#!HDES 

The State of New Hampshire 

Department of Environmental Services 

Thomas S. Burack, Commissioner 

July 30, 2015 

Mr. Curt Spalding, Administrator 

USEPA Region 1 

5 Post Office Square 

Suite 100 

Boston, MA 02109-3912 

Re: SIP Revision Proposal for VOC RACT Order No. ARD-96-00 1 

Textile Tapes Corporation 

104 Pickering Road, Gonic, NH 

Facility Identification #330170003 9, Application # 15-0005 

Dear Mr. Spalding: 

Pursuant to section 110 of the Clean Air Act and as Governor Maggie Hassan's designee, I 

hereby submit for your information a proposed revision to the State Implementation Plan (SIP). 

An electronic version of this submittal, which is an exact duplicate of the paper version, is 

enclosed on a disk. This revision involves administrative changes of a Volatile Organic 

Compound (VOC) Reasonably Available Control Technology (RACT) Order in accordance with 

the revised New Hampshire Code of Administrative Rules, Env-A 1207.03, Emission Rate 

Limits for Coating of Paper, Fabric, Film and Foil Substrates (formerly Env-A 1204.10), to 

Textile Tapes Corporation for its facility in Gonic, New Hampshire. 

Textile Tapes filed a "Reasonably Available Control Technology (RACT) Statement" on March 

15, 1993. Based on this application, the New Hampshire Department of Environmental Services, 

Air Resources Division (DES) issued a VOC RACT Order on June 28, 1996. On March 10, 

1998, the United States Environmental Protection Agency (USEPA) approved the Order into the 

NH SIP. On March 5, 1998, prior to the issuance of the approved Order by USEPA, DES 

received a request from Textile Tapes for a revision to the Order. On October 1, 1998, DES 

submitted the amended Order to USEPA as a SIP revision. On February 19, 2002, Textile Tapes 

requested the second modification of the Order to include the recuperative thermal oxidizer 

(RTO). On March 27, 2002, DES received comments from the EPA on the proposed February 

19, 2002 modification to the Order. EPA asked DES to withdraw the previous Textile Tapes SIP 

submittal dated October 1, 1998 and state in the new SIP submittal that the revised Order 

supersedes the previous orders. On December 28, 2006, DES received applications from Textile 

Tapes to amend the Order and the Permit to allow Textile Tapes to use discrete emissions 

reductions (DERs) to comply with VOC RACT and to generate DERs in the future through the 

operation of the RTO. On August 10, 2007, the Order was amended and sent to EPA as a 

revised SIP submittal. 

www.des.nh.gov 

29 Hazen Drive • P0 Box 95 • Concord NH 03302 0095 D. 

(603) 271-3503 TDD Access: Relay NH 1-800-735-2964 
Curt Spaulding, Administrator July30, 2015 

USEPA, Region 1 

On August 3, 2012, Textile Tapes submitted an application, requesting an amendment to 

the minimum temperature requirement for Textile Tapes RTO in RACT Order ARD-96-00 1. 

Specifically, the minimum temperature would be determined based on the most reáent stack test 

results. Textiles Tapes proposed retaining the destruction efficiency requirement of 95%, to be 

demonstrated through periodic stack testing. On November 16, 2012, the Order was amended 

and sent to EPA as a revised SIP submittal. 

This proposed SIP revision supersedes all previous SIP revision proposals submitted for 

this VOC RACT Order and includes the following documentation: 

• A copy of the public notice published on June 24, 2015; 

• Proposed VOC RACT Order letter dated June 24, 2015; 

• Final RACT Order issuance letter dated July 30, 2015; 

• Final RACT Order ARD-96-001 issued on July 30, 2015; and 

• Temporary Permit to Operate TP-0165 issued on July 30, 2015. 

Since the last SIP revision submittal on November 16, 2012, the most recent VOC RACT Order 

has changed as follows: 

The facility-wide VOC emissions limit has been changed from 63.8 tons to 24.9 tons, on a 

12-month rolling basis. 

• The VOC RACT citations have been updated to reflect the current rule. 

Technical support documents are not included in this submittal since the amendments to 

the RACT Order will not result in any increased emissions. The amendments will result in a 

decrease in the facility's potential emissions. 

Should you require further information, please contact Barbara DorfSchmidt of the Air 

Resources Division, Permitting and Environmental Health Bureau at (603) 271-6796 or via email at barbara.dorfschmidtdes.nh.gov. 

Sincerely, 

Craig A. Wright 

Director 

Air Resources Division 

CAW/bdd 

Enclosures 

cc: David Conroy, USEPA 

City Clerk - Rochester NH 

John Simmers - Textile Tapes Corp. VP 

Tim Donnelly - POWER Engineers, Inc. 

Ida McDonnell —USEPA 

All w/enclosures 
STATE OF NEW HAMPSHIRE 

DEPARTMENT OF ENVIRONMENTAL SERVICES 

AIR RESOURCES DIVISION 

CONCORD, NEW HAMPSHIRE 

NOTICE OF PERMIT AND VOC RACT ORDER REVIEW, OPPORTUNITY FOR 

PUBLIC HEARING AND COMMENT PERIOD 

Pursuant to the New Hampshire Code of Administrative Rules, Env-A 621.02, and Env-A 

1205.05, notice is hereby given that the Director of the New Hampshire Department of 

Environmental Services, Air Resources Division (Director), has received an application(s) for a 

state permit to operate (draft permit) and VOC RACT order (draft order) from, and based on the 

information received to date, intends to issue such permit and order to: 

Textile Tapes Corporation 

104 Pickering Road 

Gonic, New Hampshire 

For the Following Devices: 

Coating Operations 

The current VOC RACT Order is being amended to limit facility wide volatile organic 

compound emissions to 24.9 tons/year. The application and draft permit are on file with the 

Director, New Hampshire Department of Environmental Services, Air Resources Division, 29 

Ha.zen Drive, P.O. Box 95, Concord, NH 03302-0095, (603) 271-1370. Information may be 

reviewed at the office during working hours from 8 .a.m. to 4 p.m., Monday through Friday. The 

draft Order and draft permit can be acèessed electronically through the One-Stop Data and 

Information portal at http://www.des.nh.gov . Additional information may also be obtained by 

contacting Barbara Dorfschmidt at the above address and phone number. 

Requests for a public hearing must specify whether the request is for the draft permit, 

draft Order, or both, and be received by the Director no later Friday, July 24, 2015. A hearing 

request for the draft permit must be filed in accordance with Env-A 621.06. Written 

comments on the draft permit and/or draft Order received no later than Friday, July 24, 2015, 

shall be considered by the Director in making a final decision. 

Craig A. Wright 

Director 

Air Resources Division 
WRHDES 

== 

The State of New Hampshire 

Department of Environmental Services 

Thomas S. Burack, Commissioner 

June 24,2015 

Mr. John Simmers 

Vice President 

Textile Tapes Corporation 

104 Pickering Road 

Rochester, NH 03867-4604 

Re: Draft Permit and Proposed Amended VOC RACT Order 

Textile-Tapes Corporation 

104 Pickering Road, Rochester, New Hampshire 

Facility Identification # 3301700039, Application # 14-0456 and 15-0005 

Dear Mr. Simmers: 

The New Hampshire Department of Environmental Services, Air Resources Division ( 1 DES'), has prepared a 

draft permit for the device noted below. DES is also issuing a proposed amendment to RACT Order, ARD-96-00 1. A 

public notice on the draft permit and proposed order will be published in the New Hampshire Union Leader and the 

Foster 's Daily Democrat. 

Devices Application Date Notice Date Close of Comment Period 

Two Coating Lines November 5, 2014 June 24, 2015 July 24, 2015 

A copy of the draft permit, proposed RACT Order and public notice are enclosed. In accordance with the New 

Hampshire Code of Administrative Rules, Env-A 621.05, NotUlcation to EPA and Env-A 1205.04, Final Determinations 

Regarding Sufficiency; Proposed VOC RAC7' Orders, we are foi-warding a copy of the draftpennit, proposed order and 

public notice to the United States Environmental Protection Agency (USEA) for their review. A copy of the enclosed 

documents is also being sent to the City of Rochester for their review. 

Comments must be received by DES by the close of the comment period. If you have any questions regarding 

this permit and RACT Order, please contact me at (603) 271-6796 or via e-mail at barbara.dorfschmidtdes.nh.gov. 

Operating Permits Program Manager 

Permitting & Environmental Health Bureau 

By cerqfied mall # 7011 3500 0001 0292 6797 

Enclosures: Draft Permit, Application Review Summary, Proposed RACT Order and Public Notice 

cc: Donald Dahi, US EPA Region I (via e-mail) 

Robert McConnell, US EPA Region I (via e-mail) 

Tim Donnelly, Power Engineering (via e-mail) 

City of Rochester 

ç1y / 

www.des.nh.gov , 

29 Hazen Drive • P0 Box 95 • Concord, NH 03302-0095 j j Ji 

(603) 271-3503 • TDD Access: Relay NH 1-800-735-2964 
The State of New Hampshire 

MH DEPARTMENT OF ENVIRONMENTAL SERVICES 

~~DES 

Thomas S. Burack, Commissioner 

July 30, 2015 

Mr. John Simmers 

Vice President 

Textile Tapes Corporation 

104 Pickering Road 

Rochester, NH 03 867-4604 

Re: Amended Volatile Organic Compound (VOC) Reasonably Available Control Technology 

(RACT) Order ARD-96-001 

Textile Tapes Corporation, 104 Pickering Road, Gonic, NH 

Facility Identification #3301700039, Application #15-0005 

Dear Mr. Simmers: 

Please find enclosed the Amended VOC RACT Order (Order)issued by the New Hampshire 

Department of Environmental Services, Air Resources Division (DES), to Textile Tapes Corporation, 

located in Gonic, NH. The final Order is being issued in accordance with the New Hampshire Code of 

Administrative Rules Env-A 1205, RACT Procedures. 

