The State of New Hampshir 

Department of Environmental Services 

Mr. Curt Spalding, Administrator 

USEP A Region 1 

5 Post Office Square - Suite 100 

Boston, MA 02109-3912 

Thomas S. Burack, Commissioner 

October 31, 2014 

RE: SIP Revision Proposal for VOC RACT Order 

Parker-Hannifin Corporation, Chomerics Division, Hudson, NH 

Facility ID: 3301100115; RACT Order ARD-03-00lA 

Dear Mr. Spaulding: 

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

submit for your approval a proposed revision to the State Implementation Plan (SIP). An electronic version of 

this submittal, which is an exact duplicate of the paper version, is enclosed on a disk. This revision involves 

the issuance of a volatile organic compound (VOC) Reasonably Available Control Technology (RACT) Order 

in accordance with the New Hampshire Code of Administrative Rules, Env-A 1205, RACT Procedures, and 

Env-A 1207, Paper, Fabric, Film and Foil Substrates Coating, to Parker-Hannifin Corporation, Chomerics 

Division (Chomerics) of Hudson, NH. 

On September 27, 2013, Chomerics filed an application requesting that testing and monitoring 

requirements be amended for determining their Catalytic Oxidizer destruction and removal efficiency (DRE). 

Specifically, Chomerics requested that DRE be determined during the 1st and 3rd quarter of every year. In 

addition, Chomerics requested that the requirement for bed replacement within 8 working shifts of the most 

recent DRE test be revised to within 20 shifts. Chomerics proposed that if bed replacement does not occur 

within 20 shifts, DRE will be assumed to be 0% for the coating operations between the last DRE test and bed 

change out. 

The New Hampshire Department of Environmental Services, Air Resources Division (DES) published 

a public notice of an amended VOC RACT Order in the Union Leader and the Hudson Litchfield News on 

September 11 , 2014. No public comments or requests for a public hearing were received during the 30-day 

comment period. DES finalized the VOC RACT Order and submitted it to USEPA on October 22, 2014. 

This SIP revision proposal includes the following documentation: 

• A copy of the public notice published on September 11 , 2014; 

• Proposed VOC RACT Order letter dated September 11 , 2014; 

• Final RACT Order issuance letter dated October 22, 2014; 

• Final RACT Order ARD03-001A issued on October 22, 2014; and 

• State Permit to Operate SP-0285 issued on October 22, 2014. 

www.des.nh.gov 

29 Hazeh Drive• PO Box 95 •Concord, NH 03302-0095 

(603) 271-3503 •TDD Access: Relay NH 1-800-735-2964 
Parker-Hannifin Corporation, Chomeri..__,...ion 

SIP Revision Proposal for VOC RACT Or 

October3!, 2014 

Page 2 o/2 

DES is hereby withdrawing its SIP regarding VOC RACT Order ARD03-001 , issued to Chomerics 

and published in the Federal Register on November 5, 2012, and submitting VOC RACT Order ARD03-001A 

in its place. 

Should you require further information, please contact Sheila Rydel of the Air Resources Division, 

Permitting and Environmental Health Bureau at (603) 271-7669 or via e-mail at sheila.rydel@des.nh.gov. 

CAW/ssr 

Enclosures: Final RACT Order ARD03-00 lA 

cc: Robert McConnell, USEPA 

Gary L. Wood, Chomerics, w/o enclosures 

Craig A. Wright 

Director 

Air Resource division 
ST A TE OF NEW HAMPSHIRE 

DEPARTMENT OF ENVIRONMENTAL SERVICES 

AIR RESOURCES DIVISION 

CONCORD, NEW HAMPSHIRE 

NOTICE OF PERMIT AND voe RACT ORDER REVIEW, OPPORTUNITY FOR 

PUBLIC HEARING AND COMMENT PERIOD 

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

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

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

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

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

Parker-Hannifin Corporation, Chomerics Division 

16 Flagstone Drive 

Hudson 

For the Following Device(s): 

Coating Operations 

The Order is being amended to allow for modifications to monitoring requirements, testing 

frequency and the determination of Destruction Removal Efficiency (DRE). The applications, 

draft permit, and draft Order are on file with the Director, New Hampshire Department of 

Environmental Services, Air Resources Division, 29 Hazen Drive, P.O. Box 95, Concord, NH 

03302-0095, (603) 271-1370. Information may be reviewed at the office during working hours 

from 8 a.m. to 4 p.m., Monday through Friday. The draft Order and draft permit can be accessed 

electronically through the One-Stop Data and Information portal at http://www.des.nh.gov. 

Additional information may also be obtained by contacting Sheila Rydel at the above address and 

phone number. A request for a public hearing must specify whether the request is for the draft 

permit, draft Order, or both and be received by the Director no later than Monday, October 13, 

2014. A hearing request for the draft permit must be filed in accordance with Env-A 621.06. 

Written comments on the draft permit and/or draft Order must be received no later than Monday, 

October 13, 2014, shall be considered by the Director in making a final decision. 

