State of New Hampshire 

Department of Environmental Services 

Air Resources Division 

State Permit to Operate 

Permit No: SP-0141 

Date Issued: March 22, 2012 

This certifies that: 

Hutchinson Sealing Systems, Inc. 

1060 Centre Road 

Auburn Hills, MI 48326-2600 

has been granted a State Permit to Operate for: 

Sealing Systems Manufacturing Operations 

at the following facility and location: 

Hutchinson Sealing Systems, Inc. 

171 Route 85 

Newfields, NH 03856-0169 

Facility ID Number : 3301500046 

Application Number: 09-0268, received November 9, 2009 - State Permit to Operate Renewal 

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 is due to 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 March 31, 2017 

Assistant Director 

Air Resources Division 
March 2012 SP- 0141 Page 2 of 17 

Hutchinson Sealing Systems, Inc. - Newfields 

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 Resources Division 

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 Liquefied 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 

PM1o 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 
March 2012 SP- 0141 Page 3 of 17 

Hutchinson Sealing Systems, Inc. - Newfields 

I. Facility Description 

Hutchinson Sealing Systems, Inc. ("the Facility") owns and operates a facility that manufactures sealing 

systems used in automobiles and various other applications. The sealing strips are produced by several 

processes involving metal roll forming, rubber and plastic extruding, flocking (or the application of lowfriction coating) and curing, followed by certain secondary operations including but not limited to 

trimming, notching, saw cutting, stretch blending, molding and assembly. The processes at the Facility 

emit Regulated Toxic Air Pollutants (RTAPs), Hazardous Air Pollutants (HAPs), and Volatile Organic 

Compounds (VOCs) and therefore require a permit . 

II. Emission Unit Identification 

This permit covers the devices and processes identified in Table 1 . 

Table 1 -- Emission Unit Identification' 

Emission Unit 1D Process/Device identification Installation Date Maximum Capacity 

EU01 Extrusion Line #12 1980 333 lb/hr EPDM Rubber 

EU02 Extrusion Line #13 1980 333 lb/hr EPDM Rubber 

EU03 Extrusion Line #14 1980 333 lb/hr EPDM Rubber 

EU04 Extrusion Line #15 1980 53 .3 lb/hr EPDM Rubber 

EU07 Thermoplastics Extrusion Line #7 September 2004 250 lb/hr Solvay Thermoplastic 

EU08 Thermoplastic Vulcanizates Line #8 September 2004 250 lb/hr Solvay Thermoplastic 

EU09 Thermoplastic Vulcanizates Line #9 October 2003 250 lb/hr Solvay Thermoplastic 

2501b/hr Vegaprene 

Emission Unit ID 

Device Manufacturer 

Identification Model Number _ Installation Date 

Maxlntum Design, Capacity & 

Permitted Fuel Type 

EU 10 Fire Pump Engine Cummins 

Model: N-855-F 

1973 218 hp 

Diesel fuel - equivalent to 11 .7 gal/hr 

III. Pollution Control Equipment 

Air pollution control equipment listed in Table 2 shall be operated at all times the associated 

device/process is operating in order to meet permit conditions . 

Table 2 - Pollution Control Equipment Identification 

Pollution Control 

Equipment ID Description Purpose, Emission Units Controllsd 

PCE01 Smog Hog # 12 Control of Particulate Matter EU01 & EU02 [curing ovens] 

PCE02 Smog Hog # 13 Control of Particulate Matter EU02 [curing oven] 

PCE03 Smog Hog # 14 Control of Particulate Matter EU03 [curing oven] 

PCE04 Smog Hog # 15 Control of Particulate Matter EU04 [curing oven] 

PCE05 I Catalytic Oxidizer I Control of VOCs & HAPs I EU09 [adhesive coater and pre-cure oven] I 

1 Emission Units EU05 [Extrusion Line #261 and EU06 [Secondary Low Friction Coating Line] have been removed from the Facility . 
March 2012 SP- 0141 Page 4 of 17 

Hutchinson Sealing Systems, Inc. - Newfields 

IV. Stack Criteria 

Stack 

A. The following devices at the Facility shall have exhaust stacks that meet the criteria in Table 3. 

EU01 

201 (wall) 

378 

276 

..... .. .............. 

202 

379 (wall) 

.... ......... . . .................. . .._....... _ . 

164 (wall) 

282 

272 

293 

249 

135 

 116 

_........_ ._. _.._. _ ....._....._ ._...__..... .~ 

117 

135 

118 

119 

............. ... ... ......... . _........ .... 

135 ' 

124 

............_ ............ ............_ ... .............. 

123 

_.......... ............. ............ .. . ............. 

122 

W .- ~ 121 

EU08 

Adhesive Application 

Post Curing Oven 

_.._.. ......_ .............. . . .................. .........._...... ................ . .__ . ._ .. 

Adhesive Application 

Post Curing Oven 

................. .... ............. . .................. ........ . 

Adhesive Application 

38 

38 ' 

........_. ._ .__......._.....__ ._............. . ._ .I 

38 

36 

36 

. .......... ....... .. . . ........... . . 

