t 

NHDES 

VOC RACT APPLICATION 

REVIEW SUMMARY 

NH Department of Environmental Services 

Air Resources Division 

P.O . Box 95, 29 Hazen Drive 

Concord, NH 03302-0095 

Phone: 603-271-1370 Fax: 603-271-7053 

Facility : Hutchinson Sealing Systems, Inc. Engineer: PRN 

Location : Newfields 

AFS #: 3301500046 Application #: 11-0156 Date : I January 27, 2012 Page 1 of 4 

PROJECT DESCRIPTION 

VOC RACT order. EU09 - [Thermoplastics Extrusion Line #9] - the line is being modified to include a stainless steel pre-form unit 

and adhesive application ["front-end"] along with a catalytic oxidizer for control of VOC emissions from the added equipment. 

Hutchinson Sealing Systems, Inc. ["HSS" or "the Facility"] owns and operates a facility that produces sealing systems, body seals, 

and soft rubber glass-run channels used in automobiles and various other applications . The sealing strips are produced by several 

processes involving metal roll forming, rubber and plastic extruding, flocking and curing, followed by certain secondary operations 

including but not limited to trimming, notching, saw cutting, stretch blending, molding and assembly . 

On August 8, 2002, HSS was issued VOC RACT Order # ARD-01-002. At that time, the adhesive application processes were 

categorized as "unclassifiable", and were required to meet a 3.5 Ib VOC/gal VOC RACT limit [Env-A 1204.49(a)(3), adopted 12-21-

02]. The VOC RACT order currently allows the Facility to generate and expend credits to cover VOC emissions above the 3 .5 Ib/gal 

limit specified in the rule . They are able to self-generate 22 tpy of VOC credits due to the permanent shutdown of the Body Stock 

Preparation Line [9/1/1999] and the Metal Parts Painting operations [5/4/1998] . This 22tpy is the difference between the baseline 

before the shutdown of these two processes and the Facility-wide emissions after the shut-down. The Facility is allowed to use these 

credits each year, but remaining unused credits do not roll-over to succeeding years. 

On June 1, 2011, DES adopted revisions to Env-A 1200. Among those changes was the inclusion of a new source category of 

Industrial Adhesives [Env-A 1220]. HSS meets the applicability requirements of this section, and the modifications to EU09 will 

become subject to the emission limitations upon startup. HSS has opted to comply, facility-wide with the requirements of this subpart 

upon issuance of their renewed permit, SP-0141 instead of waiting until January 1, of 2016. The Facility has requested to be allowed 

to continue to use ERCs and DERs for those adhesives that do not comply with the new RACT limit. HSS has also request they be 

allowed to generate credits [DERs] for the over control of VOC emissions by the catalytic oxidizer . 

PROCESS/DEVICE DESCRIPTION 

During assembly of the sealing strips, as the formed metal and extruded rubber come together, an adhesive is applied, which bonds the 

rubber to the metal vehicle part . Some products require the application of flock to the sealing strips [flock is a polyester fiber, which 

has a similar consistency as powder]. An adhesive is applied to the part of the sealing strip to which the flock is being applied. As the 

sealing strip passes through a booth, the flock is injected through a specially designed applicator and bonded to the sealing strip. The 

strips are passed through an electric oven, to cure the rubber. The extrusion lines each have a Smog Hog [contains an electrostatic 

precipitator to control particulate matter emissions] . 

Device/Process Description 

Thermoplastic Extrusion Construction of this line commenced October 2003 with startup August 1, 2004; 

Line #9 [EU09] 

Device Model Mfi SIN I Device Model Mfa SIN 

Roll-Form NA KW R50 & R51 ~ Extruder 2.5 MV Davis AQ790 

. _ ._. ._ .__....._...._ .._......._._..._ ._______ ._.__.___..._.._ ._.... .___.___.__.._ ...__ ._._......._.__._.__. ......_. .. ..___._._.__._. ._____ ...._._._.._._.._ . ._...__.....__..._.__.__... ....__..._..._ ._ .....__...._..... . 