Craig A. Wright 

Director 

Air Resources Division 

\ 

' \ 
Mr. Gary L. Wood 

Business Manager 

The State of New Hampshirartment of Environmenta 

Thomas S. Burack, Commissioner 

September 11 , 2014 

Parker-Hannifin Corporation, Chcmei-1cs D1.vis1on 

16 Flagstone Drive 

Hudson, New Hampshire 03051 

Re: Draft Permit for Coating Operations and Proposed Amended VOC RACT Order 

Parker-Hannifin Corporation, Chomerics Division 

16 Flagstone Drive, Hudson, New Hampshire 

Facility Identification# 3301100115, Application #s 13-0155, 13-0200 

Dear Mr. Wood: 

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

permit and a proposed, amended VOC RACT Order for the device(s) noted below. A public notice inviting comments on 

the draft permit and proposed VOC RACT Order will be published in the New Hampshire Union Leader and the Hudson 

Litchfield News. 

Close of Comment 

Devices Application Dates Notice Date Period 

Coating Operations August29, 2013 

September 11 ,2014 October 13, 2014 

VOC RACT Order Amendment October 1, 2013 

The application for an amendment to the VOC RACT Order requested modifications to monitoring requirements, 

testing frequency and the determination of Destruction and Removal Efficiency (DRE). 

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

Env-A 621.05 and Env-A 1205.04(a), we are forwarding a copy of the draft permit and proposed VOC RACT Order, and 

public notice to the United State Environmental Protection Agency (USEPA) for their review. We are also forwarding a 

copy of the draft permit and proposed VOC RACT Order to the Town of Hudson for their review. 

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

permit or VOC RACT Order, please contact me at (603) 271-7669 or via e-mail at sheila.rydel@des.nh.gov. 

By certified mail# 701135000001 0293 2491 

Sincerely,_ 

Ai~~~ ~~L- Ji) 1r/J_-L, 

Sheila Rydel 

Senior State Permit Engineer 

Air Resources Division 

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

cc: Donald Dahl, USEPA Region I (via e-mail) 

Michael North, GZA GeoEnvironmental 

Town of Hudson 

www.des.nh.gov 

29 Hazen Drive• PO Box 95 • Concord, NH 03302-0095 

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

D rtment of Environmenta-..ervices 

Thomas S. Burack, Commissioner 

Mr. Gary L. Wood 

Business Manager 

Parker-Hannifin Corporatio~ Chemerics Division 

16 Flagstone Drive 

Hudson, NH 03051 

October 22, 2014 

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

Order ARD-03-001 

Parker-Hannifin Corporation, Chomerics Division, 16 Flagstone Drive, Hudson, NH 

Facility Identification #3301100115, Application #13-0200 

Dear Mr. Wood: 

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

Department of Environmental Services, Air Resources Division (DES), to Parker-Hannifin Corporation, 

Chomerics Division (Chomerics), located in Hudson, NH. The final Order is being issued in accordance with 

the New Hampshire Code of Administrative Rules Env-A 1205, RACT Procedures. 

The Order has been amended to revise the testing and monitoring requirements for the Catalytic 

Oxidizer (CATOX) destruction and removal efficiency (DRE). Specifically, Chomerics requested that DRE be 

determined during the 1st and 3rd quarter of every year. In addition, Chomerics requested that the requirement 

for bed replacement within 8 shifts of the most recent DRE test be revised to within 20 shifts. Chomerics 

proposed that ifbed replacement does not occur within 20 shifts, DRE will be assumed to be 0% for the coating 

operations between the last DRE test and bed changeout. 

If you have any questions, please contact Sheila Rydel of the Air Resources Division, Permitting and 

Environmental Health Bureau at (603) 271-7669 or via e-mail at sheila.rydel@des.nh.gov. 

caw/ssr 

By certified mail #701 1 1570 0003 6777 0291 

Enclosure: Final RACT Order ARD-03-00 I 

cc: Timothy Drew, PIP Office 

Curt Spalding, USEP A 

Town of Hudson 

Michael North, GZA GeoEnvironmental, Inc. 

www.des.nh.gov 

Sincerely, 

do; ttW-ad 

Craig A. Wright 

Director 

Air Resources Division 

29 Hazen Drive• PO Box 95 •Concord, NH 03302-0095 

(603) 271-3503 •TDD Access: Relay NH 1-800-735-2964 
Parker-Hannifin Corporation 

Chomerics Division 

16 Flagstone Drive 

Hudson, NH 03051 

] 

] 

] 

] 

] 