EU09 

Catalytic Oxidizer [PCE05] 

.. . .......... _... ... ............ ..... ............. ... ._. ............... . ...._........... ...._............ . 

Adhesive Application 

.................. ._ ....... ......... ............ ..... ............ . ... . ............. . ...... . ... ... .. _.............. . ...Post Curing Oven 

.. .. ........ ..... --- ._ ._........ _. _ ............ ..... .................. .................

. ................... 

Post Curing Oven 

25 

.................. . . _............ . . ....... .. 

38 

Maximum Exit 

Diameter (ft) 

2.35 

1 .33 

1 .42 

1 .42 

2.35 

_ .. .............. . ............... . _............ . . . _..... 

1 .57 

. ............ . . . ...... . ...... ... ....... _..... ........ 

1 .33 

1 .33 

1 .42 

1 .42 

1 .16 

1 .16 

1 .16 

1 .16 

1 .16 

0.67 

. .............. . . _.... . . .... 

1 .16 

....._........._ ._36 .. ... . ._...._.._ ...... 

36 

1 

1 

B. Stack criteria described in Table 3 may be changed without prior approval from the Division 

provided that: 

EU02 

_.. ._....__. ..._ .............._ . .................. .... ......... 

EU03 

EU01 

.._...... ... . . . 

EU02 

EU01 & EU02 

EU02 

Unit ID 

Table 3 -- Stack Criteria 

Heightabove 

Description I Ground- (ft) 

Adhesive Application 

. .................. . ......_....... ._ . ........_........ .. ............._ ... .............__ . ._...._...._.. .........._...... . 

Pre-heat Electric Oven 

........ ....... .................. .................. .................. .........._..... .... ........... . 

Adhesive Application 

Booster - Curing Oven 

..... .. .................. .. .Booster - Curing Oven 

Smog Hog # 12 [PCE01 ] 

_ .................. .................. .. ............... ._ ................ . . . 

Primer/Coating 

Adhesive Application 

.................. . _ ... _............ ..... ...... ............ ... ............ ..._........ . . . .... ... 

Curing Oven 

. ............ . . ._..... .. .. ..........._..... .................. ...... ....... .. ........ 

Smog Hog # 13 [PCE02] 

15 

38 

38 ' 

_............ 

38 

I 15 1......_ .... ........_.. . .................. ............. 

15 

......... ._..... ............ ..... .... ... ... ........... 

38 

EU03 & EU04 Booster - Curing Oven 38 

EU03 Smog Hog #14 [PCE03] 38 

EU04 Smog Hog #15 [PCE04] 38 

EU07 & EU08 

EU07 

1 . An air quality impact analysis is performed either by the facility or the Division (if requested 

by the facility in writing) in accordance with Env-A 606, Air Pollution Dispersion Modeling 

Impact Analysis Requirements, and the "Guidance and Procedure for Performing Air Quality 

Impact Modeling in New Hampshire," and 

2 . The analysis demonstrates that emission from the modified stack will continue to comply 

with all applicable emission limitations and ambient air limits . 

C. Air modeling data and analyses shall be kept on file at the facility for review by the Division 

upon request. 
March 2012 SP- 0141 Page 5 of 17 

Hutchinson Sealing Systems, Inc. - Newfields 

D. The Owner or Operator shall provide written notification to the Division of the stack change 

within 15 days after making the change. Such notification shall include: 

1 . A description of the change; and 

2. The date on which the change occurred. 

E. The stack criteria listed in Table 3 identifies emission points used in air dispersion modeling 

analysis for the Facility. Stacks not listed in Table 3, that emit RTAPs and that use either the 

de minimis or adjusted in-stack concentration methods to show compliance, shall discharge 

vertically and without obstruction . 

V. Operating and Emission Limitations 2 

The Owner or Operator shall be subject to the operating and emission limitations identified in Table 4. 

, Table 4 - Operating and Emission Limitations 

Item Applicable Requirement Applicable Itegulatory , . 

# 'Emission Unit Basis 

I . Facilit,y_Wide VOC Emission Limitations Facility Wide ERC 

Facility-wide emissions of Volatile Organic Compounds (VOCs) shall be limited Certificate No. 

to less than 50 tpy during any consecutive 12-month period .3 98VHSSOIC 

2. Facility-Wide HAP Emission Limitation Facility Wide Env-A 

Facility-wide emissions of Hazardous Air Pollutants (HAPs, as defined in 604.02(a)(1) 

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 combined during any 

consecutive 12-month period .° 

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

The emissions of any Regulated Toxic Air Pollutant (RTAP) shall not cause an 

exceedance of its associated 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 o RTAPs Facility Wide RSA 125-I :5 

In accordance with RSA 125-1:5 IV, if DES revises the list of RTAPs or their IV 

respective AALs or 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- EU04, Env-A 2103 

The average visible emissions shall not exceed 20 percent opacity for any EU07 - EU09 

continuous 6-minute period, except for one period of 6 continuous minutes in any 

60-minute period during startup, shutdown, or malfunction.s PCE01 - PCE05 

The Facility does not have the potential to emit the criteria pollutants NOx, SO2, CO, or PM,o at levels greater than the major source 

thresholds for these pollutants. Therefore, the Facility is a true minor source for NOx, S02, CO, and PM10. 

