inspect nozzles for accumulation of scale or slime.

Table C: Work Practice Standards for HEPA filter

Work Practice Standard Frequency

1. Visually inspect device to ensure there is no chromic acid buildup on the filter material and

Once per quarter no evidence of chemical attack on the structural integrity of the device.

2. Visually inspect back portion of filter to ensure Once per quarter

there is no breakthrough of chromic acid mist.

3. Visually inspect ductwork from the scrubber to Once per quarter

the HEPA unit to ensure there are no leaks.

4. Replace filter in accordance with the Per manufacturer and Table A of this Permit

manufacturer's recommendations.

Page 20 of 27


- Record Keeping and Reporting -

(27) Records of Fuel Use: The Permittee shall maintain records of the total quantity of fuel oil consumed in the boilers, in gallons, each calendar year. [10 v.s.A. §§556(c} and 556a(d)J [§5-405(1) of the Regulations]

(28) Records of Fuel Oil Certifications [Boiler]: The Permittee shall obtain from the fuel supplier, for each shipment of fuel oil received at the Facility for use in the boilers a certification or invoice regarding the sulfur content of the fuel oil. The certification o invoice shall include: the date of delivery, name of the fuel oil supplier, fuel type, quantity of fuel oil delivered, the sulfur content of the fuel delivered, and the location of the oil when the sample was drawn for analysis to determine the sulfur content of the oil, specifically including whether the oil was sampled as delivered to the affected facility, or whether th sample was drawn from oil in storage at the oil supplier's or oil refiner's facility, or othe location, and the method used to determine the sulfur content of the oil. r10 v.s.A. §§556(c and 556a(d)J [§5-405(1) of the Regulations]

(29) Records of Chemical Usage [Facility Wide]: The Permittee shall maintain records of th total quantities of solvents, acids and electroplating chemicals consumed at the Facility o an annual basis. [10 V.S.A. §§556(c) and 556a(d)J [§5-405(1) of the Regulations]

(30) Records of Maintenance [Air Pollution Control System]: The Permittee shall keep an maintain records of all inspections and maintenance procedures relating to its air pollutio control system. Such records shall include, but not be limited to, the date of eac inspection or procedure, the reason it was performed, and the outcome. [§5-405(1) of th Regulations]

(31) Records of Amp-Hours [Electroplating Tanks]: The Permittee shall maintain the followin records relating to the amperage applied to its decorative chrome electroplating tank an nickel electroplating tank:

(a) For electroplating tanks equipped with non-resettable amp-hour meters designe to measure the total cumulative amperes applied to the plating bath, at least one per month the Permittee shall record in a logbook the date and the current mete reading; and

(b) For electroplating tanks equipped with amp-hour meters designed to provide momentary measurement of the amperage, the Permittee shall measure an record in a logbook the amperage that was applied to the plating bath at least one each day plating is performed. In addition, said records shall include the date, th type of plating being performed, and the number of hours the tank was operate during that day.

[§5-405(1) of the Regulations] [Permit #QP-95-096]

Page 21 of 27


(32) Records of Pressure Drop [Air Pollution Control System]: The Permittee shall record in a logbook the date and the pressure drop across the HEPA filter and across each packed bed of the three-stage dry scrubber, at least once each day the air pollution control system is operated. [§5-405(1) of the Regulations] [Permit •oP-95-096]

(33) Hexavalent Chromium Electroplating Tank [Surface Tension Measurements]:The Permittee shall, for the tension test required by this Permit, record in a logbook the date of the test, the tanks that were tested (decorative chromium}, and the surface tension that was measured in units of dynes per centimeter. [§5-405(1) of the Regulations] [Permit #QP-95-096]

(34) Nickel Electroplating Tank [Amp-hour Records]: The Permittee shall measure and record in a log book, the amperage that was applied to the nickel electroplating tank at least once each day nickel plating is performed. In addition, said records shall include the date, type of plating being performed, name of plating line, and the number of hours each tank was operated during that day. [§5-405(1) of the Regulations]

A separate section of the logbook shall also be maintained containing records of any material safety data sheets (MSDSs) for each product associated with the chrome electroplating unit. Said operator's log book shall be present at the Facility at all times and shall be made available to representatives of the Agency upon request. [1 o v.s.A. §§556(c) and 556a(d)] [§5·402(1) of the Regulations]