FINAL RACT ORDER ISSUED 

July 18, 2002 

ARD-03-001 

Amended 10/22/2014 

~~~~~~~~~~~~~~ ] 

A. Introduction 

This RACT Order is issued by the New Hampshire Department of Environmental Services, Air 

Resources Division, to Parker-Hannifin Corporation, Chomerics Division (Chomerics), pursuant 

to RSA 125-C. 

B. Parties 

1. The New Hampshire Department of Environmental Services, Air Resources Division (DES), 

is a duly constituted administrative agency of the State of New Hampshire having its 

principal offices at 29 Hazen Drive, Concord, NH 03302, telephone number (603) 271-1370. 

2. Parker-Hannifin Corporation is an Ohio-based corporation with a license to perform business 

in New Hampshire at the mailing address of 16 Flagstone Drive, Hudson, NH 03051-4992, 

telephone number (603) 579-5732. 

C. Statements of Fact and Law 

1. Chomerics owns and operates a facility located on Flagstone Drive in Hudson, NH primarily 

engaged in the production of coated fabrics, films and other substrates for use in electrical 

shielding and thermal management materials in the electronics industry. The following four 

continuous web coaters are utilized at this facility: Faustel horizontal coater, Wolverine I 

horizontal coater, Wolverine II horizontal coater, and Magnat Tower (vertical) coater. Each 

coating station is enclosed in a permanent total enclosure (PTE) that meets the criteria of the 

Code of Federal Regulations 40 CFR Part 51 Appendix M, EPA Method 204. Therefore, 

VOC capture efficiency from the coating operations is assumed to be 100%. The dryer 

exhausts from each of the coaters are connected to a TEC Systems catalytic oxidizer model 

Magnum 1700 ("CATOX"). In addition to the four coaters, the facility has a solvent storage 

room for storage of raw adhesives and solvents used in the coating operation, and a "mixing" 

room, where the various constituents are combined and mixed prior to delivery to the coaters. 

2. Effective August 19, 1995, DES re-adopted the New Hampshire Code of Administrative 

Rules Env-A 1204, Stationary Sources of Volatile Organic Compounds (VOCs) with 

amendments. This chapter defines which facilities are subject to Reasonably Available 

Control Technology (RACT) requirements and specifies these RACT requirements for 

affected facilities. 

3. Chomerics was issued RACT Order ARD-03-001 on July 18, 2002. The RACT Order 

specifies monitoring and testing for the CATOX to determine Destruction Removal 

Efficiency (DRE) and allows the generation and use of Discrete Emission Reductions (DERs) 

or Emission Reduction Credits (ERCs) in order to comply with VOC reduction requirements. 
RA CT Order No. ARD-03-00 ,-.....___. 

Parker-Hannifin Corporation 

October 22, 2014 

Page 2 o/8 

Accordingly, as of January 1, 2014, Chomerics has approximately 45 DER credits in its bank 

to use or sell. 

4. Effective December 31 , 2002, DES re-adopted the New Hampshire Code of Administrative 

Rules Env-A 1204, with amendments. 

5. The coating 9perations, including the CATOX, are currently covered under a State Permit to 

Operate. 

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

amendments. 

7. Chomerics is subject to Env-A 1207 , Paper, Fabric, Film and Foil Substrates Coating, 

because their actual emissions, before controls, equal or exceed 3 tons of non-exempt voes 

during any consecutive 12-month period. 

8. On September 27, 2013, Chomerics submitted an application, requesting that testing and 

monitoring requirements specified in ARD-03-001 D.l. be amended for the CATOX 

destruction and removal efficiency (DRE). Specifically, Chomerics requested that DRE be 

determined during the 1st and 3rd quarter of every year. In addition, Chomerics requested that 

the requirement for bed replacement within eight (8) 8-hour shifts of the most recent DRE 

test be revised to within 20 shifts. Chomerics proposed that if bed replacement does not 

occur within 20 shifts, DRE will be assumed to be 0% for the coating operations between the 

last DRE test and bed changeout. 

9. On January 30, 2014, Chomerics submitted a request to limit VOC emission less than 25 tons 

per year to opt out of the V OC Limitations in Table 1207-1. 

10. On March 20, 2014, Chomerics submitted a revised Air Pollution Control Equipment 

Monitoring Plan which clarifies that the inlet temperature to the catalyst bed is continuously 

monitored, not the catalyst bed. 

D. Order 

Based on the statements of fact and law, DES hereby orders Chomerics, effective upon issuance 

of this order, to comply with the following requirements as RACT: 

1. Periodic Monitoring Program 

Chomerics shall conduct monitoring, as detailed below, in order to determine VOC DRE of 

the CATOX system. 

a. The following monitoring shall be conducted during DRE testing. The monitoring 

program will consist of simultaneously determining the nonmethane volatile organic 

compound ("NMVOC") concentration in both the combined inlet duct to the CATOX 