' The Facility has the potential to emit VOCs at levels greater than the major source threshold of 50 tpy. The annual emission limit in Table 

4, Item 1 is less than this threshold, and establishes the Facility as a synthetic minor source of VOCs. 

° The Facility has the potential to emit HAPs above the major source threshold of 10 tpy for any individual HAP and 25 tpy for all HAPs 

combined. The annual emission limit in Table 4, Item 2 establishes the Facility as a synthetic minor source of HAPs. 

Compliance with visible emission limitations shall be determined using 40 CFR 60, Appendix A, Method 9, upon request by the Division. 
March 2012 SP- 0141 Page 6 of 17 

Hutchinson Sealing Systems, Inc. - Newtields 

Table 4 - Operating and Emission Limitations 

Item ,Applicab ieRequheenrent 

~ 

Applicable Regulatory 

# l Emission Unit Basis ' 

6. Volatile Organic Compound (VOC) Reasonably Available Control Technolony EU01- EU04 VOC RACT ! 

(RACT) RQuirements & Order 

Comply with the terms and conditions set forth in VOC PACT Order ARD-11- EU07 - EU09 ARD-11-001 

001 issued March 2012. 

7. Minor Core Activities EU01 - EU04 Env-A 

Minor core activities of VOC emissions are exempt from the VOC RACT & 1203.38(b) 

requirements of Env-A 1200. VOC emissions from all minor core activities shall EU07 - EU09 

be limited to less than 5 tons combined in any consecutive 12-month period. 

Minor core activities currently include cleaning activities using solvents, and 

product labeling using inks. If at any time, the VOC emissions from these minor 

core activities exceed the 5-ton limit, these process(es) will become subject to the 

provisions of Env-A 1222 for unclassifiable processes . 

8. Pollution Control Eguipment PCE01- PCE04 Env-A 

a.) The Smog Hogs associated with the EU01 through EU04 shall be: 604 .01 

1 .) Operated in a manner consistent with manufacturer's recommendations 

to minimize the air pollutant emission and to meet permit conditions; 

2.) Fully operational at all times the associated processes are operating 

except to the extent that maintenance activities to any Smog Hog unit 

must occur during periods of associated process operations, the Smog 

Hog unit is allowed to be bypassed while performing said maintenance 

activities provided that the opacity of emissions from the process does 

not exceed the limitation specified in Table 4, Item 5 above; and 

3 .) No more than one Smog Hog shall be bypassed during any given time 

period.b 

........ _........ ............ .................. .................. .................. ............._... ._ .. ............._... ._ ........... ....... .... .............. . ................. .................. .................. ..... ............ ..............._. ._ ._ ..___....._ . ._ ._._........ .... ....._....... .. ._ . 

b.) The Catalytic Oxidizer associated with EU09: EU09 & PCE05 

1 .) The catalyst inlet shall be maintained at a minimum temperature which 

will be determined during the emissions stack testing required in Table 

5, Item 4, based on an hourly average ; 

2 .) The catalytic oxidizer shall meet a destruction efficiency of at least 

95%; 

3 .) The by-passed valve shall remain closed when the catalytic oxidizer is 

in operation; and 

4 .) The oxidizer shall be operated and maintained in accordance with 

manufacturer's recommendations . 

9. Application Methods: EU01 - EU04 Env-A 

Use one of the following application methods for the application of adhesives & 1220.04 

and adhesive primers : EU07 - EU09 

a.) Electrostatic spray; 

b.) HVLP spray; 

c.) Flow coat, roll coat, or hand application, including non-spray application 

methods similar to hand or mechanical powered caulking gun, or direct hand 

application; 

d.) Dip coat, including electrodeposition ; 

e.) Airless spray; 

f.) Air-assisted airless spray; or 

g.) Other adhesive application methods capable of achieving a transfer 

efficiency equivalent to or better than that achieved by HVLP spraying . 

6 Conditions for bypass of the Smog Hog equipment was specified in a letter to the Facility dated October 1, 1997 . 
March 2012 SP- 0141 Page 7 of 17 

Hutchinson Sealing Systems, Inc. - Newfields 

Table 4 - Operating and Emission Limitations 

Item  , 

Applicable Rcquirement ° 

Applfcable Regulatory,' 

Emisssi+~n Uttit ~asis 

10 . Work Practices for Waste Materials EU01 - EU04 Env-A 

Implement the following work practice standards for adhesives, thinners, and & 1220.05 

adhesive-related waste materials: EU07 - EU09 

a.) Store all VOC-containing adhesives, adhesive primers, and process-related 

waste materials in closed containers ; 

b.) Ensure that mixing and storage containers used for VOC-containing 

adhesives, adhesives primers, and process-related waste materials are kept 

closed at all times except when depositing or removing these materials; 

c.) Minimize spills of VOC-containing adhesives, adhesive primers, and 

process-related waste materials; and 

d.) Convey VOC-containing adhesives, adhesive primers, and process-related 

waste materials from one location to another in closed containers or pipes. 