On November 5, 2014, Textile Tapes Corporation submitted an application requesting that the 

facility be reclassified as a synthetic minor source for VOCs. The source requested a VOC cap of 24.9 

tons/year which also allows the source to opt out of the new VOC RACT limits which become effective 

on January 1, 2016. The emissions limit contained in Condition D.1.e. of the Order has been reduced 

from 63.8 tons/year to 24.9 tons/year. 

If you have any questions, please contact Barbara Dorfschmidt of the Air Resources Division, 

Permitting and Environmental Health Bureau at (603) 271-6796 or via e-mail at 

barbara.dorfschmidtdes.nh.gov . 

Sincerely, 

4 a4~~_ -~ Z 

Craig X. Wright 

Director 

Air Resources Division 

caw/bdd 

By certfled mail #7011 3500 0001 0293 1838 

Enclosure: Final RACT Order ARD-96-001 

cc: David Conroy, USEPA 

City of Rochester 

Timothy Donnelly, POWER Engineers, Inc. 

DES Web site: www.des.nh.gov 

P.O. Box 95, 29 Hazen Drive, Concord, New Hampshire 03302-0095 

Telephone: (603) 271-1370 • Fax: (603) 271-1381 • TDD Access: Relay NH 1-800-735-2964 
Textile Tapes Corporation ] FINAL RACT ORDER IS SUED 

104 Piôkering Road ] DEC1MBER 9, 1996 

Gonic, NH 03839 ] ARD-96-001 

] AMENDED AUGUST 10, 2007 

AMENDED NOVEMBER 16, 2012 

AMENDED July 30, 2015 

A. Introduction 

This proposed revised RACT Order is issued by the New Hampshire Department of Environmental 

Services, Air Resources Division, to Textile Tapes Corporation, pursuant to RSA 125-C. 

B. 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, telephone number (603) 271-1370. 

Textile Tapes Corporation ("Textile Tapes") is a New Hampshire corporation, having a mailing 

address of 104 Pickering Road, Rochester, NH 03867-4604, telephone number (603) 332-5816. 

C. Statements of Fact and Law 

1. Textile Tapes owns and operates the following processes located at its Gonic Plant at 104 

Pickering Road in Gonic, NH ("the Facility"): 

Line 1A, Fabric Coating Line (removed in 1999); 

Line 1B, Fabric Coating Line; 

Line 1C, Hot Melt Coating Line (installed in 1993). 

2. Textile Tapes reported to DES that 1990 total VOC emissions were 90 tons and noted that the 

facility was operated by a company other than Textile Tapes in 1990. 

3. Textile Tapes filed a "Reasonably Available Control Technology (RACT) Statement" on March 

15, 1993 for the facility. 

4. DES issued a Letter of Insufficiency dated May 19, 1993. 

5. Textile Tapes filed a VOC RACT compliance schedule, in response to DES's Letter of 

Insufficiency, on June 10, 1993 as amendment to the March 15, 1993 submittal. 

6. Textile Tapes initially, in letters dated March 15, 1993 and June 10, 1993, proposed the 

following measures as RACT: 

a. For Line 1A, Line 113, and Line 1C (with the exception stated in part C.6.b below) comply 

with the provisions of Env-A 1204.10, Applicability Criteria and Compliance Standards for 

Coating of Paper, Fabric, Film and Foil Substrates, which limits the emission rate of VOC 
Amended VOC RACT Order ARD-96-001 July30. 2015 

Textile Tapes Corporation Page 2 .01- 11 

at all times to 2.9 lb/gallon of coating; as applied, excluding water and exempt compounds; 

and 

b. For the coating described as "5000 series adhesive" utilized on Line 1A and lB: 

Reformulate the "5000 series adhesive" to comply with the emissions limitation in part 

C.6.a., above; or 

Install a thermal oxidizer to control VOC emissions equivalent to the emissions 

limitation in part C.6.a.; or 

Subcontract all coatings activities, which would result in emission rates exceeding the 

emission limitation in part C.6.a. 

7. DES issued a letter on February 8, 1995 requesting an updated VOC RACT plan. 

8. Textile Tapes filed further revisions to update its VOC RACT plan as requested by DES on 

February 24, 1995. 

9. Effective August 19, 1995, DES re-adopted Rule Env-A 1204 Stationary Sources of Volatile 

Organic Compounds (VOCs) with amendments. 

10. Textile Tapes filed an evaluation of RACT control options and an application for a RACT order 

pursuant to ENV-A 1204.05 on December 7, 1995. 

11. Textile Tapes ultimately proposed the following measures as RACT in its December 7, 1995 

application for RACT order: 

a. For Line 1A, Line 1B, and Line 1C (with the exception stated in part C.6.b) comply with the 

provisions of Env-A 1204.10, Applicability Criteria and Compliance Standards for Coating 

of Paper, Fabric, Film and Foil Substrates, which limits the emissions rate of VOC at all 

times to 2.91b VOC/gallon of coating; as applied, excluding water and exempt compounds; 

b. For the coating described as "5000 series adhesive," utilized on Line 1A and 113: 

Increase solids content of "5000 series adhesive" from 33% by weight to 40% by weight; 

and 

Limit the emission rate of VOC resulting from the application of the "5000 series 

adhesive" at all times to 4.7 lb VOC/gallon of coating, as applied, less water and exempt 

compounds; 

c. Limit facility-wide VOC emissions to 70 tons, on a 12-month rolling basis; and 

d. File annual reports detailing efforts to meet emission limitation inC.11.a. for all coatings. 

12. On June 28, 1996, DES received Textile Tapes' application for a Title V Permit as required 

by Env-A 609. The application included a request to include the limits specified by the VOC 

RACT Order in the Title V permit once issued. 

13. DES issued a RACT Order ARD-96-001 ("The Order") on December 9, 1996. 

14. On March 5, 1998, DES received Textile Tapes' request for a modification to the Order issued 

December 9, 1996 to include a provision for the use of a generic release coating on line 1 C, 

which was not addressed in the original Order. 
Amended VOC RACT Order ARD-96-001 July 30. 2015 

Textile Tapes Corporation - Page 3 of 11 

15. On March 10, 1998, The United States Environmental Protection Agency ("EPA") approved the 

Order into the New Hampshire State Implementation Plan ("SIP"). 

16 DES issued an amended'Order on September 8, 1998. 

17. On October 1, 1998, DES submitted the amended Order to EPA as a SIP revision. 

18. On September 24, 1999, Textile Tapes submitted an application for installation of the 

recuperative thermal oxidizer ("RTO") and dryer replacement on coating line lB. Coating line 

1A was eliminated. 

19. On January 18, 2000, Temporary Permit TP-BP-65 1 was issued to Textile Tapes for the RTO 

oncoating line lB. 

20. On February 19, 2002, Textile Tapes requested the second modification of the Order to include 

the RTO. 

21. On March 27, 2002, DES received comments from the EPA on the proposed February 19, 

2002 modification to the Order. EPA asked DES to withdraw the previous Textile Tapes SIP 

submittal dated October 1, 1998 and state in the new SIP submittal that the revised Order 

supersedes the previous orders. 

22. On April 23, 2002, DES submitted the revised Order as a revision to the SIP; EPA deemed the 

submittal complete on May 28, 2002. 

23. Effective December 31, 2002, DES re-adopted Rule Env-A1204, Stationary Sources of Volatile 

Organic Compounds (VOCs) with amendments. 

24. On or about September25, 2006, Textile Tapes notified DES via phone and email of a 

potential business opportunity to coat product with a new coating known as Chemlok TS3320-

19 Primer ("Chemlok"). The new coating exceeds the 2.9 lb/gal VOC standard required by 

Env-A 1204.10 (c) and the Order. 

25. Textile Tapes indicated to DES that the new coating can not be applied on the RTO-controlled 

Line lB due to physical properties of the non-compliant Chemlok coating. DES directed 

Textile Tapes to: 

Purchase Discrete Emissions Reduction ("DER") credits as described in Env-A 3100 for the 

excess emissions generated by applying the non-compliant Chemlok coating; 

Modify the Order to allow the application of non-compliant Chemlok coating on Line 1 C; 

and 

Modify Title V Permit TV-OP-009 ("the Permit") to include the application of noncompliant Chemlok coating on Line 1C. 

26. On October 24, 2006, in accordance with Env-A 3104.08, MacMillan & Donnelly, Inc. 

("M&D") submitted a "Notice of Intent to Use Discrete Emission Reduction Credits" for the 

period of October 25, 2006 to December 31, 2007, on behalf of Textile Tapes, for the predicted 

generation of excess emissions when using the non-compliant Chemlok coating on Line 1C. 