downstream of the induced draft fan and in the stack. The total VOC concentration at 

both locations will be monitored for one hour with Total Hydrocarbon ("THC") Flame 

Ionization Detection ("FID") analyzers operating according to EPA Method 25A. The 

methane concentration in the outlet gas stream will be determined either by collecting a 

bag sample and quantifying the methane concentration via a Gas Chromatograph 

("GC")/FID or with the hydrocarbon analyzer operating in the methane only mode. 
RACT Order No. ARD-03-00 

Parker-Hannifin Corporation 

October 22, 2014 · 

Page 4 o/8 

(i) "S" means the VOC emission standard in terms oflb VOC/gal or kg VOC/l of 

coating solids, as calculated in Part D.2, above; 

(ii) "W" means the weight of coating or dilution solvent used in the coating line on a 

given day in units of lbs/day or kg/day; 

(iii) "D" means the density of the coating or dilution solvent in units of lbs/gal coating, or 

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

(iv) "VS" means the volume fraction solids content of the coating, in units of gal 

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

formulation; and 

(v) " Ea1" shall be equal to the product of S, VS and W divided by D for each coating or 

dilution solvent used, as in the following equation: 

Ea1 = S*VS*(W/D) 

b. Calculation of Daily DRE of the CATOX 

Chomerics shall calculate a value for the DRE of the CATOX for each day in which the 

CATOX operates, using the results of DRE testing as specified in Part D.l. 

I. DRE for days between the previous DRE test, and i.ncluding the date of the most 

recent DRE test will be the lower of the most recent DRE test result, and the lowest 

previous DRE test result for the same catalyst bed. In cases where there is a DRE 

drop between the previous and most recent DRE test, DRE drop can be 

proportioned linearly among oxidizer operating days, providing there is not a lower 

previous DRE test for the same catalyst bed. 

IL DRE for the period immediately following the installation of a fresh catalyst bed 

will be determined as follows: the results of the first test conducted on the system 

shall be applied backwards to the date that the fresh bed was installed. 

c. Calculation of Actual VOC Emissions per Coating per Day 

The daily VOC emissions shall be calculated for each coating as follows: 

(i) "Eac" means the actual VOC emission rate of a given coating in units of lbs/day or 

kg/day; 

(ii) "W" means the weight of coating or dilution solvent used in the coating line on a 

given day in units of lbs/day or kg/day; 

(iii) "WV" means the weight fraction of VOC content of the coating, in units oflbs 

VOC/lb coating or kgs VOC/kg coating as determined by calculation using the 

formulation; 

(iv) "DRE" means the destruction removal efficiency of the CATOX calculated using the 

method described in Part D.3 .b, above; and 
RACTOrder No. ARD-03-

Parker-Hannifin Corporation 

October 22, 2014 

Page 3 of8 

Alternatively, a second THC analyzer operating in the methane only mode will analyze a 

slipstream from the main sample line. 

b. DRE testing shall occur during the 1st quarter (January - March) and the 3rd quarter 

(August - October) of every year. 

c. In order to determine the lowest DRE achieved prior to replacement of the catalyst bed, 

testing will be conducted within twenty, 8-hour work shifts prior to the replacement of 

the spent catalyst with new catalyst. If testing is not conducted within twenty, 8 hour 

work shifts prior to catalyst replacement, Chomerics will assume 0% DRE for the coating 

operations between the last DRE test and bed changeout. 

d. Chomerics shall operate and maintain equipment to continuously monitor and record the 

inlet temperature of the catalytic incinerator bed. 

2. Calculation of Emission Standard for Sources Complying with VOC RACT Using Add-On 

Pollution Control. 

a. For those Chomerics processes that use add-on pollution control to achieve compliance 

with Env-A 1205.01 , the overall emission standard shall be calculated as follows: 

(i) "S" means the VOC emission standard in terms of pounds VOC per gallon 

(lb VOC/gal) of coating solids, or kilograms VOC per liter (kg VOC/l) of coating 

solids; 

(ii) "Ee" means the VOC emission standard in terms of lb VOC/gal or kg VOC/l of 

coating, minus water and exempt compounds, obtained from the appropriate section 

ofEnv-A 1207; and 

(iii) "dA" means the actual mass density of the VOC in the applied Surface Coating 

formulation in terms oflb/gal or kg/l. For those stationary sources that have multiple 

coating lines feeding add-on control equipment, dA means the weighted-average 

actual mass density of the voe in the applied surface coatings in terms oflb/gal or 

kg/l. 

(iv) S shall be equal to Ee divided by the difference between one and the quotient of Ee 

and dA, as in the following equation: 

Ee S=----

[l -Ec / dA] 

3. Emissions Calculation for the Generation and Use of Emission Credits 