11 . Work Practices or CleaninQ Materials EU01 - EU04 Env-A 

Implement the following work practices for cleaning materials used for surface & 1220.06 

preparation or for application equipment cleaning : EU07 - EU09 

a.) Store all VOC-containing cleaning materials and used shop towels in closed 

containers ; 

b.) Ensure that storage containers used for VOC-containing cleaning materials 

are kept closed at all times except when depositing or removing these 

materials; 

c.) Minimize spills of VOC-containing cleaning materials; 

d.) Convey VOC-containing cleaning materials from one location to another in 

closed containers or pipes; and 

e.) Minimize VOC emissions from the cleaning of application, storage, mixing, 

and conveying equipment by ensuring that equipment cleaning is performed 

without atomizing the cleaning solvent and that all spent solvent is captured 

in closed containers. 

12 . Maximum Sulfur Content Allowable in Liquid Fuels EU 10 40 CFR 

The sulfur content of diesel fuel burned in the diesel fire pump engine shall not 63 .6604 

exceed 15 ppm (0 .0015 percent by weight). 

subpart ZZZZ 

13 . Emergency Generators EU 10 Env-A 

The diesel fire pump engine shall be limited to 500 hours of total operation 1301 .02(j)(1) , 

during any consecutive 12-month period. 

14. Visible Emission Standard for Fuel Burning Devices Installed After May 13. EU 10 Env-A 

1970 2002.02 

The average opacity from fuel burning devices installed after May 13, 1970 shall 

not exceed 20 percent for any continuous 6-minute period .' 

15 . Particulate Standards for Fuel Burning Devices Installed after May 13, 1970 but EU 10 Env-A 

Before January 1. 1985 2002.07 

The particulate matter emissions from fuel burning devices installed after May 

13, 1970, but before January 1, 1985 shall not exceed 0.60 lb/MMBtu. 

16 . Emergenay Generator EU 10 Env-A ', 

The emergency generator [fire pump engine] shall only operate during normal 101 .671 

maintenance and testing as recommended by the manufacturer. 

Compliance with visible emission limitations shall be determined using 40 CFR 60, Appendix A, Method 9, upon request by the Division . 
March 2012 SP- 0141 Page 8 of 17 

Hutchinson Sealing Systems, Inc. - Newfields 

Table 4 - Operating and Emission Limitations 

item 

., . , 

°hwpplicable Re quii~en~eip~# Applicabl~e Regulatory " 

# , Emission V nit Basis 

17 . Emergency Engines Manufactured Prior to June 12. 2006 EU 10 40 CFR 

Beginning May 3, 2013, EU 10 is limited to 100 hours per year of operation for 63.6640 

the purpose of maintenance checks and readiness testing, provided that the tests subpart ZZZZ 

are recommended by Federal, State, or local government, the manufacturer, the 

vendor or the insurance company associated with the engine. 

EU 10 may operate up to 50 hours per year in non-emergency situations, but those 

50 hours are counted towards the 100 hours per year provided for maintenance 

and testing. The 50 hours per year for non-emergency situations cannot be used 

for peak shaving or to generate income for a facility to supply power to an 

electric grid or otherwise supply power as part of a financial arrangement with 

another entity ; except that owners and operators may operate the emergency 

engine for a maximum of 15 hours per year as stated in Table 4, Item 16 above. 

18. Engine Operating Requirements EU 10 40 CFR 

After May 3, 2013, the engine shall be operated as follows : 63.6603 

a.) Change oil and filter annually; subpart ZZZZ 

b.) Inspect air cleaner annually ; 

c.) Inspect hoses and belts annually; 

d.) Minimize isle time during startup and minimize startup time to a period 

needed for appropriate and safe loading, not to exceed 30 minutes ; and 

e.) Operate and maintain the engine according to the manufacturer's emissionrelated operation and maintenance instructions. 

VI. Monitoring and Testing Requirements 

The Owner or Operator is subject to the monitoring and testing requirements as contained in Table 5. 

Table 5 - Monitoring and Testing Requirements 

Ite~n Parameter Method of Compliance Frequency ;Applicable Regulatory 

# Unit "_ Basis 

1 . To Be When conditions warrant, the Division may require Upon request by Facility RSA 125-C:6 

Determined the Owner or Operator to conduct stack testing in the Division Wide XI 

accordance with USEPA or other Division approved 

methods. 

2. Sulfur Conduct testing in accordance with appropriate For each delivery EU10 Env-A 806.02 

Content of ASTM test methods or retain delivery ticket in of fuel oil/diesel to & 

Liquid Fuels accordance with Table 6, Item 4 in order to the facility Env-A 806.05 

demonstrate compliance with the sulfur content 

limitation provisions specified in this permit for 

liquid fuels . 