27. M&D estimated the excess emissions from the non-complaint Chemlok coating to be 

approximately 3.6 tons per year. 
Amended VOC RACT Order ARD-96-001 July 30. 2015 

Textile Tapes ,Corporation Page 4 of 11 

Textile Tapes provided the purchase contract from Public Service of New Hampshire 

("PSNH"), dated October 3, 2006, documenting the purchase of a total of 4 DER credits (2 

ozofle season credits and 2 non-ozone season), the serial numbers, and associated cost of the 

credits. 

Textile Tapes began applying the non-compliant Chemlok coating on Line 1C on October 25, 

2006. 

On December 28, 2006, DES received applications from Textile Tapes to amend the Order and 

the Permit to allow Textile Tapes to use DERs to comply with VOC RACT and to generate 

DERs in the future through the operation of the RTO. 

On January 17, 2007, Textile Tapes entered into Administrative Order by Consent No. AO 

ARD 07-003 with DES, allowing Textile Tapes to use DERs until such time as the Order and 

Permit are modified. 

On August 10, 2007, DES issued an amended RACT Order which allowed for the use of DERs. 

On May 6, 2011, Textile Tapes submitted an application to replace the existing RTO with a 

new RTO. Temporary Permit, TP-0086, was issued on July 8, 2011 for the installation of a 3.0 

MMBtu/hr natural gas fired TANN Lanbein Engelbracht America Regenerative Thermal 

Oxidizer. 

On October 5, 2011, Textile Tapes conducted stack testing on the RTO. The RTO 

demonstrated compliance with the 95% destruction efficiency at 1568 OF which is higher than 

the temperature listed in RACT Order ARD-96-001 last issued on August 10, 2007 of 1250 °F. 

On August 3, 2012, Textile Tapes submitted an application, requesting an amendment to link 

the minimum temperature requirement to stack test conditions for the Textile Tapes RTO in 

RACT Order ARD-96-001. Textiles Tapes proposed to maintain the destruction efficiency 

requirement of 95% which would be demonstrated through periodic stack testing. 

On November 16, 2012, ARD-96-001 was revised to replace the minimum temperature 

requirement of 1250 OF with the requirements that the RTO temperature will not drop below the 

average temperature at which the facility has demonstrated compliance through the most recent 

DES approved stack testing. 

Effective June 1, 2011, DES readopted Env-A 1200 (formerly Env-A 1204), with amendments. 

The RACT Order has been updated to reflect the readopted Env-A 1200. 

On November 5, 2014, Textile Tapes submitted a temporary permit application to limit facility 

wide VOC emissions to 24.9 tons per year. The purpose of the request was to limit VOCs 

emission to be below major source thresholds and to avoid the applicability of Env-A 

1207.03(b) and (c) under VOC RACT. 

D. Order 

Based on the above findings and determinations, DES hereby orders Textile Tapes to implement 

the following as RACT: 

a. For Line lB and Line 1C, when applying compliant coatings, (as defined in Env-A 1203.38) 

the Facility shall comply with the provisions of Env-A 1207.03(a), Applicability Criteria 

and Compliance Standards for Coating of Paper, Fabric, Film and Foil Substrates, which 
Amended VOCRACTOrderARD-96.-001 July 30. 2015 

Textile Tapes Corporation . . Page 5 of 11 

limits the emission rate of VOC, at all times, to 2.9 lb VOC/gallon of coating; as applied, 

excluding water and exempt compounds; 

b. For line 113, when applying non-compliant coatings, (as defined in Env-A 1203.52) the 

Facility shall demonstrate compliance with the provisions of Env-A 1207.03(a) as specified 

in D.1.a. above by: 

Venting all emissions from non-compliant coatings to the thermal oxidizer; or 

Using the daily weighted average procedure described as follows: 

"VOC" means the daily-weighted average VOC content of coatings, as applied, used 

on a given coating line, in units of pounds of VOC per gallon of coating, minus water 

and exempt compounds; 

"n" means the number of different coatings, as applied, used each day on a coating 

line; 

"V1" means the volume of the jth coating, as applied, used each day on a coating line, 

in units of gallons, minus water and exempt compounds; 

"C1" means the VOC content of the jth coating, as applied, used each day on a coating 

line in units of pounds of VOC per gallon of coating, minus water and exempt 

compound; 

"VT" means the total volume of all coating, as applied, used each day on a coating 

line in units of gallons, minus water and exempt compounds; and 

The "VOC" shall be equal to the sum, over the n coatings used on a given coating 

line, of the products of each V 1and C1, divided by VT, as in the following equation: 

(VICi) 

VOCw JL 

VT 

c. For Line 1 C, when applying non-compliant coatings other than generic release coatings, the 

Facility shall comply with the provisions of Env-A 1207.03(a) as specified in D. l.a. above 

either by: 

Using the daily weighted average procedure as described in D. 1 .b.ii. above; or 

Using generated or purchased DERs to offset excess emissions in accordance with 

Condition D.6; 

d. For any generic release coating utilized on Line 1 C, the Facility shall: 

Limit the emission rate of VOC resulting from the application of the generic release 

coating, at all times, to 5.9 lb VOC/gallon of coating applied, less water and exempt 

compounds; and 

Limit the facility-wide use of the generic release coating to less than 5 tons during any 

consecutive 12-month period; 

e. Limit facility-wide VOC emissions to 24.9 tns, on a 12-month rolling basis; and 
Amended VOC RACT Order ARD-96-001 July 30. 2015 

Textile Tapes Corporation . . . Page 6 of 11 

f. As part of the Annual Emissions Report submitted annually by April 15' of the following 

year, include information detailing efforts to meet the emission limitation in D. 1 .a. for a 

generic release coating including: 

A technical evaluation of each alternative coating considered and basis for acceptance or 

rejection; or 

A statement indicating that no coatings were evaluated during the time period covered by 

the report. 

2. Prior to the use of any new coating, Textile Tapes shall demonstrate compliance by one of the 

following options: 

a. Chemical manufacturers Material Safety Data Sheet (MSDS) information (density and 

weight percent VOC content) along with the Facility coating formulation recipe information 

(gallons of each ingredient, i.e. coatings, diluent solvent, and exempt diluent solvent; density 

of each ingredient; and weight percent VOC content of each ingredient). The Facility shall 

calculate the pounds VOC per gallon coating as applied, minus water and exempt 

compounds using the following formula: 

P*.x 

(1—Yw--Ye) 

Where: 

"P" means the density of the mixed coating as applied (pounds coating/gallon coating); 

means the weight fraction of VOC in the mixed coating; 

means the volume fraction of water in the mixed coating; and 

"Ye" means the volume fraction of exempt compounds in the mixed coating. 

When using this option, the Facility shall maintain the calculation sheets and records for each 

coating formulation; or 

b. The referee liquid VOC test method specified as follows: 

Method 24, 40 CFR part 60, Appendix A for all coatings as applicable using the 60-

minute bake time procedure; or 

Method 24A, 40 CFR Part 60, Appendix A as applicable. 

DES reserves the right to have the facility perform Method 24 testing on any coatings for 

formal demonstration of compliance. 

d. All Method 24 analyses and/or calculation sheets for new coatings shall be submitted in the 

annual VOC report. 

3. Textile Tapes is subject to Env-A 1207.03, Applicability Criteria and Compliance Standards for 

Coating of Paper, Fabric, Film and Foil Substrates and has chosen to comply with this section 

for its non-compliant coatings on Line lB by implementing an add-on control system as 

specified in D. 1 .b.i. Textile Tapes is required to comply with the more stringent of: 

a. A VOC emission reduction efficiency of 95%, as specified in D.4.a; 
Amended VOC RACT Order ARD-96-001 July 30. 2015 

Textile Tapes Corporation. . . Page 7 of 11 

b. An overall VOC emission reduction efficiency determined as follows: 

The VOC emission rate limit, when operating with the thermal oxidizer, shall be 

determined, on a solid basis, by the following equation in accordance with Env-A 

1205.01(d): 

Ec 

( d4 

Where: 

"S" means the VOC emission rate limit in terms of lbs VOC/gal of coating solids; 

"dA" means the actual density of VOC for converting the.emission limitation to a solids 

basis in lbs/gal. The Permittee has an option to use the density value of 7.36 lb/gal if 

running more than one coating; 

"E "means the emission rate limit prescribed for the applicable coating category. For 

those processes applying a coating to any woven or non-woven, fibrous or non- fibrous 

substrate, including paper, fabric, glass matting, plastic film, ribbon, and magnetic tapes, 

Ecshall be equal to 2.9 lbs VOC/gal of coating, as applied to the substrate; and 

The required overall emission reduction efficiency, E, shall be determined by the 

following equation: 

(VOCa—S" 

VOCaf 

Where: 

S = The VOC emission rate limit in terms of lbs VOC/gal of coating solids; 

VOCa= The maximum VOC content of the coatings used in lb VOC/gal solids or the daily 

weighted average VOC content of the coatings used in lb VOC/gal solids; or 

4. Textile Tapes shall perform the following monitoring and testing of the RTO: 

Minimum destruction efficiency for the RTO shall be at least 95% and the RTO combustion 

temperature shall not drop below the average temperature at which Textile Tapes has 

demonstrated compliance through the most recent DES approved stack testing with the 95% 

efficiency. 