Extruder 2.5 MarkV Davis AG889 ~ Extruder MV35 IN35 Davis AQ794 

_ .._ --- ..... ._ ._.._ ......_........_...~_.._........ ......_ ...._....._ . .. 

Extruder DS125 Davis AN810 1Flash Cure Oven 6 meter Precision NA 

I Control 

......_.___.___. ._ ....___.__.__ ._.._...__ ._ ........_._._. .__.._..._.___._.__ ._.___.. ._ ._._._._ ._....._ .__...._...~...._... ..__..___._.._-__..._..__._ .._____. 

Post cure oven 10-12x72G CC[ Thermal 0004-009 ? 

Flash cure and post cure ovens are LPG fired (below permitting threshold) 

VOC POLLUTION CONTROL EQUIPMENT 

HSS is proposing to install a catalytic oxidizer to control emissions from the "front end" process of EU09 [specifically the adhesive 

coater] . The oxidizer is expected to capture 100% of the emissions from the adhesive coater, and to have a destruction efficiency of 

99.0% for VOCs [a destruction efficiency of 95% was assumed in the permit application for emissions calculations] . The minimum 

operating temperature of the cat ox [PCE05] will be determined during performance testing to confirm destruction efficiency. When 

the oxidizer shuts down due to malfunction or for maintenance, or when the "front-end" of EU09 is not in operations, the exhaust from 
- Facility : 

Location : 

AFS #: 

----- 

VOC RACT APPLICATION REVIEW SUMMARY 

- -- -------- ------ ------------- 

m

---- 

. 

-I - I lutchin son Sealing Systems, Inc . En ineer " PRN 

Newfeld Is 

3301500046 ~ Application #: I 11-0156 

---------- - - I---~l--------- Date: January 2 7, 2012 I Page 2 of 4 

the adhesive coater and pre-cure oven will be directed out the existing exhaust stack, bypassing the oxidizer stack. During these times, emission credits will be used for compliance with VOC PACT if required. 

VOC RACT COMPLIANCE (CREDIT USE) CALCULATIONS 

To determine how many [if any] credits are to be used in any month/year, the Facility must calculate the weighted average VOC emissions from all coatings [i .e . adhesives] used, minus water and exempt VOC compounds as applied. 

The Facility is not required to use credits for solvent materials used as cleaners or to the ink [Image ink] used to label parts, and the VOC RACT limit does not apply to these materials. These materials will be addressed in Table 4, Item 7 of the permit (SP-0141) and are limited to 5 tons per consecutive 12-month period . These are considered minor core activities . 

Calculations for adhesive mixture of Chemlok 487A and Chemlok 487B to be used on EU09 after the modification : 

VOC Containine 

Adhesive 

Density (Ib % weight VOC % vol VOC HZ0 

C/eal C) (Ib VOC/Ib C) (Qal VOC/¢al C) M wt % wt 

. 

A  ,7,.22 ' 85.42% 87,62 % 0% 0% Ch

.. . 

em 

. . 

lok 

.. .. 

487 

... ... .. .. . . .. .. . ...... .. . ...._......__ ..~_......._-.-..-__.._.._ ... ._........... . _ .. ......_ ._.._ ..__........._._ ._ .-_.----- , ........._.... ._ ... ... .......... .. . ... . ........... ..... __ ._.. .... Chemlok 487B I 6.71 1 

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

98.02% 98 .43% I 0% 1 0% ._......__ ._ ._ .___._...,._.__ ... ._..._ ._.... ....._._..._ .___

.._._..__._._i_ .. ._.._.__._ .--_-. .... ... .. . .............. .. . ..... .......... _ . Information is from MSDS' provided by the Facility 

Mixture ratio: 100 gal A to 15 gal B; projected usage rate : 74 Ibs CM/day 

Solids (%v) 

11 .5% 

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

1 .5% 

l . Calculation of VOC-emissions from the coating mixture as applied minus water and exempt VOC compounds: 

Chemlok 487A 

7.221bC'A' 0.8542lbVOC 

lC'A' x IbC'A' 

x100ga1C'A'=61716VOC 

ga 

Chemlok 487B 

6.711bC ' B' x 0.980216 VOC x 15galC ' B'= 98.661b VOC ga1C'l3' IbC'B' 

161716 FOC+98 .661b VOCI 

-6.221bs 

VOC minus water & exempt VOC compounds 

115ga1 C, gal C M 

VOC RACT limit = 6.3 lb VOC/gal C as applied minus water & exempt VOC compounds 

2 . Calculation of Emission Standard on a Solids Basis: 

If a coating used by the HSS does not meet the VOC RACT limit, HSS may use the following calculation to bubble emissions: 

E~. 

