Hutchinson Sealing Systems North America Inc.

171 Route 85 

### POBox 169 Newfields, NH 03856 A . ]

] Final RACT ORDER ] March 22, 2012 ] ARD-11-001 

## l Introduction This RACT Order is issued by the New Hampshire Department of Environmental Services, Air Resources Division, to Hutchinson Sealing Systems North America Inc., pursuant to RSA 125-C. B . l . 

### 2. Parties The New

Hampshire Department of Environmental Services, Air Resources Division ("DES"), is a duly constituted administrative agency of the State of New Hampshire having its principal offices at 29 Hazen Drive, Concord, NH 03302, telephone number (603) 271-1370. Hutchinson Sealing Systems, Inc. ("HSS") is a Delaware corporation, having a mailing address of 1060 Centre Road, Auburn Hills, MI . C . Statements of Fact and Law 1 . 2 .



### 3. HSS owns and operates a facility located on Route 85 in Newfields, NH . HSS is primarily engaged in theproduction ofsealing systems that are designed for use in automotive and various other applications. The sealing strips are produced by several complex processes involving metal roll forming, rubber and plastic extruding, flocking (or the application of a low-friction coating) and curing, followed by certain secondary operations including but not limited to trimming, notching, saw cutting, stretch bending, molding and assembly. On August 8, 2002, DES issued RACT Order # ARD-01-002 to HSS for the sealing systems production operations. The RACT Order required HSS to: a . 

### b. Terminate the Body Stock Preparation Process operations, and the Metal Parts Painting Operations; and Continue to research and test water-based and/or high solids adhesives and low friction primer and top coatings as new products become available in search of RACT-compliant coatings (3.5 pounds ofVOCs per gallon of coating excluding water and exempt VOC compounds as applied) ; and/or obtain credits or use its own shutdown ERCs to comply with the VOCRACT requirements of 3.5 pounds of VOCs per gallon of coating excluding water and exempt VOCcompounds as applied 4. On August 8, 2002, DES submitted to United States Environmental Protection Agency (USEPA) VOC RACT Order # ARD-O1-002 as a revision to the New Hampshire State Implementation plan (SIP) .RACT Order No. ARD-I1-001 March 22, 2012

Hutchinson Sealing Systems, Inc . - Page 2 of5

, 5. Effective July 1, 1979, DES adopted PART Env-A 1200 STATIONARY SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOCs) . Effective June 1, 2011, DES revised and adopted Env-A 1220

. 6 . On November 9, 2009, HSS submitted an application for renewal of State Permit to Operate FP-S-0255. 7. On August 11, 2011, HSS submitted an addendumto the permit renewal application to include a modification to Thermoplastics Extrusion Line #9 [TPV Line #9] and the installation of an associated control device (catalytic oxidizer) . 8 . On October 3, 2011, HSS submitted a request for a modification to VOC RACT Order ARD-O1-002 to be allowed to generate DERs for the over control of VOCs generated fromthe modification to TPV Line #9 and the installation of the catalytic oxidizer . 9. On March 22, 2012, HSS will be issued a renewal of its State Permit to Operate for the Sealing SystemProduction Operations, which will allowHSS to modify the "front end" ofTPV#9, and install and operate a catalytic oxidizer to control those VOCemissions. 10. HSS' current VOCemitting sources subject to this Order include the following:

Emission Unit ID Process/Device,Identification EU01 Extrusion Line #12 EU02 Extrusion Line #13 EU03 Extrusion Line #14 EU04 Extrusion Line #15 EU07 Thermoplastics Extrusion Line #7 EU08 Thermoplastic Vulcanizates Line #8 EU09 Thermoplastic Vulcanizates Line #9 11 . DES will submit a request to withdrawRACT Order # ARD-01-002 to EPAto be replaced with this PACT Order ARD-11-001 as a SIP revision D . Order Based on the above findings and determinations, DES hereby orders HSSas follows: 1 . Comply with the VOClimit codified in Env-A 1220.02of 6.3 lbs VOC/gallon of coating as applied, excluding water and exempt VOCcompounds, as a monthly average for all motor vehicle weather-strip adhesive coatings applied by using credits in accordance with D .4. below . 2 . Continue to research and test water-based and/or high solids coatings as new products become available; 3. HSS shall be allowed to use discrete emissions reductions (DERs) or emissions reductions credits (ERCs) for the purpose of complying with VOC RACT by acquiring DERs or ERCs on the open market or by self-generating ERCs in accordance with Chapter Env-A 3000and in accordance with HSS' June 30, 1998 Notice of ERCGeneration and the accompanying protocols dated June 7, 1999 (i .e., substitute NOx for VOCcredits, ration 1 :1) or by selfgenerating DERs in accordance with Chapter Env-A3100and in accordance with the provisions in Part E of this Order for self-generation of DERs.RACT Order No. ARD-11-001 March 22, 2012

Hutchinson Sealing Systems, Inc. Page 3 of5 a. Emission standard on a solids basis shall be determined as specified below : i . "E," means the VOCemission limit as stated in Part D .1 ., above; and ii . "dA" means the actual mass density of the VOCin the applied surface coating formulation in terms of lbs VOC/gal VOC ; and iii . "S" means the VOCemission standard in terms of lbs VOC/gallon of coating solids as applied; and shall be equal to Ec divided by the difference between one and the quotient of Ec and dA, as in the following equation: 

### S E, 1-I E, dA b. Allowable VOCemissions for each coating as applied shall be calculated as follows: i . "S" means the VOCemission standard in terms of lbs VOC/gal coating solids as applied or kg VOC/I of coating solids as applied, as calculated in Part D .4.a. above; ii . "Vs" means the volume fraction solids content of the coating as applied, in units of gal solids/gal coating or 1 solids/1 coating as determined by calculation using the formulation; 