(35) Records: All records shall be retained for a minimum period of five (5) years from the date of record and shall be made available to the Agency upon request. [10 v.s.A. §§556(c) and 556a(d)] [§§5-402, 5-405(1) and 5-1015(a)(7) of the Regulations]

(36) Notification: The Permittee shall notify the Agency in writing within ten (10) days of any violation, of which it is aware, of any requirements of this Permit. This notification shall include, at a minimum, the cause for the violation and corrective action or preventative maintenance taken to correct the violation. [10 v.s.A. §§556(c) and 556a(d)J [§§5-402 and 5-1015(a)(6) of the Regulations]

(37) Notification: The Permittee shall notify the Agency in writing of any proposed physical o operational change at the Facility which may increase the emission rate of any ai contaminant to the ambient air regardless of any concurrent emission reductions that may be achieved. This notification requirement includes, but is not limited to, the proposed installation of any new equipment that is a source of air pollution, including the replacement of an existing permitted air pollution source. If the Agency determines that a permit amendment is required, a new application and the appropriate application fee shall be submitted. The permit amendment shall be obtained prior to commencing any such change except as may otherwise be allowed by the Regulations. [10 v.s.A §§556(c) and 556a(d) [§§5-402 and 5-501 of the Regulations]

Page 22 of 27


(38) Annual Registration: The Permittee shall calculate the quantity of emissions of air contaminants from the Facility annually. If the Facility emits more than five (5) tons of any and all air contaminants per year or if the Facility performs one or more of the air contaminant emitting operations listed in 5-802(2) of the Regulations, the Permittee shall register the source with the Secretary of the Agency (hereinafter "Secretary"), and shall renew such registration annually. Each day of operating a source which is subject to registration without a valid, current registration shall constitute a separate violation and subject the Permittee to civil penalties. The registration process shall follow the procedures set forth in Subchapter VIII of the Regulations, including the payment of the annual registration fee on or before May 15 of each year. r10 v.s.A. §§556(c) and 556a(d)J [Subchapter VIII §§5-802, 5-803, 5-807, 5-808 of the Regulations]

(39) All records, notifications and reports that are required to be submitted to the Agency by this Permit shall be submitted to:

Air Quality & Climate Division Department of Environmental Conservation Agency of Natural Resources Davis 2 One National Life Drive Montpelier, Vermont 05620-3802

[10 V.S.A. §§556(c) and 556a(d)] [§5-402 of the Regulations]

(40) All records, notifications and reports that are required to be submitted to the U.S. EPA by this Permit shall be submitted to:

Air Compliance Clerk U.S. EPA-New England 5 Post Office Sq. Suite 100 (OES04-2) Boston, MA 02109-3912

[10 V.S.A. §§556(c) and 556a(d)] [§5-402 of the Regulations]

- Standard Permit Conditions -

(41) At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Agency which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. [10 v.s.A §§556(c) and 556a(d)] [40 CFR Part 60.11 (d) and 63.6(e)]

Page 23 of 27


(42) These Permit conditions may be suspended, terminated, modified, or revoked for cause and reissued upon the filing of a written request with the Secretary of the Agency (hereinafter "Secretary") or upon the Secretary's own motion. Any modification shall be granted only with the written approval of the Secretary. If the Secretary finds that modification is appropriate, only the conditions subject to modification shall be re-opened. The filing of a request for modification, revocation and reissuance, or termination, or of a notification of planned changes or anticipated non-compliance does not stay any terms or conditions of this Permit. The Secretary may provide opportunity for public comment on any proposed modification of these conditions. If public comments are solicited, the Secretary shall follow the procedures set forth in 10 V. S.A. §556 and §556a, as amended. [1 O V.S.A. §§556(c) and 556a(d)) [§§5-1008(a) and 5-1008(e) of the Regulations]

(43) Cause for reopening, modification, termination and revocation of this Permit includes, but is not limited to:

(a) Inclusion of additional applicable requirements pursuant to state or federal law; (b) A determination that the permit contains a material mistake or that inaccurate

information was used to establish emissions standards or other terms or conditions of the operating permit;

(c) A determination that the operating permit must be modified or revoked to ensure compliance with applicable requirements;

(d) A determination that the subject source has failed to comply with a permit condition;

(e) For Title V subject sources, a determination by U.S. EPA that cause exists to terminate, modify, revoke or reissue an operating permit;

(f) Those causes which are stated as grounds for refusal to issue, renew or modify an operating permit under §5-1008(a) of the Regulations; or

(g) If more than three (3) years remain in the permit term and the source becomes subject to a new applicable requirement.