1- E` 

IdA 

S = VOC emission standard in terms of pounds VOC per gallon of coating solids ; 

Ec = VOC emission limit [6 .3 Ib VOC/gal coating] specified in the VOC RACT Order; 

dA = Actual mass density of the VOC in the applied adhesive formulation [lb VOC/gal VOC]; 

average of the VOC densities of the coatings as follows: 

Chemlok 

487A 

Ethyl 

.~benzenew,Y~- .-~7 .23 

calculated based on a weighted 

Saeciated Densit Dd 

VOC ISVI Ib/ al %wt gal soeciated VOC 

0.701b Xy 7.221b C' A' 505.41b Xy / galC 

= -

X lene 7.1 8 70% lb C' A' 

* 

gal C' A' 

*looga1C'A' 

7.181bC / ga1C - ""'

gal Xy 

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

0.201b EB 7.221b C' A' 144.41b EB * IOOgal C' A'= =19.97gal EB lb C' A' gal C' 20% A' 7.231b /. gal 

Exempt VOCs 

0.01lb CF 7.221b C' A' 7.221b CF * " IOOgaI C'A'= = 0.58ga1 CF Chloroform 12 .35 1% Ib C'A' gal C'A' 12 .351b1 gal 
VOC RACT APPLICATION REVIEW SUMMARY 

Facility : Hutchinson Sealing Systems, Inc. 

Engineer: PRN 

L ti Newfields oca on : 4 

3301500046 Application #: 11-0156 Date: January 27, 2012 Page 3 of 

AFS #: 

Sneciated Densit D~1 

VOC SV Ibl al %wt gal saeciated VOC 

Chemlok 1 .0lb MIBK * 6 .711b C' B' * 15ga1 C' A'- 

100.616 MIBK 

-15 .06ga1 M/BK 

487B MIBK 6.68 100% Ib C'B' gal C' B' 6.68161 gal 

----------------------------------------------------------------------------------------------- 

---------------------------------------------------------------------------------------------------------------- 757.6216 SV 7.1516 VOC 505.41b Xy+144.41b EB+7.221b CF+100.616 MIBK _ 

d" 70.39ga1 Xy+19.97gal EB+0.58ga1 CF+15.06gal MIBK 106ga1 SV gal VOC 

6.316 VOC 1 gal C 

S= - = 52.991b VOClga1 C, solids 

6.31b VOClgal C 

] 1C 7.151b SV / gal C,,, 

3 . Calculation of Allowable VOC Emissions - [E-,] 

W 

E., =S*VS * D m 

Ee, = the allowable VOC emission rate of a given coating [lb/day] ; for each coating or dilution solvent used; 

S = the VOC emission standard [lb VOC/gal of coating solids], as calculated in 2 above [52.99 lb VOC/gal coating 

solids] ; 

Vs = the volume fraction solids content of the coating, [gal solids/gal coating] calculated as follows: 

Chemlok 487A Chemlok 487B 

0.115gal Solids 

x 100ga1 C = 11 .Sgal solids 

0.015gal Solids 

x 15ga1 C = 0.225ga1 solids 

gal C gal C 

Total solids in coating as applied (11.5gal solids + 0.225 gal solids ) x 100 = 10 .2%vol 

115gal C 

W = the weight of coating as applied on the coating line [lb coating/day] ; 

Dm = the density of the coating mixture as applied [lb Cm/gal C], as determined from Method 24 or 24A analysis 

0.102gal C solids ~ C 7416 CM /day ay 52 .99lbVOC » 55 861b VOC l d 

- 

_ . 

