January 21, 1997

Vicki Carano
Plating Resources, Inc.
2030 Midway Drive
Twinsburg, Ohio 44087

Dear Ms. Carano:

This letter is in regards to your December 13, 1996, application for an air permit for Integrated
Products, Inc. It was submitted to the United States Environmental Protection Agency
(USEPA) to allow construction of a new hard chrome electroplating process in DePere, Brown
County, Wisconsin. The proposed facility is to be located within the exterior boundaries of the
Oneida Tribal reservation. This application was reviewed under the Prevention of Significant
Deterioration (PSD) provisions of the Clean Air Act (CAA), Sections 160-169. Section 165
and its implementing regulations prohibit the construction of a major emitting facility in an
attainment area without a PSD permit, i.e., a permit which contains limitations to prevent the
significant deterioration of air quality. To be consider a "major" source for PSD purposes, a
new hard chrome electroplating source would generally have to have the potential to emit more
than 250 tons per year (tpy) of a criteria pollutant. The information which you have submitted
indicates that the facility you propose to construct will not have the potential to emit more than

250 tpy of a criteria pollutant. Thus, you are not required to obtain a PSD permit, and USEPA
is currently not issuing construction permits to true PSD minor sources in Tribal lands.

Even though a source may not require a construction permit under the PSD program, it may in
the future be required to obtain an operating permit under Title 5 of the CAA. This is because
all stationary sources in attainment areas must get such a permit if they are major for Title 5
purposes, i.e., have the potential to emit over 100 tpy of an air pollutant (lesser amounts in
certain non-attainment areas), 25 tpy of a combination of hazardous pollutants, or 10 tpy of one
hazardous pollutant. On Tribal lands, operating permits for major Title 5 sources will be issued
in the 1998-1999 time frame either by the Tribes themselves under the authority outlined as
being available to Tribes in USEPA's proposed "Tribal Rule" or, if a Tribe does not wish to
develop or be delegated such an operating permit program, by USEPA. Title 5 permits are
also required for certain minor (area) sources under the National Emission Standards for
Hazardous Air Pollutants For Source Categories, Title 40 Code of Federal Regulations (CFR)
Part 63. The dates for issuance of these permits differ under each standard.

As to the proposed Integrated Products, Inc. hard chrome electroplating facility in DePere, your
application indicates that there will be no criteria pollutant emissions from it, and that it will emit
less than 10 tpy of any one hazardous pollutant and less than 25 tpy of any combination of
hazardous pollutants. Therefore, it will be a minor source under Title 5 as well. The proposed
facility is, however, subject to the Part 63 Maximum Achievable Control Technology (MACT)
standards for hard chrome electroplating. All hard or decorative chromium electroplating or
chromium anodizing activities, regardless of size, are affected by this MACT standard and
new sources must be in compliance upon operation (40 CFR 63.343).

Chromium electroplating area sources, if not located at major sources, however may be
deferred by the applicable title V permitting authority from Title V permitting requirements until
December 9, 1999. Title V applications for such deferred area sources must then be
submitted no later than December 9, 2001. (See Volume 61 Federal Register Page 27785,
June 3, 1996.) Further, under 40 CFR 71.3(b)(1), certain area sources are exempted from the
requirement to obtain a Title V permit until such time that USEPA completes rulemaking to
determine how the program should be structured for non-major sources and the
appropriateness of any permanent exemption. At such time that a Title 5 permit is required,
and if the Integrated Products, Inc. facility is still in operation, the Oneida Tribe or USEPA will
issue an operating permit.

If you have any further questions or comments, please contact Constantine Blathras at (312)

Sincerely yours,


Robert Miller, Chief
Permits and Grants Section

cc: Deborah Doxtator, Chairperson
Oneida Tribe
P.O. Box 365
Oneida, Wisconsin 54155

Jeffery Sanders
Oneida Planning Department
Oneida Tribal Reservation

Donald F. Theiler, Director
Bureau of Air Management
Wisconsin Department of Natural Resources