Textile Tapes shall conduct compliance stack testing once every 5 years within 90 days of 

the anniversary of the previous stack test. For stack testing purposes only, Textile Tapes 

shall be allowed to operate at a lower temperature than identified in item 4.a above in an 

effort to demonstrate compliance with the RACT Order RTO 95% efficiency requirement. 

In the event that Textile Tapes does not meet the provisions of the RACT order during the 

stack test, then Textile Tapes shall be allowed to use DERs as described in item 5 below for 

RACT compliance during the stack testing period. 

The Facility shall maintain copies of compliance stack test records on site. These records 

shall be made available to DES/USEPA upon request. 
Amended VOC RA CT Order ARD-96-001 July 30. 2015 

Textile Tapes Corporation . . Page 8 of 14 

The combustion temperature of the RTO shall be monitored and recorded continuously. 

The Facility shall operatelow-temperature lockout,,a low temperature alarm, or a 

temperature chart which shall be examined at least once every 24 hours to ensure 

compliance with the minimum combustion temperature identified in item 4.a above. 

Records of all temperature monitoring shall be maintained at the facility for inspection for at 

least 5 years. 

Compliance with the monitoring requirement to reduce VOC emissions from the dryer 

exhaust by a minimum of 95% shall be demonstrated using the applicable procedure(s) 

described in Env-A 804, Volatile Organic Compound Testing, and in accordance with the 

Permit 

Textile Tapes shall be allowed to generate DERs for emission reductions that are achieved in 

excess of the reductions required in Part D.3 or the lowest applicable allowable emissions 

rate limit, as specified in Env-A 3103.02. 

5. Textile Tapes shall be allowed to use DERs for RACT compliance during times that it is unable 

to meet the maximum emission rate stated in Part D. l.a. The following calculations will be 

used to determine the amount of credits generated on a given day: 

Calculation of Allowable VOC Emissions per Day 

means the allowable VOC emission rate; 

"Epre" means the actual emission rate from line lB before entering the thermal oxidizer; 

"E" means the required overall reduction efficiency (expressed as a decimal) as determined 

in Part D.3; and 

"Eat" shall be calculated as in the following equation: 

Ea1 = Epre * (1E) 

Actual VOC Emissions per Day 

"Eac" means the actual VOC emission rate 

Emission Credit Generation Calculation 

Textile Tapes shall subtract the actual VOC emission rate (E ac) from the allowable VOC 

emission rate (Eai); 

Eai - Eac 

to determine if emission credits will be generated on a given day using the following 

criteria: 

If the result of the subtraction is a positive number, then the emissions are 

below the requirements of RACT and the amount equal to the difference 

between Eat and Eacwill count towards emission credits; 

Actual emission credits shall be calculated by taking the amount of credited 

emissions in part D.5.c.i and multiplying them by a safety factor of 0.9; and 

iii. In no instance should generated DERs plus Textile Tapes' actual emissions in 

any 12-month period exceed the annual VOC emissions limit stated in the 
Amended VOCRACT Order ARD-96-001 July 30. 2015 

Textile Tapes Corporation - - Page 9 of 11 

Permit. 

6. Textile Tapes shall be allowed to use generated or purchased DERs to comply with VOC RACT 

according to the following: 

Non-compliant coatings shall only be applied on Coating Line 1 C when there is a physical 

limitation preventing Textile Tapes from applying the coatings on Coating Line 1B; 

DERs shall only be used to achieve compliance when the RTO is out of service due to a 

malfunction or routine maintenance, or when a non-compliant coating must be applied on 

Coating Line 1 C; 

The amount of DERs required to achieve compliance shall be calculated according to the' 

following: 

i. The emission rate limit shall be determined on a solids basis, according to the equation 

in D.3.b.i. 

ii. The Allowable VOC Emissions per Coating shall be calculated for each coating as 

follows: 

"Eat" means the allowable VOC emission rate of a given coating in units of lb/month 

or kg/month; 

"S" means the VOC emission standard in terms of lb VOC/gal or kg VOC/l of 

coating solids, as calculated in item 6.c.i, above; 

"W" means the weight of coating or dilution solvent used in the coating line in units 

of pounds or kg; 

"D" means the density of the coating or dilution solvent in units of lb/gal coating, or 

kg/i coating as determined from Method 24 or 24A analysis; 

"Vs" means the volume fraction of the solids content of the coating, in units of gal 

solids/gal coating or 1 solids/i coating as determined by calculation using the 

formulation; and 

"Eat" shall be equal to the product of S, VS and W divided by D for each coating or 

dilution solvent used, as in the following equation: 

Eat = S's' Vs *(\J/]) 

iii. The Actual VOC Emissions per Coating shall be calculated for each coating as follows: 

"Eac" means the actual VOC emission rate of a given coating in units of pounds; 

"W" means the weight of coating or dilution solvent used in the coating line in units 

of pounds; 

"WV,,means the weight fraction of VOC content of the coating, in units of lb 

VOC/ib coating as determined by calculation using the formulation; and 

"Eac" shall be equal to the product of W and Wv, as in the following equation: 

Eac= W Wv 
Amended VOC RACT Order ARD-96-001 July 30. 2015 

Textile Tapes Corporation . . Page 10 of 11 

The Excess Emissions per Coating shall be equal to the difference between the actual 

VOC emissions (Eac) and the allowable VOC emissions (Eai). 

Excess Emissions = Eac- Eai 

At the time of use, Textile Tapes shall permanently retire ten percent of all DERs 

dedicated to that particular use, such that the amount of DERs required to demonstrate 

compliance shall equal the excess emissions calculated in item iv above divided by an 

environmental benefit factor of 0.9. 

7. Textile Tapes shall comply with recordkeeping requirements of Env-A 904.03, and Env-A 

904.07 for an add-on pollution control device, specifically the RTO. 

8. Annually by November 30, Textile Tapes shall submit a report to DES on the projected use of 

credits for the upcoming year. This report shall meet the requirements of Env-A 3104.08, 

Notice ofIntent to Use DERs, including the following information: 

The name and location of the user; 

A copy of the Notice and Certification of Generation submitted by the generator source to 

the State (for paperwork reduction purposes, a certified statement that the notice is on file 

with DES will suffice); 

The protocol used to document the amount of DERs needed to demonstrate compliance; and 

Information documenting that Textile Tapes is in compliance with Env-A 1400, Regulated 

Toxic Air Pollutants. 

9. Annually by April 15, Textile Tapes shall submit a report to DES on the balance of credits for 

the previous calendar year. This report shall meet the requirements of Env-A 3103.08, Notice 

and Certflcation of Generation and Env-A 3104.09, Notice and CertjfIcation of Use, including 

the following information: 

The name and location of the owner or operator of the source; 

A brief description of the generation activity; 

A list of the source's applicable allowable emission rates; 

The amount of DERs generated each month; 

A calculation of the amount of DERs generated; 

The amount of DERs used each month; 

A calculation of the amount of DERs required to demonstrate compliance with the emission 

limits stated above; 

A statement that the reductions were calculated in accordance with Env-A 3103.07; 

A statement that the DERs were not generated in whole or in part from actions prohibited 

pursuant to Env-A 3103.07; 

A statement that due diligence was made to verify that the DERs were not previously used, 
Amended VOC RACT Order ARD-96-001 July 30. 2015 

Textile Tapes Corporation Page 11 of 11 

and not generated as a result of actions prohibited under the regulations or other provisions 

of law; 

k. A statement that the DERs were not used in a manner prohibited under the regulations or 

other provisions of law; and 

1. A certification by a responsible official of truth, accuracy, and completeness that states: 

Based on information and belief formed after reasonable inquiry, the statements and 

information in the document are true, accurate, and complete; and 

The user source in compliance with all National Ambient Air Quality Standards, except 

ground level ozone, and all Ambient Air Limits for Regulated Toxic Air Pollutants. 

10. Textile Tapes shall comply with all terms and conditions contained in permits to be issued by 

DES. 

Please address any correspondence and communication in reference to this Order to: 

Air Permit Programs Manager 

Permitting & Environmental Health Bureau 

NHDES, Air Resources Division 

29 Hazen Drive., P.O. Box 95 

Concord, NH 03302-0095 

(603) 271-1370 

Please address any correspondence and communication in reference to the DERs to: 

Joseph T. Fontaine 

Technical Services Bureau 

NHDES, Air Resources Division 

29 Hazen Drive., P.O. Box 95 

Concord, NH 03302-0095 

(603) 271-6794 

4 ajz/ 

Craig A. Wright, Director 

Air Resources Division 

cc: Timothy Drew, PIP Office 

Anne Arnold, US EPA 

City of Rochester 

Tim Donnelly, Power Engineers, Inc. 
State of New Hampshire 

Department of Environmental Services 

Air Resources Division 

Temporary Permit 

Permit No: TP-0 165 

Date Issued: July 30, 2015 

This certifies that: 

Textile Tapes Corporation 

104 Pickering Road 

Rochester, NH 03867-4604 

has been granted a Temporary Permit for: 

Two Coating Lines 

at the following facility and location: 

Textile Tapes Corporation 

104 Pickering Road 

Rochester, NH 03867-4604 

Facility ID No: 3301700039 

Application No: 14-0456, received November 5, 2014 a request for a Synthetic Minor Source Permit, 

Temporary Permit Application 

which includes devices that emit air pollutants into the ambient air as set forth in the permit application 

referenced above which was filed with the New Hampshire Department of Environmental Services, Air 

Resources Division (Division) in accordance with RSA 125-C of the New Hampshire Laws. Request for 

permit renewal must be received by the Division at least 90 days prior to expiration of this permit and 

must be accompanied by the appropriate permit application forms. 