### iii . "G" means the volume of coating as applied used in the coating line on a given day in units ofgal/day or 1/day; and iv. "Ea," means the allowable VOCemission rate of a given coating as applied minus water and exempt VOCcompounds in units of lbs/day or kg/day; and shall be equal to the product of S, Vs and the quotient of W and Dfor each coating, as in the following equation: 

## EQ, =S*VS *G c. Actual VOCemissions for each coating as applied shall be calculated as follows: i . "Wv" means the weight fraction ofVOCcontent of the coating minus water and exempt VOCcompounds, in units of lbs VOC/gal coating as determined by calculationusing the formulation; ii . "G" means the volume of coating as applied used in the coating line on a given day in units of gal/day or 1/day; and iii . " Eu c" means the actual, uncontrolled VOCemission rate of a given coating as applied minus water and exempt VOCcompounds in units of lbs VOC/day; and shall be equal to the product ofWv and G, as in the following equation:



## Eunc = 

## W

1 * 

## G iv. "DRE" means the destruction removal efficiency ofthe pollution control device as measured during the most recent emissions testing of the unit.I v. "Ec" means the actual, controlled VOCemission rate of a given coating as applied in units of lbs/day; and shall be equal to the product of Eu c and one minus the DRE, as in the following equation: Prior to the initial compliance test ofthe control device required in Section VI ., Table 5, Item5 of permit SP-0141, the DRE shall be equal to 95.0% .RACT Order No . ARD-11-001 March 22, 2012 Hutchinson Sealing Systems, Inc . Page 4of5 

### EC = Eu e * (1- DRE) d. Bubble and Use of DERs - Emission credit use calculations shall be done on a daily basis as follows: i . HSS shall be allowed to bubble the emissions frommultiple coatings and/or use DERs to offset excess emissions. ii . Excess emissions shall be calculated for each coating by subtracting the actual emissions fromthe allowable emissions (Ed, - E nc for coatings that are not controlled by the control device, or Ea, - Ec. for coatings that are controlled)

. The excess emissions fromall the coatings shall be added together (bubbling), and based on the results, one of the following shall be required: 1 . If the result of the bubble calculation is a positive number, then the source is in compliance with the emission limits and no further action is required. 2. If the result of the bubble calculation is a negative number, then actual emissions exceed the allowable emission rates and need to be offset with the use ofcredits. The actual DERs required shall be calculated by taking the absolute value of the total excess emissions and dividing by an environmental benefit factor of 0 .9. 5 . HSS shall either test all coatings according to Env-A 804.04, or retain sufficient records for prima facie evidence in support of demonstrating compliance with the VOCRACT limit specified in D

.1 above. 6 . Annually by September 1, HSS shall continue to true up the balance ofcredits required for the previous year (for the period from June 1 to May 3 1) and shall report the balance to DES. 7. HSS shall comply with the recordkeeping and reporting requirements of New Hampshire Code ofAdministrative Rules Chapters Env-A 3000 and Env-A 3100for ERCand DERgeneration and use. 8 . HSS shall comply with the recordkeeping and reporting requirements ofthe New Hampshire Code ofAdministrative Rules Chapter Env-A900 . E. Discrete Emissions Reductions (Credi ts) 1 . HSS shall be allowed to generate DERs in accordance with Env-A 3 100for surplus reductions below the following emissions rates: a . The alternative limit (an overall control efficiency of at least 85%) to the VOCemission limit (6.3 lb/gal) for motor vehicle weather-strip adhesive listed in table 1220-1, in accordance with Env-A 1220.02(e) . This is equivalent to a facility-wide emissions rate equal to 15%

ofuncontrolled emissions. b. The emissions rate of 3.5 Ib/gal included in conditions D .2. and D

.3. of RACT Order ARD-01-002 dated August 8, 2002; and c. An emissions rate of 23 tons/year, in order to preserve the previously agreed upon protocol for calculating the 22 ERCs that Hutchinson Sealing Systems (HSS) receives each year. 2. If HSS exceeds any of the above emissions rates, then no DERcredits would be generated.RACT Order No. ARD-11-001 March 22, 2012

Hutchinson Sealing Systems, Inc. Page 5 of5 3. Calculation of the uncontrolled facility-wide emissions shall be in accordance with Monitoring and Testing condition 4 of Table 5 of State Permit to Operate SP-0141 . Actual calendar year emissions shall be reported in accordance with Reporting condition 1 ofTable 7 of the permit . The daily allowable emissions rate for credit generation shall be calculated by substituting 3.5 lb/gal for the VOCRACT limit of 6.3 lb/gal in the above VOC RACT compliance calculations in Part D . Please address any correspondence and communication in reference to this Order to the following: Ms. Patricia North NHDES, Air Resources Division Permitting and Environmental Health Bureau 29 Hazen Drive P.O . Box 95 Concord, NH03302-0095 (603) 271-1370 Please address any correspondence and communication in reference to the ERCs or DERs to the following: Mr . Joe Fontaine NHDES, Air Resources Division Technical Services Bureau 29 Hazen Drive P.O . Box 95 Concord, NH03302-0095 (603) 271-6794 

# a Craig A . right, Assistant Director Department ofEnvironmental Services Air Resources Division

cc: Johnny Ray Evans, Hutchinson Sealing Systems, Inc Timothy Drew, PIP Office David Conroy, USEPA Town ofNewfields CAW/prn