* 

EQ~ - ( gal C solids ) C gal C, 7.1616 C, / gal CM 

4. _ Example Calculation of Actual VOC Emissions per Adhesive - E, 

W 

E Q` = W,, * ( D,, 

Wv = weight fraction of VOC in the coating as applied [lb VOC/gal CM] ; 

6.221b VOC 7416 C, l day 64.316 VOC 

E°` gal C, *(7.161b C,y l gal C, ) day 

5. Calculation of Credit Use 

E = Eal - Eac 

55 .861b VOC 64.31b VOC 

E= --- = -8.441b VOC l day 

day day 
Facility : 

Location : 

AFS #: 

------------ - 

VOC RACT APPLICATION REVIEW SUMMARY 

Hutchinson Scaling 

-- ---- ------- - ---------- ------------ -- Systems, Inc. ~ Engineer " 

Ncwfields 

330-1500046-- --_---I_ .Application #: 11-0156 Date: 

PRN 

January 27, 2012 Page 4 of 4 

Since the result of the subtraction is a negative number, it means that actual emissions are greater than allowable emission rates, and emission credits must be used. 

6. Bubble and Use of DERs 

The Facility will be allowed to bubble the emissions from multiple coatings (as applied minus water and exempt VOC compounds) on a daily basis if an adhesive is used that does not meet the 6.3 lb VOC/gallon of coating as applied minus water and exempt VOC compounds, and use ERC's/DERs to offset the excess emissions. 

a. Compliant Coatings: 

Each operating day, when all coatings applied on all lines meet the emission limit of 6.3 Ib/gal of coating as applied minus water and exempt VOC compounds is in use, emission credits do not need to be used . 

b . Non-Compliant Coatings: 

Excess emissions shall be calculated for each coating by subtracting the actual emissions (as applied, minus water and exempt VOC compounds) from the allowable emissions (Ee, - E j. The excess emissions from all the coatings (as applied minus water and exempt VOC compounds) shall be added together (bubbling), and based on the results, one of the following shall be required : 

i . 

ii . 

If the result of the bubble calculation is a positive number, then the source is in compliance with the emission limits and no further action is required ; and 

If the result of the bubble calculation is a negative number, then actual emissions exceed the allowable emission rates and need to be offset with the use of credits; 

The actual ERC's/DERs required shall be calculated by taking the absolute value of the total excess emissions and dividing by an environmental benefit factor of 0.9 . 

VOC RACT CREDIT GENERATION CALCULATIONS 

In accordance with Env-A 3103 .02, the general rule for computation of DERs is as follows: 

"The amount of DERs shall be the difference between: 

(a) The amount of vOC or NOx emissions that would have been emitted from the source during the generation period calculated by multiplying the actual activity levels during that period by the lower of 

(1) The lowest applicable allowable emissions rate ; or 

(b) The amount of actual emissions during the generation period based on actual activity levels during that period" 

(2) The actual emissions rate that would have been emitted based on normal source operation; and 

In this case, the "lowest applicable allowable emissions rate" for credit generation is the lower of: 

The alternative limit (an overall control efficiency of at least 85%) to the VOC emission limit (6 .3 lb/gal) for motor vehicle weatherstrip adhesive listed in Table 1220-1, in accordance with Env-A 1220.02(e) . This is equivalent to a facility-wide emissions rate equal to 15% of uncontrolled emissions; 

a. The emission rate of 3.5 Ib/gal included in conditions D.2 . and D.3 . of RACT Order ARD-O1-002 dated August 8,2002; 

or 

b. An emissions rate of 23 tons/year, in order to preserve the previously agreed upon protocol for calculating the 22 ERCs that HSS receives each year . 

In other words, if HSS exceeds any of the above emissions rates, then no DER credits would be generated. 

Calculation of the uncontrolled facility-wide emissions shall be in accordance with Table 5, Item 4 of the permit (SP-0141). Actual calendar year emissions shall be reported in accordance with Table 7, Item 1 of the permit (SP-0141). The daily allowable emissions rate for credit generation shall be calculated by substituting 3.5 Ib/gal for the VOC RACT limit of 6.3 Ib/gal in the above VOC RACT compliance calculations .