Chomerics shall use the simultaneous generation and use of emission credits, along with the 

calculations described in Part D.3.a through d, below, as a means of complying with the VOC 

RACT requirements ofEnv-A 1207. 

a. Calculation of Allowable VOC Emissions per Coating per Day 

The daily allowable VOC emissions shall be calculated for each coating as follows: 

(i) "Ea1" means the allowable VOC emission rate of a given coating in units of lbs/day or 

kg/day; 
. . RACT Order No. ARD-03-

Parker-Hannifin Corporatio 

October 22, 2014 

Page 5 of8 

(v) "Eac" shall be equal to the product of Wand WV multiplied by the DRE subtracted 

from one, as in the following equation: 

Eac = W*WV*(l-DRE) 

d. Emission Credit Use and Generation Calculations 

Chomerics shall.subtract the actual VOC emission rate (Eac) from the allowable VOC 

emission rate {Ea t~ determine if emission credits will be used or generated on a given 

day using the following criteria. 

(i) If the result of the subtraction is a positive number, then the emissions are below the 

requirements ofVOC RACT and the amount equal to the difference between Ea1 and 

Eac will count towards emissions credits; 

(ii) If the result of the subtraction is a negative number, then the emissions exceed the 

VOC RACT requirements and emission credits equal to the difference between Ea1 

and Eac shall be used to offset these excess emissions. 

(iii) Chomerics shall determine the overall generation or usage of credits for each 

operating day by adding the results of the calculations specified in 3.d.(i) and (ii) for 

each coating used that would be defined as a non-compliant coating per 

Env-A 1203.52, Definitions, prior to control. 

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

emissions determined by the method specified in 3.d.(iii) and multiplying them by a 

safety factor of 0.9. 

(v) To calculate the amount of credits needed to offset excess emissions the excess 

emissions determined by the method specified in 3.d.(iii) will be divided by an 

environmental impact factor of 0.9. 

4. Bypass Operating Program 

a. Emissions from compliant coatings, as defined in Env-A 1202.38, Definitions, do not 

require add-on controls to meet VOC RACT requirements. Therefore, Chomerics shall 

be allowed to bypass these emissions from the CA TOX. 

b. Records shall be maintained as required in Part D.5 to show that all bypassed coatings 

meet the requirements ofVOC RACT without add-on controls. 

c. Bypassed coatings shall not be used to generate emission credits. 

5. Recordkeeping Requirements 

Chomerics shall maintain the following records in order to show compliance with this Order. 

Each record shall be kept for a period of at least five years. 

a. All coatings used at the facility after the issuance of this RACT order shall be either 

tested using Methods below or the facility will retain sufficient records for prima facie 

evidence in support of demonstrating compliance with the VOC RACT limit. 
RACT Order No. ARD-03-00 

Parker-Hannifin Corporation 

October 22, 2014 

Page 6 of8 

(i) Method 24, 40 CFR Part 60, Appendix A at I-hour bake time, or an alternative test 

method approved by the Director and EPA; or 

(ii) Method 24A, 40 CFR Part 60, Appendix A, or an alternative test method approved 

by the Director and EPA. 

(iii) The testing required above will be required for existing coatings used at the facility 

at the time that the coating is first ordered or used after the issuance of this RACT 

-Order. Chomeriecs cshaH have 30 days from the time that the coating is first used after 

the issue date of this order to certify the voe content of the coating. 

c. All DRE test data and results conducted in conjunction with Part D. l ; and 

d. Daily records of coatings used in the coating process. 

e. Records of all calculations, as detailed in Part D .3. 

6. Work Practice Standards 

Chomerics shall comply with the work practice standards specified in Env-A 1207.02. VOC 

emissions from cleaning materials shall be controlled using the following work practices: 

a. Storing VOC-containing cleaning materials in closed containers; 

b. Keeping mixing and storage containers closed at all times except when depositing or 

removing VOC-containing materials; 

c. Minimizing spills of VOC-containing cleaning materials; 

d. Conveying VOC-containing cleaning materials from one location to another in closed 

containers or pipes; and 

e. Minimizing VOC emissions from the cleaning of storage, mixing, and conveying 

equipment. 

E. Emissions Reductions Credits 

1. Chomerics shall be allowed to use discrete emissions reductions (DERs) or emissions 

reductions credits (ERCs) for the purpose of satisfying the requirements ohhis Order by 

acquiring DERs or ERCs on the open market or by self-generating DERs or ERCs in 

accordance with Env-A 3000, Emissions Reduction Credits Trading Program and 

Env-A 3100, Discrete Emissions Reduction Trading Program . ... 