[10 V.S.A. §§556(c) and 556a(d)J [§5-1008(e)(4) of the Regulations]

(44) The Permittee shall furnish to the Agency, within a reasonable time, any information that the Agency may request in writing to determine whether cause exists to modify, revoke, reissue, or terminate the Permit or to determine compliance with this Permit. Upon request, the Permittee shall also furnish to the Agency copies of records required to be kept by this Permit. [10 V.S.A. §§556(c) and 556a(d)J [§5-402 of the Regulations]

(45) By acceptance of this Permit, the Permittee agrees to allow representatives of the State of Vermont access to the properties covered by the Permit, at reasonable times, to ascertain compliance with Vermont environmental and health statutes and regulations and with this Permit. The Permittee also agrees to give the Agency access to review and copy any records required to be maintained by this Permit, and to sample or monitor a reasonable times to ascertain compliance with this Permit. r10 v.s.A. §§556(c) and 556a(d)J [§§5 402, 5-404, and 5-1015(a)(10) of the Regulations]

Page 24 of 27


(46) All data, plans, specifications, analyses and other information submitted or caused to be submitted to the Agency as part of the application for this Permit or an amendment to this Permit shall be complete and truthful and, for Title V permit applications, certified by a responsible official whose designation has been approved by the Secretary. Any such submission which is false or misleading shall be sufficient grounds for denial or revocation of this Permit, and may result in a fine and/or imprisonment under the authority of Vermont statutes. (10 V.S.A. §§556(c) and 556a(d}] (§§5-505 and 5-1006(f) of the Regulations]

(47) For the purpose of establishing whether or not a person has violated or is in violation of any condition of this Permit, nothing in this Permit shall preclude the use, including the exclusive use, of any credible evidence or information relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. 110 v.s.A. §§556(c) and 556a(d)J

(48) Any permit noncompliance could constitute a violation of the federal Clean Air Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. 110 v.s.A. §§556(c) and 556a(d)J [§§5-1oos(a) and 5-1008(e) of the Regulations]

(49) It shall not be a defense for the Permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity to maintain compliance with the conditions of this Permit. 110 v.s.A. §§556(c) and 556a(d)J

(50) No person shall build, erect, install or use any article, machine, equipment or other contrivances, the use of which, without resulting in a reduction in the total release of air contaminants to the atmosphere, reduces or conceals an emission which otherwise would constitute a violation of these Regulations. 110 v.s.A. §§556(c} and 556a(d)J [§5-403 of the Regulations]

(51) The provisions of this Permit are severable. If any provision of this Permit, or its application to any person or circumstances is held invalid, illegal, or unenforceable by a court of competent jurisdiction, the invalidity shall not apply to any other portion of this Permit which can be given effect without the invalid provision or application thereof. 110 V.S.A. §§556(c) and 556a(d}]

(52) This Permit does not convey any property rights of any sort or any exclusive privilege, no does it authorize any injury to private property or any invasion of personal rights. 110 v.s.A. §§556(c) and 556a(d)]

Page 25 of 27


(53) All subsequent owners and/or operators of this Facility must request an amendment and transfer of this Permit prior to commencing any operations covered by this Permit. All subsequent owners and/or operators shall submit to the Agency as part of the request for amendment all such information the Agency deems necessary to establish legal ownership and/or interest in the property and all such information the Agency deems necessary to ensure the new owners and/or operators will construct and operate the Facility in compliance with the Regulations and this Permit. The terms and conditions of this Permit shall remain in full force and effect after submittal of the request for amendment and until the issuance of an amended Permit or denial. Should the Secretary deny the request, the new owner and/or operator must take whatever action is necessary to comply with the denial. (10 V.S.A. §§556(c) and 556a(d)] (§§5-501, 5-1004, and 5-1013(a} of the Regulations]