This permit is valid upon issuance and expires on January 31, 2017. 

DIb 

Air Resources Division 
TP-0165 Page2of2O 

Textile Tapes Corporation 

Abbreviations and Acronyms 

AAL, Ambient Air Limit 

acf actual cubic foot 

ags above ground surface 

ASTM American Society of Testing and Materials 

Btu British thermal units 

CAS Chemical Abstracts Service 

cfm cubic feet per minute 

CFR Code of Federal Regulations 

CO Carbon Monoxide 

DER Discrete Emission Reduction 

DES New Hampshire Department of Environmental Services 

Env-A New Hampshire Code of Administrative Rules - Air Related Programs 

ERC Emission Reduction Credit 

ft foot or feet 

ft3 cubic feet 

gal gallon 

HAP Hazardous Air Pollutant 

hp horsepower 

hr hour 

kW kilowatt 

lb pound 

LPG Liquified Petroleum Gas 

MM million 

MSDS Material Safety Data Sheet 

MW megawatt 

NAAQS National Ambient Air Quality Standard 

NG Natural Gas 

NOx Oxides of Nitrogen 

NSPS New Source Performance Standard 

PM10 Particulate Matter < 10 microns 

ppm parts per million 

psi pounds per square inch 

RACT Reasonably Available Control Technology 

RSA Revised Statutes Annotated 

RTAP Regulated Toxic Air Pollutant 

scf standard cubic foot 

S02 Sulfur Dioxide 

TSP Total Suspended Particulate 

tpy tons per consecutive 12-month period 

USEPA United States Environmental Protection Agency 

VOC Volatile Organic Compound 
TP-0165 Page 3 of 20 

Textile Tapes Corporation 

Facility Description 

Textile Tapes Corporation (TTC) operates a substrate coating facility in Gonic, New Hampshire. 

The plant operates two coating lines, lB and iC, which coat woven and non-woven materials 

with adhesive in the production of tapes and coated products. TTC utilizes the knife coating 

process in the coating lines. Coating Line 1 B vents its emissions from the dryer, associated with 

the coating line, to the regenerative thermal oxidizer (RTO). Coating Line 1 C utilizes hot melt 

technology which coats a backing material without the heat curing step. The facility has 

requested a cap of 25 tons/year for VOC emissions. The facility is a synthetic minor source for 

VOCs and HAPs. This Temporary Permit supersedes all the conditions of Title V Permit TV0009 which was issued on May 22, 2014: TV-0009 will be terminated upon issuance of this 

Temporary Permit. 

Emission Unit Identification 

This permit covers the devices identified in Table 1: 

Table I - Significant Activities 

Emission I)escription of Emissioii installation . 

( II) Uiiit Dale M axini urn 1)esign C apacilv 

EUO1 Coating Line lB Prior to The solvent application rate for nonNatural Gas Dryer 1979 compliant coatings shall not exceed 

1 .5MMBtuthr 500 pounds per hour. 

EU02 Coating Line 1 C 1993 VOC emissions from generic release 

coating shall be limited to less than 

5 tons/yr during any consecutive 12 

month period. 

Stack Criteria 

A. The following devices at the Facility shall have exhaust stacks that discharge vertically, 

without obstruction, and meet the criteria in Table 2: 

Table 2 - Stack Criteria 

Millillmill II eight 

I . 

I Maximum Exit 

't uk # I iflisslOil unit # (fct 1i)O\ t gr otind Di iniitu (ft) 

ui! 1e) 

Stack 1 1 EUO1/PCEO1 1 35.0 2.85 

Stack 2 EU02 23.5 0.92 x 1.29 (width 

x length) 
TP-0165 Page 4 of 20 

Textile Tapes Corporation 

Pollution Control Equipment Identification 

Air pollution control equipment listed in Table 3 shall be operated at all times that the associated 

device is processing non-compliant coatings in order to meet permit conditions. 

laJ)le 3 - PolJLllion (ontro1 Etjniptiieiit Idenl ilication 

1o11ution 1)escripl ion Pu rJ)OSC 1T1iiission Jiiii 

(Toni i'ol C() fl tJ() I led 

lt(111i1)lIlCflt 11) 

PCEO1 Regenerative Thermal Oxidizer Control of VOCs EUO1 

(RTO) 

TANN Langbein Engelbracht 

America 

3.0 MMBtu/hr Natural Gas fired 

burner 

Model No.: TR-1090 

Installed August 2011 

Operating and Emission Limitations 

A. The Owner or Operator shall be subject to the operating and emission limitations identified 

in Table 4: 

Tabk 4 - Operating and Emission Limitations 

A p p11 cal) Ic 

Ite m lquit em€nt 1 mission Regulators Basis 

U hit 

Facility-Wide Emission Limitation Facility Wide Env-A 604.02(a)(1) 

Facility-wide emissions of VOC shall be limited to less & 

than 25 tpy 1 . Env-A 1207 

2 Facility-Wide HAP Emission Limitation Facility Wide Env-A 604.02(a)(1) 

Facility-wide emissions of Hazardous Air Pollutants 

(HAPs, as defined in Section 112 of the 1990 Clean Air 

Act Amendments) shall be limited to less than 10 tpy 

for any individual HAP and 25 tpy for all HAPs 

combined2. 

The Facility has the potential to emit VOCs at levels greater than the major source threshold for this pollutant of 50 

tpy. The annual emission limit is less than this threshold and establishes the Facility as a synthetic minor source of air 

pollution for VOCs. In addition, the annual limit in Table 4, Item 1 is less than the threshold stated in Env-A 

1207.03(c) and allows the source to opt out of the VOC emission limits stated in Table 1207-1. 

2 The Facility has the potential to emit RAPs at levels greater than the major source threshold for these pollutants 25 tpy 

for total HAPs and 10 tpy for any individual HAP. The annual emission limits in Table 4, Item 2 are less than these 

thresholds and establish the Facility as a synthetic minor source of air pollution for HAPs. The Facility does not have 

the potential to emit the criteria pollutants NOx, SO 2, CO and PM at levels greater than the major source thresholds 

for these pollutants. Therefore the Facility is a true minor source for NOx, SO 2, CO, and PM 
TP-0165 Page5of2O 

Textile Tapes Corporation 

Table 4 - Operating and Lmisioji Limitations 

Applicalile 

Item # Requirement Lmission Regulatory Basis 

lTnht 

3 24-hour and Annual Ambient Air Limit Facility Wide Env-A 1400 

The emissions of any Regulated Toxic Air Pollutant (State-only 

(RTAP) shall not cause an exceedance of its associated Enforceable Limit) 

24-hour or annual Ambient Air Limit (AAL) as set forth 

in Env-A 1450.01, Table Containing the List Naming . 

All Regulated Toxic Air Pollutants. 

4 Revisions of the List ofRTAPs Facility Wide Env-A 1404.02 

In accordance with RSA 1254:5 IV, if the Division (State-only 

revises the list of RTAPs or their respective AALs or Enforceable Limit) 

classifications under RSA 125-1:4, II and III, and as a 

result of such revision the Owner or Operator is 

required to obtain or modify the permit under the 

provisions of RSA 125-I or RSA 125-C, the Owner or 

Operator shall have 90 days following publication of 

notice of such final revision in the New Hampshire 

Rulemaking Register to file a complete application for 

such permit or permit modification. 

5 Visible Emission Standards EU01 & Env-A 2103.02 

The average opacity shall not exceed 20 percent for EU02 & 

any continuous 6-minute period. 3 Env-A 2102.03 

The owner or operator shall not cause or allow the 

emission of particulate matter to exceed the 

emission standards specified for "New Devices" 

listed in Env-A 2102.03 Table 2102-1. 

6 Emission Rate Limits for Coating of Paper, Fabric, EU01 & Env-A 1207.03 

Film and Foil Substrates EU02 

The coating operation shall be equipped with an RTO 

and shall be limited to an emission rate of 0.35 kg 

VOC/l, equivalent to 2.9 lb VOC/gallon, of coating, as 

applied, excluding water and exempt compounds. 