3 . Hours of The emergency generator [fire pump engine] shall be Continuous EU 10 40 C FR 

Operation equipped with a non-resettable hour meter. 63.6625 

subpart ZZZZ 
March 2012 SP- 0141 Page 9 of 17 

Hutchinson Sealing Systems, Inc. - Newfields 

Table 5 - Monitoring and Testing Requirements 

Item > ~ Pa rameter Method_of Compliance Frequency ~# 

Applicable, 

11nit 

Regulatory . 

Basis - 

4. VOC Control Compliance testing shall be conducted as follows for Within 60 days PCE05 Env-A 802 

Device the capture and control devices associated with EU09: of achieving the 

Efficiency a.) Testing shall be planned and carried out in maximum 

accordance with the following schedule : production rate 

1 .) A pre-test protocol shall be submitted to the of the process, 

Division at least 30 days prior to the but not later than 

commencement of testing ; 180 days from 

2.) The Owner or Operator and any contractor startup of the 

retained by the Owner or Operator to conduct device 

the test shall meet with a Division 

representative at least 15 days prior to the test 

date to finalize the details of the testing; and 

3.) A test report shall be submitted to the 

Division within 60 days after the completion 

of testing 

b.) The following test methods, or Division approved 

alternatives, shall be used: 

1 .) USEPA Methods 1-4 for exit flow rate, 

percentage of carbon dioxide, oxygen and 

moisture ; 

2 .) USEPA Method 204 for capture efficiency ; 

3 .) USEPA Method 25 or 25A for total gaseous 

organic emissions ; and 

4 .) Testing shall be performed at the inlet and 

outlet of the catalytic oxidizer in order to 

determine the destruction efficiency of the 

device ; 

5 .) Continuously monitor the inlet temperature to 

the catalytic oxidizer; and 

.... ....... . .......... . .................. ... ............. .... .................. .................. .... ............~ ... . ......_........... ............. ........ _....... . ... _....... . ................ 

c.) The Owner or Operator shall be subject to fees for Env-A 

any testing and monitoring which Division 704.02 

personnel undertake or audit in accordance with 

this permit 

5 . Catalytic a.) Monitor and record the inlet temperature to the Continuous PCE05 Env-A 906 

Oxidizer catalyst ; and 

Combustion 

Temperature 

. ..._. . .. . ._ .................. ..... ........... . ..... ..... ... ........... . ..... ............ . ............. . . .......... ...... ....... 

b.) If the inlet catalyst temperature reading is less than 

......... .................. ................. ..... .... 

As noted 

the range determined during the compliance stack , test required by Table 5, Item 4 above, then 

inspect the unit and take corrective action to raise 

the temperature. 

6. Catalytic Conduct a visual external integrity inspection of the Annually and as PCE05 RSA 125- 

Oxidizer catalytic oxidizer . The inspection shall: conditions C:6, XI 

Inspection a.) Include an evaluation of whether all emissions are indicate an 

being vented through the dedicated stack exit ; and inspection is 

b.) Be conducted by plant personnel familiar with the warranted 

operation of the oxidizer and associated 

equipment. 
March 2012 SP- 0141 Page 10 of 17 

Hutchinson Sealing Systems, Inc. - Newfields 

Table 5 - Monitoring and Testing Requirements 

I It,tm 

~-- Parameter Method 6f Compliance Froquency 

Applicable 

U it 

Regt~Iatory, 

n Basis 

7. Catalytic The Owner or Operator shall develop a catalyst Within 120 days of PCE05 Env-A 

Oxidizer management plan that will contain the maintenance issuance of this 604.02 

Operation and monitoring requirements that will be undertaken to permit or prior to 

assure that the catalyst is performing adequately . startup of the 

oxidizer, 

whichever is 

sooner 

8. Bypass The Owner or Operator shall: Env-A 

Monitoring 

a.) Monitor the valve or closure mechanism Continuously PCE01 - 

604.02 

controlling the bypass line in a non-diverting PCE05 

position in such a way that the valve or closure 

mechanism cannot be opened without creating a 

record that the valve was opened; 

........ .................. ........__......_._. .._........ ....._ .................. ..................._ .. ........._._. . .... ............ .._ ....._..........._ . ._ .__. . ................ _ .. _......... ..... . 

b.) Use a method to monitor the valve or closure PCE05 

mechanism where, the coating line will stop when 

flow is diverted away from the catalytic oxidizer 

to the bypass line when the catalytic oxidizer is in 

operation ; 

c.) Perform 

hog 

- .......

is 

..

by-passed

.........

opacity 

...... ..................

observations 

; 

._

and 

.. .. ..................

whenever 

............ .... ...........

a 

.......

smog 

............... .. . . ... ........... .... .. 

As noted 

..... . ........ ...........

PCE01 

.... .. ................... ... ..- ............... . . ........ ...... . . .................. . .... ........_.. .....

.___

...._ .__..... _.. ..... . .................. .................. ............._... ..... . . . . . . . . . . . . . . . . . . . . ._. . . . . ._. . . . . . . . . . . . . . . . . . . . . . . . _ . . . . . _ 

PCE04 

... . . ... ............. . _ .... _ ........... . 

d.) Inspect the duct work and shutdown systems at Monthly PCE01 - 

least once every month to verify that there are no PCE05 

leaks. 