(54) Renewable Energy Projects - Right to Appeal to Public Service Board. If this decision relates to a renewable energy plant for which a certificate of public good is required under 30 V.S.A. §248, any appeal of this decision must be filed with the Vermont Public Service Board pursuant to 10 V.S.A. §8506. This section does not apply to a facility that is subject to 10 V.S.A. §1004 (dams before the Federal Energy Regulatory Commission), 10 V.S.A. §1006 (certification of hydroelectric projects) or 10 V.S.A. Chapter 43 (dams). Any appeal under this section must be filed with the Clerk of the Public Service Board within 30 days of the date of this decision; the appellant must file with the Clerk an original and six copies of its appeal. The appellant shall provide notice of the filing of an appeal in accordance with 10 V.S.A. 8504(c)(2), and shall also serve a copy of the Notice of Appeal on the Vermont Department of Public Service. For further information, see the Rules and General Orders of the Public Service Board, available on line at www.psb.vermont.gov. The address for the Public Service Board is 112 State Street, Montpelier, Vermont, 05620-2701 (Tel. # 802-828-2358). (10 V.S.A. §§556(c) and 556a(d)J

(55) All Other Projects - Right to Appeal to Environmental Court. Pursuant to 10 V.S.A. Chapter 220, any appeal of this decision must be filed with the clerk of the Environmental Court within 30 days of the date of the decision. The Notice of Appeal must specify the parties taking the appeal and the statutory provision under which each party claims party status; must designate the act or decision appealed from; must name the Environmental Court; and must be signed by the appellant or their attorney. In addition, the appeal must give the address or location and description of the property, project or facility with which the appeal is concerned and the name of the applicant or any permit involved in the appeal. The appellant must also serve a copy of the Notice of Appeal in accordance with Rule 5(b)(4)(B) of the Vermont Rules for Environmental Court Proceedings. For further information, see the Vermont Rules for Environmental Court Proceedings, available on line atwww.vermontjudiciary.org. The address for the Environmental Court is 2418 Airport Road, Suite 1, Barre, VT 05641 (Tel. #802-828-1660). (10V.S.A.§§556(c)and556a(d)J

Page 26 of 27


(56) This Operating Permit shall expire as indicated on the cover page to this Permit. The Permittee shall submit to the Agency a complete application for renewal of the Operating Permit at least six (6) months before the expiration of the Operating Permit. If a timely and administratively complete application for an operating permit renewal is submitted to the Secretary, but the Secretary has failed to issue or deny such renewal before the end of the term of this Operating Permit, then the Permittee may continue to operate the subject source and all terms and conditions of this Operating Permit shall remain in effect until the Secretary has issued or denied the operating permit renewal. However, this Operating Permit shall automatically expire if, subsequent to the renewal application being determined or deemed administratively complete pursuant to §5-1006 of the Regulations, the Permittee fails to submit any additional information required by the Secretary as well as information pertaining to changes to the Facility within thirty (30) days or such othe period as specified in writing by the Secretary. 11 o v.s.A. §§556(c) and 556a(d)J [§§5-1011 and 5-1012(a) of the Regulations] [§§5-1005(c) and 5-1012 of the Regulations]

(57) The conditions of this Permit as set forth above supersede all conditions contained in all prior Permits issued by the Agency to the Permittee for this Facility. 110 v.s.A. §§556(c) and 556a(d)]

The Agency's issuance of this Air Pollution Control Permit relies upon the data, judgment, and other information supplied by the Permittee. The Agency makes no assurances that the ai contaminant source approved herein will meet performance objectives or vendor guarantee supplied to the source Permittee. It is the sole responsibility of the Permittee to operate the sourc in accordance with the conditions herein and with all applicable state and federal standards an regulations.

Permit issued and effective this .' ft day of --1-,Uf'-'P~'.!1.""""""",o\'.-L..,,.......--------' 2018.

Permit issuance authorized by: Agency of Natural Resources Emily Boedecker, Commissioner Department of Environmental Conservation

By: Heidi C. Hales, Director Air Quality & Climate Division

jh Y:\AP _Admin\StationaryFacilities\Precision Valley Finishing\Permits\AOP-12-029

Page 27 of 27

ate Signed

~-VERMONT · • Keeping the nickel plating tanks covered with well-fitting lids when not in...

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Transcript of ~-VERMONT · • Keeping the nickel plating tanks covered with well-fitting lids when not in...