Compliance with visible emission limitations shall be determined using 40 CFR 60, Appendix A, Method 9, or other 

Division approved method, upon request by the Division. 
TP-0165 Page6of2o 

Textile Tapes Corporation : 

laI)Ic 1 - Opraiiiig and Fin ision I iinith1ions 

1)j)1icaJ)Ie 

I tcifl # Req(jii'cinent 1niission Regulaltu- Basis 

Iliiit 

7 Applicability Criteria and Compliance Standards for EU01 & Env-A 1207.02 

Coating of Paper, Fabric, Film and Foil Substrates EU02 

A coating operation that uses VOC-containing cleaning 

materials shall control VOC emissions from the 

cleaning materials using the following work practices: 

Storing VOC-containing cleaning materials in closed 

containers; 

Keeping mixing and storage containers closed at all 

times except when depositing or removing VOCcontaining materials; 

Minimizing spills of VOC-containing cleaning 

materials; 

Conveying VOC-containing cleaning materials from 

one location to another in closed containers or pipes; 

and 

Minimizing VOC emissions from the cleaning of 

storage, mixing, and conveying equipment. 

8. Pollution Control Equipment Operation and PCE01 Env-A 604.01, Env-A 

Maintenance 810 

RTO shall be operated whenever the non-compliant & 

coatings are run on Line lB. RACT Order 

The minimum destruction efficiency shall be at least ARD-96-001 

95%; Amended July XX, 

The RTO combustion temperature shall not drop 2015 

below the hourly average temperature at which TTC 

has demonstrated compliance with 95% destruction 

efficiency during the most recent DES-approved 

stack test; 

The combustion temperature of the RTO shall be 

monitored and recorded continuously. 

Bypassing of the RTO shall be monitored and 

recorded. 

RTO shall be maintained in a manner consistent 

with manufacturer's recommendations, and the 

Monitoring Plan per Table 7, Item 11. 

The Facility shall operate low-temperature lockout, 

a low temperature alarm, or a temperature chart 

which shall be examined at least once every 24 

hours to ensure compliance with the combustion 

temperature identified in Table 5, Item 5(c) above. 

Records of all temperature monitoring shall be 

maintained at the facility for inspection for at least 5 

years. 
TP-0165 Page7of2o 

Textile Tapes Corporation 

Tabk 4 - O)cra1itIg and Emission Limitations 

Applicable 

Item # Requirement Emission ReguIaoiy Basis 

Unit 

9. Prior to the use of any new coating, TTC shall EU01 & RACT Order ARDdemonstrate compliance by one of the options below. If EU02 96-00 1 

the calculations below indicate that the new coating is Amended July XX, non-compliant, TTC shall operate the RTO to comply 2015 with the limits identified in Table 4, Item 6. 

a.) Chemical manufacturers Material Safety Data Sheet 

(MSDS) information (density and weight percent 

VOC content) along with the Facility coating 

formulation recipe information (gallons of each 

ingredient, i.e. coatings, diluent solvent, and exempt 

diluent solvent; density of each ingredient; and 

weight percent VOC content of each ingredient). 

The Facility shall calculate the pounds VOC per 

gallon coating as applied, minus water and exempt 

compounds using the following formula: 

F*x 

(l—Yw—ie) 

Where: 

"P" means the density of the mixed coating as applied 

(pounds coating/gallon coating); 

means the weight fraction of VOC in the mixed 

coating; 

means the volume fraction of water in the mixed 

coating; and 

"Ye" means the volume fraction of exempt compounds 

in the mixed coating. 

When using this option, the Facility shall maintain the 

calculation sheets and records for each coating 

formulation; or 

b.) The reference liquid VOC test method specified as 

follows: 

Method 24, 40 CFR part 60, Appendix A for all 

coatings as applicable using the 60-minute bake 

time procedure; or 

Method 24A, 40 CFR Part 60, Appendix A as 

applicable. 

c.) DES reserves the right to have the Facility perform 

Method 24 testing on any coatings for formal 

demonstration of compliance. 
TP-0165 Page8of2O 

Textile Tapes Corporation 

Tabk 4 - Operating and ImIssion Limiations 

I)I)IJcaJ) 1 e 

Itun # Ii(iu1I t. nn.nI I niission i'tgnI itory Bass 

I 'nit 

Applicability Criteria and Compliance Standards for EU01 & Env-A 1205.02(b) 

Coatins of Paper, Fabric, Film, and Foil Substrates EU02 

TTC shall be allowed to use, generate and purchase 

Discrete Emissions Reduction Credits (DER5) for the 

purpose of complying with the' requirements of VOC 

RACT pursuant to VOC RACT Order ARD-96-00 1, 

NSPS General Provisions EU01 & 40 CFR 60.11(d) 

At all times, including periods of startup, shutdown, EU02 

and malfunction, owners and operators shall, to the ' & 

extent practicable, maintain and operate any affected 40 CFR 60.11(g) 

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 Administrator 

which may include, but is not limited to, monitoring 

results, opacity observations, review of operating 

and maintenance procedures, and inspection of the 

source; 

For the purpose of submitting compliance 

certifications or establishing whether or not a person 

has violated or is in violation of any standard in this 

part, nothing in this part 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. 

VI. Monitoring and Testing Requirements 

The Owner or Operator is subject to the monitoring and testing requirements as contained in 

Table 5: 

IiI)Ie 5, - I\ionttoring an(I Iesliiig 1'C(1Uircfl1dntS 

1t,n P ii iinetet i1thod of C onipli 1114,1 Ft LqLiI.nt\ ppIit. ihk l'igiiI ttorv 

l'nit U isis 

To Be When conditions warrant, the Division Upon request Facility RSA 125- 

Determined may require the Owner or Operator to by the Wide C:6, XI 

conduct stack testing in accordance with Division 

USEPA or other Division approved 

methods. 
TP-0165 Page9of2O 

Textile Tapes Corporation 

Table 5 - Monitoring and Testing Requirements 

Item Parameter Mth eod of (_ omphance Frequency 

Applicable 

Unit 

Regulatory 

Basis 

2. VOC content Indication of VOC content of a coatin N/A EU01 & Env-A 

of coatings voc coating information based upon EU02 804.03 

supplier or stationary source 

formulation data shall be prima facie 

evidence of the actual VOC content of 

the coating. 

4 RTO Conduct a visual external integrity As needed, PCE01 RSA 125 

Preventative inspection of the RTO. but not less C:6, XI & 

Maintenance The inspection shall include an than annually RACT 

evaluation of whether all emissions Order ARDare being vented through the 96-00 1 

dedicated stack exit. Amended 

The inspection shall be conducted July XX, 

by personnel familiar with the 2015 

operation of the oxidizer and 

associated equipment 4 . 

Annual check for accuracy of RTO 

thermocouples. Replace 

thermocouples per manufacturer's 

recommendations. 

5 VOC Conduct emissions testing.to evaluate Within 5 PCE01 Env-A 804, 

Control compliance with the VOC control years of the Env-805, 

Efficiency efficiency requirement in Table 4 Item date of the & 

8(b). Testing shall be conducted in most recent RACT 

accordance with Table 5, Items 6, 7 and compliance Order ARD8. test 96-00 1 

Amended 

July XX, 

2015 

TIC currently contracts with a vendor to perform aimual inspection and maintenance. 
TP-0165 Page 10 of 20 

Textile Tapes Corporation 

Table 5 - Monitoring and Testing Rcquireiiients 

Item J) ara I\Iilhod of ( om ph iu1( 

-. I I pJ)Ift l)lt Rgril itor 

Ijilit Bisis 

6 Pretest Compliance testing shall be planned and Within 5 PCE01 Env-A 802, 

Protocol & carried out in accordance with the years of the Env-A 805, 

Test Report following schedule: date of the & 

A pre-test protocol shall be most recent PSACT 

submitted to the Division at least 30 compliance Order ARDdays prior to the commencement of test 96-00 1' 

testing; Amended 

The Owner or Operator and any July XX, 

contractor retained by the Owner or 2015 

Operator to conduct the test shall 

meet with a Division representative 

in person or by phone at least 15 

days prior to the test date to finalize 

the details of the testing; and 

A test report shall be submitted to 

the Division within 60 days after the 

completion of testing. 

7. VOC The following test methods, or Division Within 5 PCE01 Env-A 804, 

Control approved alternatives, shall be used: years of the Env-A 805, 

Efficiency USEPA Methods 1-4 for exit flow date of the & 

rate, percentage of carbon dioxide, most recent RACT 

oxygen and moisture; compliance Order ARDUSEPA Method 25 or 25A for total test 96-001 

non-methane VOCs. Amended Testing shall be performed at the July XX inlet and outlet of the RTO in order 2015 to determine the destruction 

efficiency of the device. 

USEPA Method 204 for capture 

efficiency. 
TP-0165 Page 11 of 20 

Textile Tapes Corporation 

Tahlc 5 - Moiiitoring and Testing Requirements 

Item Parameter - Method of ( oinpliance Frequency 

Applicable 

Unit 

Rcgulatoiy, 

Basis 

8. VOC During the compliance testing, the Within 5 PCE01 Env-A 802 

Control combustion chamber temperature shall years of the & 

Efficiency be recorded and the corresponding date of the RACT 

instantaneous and hourly average RTO most recent Order ARDbed temperatures shall be monitored and compliance 96-001 

recorded during the test. If the hourly test Amended 

average bed temperatures at which July XX, 

compliance is demonstrated during the 2015 

test are different than those specified in 

the previous compliance stack test, then 

the hourly average RTO chamber 

temperatures recorded during the test 

shall become the new operational limit 

for the RTO, as is specified in Table 4, 

Item 8(c). 

