## 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 DivisionMarch 2012 SP- 0141 Page 2 of 17 Hutchinson Sealing Systems, Inc. - N ewfields 

### 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 CompoundMarch 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 MaxlntumDesign, 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 Oxid iz e r I Control of VOCs & HAPs I EU09 [adhesive coater and pre-cure oven] I

1 Emission Units EU05 [Extrusion Line #261 and EU06 [Secondary LowFriction Coating Line] have been removed from the Facility .March 2012 SP- 0141 Page 4 of 17 Hutchinson Sealing Systems, Inc. - New fields 

### 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 fromthe 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

. . . . . . . . . . . . . . . ._. . . . . . . . . . . . . . . . . . . ._. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Sm og 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 fromthe 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 . Adescription 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, Item2 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 ,ApplicabieRequheenrent ~ 

### Applicable Regulatory # l Emission Unit Basis ' 6 . Volatile Organic Compound (VOC) Reasonably Available Control Technolony EU01- EU04 VOCRACT ! (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 fromthe VOC RACT & 1203 .38(b) requirements of Env-A 1200 . VOC emissions fromall 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 fromthese 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 fromthe 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, Item4, 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 fromone 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 fromone location to another in closed containers or pipes ; and e.) Minimize VOC emissions fromthe 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 Standardfor Fuel Burning Devices InstalledAfter May 13. EU 10 Env-A 1970 2002.02 The average opacity fromfuel 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 fromfuel 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 . - Ne wfields Table 4 - Operating and Emission Limitations 

### item ., . , quii~en~eip~# °hwpplicable Re 

### 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 maximumof 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 ZZZZMarch 2012 SP- 0141 Page 9 of 17 Hutchinson Sealing Systems, Inc . - Newfields Table 5 - Monitoring and Testing Requirements Item > ~ Parameter Method_of Compliance Frequency Applicable, Regulatory . ~# 11nit 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 flowrate, 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, I nc . - Newfields Table 5 - Monitoring and Testing Requirements I It,tm ~-- Parameter Method 6f Compliance Froquency Applicable it U Regt~Iatory,

Basis n 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 mechanismcannot be opened without creating a record that the valve was opened;

........ .................. ....... .__

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

. . .... ............ .._ .... ._ ..........._ . ._ .__. . ................_ .._ ......... ..... . b .) Use a method to monitor the valve or closure PCE05 mechanismwhere, the coating line will stop when flowis diverted away from the catalytic oxidizer to the bypass line when the catalytic oxidizer is in operation ;

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

# .......................................... ..............

c.) Performopacity observations whenever a smog As noted PCE01 - hog is by-passed; and

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ._. . . . . . . .___ . . . ._ .__ . . . . . _ . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ._. . . . . . . .

# ....................._......_........................_....._ 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 minimumof Wide reviewby 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 fromthe 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 fromthe 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 . airflowrate) 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 fromnon-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, Item8, 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 . VOCEmission 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, Item9. a.) above, including: 1 .) Actual VOC emissions for : i .) The calendar year, in tons ; and ii .) Ahigh 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 performan 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 fromall 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 VOCemissions 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 . Apermit 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. Adescription 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. Acomplete application form, as described in Env-A 1703 through Env-A 1708, as applicable ; b . Adescription of: i . The proposed change ; ii . The emissions resulting fromthe 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 fromthe 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 ofActual Emissionsfor use in Calculating of Emission-based Fees : The Owner or Operator shall determine the total actual annual emissions fromthe 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