VII. Recordkeeping Requirements 

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

Table 6 - Recordkeeping Requirements 

Item ReCt~ril,I~epi~lg Requirement 

J~raxi~ul Applicable Regulatory_ 

Frequency Unit Basis 

1 . Record Retention and Availability Retain for a Facility Env-A 902 

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

review by the Division upon request. 

5 years 

2. General Recordkeeping Requirements for Process Operations Monthly EU01- EU04 Env-A 

Maintain the following records for process operations : & 903.02 

a.) Total quantity of raw materials containing, VOCs, HAPs and EU07 - EU09 

RTAPs; and 

b.) Hours of operation for each process . 

3 . General Recordkeeping Requirements for Combustion Devices Monthly EU10 Env-A 

Maintaining records of: 903 .03 

a.) Fuel type (e .g . diesel fuel); and 

b.) Amount of fuel burned in the device . 
March 2012 SP- 0141 Page 11 of 17 

Hutchinson Sealing Systems, Inc. - Newfields 

Table 6 -Recordkeeping Requirements 

Item Reeordkeepi ng Reyaireaaeht Duration/ Applicable, 

' 

Regulatory 

# Frequency Unit Basis4 . Liquid Fuel Oil Recordkeeping Requirements Whenever EU 10 Env-A 

A written statement from the fuel supplier that the sulfur content of the there is a 806.05 

fuel as delivered does not exceed the sulfur limit specified in Table 4, change in 

Item 12. 

fuel supplier 

but at least 

annually 

5 . Regulated Toxic Air Pollutants Update prior Facility Env-A 

Maintain records documenting compliance with Env-A 1400 . 

to process Wide 902.01 

Compliance was demonstrated at the time of permit issuance as changes and 

described in the Division's Application Review Summary for within 90 

application 09-0268. The source must update the compliance days of each 

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

a.) There is a revision to the list of RTAPs lowering the AAL for any Env-A 1400 

RTAP emitted from the Facility; 

b.) The amount of any RTAP emitted is greater than the amount that 

was evaluated in the Application Review Summary (e .g., coating 

change); 

c.) An RTAP that was not evaluated in the Application Review 

Summary will be emitted (e .g ., new coating is used); or 

d.) Stack conditions (e .g. airflow rate) change. 

6. Additional Recordkeeping Requirements : Facilitv-wide Emission Monthly Facility Env-A 906 

Limitations Wide & 

Maintain a 12-month running total of Facility-wide emissions of VOCs Env-A 

and HAPs, which shall include emissions from non-permitted devices, 604.02(a)(3) 

for the purpose of demonstrating that the total emissions of these 

pollutants are below the major source threshold of 50 tpy of VOC, and 

10 tpy for any single HAP and 25 tpy for all HAP combined. 

7. Recordkeepin for Add-on Control Devices Maintain on a PCE01 - Env-A 

Maintain the following information: continuous PCE05 904.07 

a.) Air pollution control device identification number, type, model basis 

number, and manufacturer ; 

b .) Installation date ; 

c.) Processes or devices controlled; 

d.) 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 processes or devices are in operation ; 

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

control equipment including: I 

1 .) Ddstruction or removal efficiency, in percent; 

2 .) Date tested; 

3 .) The emission test results, if tested, including: 

i.) The inlet VOC concentration in ppm; 

ii.) The outlet VOC concentration in ppm; and 

iii .) The method of determination of the concentration in i . 

and ii. above; and 

4.) The method of determining destruction or removal efficiency 

if not tested ; 
March 2012 SP- 0141 Page 12 of 17 

Hutchinson Sealing Systems, Inc. - Newfields 

Table 6 - Recordkeeping Requirements 

Item 

_ 

. , 

. Re+portlkeiping Requirement . . 

Duration/- Ap 13cabte Regulatory 

, Freqnoniy . . T1"n:it Basis 

7. g.) For the catalytic incinerator : Maintain on a PCE05 Env-A 

cont 1,) The design exhaust gas temperature in degrees F; continuous 904.07 

2.) The design temperature rise across the catalyst be in degrees F; basis 

3 .) The anticipated frequency of catalyst change; and 

4.) Any actual catalyst changes. 

8. Additional Recordkeeping Requirements for Pollution Control Maintain on a PCE01 - Env-A 906 

Equfyment continuous PCE05 

Maintain records of maintenance activities specified in Table 4, Item 8, basis 

including: 

a.) Periods when a Smog Hog is by-passed ; 

b.) Results of opacity observations of the Smog Hog by-pass vents 

which shall include the following information : 

1 .) Name of the operator ; 

2 .) Date and time the Smog Hog is put into by-passed mode; 

3 .) Duration of the by-pass event; and 

4.) Results of the opacity observation ; 8 

c.) Catalytic oxidizer inlet temperature ; 

d.) Periods when the catalytic oxidizer bypass line is opened, record a 

description of why the bypass line was opened and the length of 

time it remained open; and 

e.) Air pollution control equipment maintenance activities, including 

preventative maintenance and annual visual inspections. 