VII. Recordkeeping Requirements 

The Owner or Operator shall be subject to the recordkeeping requirements identified in Table 6: 

FaJ)Ie 6 - Iecordkeepiiig 1equireiiients 

1 teni . 1)ii rition/ AJ)j)IicaJ)le iegnlatoJ\ 

fl 

Requirement Frequency t'nit Basis 

Record Retention andAvailabilitv Retain for a Facility Env-A 902 

Keep the required records on file. These records shall minimum of Wide 

be available for review by the Division upon request. 5 years 

2 General RecordkeepiLig Requirements for Process Monthly EUO 1 & Env-A 

Operations EU02 903.02 

Maintain the following records for process operations: & 

Total quantity of raw materials containing VOCs or Env-A 

RTAPs; 903.03 

Hours of operation of each process; and 

Amount of fuel combusted in the dryer ovens 5 . 

The facility currently tracks and reports plant wide natural gas usage because there is no mechanism to calculate or measure 

natural gas usage in the dryer ovens. 
TP-0165 Page 12 of 20 

Textile Tapes Corporation 

lable ( - Recordkcepiiig Rcquiremculs 

Item Requirement 'Duration! Applicable Regulatory 

Frequency unit Basis 

3 VOC Emission Statements Recordkeeving Maintain EUO 1 & Env-A 904 

Requirements Data for EU02 

If the actual annual VOC emissions from all permitted Annual 

devices located at the Facility are greater than or equal Report 

to 10 tpy, then record the following information: 

a. Identification of each VOC-emitting process or 

device; 

b. The operating schedule during the high ozone 

season (June 1 through August 31) for each VOCemitting process or device identified in a. above, 

including: 

Typical hours of operation per day; and 

Typical days of operation per calendar month. 

c. The following VOC emission data from all VOCemitting processes or devices identified in Table 6, 

Item 3.a above, including: 

Actual monthly VOC emissions, in tons; 

Typical high ozone season day VOC emissions 

in pounds per day; and 

The emission factors and the origin of the 

emission factors used to calculate the VOC 

emissions. 
TP-0165 Page 13 of 20 

Textile Tapes Corporation 

Table ( - Recor(lkeeping Retiuirdnieiits 

Item Rcquireiiient l)uration/ Applicable Regulators 

l rcquency Unit Basis 

4 VOC Recordkeeping for Surface Coating and Printing Maintain EUO 1 & Env-A 

Operations Data for EU02 904.03 

Record the following information for each coating Annual 

operation subject to Env-A 1200: Report 

a. Coating formulation and analytical data, as follows: 

Supplier; 

Name and color; 

Type; 

Identification number; 

Density described as lb/gal; 

Total volatile content described as weight 

percent; 

Water content described as weight percent; 

Exempt solvent content described as weight 

percent; 

VOC content described as volume percent; 

Solids content described as volume percent; 

Diluent name and identification number; 

Diluent solvent density described in lb/gal; 

Diluent VOC content described as weight 

percent; 

Diluent exempt solvent content described as 

weight percent; 

Volume of diluent VOC described as gal; and 

Diluent/solvent ratio described as gal diluent 

solvent per gal coating. 

b. The number of gallons of each coating, including 

solvents and diluents, utilized during a typical high 

ozone season day; and 

c. Process information for a typical high ozone season 

day, including: 

Method of application; 

Number of coats; 

Drying method; and 

Substrate type and form. 

5 Format for Recording Information Maintain EUO 1 & Env-A 

The information recorded pursuant to Table 6, Item 4 Data for EU02 904.04 

shall be recorded on standard forms included in the Annual 

Recordkeeping Guidance Document for Surface Report 

Coating Operations and the Graphic Arts Industry, 

USEPA, July 1988, or alternative forms that contain all 

the data recorded pursuant to Table 6, Item 4. 
TP-0165 Page 14 of2O 

Textile Tapes Corporation 

laJile 6 - 1'ccor(1hceJ)ing Requircinctits 

item . I (Jil ii hut iii 

l)uration/ 

Ut tquni 

Apl)JlCal)le 

I Init 

Regulatory 

Basis 

6 ReRulated Toxic Air Pollutants Update Facility Env-A 

Maintain records documenting compliance with prior to Wide 902.01 

Env-A 1400. process State-only 

Compliance was demonstrated at the time of permit changes and Requiremen 

issuance as described in the Division's Application within 90 t 

Review Sunmiary for application 414-0456. The days of each 

source must update the compliance demonstration revision of 

using one of the methods provided in Env-A 1405 if: Env-A 1400 

There is a revision to the list of RTAPs lowering the 

AAL or Deminimis Value for any RTAP emitted 

from the Facility; 

The amount of any RTAP emitted is greater than the 

amount that was evaluated in the Application 

Review Summary (e.g., use of a coating will 

increase); 

An RTAP that was not evaluated in the Application 

Review Summary will be emitted (e.g., a new 

coating will be used); or 

Stack conditions (e.g. air flow rate) change. 

7 Additional Recordkeeping Requirements: Facilit'-wide Monthly Facility Env-A 906 

emission limitations Wide and Env-A 

Maintain a 12-month running total of Facility-wide 604.02(a)(3) 

emissions of VOC and HAPs, which shall include 

emissions from non-permitted devices, for the purpose 

of demonstrating that the total emissions of these 

pollutants are below the limits identified in Table 4, 

Items 1 and 2 respectively. 

8 NSPS RecordkeepiL7g Requirements for Polymeric Maintain EUO 1 & 40 CFR 

Coating of Supportin. Substrates current data EU02 60.744(b) 

Maintain the following records: Subpart 

Semiannual estimates of projected annual VOC to VVV 

be used for the manufacture of polymeric coated & 

substances; and 40 CFR 

Actual 12-month VOC used for the manufacture of 60.445(d) 

polymeric coated substances. Subpart RR 

Actual 12 month record of the amount of solvent 6 

applied in the coating at the facility. 

applied in the coating means all organic solvent contained in the adhesive, release, and precoat formulations that is 

metered into the coating applicator from the formulation area. 
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Textile Tapes Corporation 

IaI)Ie 6 - Rccordhecpng Requirements 

Iteni Req Ui renient Duration! Applicahk Regulatory 

Frequency 1 Tj( Basis 

10. The Facility shall maintain copies of compliance stack Maintain PCE01 RACT 

test records on site. These records shall be made up-to-date Order ARDavailable to DES/USEPA upon request. data 96-001 

The combustion temperature of the RTO shall be 

S Amended 

monitored and recorded continuously. July XX, 

Maintain records in accordance with the most 2015 

recent stack test conducted per Table 5, Items 5, 6, 

7, and 8. 

11. Maintain records of DER credits identified in RACT Maintain EUO 1 & RACT 

Order ARD-96-000 1. up-to- date EU02 Order ARDdata 96-00 1 

Amended 

July XX, 

2015 

12. Recordkeepin. for Sources or Devices with Add-on Maintain PCE01 Env-A 

VOC Air Pollution Control Equment. ________ ip up-to- date 904.07 

The owner or operator of any stationary source or data 

device with add-on VOC control equipment shall 

record and maintain the following information, as 

applicable: 

a) The air pollution control device identification 

number, type, model number, and manufacturer; 

b) Installation date; 

c) Process(es) or device(s) controlled; 

d) The type and location of the capture system, 

capture efficiency percentage, and method of 

determining capture efficiency; 

e) Information as to whether or not the control device 

is always in operation when the process(es) or 

device(s) are in operation; 

f) The destruction or removal efficiency of the add-on 

air pollution control equipment, including: 

Destruction or removal efficiency, in percent; 

Date tested; 

The emission test results, if tested, including: 

The inlet VOC concentration in ppm; 

The outlet VOC concentration in ppm; and 

The method of determination of the 

concentrations in 1) and 2) above; 

g) The method of determining destruction or removal 

efficiency, if not tested; and 

h) The design combustion temperature in degrees F. 
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Textile Tapes Corporation 

VIII. Reporting Requirements 

Pursuantto Env-C 203.02(b), Datq of Issuance or Filing, witten documents shall be 

deemed to have been filed with or received by the Division on the actual date of receipt by 

the Division, as evidenced by a date stamp placed on the document by the Division in the 

normal course of business. 

All emissions data submitted to the Division shall be available to the public. Claims of 

confidentiality for any other information required to be submitted to the Division pursuant 

to this permit shall be made at the time of submission in accordance with Env-A 103, 

Claims of Confidentiality. 

The Owner or Operator shall be subject to the reporting requirements identified in Table 7 

below. 

Tahlc 7 - Wportina Requirements 

IRm 

W(luirement Fi eqtiui\ 

Alicable pp 

Emission Rgti1 ilory 

Umt 

l3isis 

Annual Emissions Report Annually EU01 & Env-A 

Submit an annual emissions report which shall (received by DES EU02 907.01 

include the following information: no later than April 

Actual calendar year emissions from each 15th of the 

coating emission unit of VOCs, HAPs following year) 

(speciated by individual HAP), and RTAPs 

(speciated by individual RTAP); 

Actual calendar year emissions from the 

natural gas dryer ovens of NO N, CO, SO2, 

TSP, and VOCs 7; 

The methods used in calculating such 

emissions in accordance with 

Env-A 705.02, Determination ofActual 

Emissions for Use in Calculating EmissionBased Fees; and 

All information recorded in accordance 

with Table 6, Item 2. 