2. This Order grants approval to Chomerics to use those DERs or ERCs in accordance with the 

procedures described in Env-A 3000 and Env-A 3100. 

3. Chomerics shall acquire additional DERs if at least one full credit for each season is not 

available in the bank. If at any time, DERs are needed to show compliance with this order, 

Chomerics shall submit the requisite notices to DES. 

4. Annually by November 30, Chomerics shall submit a report to DES on the projected use of 

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

Notice of Intent to Use DERs, including the following information: 

a. The name and location of the user (Chomerics); 
RACT Order No. ARD-03-0 

Parker-Hannifin Corpo1;ati---

October 22, 20 J 4 

Page 7 of8 

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

(Chomerics) to the State (for paperwork reduction purposes, a certified statement that the 

notice is on file with DES will suffice); 

c. The protocol, including sample calculations, used to document the amount of DERs 

needed to demonstrate compliance; and 

d. A certified statement attesting that Chomerics is in compliance with Env-A 1400, 

Regulated Toxic Air Pollutants. 

5. Annually by April 15, Chomerics shall submit a report to DES on the balance of credits for 

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

and Certification of Generation and Env-A 3104.09, Notice and Certification of Use , 

including the following information: 

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

b. A brief description of the generation activity; 

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

d. The amount of DERs generated each month; 

e. A calculation of the amount ofDERs generated; 

f. The amount of DERs used each month; 

g. A calculation of the amount of DERs required to demonstrate compliance with the 

emission limits stated in Part D, above; 

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

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

pursuant to Env-A 3103.07; 

J. A statement that due diligence was made to verify that the DERs were not previously 

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

provisions of law; 

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

other provisions of law; and 

I. The report shall contain a certification by a responsible official that states: 

I. Based on information and belief formed after reasonable inquiry, the staterrients and 

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

11. The user source is in compliance with all National Ambient Air Quality Standards, 

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

Pollutants. 
RA CT Order No. ARD-Ol-00 

Parker-Hannifin Corporation 

October 22, 2014 · 

Page 8 o/8 

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

following: 

Air Permit Programs Manager 

NHDES, Air Resources Division 

Bureau --of Permiitmg and Environmental Health Permitting 

29 Hazen Drive · 

P.O. Box 95 

Concord, NH 03302-0095 

(603) 271-2630 

Please address any correspondence and communication in reference to the ERCs or DERs to the 

following: 

Mr. Joseph Fontaine 

NHDES, Air Resources Division 

29 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

(603) 271-6794 

cc: Timothy Drew, PIP Office 

Curt Spaulding, USEPA 

Town of Hudson 

Craig A. Wright 

Director 

Air Resources Division 
State of New Ham psi,.__,,_, 

Department of Environmental Services 

Air Resources Division 

State Permit to Operate 

Permit No: SP-0285 

Date Issued: October 22, 2014 

This certifies that: 

Parker-Hannifin Corporation 

77 Dragon Court 

Woburn, MA 01888 

has been granted a State Permit to Operate for: 

Coating Operations 

at the following facility and location: 

Parker-Hannifin Corporation, Chomerics Division 

16 Flagstone Drive 

Hudson, NH 03051 

Facility ID No: 3301100115 

Application No: 13-0155, permit renewal received August 29, 2013 

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

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

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

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

accompanied by the appropriate permit application forms. 

This permit is valid upon issuance and expires on October 31, 2019. 

Director . 

Air Resources Division 
SP-0285 

Parker-Hannifin Corp., Chomerics Division 

Abbreviations and Acronyms 

AAL Ambient Air Limit 

acf 

ags 

ASTM 

Btu 

CAS 

cfm 

CFR 

co 

DER 

DES 

Env-A 

ERC 

ft 

ft3 

gal 

HAP 

hp 

hr 

kW 

lb 

LPG 

MM 

MSDS 

MW 

NAAQS 

NG 

NOx 

NSPS 

PMIO 

ppm 

psi 

PTE 

RACT 

RSA 

RTAP 

scf 

S02 

TSP 

tpy 

USEPA 

voe 

actual cubic foot 

above ground surface 

American Society of Testing and Materials 

British thermal units 

Chemical Abstracts Service 

cubic feet per minute 

Code of Federal Regulations 

Carbon Monoxide 

Discrete Emission Reduction 

New Hampshire Department of Environmental Services 

New Hampshire Code of Administrative Rules -Air Related Programs 

Emission Reduction Credit 