9. VOC Emission Statements Recordkeeping Requirements Maintain on a EU01- EU04 Env-A 904 

Maintain the following records : continuous & 

a.) Identification of each VOC emitting process or device, except basis EU07 - EU09 

processes or devices associated exclusively with non-core 

activities, as defined in Env-A 1204.03(bp); 

b.) The operating schedule during the high ozone season for each 

VOC emitting process or device identified in a.) above, including : 

1 .) Hours of operation per calendar month; and 

2 .) Days of operation per calendar month; 

c.) The following VOC emissions data from all VOC-emitting 

processes or devices identified in Table 6, Item 9. a.) above, 

including: 

1 .) Actual VOC emissions for: 

i .) The calendar year, in tons; and 

ii .) A high ozone season day during the calendar year, in 

pounds per day; and 

2 .) The emission factors and the origin of the emission factors 

used to calculate the VOC emissions. 

e If the operator cannot perform an opacity observation during a by-pass event, the reason no opacity reading was performed must be recorded 

in the log. No more than 50% of the by-pass events in any rolling 12-month period shall have a "no opacity reading" recorded . 
March 2012 SP- 0141 Page 13 of 17 

Hutchinson Sealing Systems, Inc. - Newfields 

Table 6 - Recordkeeping Requirements 

Item Recordkeeping Requirement,,, . 

Duration/ Applicable 

'' 

Regulatory 

# Frequency, Unit Basis 

10. VOC Content of Coatings Upon use of EU01- EU04 VOC RACT 

Continue to comply with the terms and conditions of VOC RACT coatings & Order 

Order ARD-I 1-001, including the following : subject to EU07 - EU09 ARD-11-001 

a.) Maintain records (Material Safety Data Sheets - MSDS', VOC RACT 

furnished by the material supplier) documenting the pounds of 

VOC per gallon of material, excluding water and exempt VOC 

compounds; and 

b.) For materials used after the issuance of the RACT Order, each 

material supplier (including the Facility for self-made materials) 

shall provide the Facility with a signed certification that the 

information disclosed on the MSDS' was derived in accordance 

with an approved EPA test method. 

11 . Operation Log for the Emergenoy Generator Keep a EU 10 40 CFR 

The Owner or Operator shall keep records of: running log 63 .6655 

a.) The hours of operation of the engine that is recorded through the subpart 

non-resettable hour meter; and ZZZZ 

b.) Documentation of how many hours are spent for emergency 

operation, including what classified the operation as emergency 

and how many hours are spent for non-emergency operation. 

VIII. Reporting Requirements 

A. Pursuant to Env-C 203 .02(b), Date of Issuance of Filing, written 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. 

B. 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 . 

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

below. 

Table 7 - Reporting Requirements 

Item Reporting Requirements ' Frequency Applicable Regulatory 

Unit Basis 

1 . Annual Emissions Report Annually (received Env-A 

The Owner or Operator shall submit an annual emissions by DES no later 907.01 

report which shall include the following information: than April 15`b of 

a.) Actual calendar year emissions of PM, VOCs (speciated 

the following year) 

EU01 - EU04 i 

by individual VOC), HAPs (speciated by individual & 

HAP), and RTAPs (speciated by individual RTAP); 

. . . . ....... ..... . _ .... ...... ...... .................. .. .. ..... ......._ ... ....._...... ... .......... 

EU07 - EU09 

. ............ ..... .................. . ........ ........ . . ... . . .......... ..... ............ . ...... ........... . 

b.) Actual calendar year emissions of NOx, CO, SO2, TSP EU 10 

and VOCs; 
March 2012 SP- 0141 Page 14 of 17 

Hutchinson Sealing Systems, Inc. - Newfields 

Table 7 - Reporting Requirements 

Item ` Reporting Requirements ' = Frequency Applkable ; -Regulatory 

~ _ _ . . unit Basis, 

1 . c.) The methods used in calculating such emissions in Annually (received EU01- EU04 Env-A 

cont accordance with Env-A 705 .02, Determination ofActual by DES no later & 907.01 I 

Emissions for Use in Calculating Emission-Based Fees; than April 15'h of EU07 - EU 10 

and the following year) 

d.) All information recorded in accordance with Table 6, 

Items 2 and 3, compiled on a monthly basis. 

2. Startup Notification Actual date of initial EU09 & Env-A 

Submit a notification to the Division stating the date of initial startup of the PCE05 910.01 

startup of the device . 

device, received by 

DES within 15 days 

after such date 

3. VOC Reporting Reguirements Annually (received EU01- EU04 VOC RACT 

If the actual annual VOC emissions from all permitted by DES no later & Order 

devices located at the Facility are greater than or equal to 10 than April 15`" of EU07 - EU09 ARD-11-001 

tpy, then include the following information with the annual the following year) & 

emission report : Env-A 908.03 

a.) Facility information, including : 

1 .) Source name: 

2.) Standard Industrial Classification (SIC) code; 

3 .) North American Industrial Classification System 

(NAICS) code; 

4.) Physical and mailing addresses ; and 

b.) A breakdown of VOC emissions reported pursuant to 

Table 7, Item 1 by month; and 

c.) All data recorded pursuant to Table 6, Items 8 and 9. 