2 VOC Emission Statements Reporting Annually EUO 1 and Env-A 908 

Requirements (received by DES EU02 

If the actual annual VOC emissions from all no later than April 

permitted devices located at the Facility are 15th of the 

greater than or equal to 10 tpy, then include the following year) 

following information with the annual emission 

report: 

A breakdown of VOC emissions reported 

pursuant to Table 7, Item 1 by month; and 

All data recorded pursuant to Table 6, 

Item 3. 

The facility currently tracks and pays fees on facility wide natural gas usage. 
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Textile Tapes Corporation 

TaJ)Jc 7 - 1eporting Rec1nircmcnts 

Item Requirernen I Frequency 

App'icable 

Emission Regulatory 

Unit Basis 

Update to Air Pollution Dispersion Modelin,g As specified Facility- Env-A 

Impact Analysis wide 910.01 

If an update to the facility's air pollution 

dispersion modeling impact analysis is required 

pursuant to Env-A 606.02. Submit the 

information required pursuant to Env-A 606.04 

if a change triggers modeling analysis. 

Annually by April 15, TTC shall submit a Annually EU01 & RACT Order 

report to DES on the balance of credits for the (received by DES EU02 ARD-96-001 

previous calendar year. This report shall meet no later than April Amended 

the requirements listed in RACT Order ARD- 15th of the July XX, 

96-001. following year) 2015 

Site Specific MonitoriL7g Plan Within 30 days of PCE01 Env-A 

The Owner or Operator shall submit an updated any change to the 810.01 

air pollution control equipment monitoring plan plan 

within 30 days of any change to the plan for 

each piece of air pollution control equipment. 

The monitoring plan shall include: 

The type of control device; 

The manufacturer; 

The model and serial number (if known); 

The pollutant(s) controlled; 

A description of the control device and how 

it operates in the process; 

The capture efficiency of the device and its 

method of determination; 

The control efficiency of the device and its 

method of determination; 

The operational parameters of the devices 

that are or will be monitored, such as 

temperature, pressure, differential pressure, 

pH, and flowrate; 

The normal range for each parameter 

monitored, and the range of each parameter 

during startup or, shutdown conditions if 

different; 

A description of any data recording, 

parameter set points and alarms, and 

responses to malfunctions; and 

Recommended procedures for operation, 

service and maintenance of device. 
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Textile Tapes Corporation 

JaI)le 7 - 1f)rtiflg Requirement s 

Item -. 

AJ)J)IiCallJe 

RegiiIator Requi flu)ent I req u cucy L niis ion 

Init Basis 

Permit Deviation Reporting Requirements Within 24 hours of EUO1 & Env-A 

Report permit deviations that cause excess discovery of EU02 911.04(b) 

emissions in accordance with Condition IX.B. excess emission 

Emission Based Fees Annually EUO 1 & Env-A 700 

Pay emission-based fees in accordance with (received by DES EU02 

Condition XII. no later than April 

15th of the 

following_year) 

IX. Permit Deviation Reporting Requirements 

A. Env-A 101, Definitions: 

A permit deviation is any occurrence that results in an excursion from any emission 

limitation, operating condition, or work practice standard as specified in either a Title 

V permit, state permit to operate, temporary permit or general state permit issued by 

the Division. 

An excess emission is an air emission rate that exceeds any applicable emission 

limitation. 

B. Env-A 911.04, Reporting Requirements: In the event of a permit deviation that causes 

excess emissions, or for pollution control equipment monitoring parameter excursions 

lasting more than 48 hours in duration: 

Notify the department of the permit deviation and excess emissions by telephone (603-

271-1370), fax (603-271-7053) or e-mail (pdeviationsdes.nh.gov ), within 24 hours of 

discovery of the permit deviation, unless it is a Saturday, Sunday, or state legal 

holiday, in which event, the department shall be notified on the next day which is not a 

Saturday, Sunday, or state legal holiday. 

Submit a written report of the deviation on paper or by electronic means to the 

department within 10 days of discovery of the permit deviation reported above. The 

report shall include all of the following information: 

Facility name; ' 

Facility address; 

Name of the responsible official; 

Facility telephone number; 

A description of the permit deviation, including the applicable permit number and 

permit condition(s); 

The probable cause of the permit deviation; 

The date and time of the discovery of the permit deviation; 

The actual date(s) and time(s) of the permit deviation; 

The duration of the permit deviation, including the date and time that the device, 

process or air pollution control equipment returned to operation in compliance with 

an enforceable emission limitation or operating condition; 
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Textile Tapes Corporation 

The specific device, process or air pollution control equipment that contributed to 

the prmit deviation; 

Any corrective measures taken to address the permit deviation; 

1. Preventative measures taken to prevent future permit deviations; 

The type and amount of excess emissions that occurred as a result of the permit 

deviation; and 

The calculation or estimation used to quantifr the excess emissions. 

X. Permit Amendments 

A. Env-A 612.01, Administrative Permit Amendments: 

1. An administrative permit amendment includes the following: 

Corrects typographical errors; 

Identifies a change in the name, address, or phone number of any person identified 

in the permit, or provides a similar minor administrative change at the source; 

Requires more frequent monitoring or reporting; or 

Allows for a change in ownership or operational control of a source provided that a 

written agreement containing a specific date for transfer of permit responsibility, 

coverage, and liability between the current and new permittee has been submitted 

to the Division. 

2. The Owner or Operator may implement the changes addressed in the request for an 

administrative amendment immediately upon submittal of the request. 

B. Env-A 612.03, Minor PermitAmendments: Temporary Permits and State Permits to 

Operate: 

1. The Owner or Operator shall submit to the Division a request for a minor permit 

amendment for any proposed change to any of the conditions contained in this permit 

which'does not qualify 'as either'an administrative or significant amendment. 

2. The request for a minor permit amendment shall be in the form of a letter to the 

Division and shall include the following: 

A description of the proposed change; and 

A description of any new applicable requirements that will apply if the change 

occurs. 

3. The Owner or Operator may implement the proposed change immediately upon filing a 

request for the minor permit amendment, but shall be subject to enforcement if the 

Division later determines that the change violated any applicable state or federal 

requirement. 

C. Env-A 612.04, Sign Ulcant Permit Amendments: Temporary Permits and State Permits to 

Operate: 

1. The Owner or Operator shall submit a written request for a permit amendment to the 

Division prior to the implementation of any proposed change which meets one of the 

following: 

Any proposed change that results in the following: 

Any increase in allowable hourly or annual emissions of NOx, SO2, VOCs, HAPs 

or PM10; or 

ii. Any increase in potential emissions equal to or greater than 5 lb/hr of CO; 

Any proposed change to operating or emission limitations; 
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Textile Tapes Corporatioii 

2. A request for a significant permit amendment shall include the following: 

. A complete application form, as described in Eny-A 1703 through Env-A J 708, as 

applicable; 

b. A description of: 

The proposed change; 

The emissions resulting from the change; and 

Any new applicable requirements that will apply if the change occurs; and 

c. Where air pollution dispersion modeling is required for a device pursuant to 

Env-A 606.02, the information required pursuant to Env-A 606.04. 

3. The Owner or Operator shall not implement the proposed change until the Division 

issues the amended permit. 

Inspection and Entry 

DES personnel shall be granted access to the facility covered by this permit, in accordance with 

RSA 125-C:6, VII for the purposes of: inspecting the proposed or permitted site; investigating a 

complaint; and assuring compliance with any applicable requirement found in the New Hampshire 

Rules Governing the Control of Air Pollution and/or conditions of any permit issued pursuant to 

Chapter Env-A 600. 

Emission-Based Fee Requirements 

Env-A 705.01, Emission-based Fees: The Owner or Operator shall pay to the Division 

each year an emission-based fee for emissions from the emission units listed in 

Condition II. 

Env-A 705.02, Determination ofActual Emissions for use in Calculating of Emissionbased Fees: The Owner or Operator shall determine the total actual annual emissions from 

the emission units listed in Condition II for each calendar year in accordance with the 

methods specified in Env-A 705.02. If the emissions are determined to be less than one 

ton, the emission-based fee shall be calculated using an emission-based multiplier of one 

ton. 

Env-A 705.03, Calculation of Emission-based Fees: The Owner or Operator shall 

calculate the annual emission-based fee for each calendar year in accordance with the 

procedures specified in Env-A 705.03 and the following equation: 

FEE =E*DPT 

where: 

FEE = The annual emission-based fee for each calendar year as specified in Env-A 705; 

E = Total actual emissions as determined pursuant to Condition XII.B; and 

DPT = The annual fee, in dollars per ton of emissions, which the Division has calculated 

in accordance with Env-A 705 . 03 8 . 

Env-A 705.04, Payment of Emission-based Fee: The Owner or Operator shall submit, to 

the Division, payment of the emission-based fee so that the Division receives it on or 

before April 15th for emissions during the previous calendar year. For example, the fees 

for calendar year 2015 shall be received on or before April 15, 2016. 

For additional information on emission-based fees, visit the DES website at 

http://des.nh.gov/organization!divisions/air/pehb/apps/fees.htm.