foot or feet 

cubic feet 

gallon 

Hazardous Air Pollutant 

horsepower 

hour 

kilowatt 

pound 

Liquified Petroleum Gas 

million 

Material Safety Data Sheet 

megawatt 

National Ambient Air Quality Standard 

Natural Gas 

Oxides of Nitrogen 

New Source Performance Standard 

Particulate Matter < 10 microns 

parts per million 

pounds per square inch 

Permanent Total Enclosure 

Reasonably Available Control Technology 

Revised Statutes Annotated 

Regulated Toxic Air Pollutant 

standard cubic foot 

Sulfur Dioxide 

Total Suspended Particulate 

tons per consecutive 12-month period 

United States Environmental Protection Agency 

Volatile Organic Compound 

Page 2of15 
I. Facility Description 

SP-0285 

er-Hannifin Corp., Chomerics 

Page 3of15 

Chomerics, a division of Parker Hannifin Corporation (Chomerics), located in Hudson, New Hampshire, 

performs coating of various web substrates including nylon fabric, Mylar film, paper, copper, aluminum, 

stainless steel and fiberglass cloth. The primary sources of emissions are web coating lines and the 

associated dispensing, mixing, and cleaning operations. 

II. Emission Unit Identification 

This permit covers the devices identified, in Table 1: 

EUOJ Faustel Horizontal Coater 1970 56.3 square feet per minute of web 

EU02 Wolverine I Horizontal Coater 1974 79.2 square feet per minute of web 

EU03 Wolverine II Horizontal Coater 1998 56.3 square feet per minute of web 

EU04 Magnat Vertical Coater 1991 175.0 square feet per minute of web 

EU05 Mixing Area na na 

EU06 Chemical Storage Rooms I and 2 na na 

III. Pollution Control Equipment Identification 

Air pollution control equipment listed in Table 2 shall be operated in order to meet permit conditions. 

PCEOl Catalytic Oxidizer EUOl -EU04 

IV. Stack Criteria 

The following devices at the Facility shall have exhaust stacks that discharge vertically, without 

obstruction, and meet the criteria in Table 3: 

. . .. . . 

Emission Unit or Pollution Maximum J!:xit , 

,-·.•. ·-·-,· Control Eq~ipl11ent ID Diaineter (feet) 

4-

PCEOJ 49 3.0 

2 EUO 1 (bypass stack) 29 1.17 

3 EU02 (bypass stack) 28 2.0 

4 EU03 (bypass stack) 29 1.33 

5 EU04 (bypass stack) 63 1.33 

6 EU06 (Chemical Storage Room 1) 23 0.75 

7 EU06 (Chemical Storage Room 2) 15.5 1.49 

8 EUOS 25 1.22 
SP-0285 Page 4of15 

Parker-Hannifin Corp., Chomerics Division 

V. Operating and Emission Limitations 

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

2 

3 

4 

5 

Facility-Wide Emission Limitations 

a. Facility-wide emissions of VOCs shall be limited to less 

than 25 tpy1

; and 

b. Facility-wide emissions of HAPs shall be limited to less 

than l 0 tpy for any individual HAP and 25 tpy for all 

HAPs combined. 

2 

24-hour and Annual Ambient Air Limit 

The emissions of any Regulated Toxic Air Pollutant (RT AP) 

shall not cause an exceedance of its associated 24-hour or 

annual Ambient Air Limit (AAL) as set forth in Env-A 

1450.0 l, Table Containing the List Naming All Regulated 

Toxic Air Pollutants. 

Revisions of the List ofRTAPs 

In accordance with RSA 125-1:5 IV, if the Division revises 

the list ofRTAPs or their 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. 

Facility Wide 

Facility Wide 

Facility Wide 

Visible Emission Standards EUOl - EU06 

The average opacity shall not exceed 20 percent for any 

continuous 6-minute period. 3 

Each of the four coaters shall be operated at all times within EUO l - EU04 

a Permanent Total Enclosure (PTE) that meets the criteria of 

40 CFR 51 Appendix M, Method 204. 

Env-A 604.02(a)(I) 

Env-A 1207.03(c) 

Env-A 1400 

(State-only Enforceable 

Limit) 

EnvA 1404.02 

(State-only Enforceable 

Limit) 

Env-A 2103.02 

Env-A 604.0 I 

I The Facility has the potential to emit voes at levels greater than the major source threshold for this pollutant of50 tpy. The 

annual emission limit is Jess than this threshold and establishes the Facility as a synthetic minor source of air pollution for VOCs. 

In addition, the annual limit in Table 4, Item la is less than the threshold stated in Env-A 1207.03(c) as allows the source to opt out 

of the VOC emission limits stated in Table 1207-1. 2 The Facility has the potential to emit HAPs at levels greater than the major source threshold for these pollutants 25 tpy for total 

HAPs and I 0 tpy for any individual HAP. The annual emission limits in Table 4, Item I b are less than these thresholds and 

establish the Facility as a synthetic minor source of air pollution for HAPs. The Facility does not have the potential to emit the 

criteria pollutants NOx, S02, CO and PM at levels greater than the major source thresholds for these pollutants. Therefore the 

Facility is a true minor source for NOx, S02, CO, and PM. 3 Compliance with visible emission limitations shall be determined using 40 CFR 60, Appendix A, Method 9, or other Division 

approved method, upon request by the Division. 
Item# 

6 

7 

8 

SP-0285 

er-Hannifin Corp., Chomerics 