4. Reporting Requirements ,for DERs and ERCs Annually (received EU01- EU04 VOC RACT 

The Facility shall true up the balance of credits required for by DES no later & Order 

the previous year (for the period of June 1g` to May 31), and than September Is') EU07 - EU09 ARD-11-001 

shall report the balance to the Division by September lst. 

5. Permit Deviation Re,porting Reguirements Within 24 hours of EU01- EU04 Env-A 

Report permit deviations resulting in excess emissions in discovery of excess & 911 .04(b) 

accordance with Condition X.B . 

emissions EU07 - EU 10 

6. Emission Based Fees Annually (received EU01- EU04 Env-A 700 

Pay emission-based fees in accordance with Condition XIII. 

by DES no later & 

than April 15''' of EU07 - EU 10 

the following year) 

IX. Process Changes 

A. For the purpose of this Permit, a regulated "Process Change" is defined as: 

1 . The internal relocation or addition of a process device (e.g., extrusion line, TVP line, etc.) ; 

2. The addition of a stack or the change in size and/or mechanical configuration (i .e ., exit 

velocity, etc.) of a stack listed in Table 3; 

3 . The addition or reformulation of a coating or product . 

B. The Owner or Operator may make Process Changes without requiring revisions or amendments 

to this Permit as long as: 

1 . The Process Change does not result in exceedance of any emission limitation specified in 
March 2012 SP- 0141 Page 15 of 17 

Hutchinson Sealing Systems, Inc. - Newfields 

Table 4, specifically the process change does not result in an exceedance of any RTAP 

limit in Env-A 1400; 

2. The increase in actual VOC emissions from all process changes made during the life of this 

Permit is less than 10 tpy; and 

3 . The process change does not cause the Facility to become subject to any requirements not 

covered in this Permit (e.g ., a new VOC RACT requirement) . 

C. The Owner or Operator shall provide written notification to the Division of each Process 

Change within 15 days of making the change. Such notification shall include: 

1 . A description of the change; 

2 . A description of the resulting facility setup including a description of the process device, 

control devices, if any, and stacks ; 

3 . The date on which the change occurred; and 

4. Documentation demonstrating compliance with the emission limitations in Table 4, 

including documentation demonstrating compliance with the most recent list of RTAP's 

and associated AALs presented in Env-A 1450. 

D. Any Process Change made pursuant to this permit condition that is later determined to either 

not qualify as a Process Change or violates any applicable requirement or permit condition shall 

be considered a violation of this Permit. 

X. Permit Deviation Reporting Requirements 

A. Env-A 101, Definitions: 

1 . 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. 

2. An excess emission is an air emission rate that exceeds any applicable emission limitation . 

B. Env-A 911 .04(b), Reporting Requirements : In the event of a permit deviation that causes 

excess emissions, notify the Division of the permit deviation and excess emissions by telephone 

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

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

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

Sunday, or state or federal legal holiday. 

XI. Permit Amendments 

A. Env-A 612.01, Administrative Permit Amendments : 

1 . An administrative permit amendment includes the following: 

a. Corrects typographical errors ; 

b. 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 ; 

c. Requires more frequent monitoring or reporting; or 

d. 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. 
March 2012 SP- 0141 Page 16 of 17 

Hutchinson Sealing Systems, Inc. - Newfields 

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 Permit Amendments: 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 will not result in an increase in the amount of a specific air pollutant currently 

emitted by the emission units listed in Condition 11 and will not result in the emission of 

any air pollutant not emitted by the emission unit . 

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. A description of the proposed change; and 

b. 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 filling a 

request for the minor permit amendment. 

C. Env-A 612 .04, Significant 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 at least 90 days prior to the implementation of any proposed change to the 

physical structure or operation of the emission units covered by this permit which increases 

the amount of a specific air pollutant currently emitted by such emission unit or which 

results in the emission of any regulated air pollutant currently not emitted by such emission 

unit . 

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

a. A complete application form, as described in Env-A 1703 through Env-A 1708, as 

applicable; 

b . A description of: 

i . The proposed change ; 

ii . The emissions resulting from the change; and 

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

iv. Where air pollution dispersion modeling is required for an emission unit pursuant 

to Env-A 606 .02, the information required pursuant to Env-A 606.03 . 

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

the amended permit . 

XII. Inspection and Entry 

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

125-C:6, V11 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. 

XIII. Emission-Based Fee Requirements 

A. 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 Il . 
March 2012 SP- 0141 Page 17 of 17 

Hutchinson Sealing Systems, Inc. - Newfields 

B. Env-A 705.02, Determination of Actual Emissions for use in Calculating of Emission-based 

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. 

C. 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 XIII.B ; and 

DPT = The dollar per ton fee the Division has specified in Env-A 705 .039. 

D. 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 

2012 shall be received on or before April 15, 2013. 

9 For additional information on emission-based fees, visit the DES website at http ://des .nh. oi? v/organi-r.ation/divisions/air/pehb/apps/fees .htm