Pollution Control Equipment Operation and Maintenance PCEO l 

a. The inlet to the catalytic oxidizer bed shall be 

maintained at a minimum temperature of 500°F; and 

b. The Catalytic Oxidizer shall be operated and maintained 

in accordance with the requirements of the RACT Order 

ARD-03-001 , and in accordance with the Air Pollution 

Control Equipment Monitoring Plan submitted with 

application 13-0155 and any updates made in accordance 

with Table 7, Item 5. 

Applicability Criteria and Compliance Standards for EUOl -EU04 

Coating o[Paper. Fabric, Film and Foil Substrates 

The Coaters shall be equipped with add-on control 

equipment in accordance with Condition III and comply with 

a solids-based emission rate limit calculated using the 

procedure of Env-A 1204.04( d), Determination of Emissions, 

and the following equation: 

where: 

S = The VOC emission rate limit in terms of lb/gal of 

coating solids; 

dA = The actual mass density of voe in the applied surface 

coating formulation in terms of lb/gal; and 

Ee= The emission rate limit prescribed for the applicable 

coating category as calculated on a coatings basis, in 

terms of lb VOC/gal of coating, as applied to the 

substrate. For a paper, fabric, film or foil coating 

operation that has a TPE equal to or greater than I 0 

tons per consecutive 12-month period, but less than 25 

tons per consecutive 12-month period, Ee shall be equal 

to 2.9 lb VOC/gal of coating, as applied to the 

substrate. 

Applicability Criteria and Compliance Standards for 

Coating of Paper. Fabric. Film and Foil Substrates 

The Owner or Operator shall be allowed to generate and use 

Discrete Emissions Reduction Credits (DERs) for the 

purpose of complying with the requirements of VOC RACT 

pursuant to RACT Order ARD03-00J. 

EU01 - EU04 

Page 5of15 

Env-A 604.01 

Env-A 1205.01 

Env-A 1205.02(b) 
9 

SP-0285 

Parker-Hannifin Corp., Chomerics Division 

'Requirement 

' , 

Work Practice Standards for Cleaning Materials Used in 

Coating of Paper, Fabric, Film and Foil Substrates 

voe emissions from cleaning materials shall be controlled 

using.the following wm:k-pr.actires: 

a. Storing VOC-containing cleaning materials in closed 

containers; 

b. Keeping mixing and storage containers closed at all 

times except when depositing or removing VOCcontaining materials; 

c. Minimizing spills ofVOC-containing cleaning materials; 

d. Conveying VOC-containing cleaning materials from one 

location to another in closed containers or pipes; and 

e. Minimizing VOC emissions from the cleaning of storage, 

mixing, and conveying equipment. 

EU01 -EU06 

Page 6of15 

Env-A 1207.02 

VI. Monitoring and Testing Requirements 

2 

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

To Be When conditions warrant, the Division may 

Determined require the Owner or Operator to conduct 

stack testing in accordance with USEP A or 

other Division approved methods. 

Catalytic 

Oxidizer 

Temperature 

a. Monitor and record the temperature of the 

inlet to the catalytic oxidizer bed. 

b. If the temperature reading is less than the 

minimum specified in Table 4, Item 6.a, 

then immediately inspect the unit and 

take corrective action to raise the 

temperature. 

4 

Upon request 

by the 

Division 

Continuous 

As noted 

Facility 

Wide 

PCEOl 

RSA 125-

C:6, XI 

Env-A 906 

The coaters are automatically shutdown when the oxidizer inlet temperature is below 500 °F. lfrepairs or corrective action 

cannot be taken immediately, the catalytic oxidizer will be shutdown until corrective actions are implemented. 
3 

4 

Catalytic 

Oxidizer 

Inspection 

SP-0285 . 

Parker-Hannifin Corp., Chomerics 

':.t . 

·Method, ~f C.ompliance 

Conduct a visual external integrity inspection 

of the catalytic oxidizer. 

a. The inspection shall include an 

evaluation of whether all emissions are 

being vented tnrougb fue dedicated stack 

exit. 

b. The inspection shall be conducted by 

plant personnel familiar with the 

operation of the oxidizer and associated 

equipment. 

VOC Control Conduct emissions testing to evaluate 

Efficiency compliance with VOC RACT requirements. 

Testing shall be conducted in accordance 

with RACT Order ARD-03-001 

VII. Recordkeeping Requirements 

Annually and 

as conditions 

indicate 

inspection is 

warranted 

Pursuant to 

the schedule 

contained in 

RACT Order 

ARD-03-001 

PCEOI 

PCEOI 

Page 7of15 

RSA 125-

C:6, XI 

Env-A 802 

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

Record Retention and Availability 

Keep the required records on file. These records shall be 

available for review by the Division upon request. 

2 General Recordkeeping Requirements for Process 

Operations 

3 

Maintain the following records for process operations: 

a. Total quantity of raw materials containing VOCs or 

RTAPs; 

b. Total quantity of fuel combusted in the coating process 

dryers; and 

c. Hours of operation of each process. 

VOC Emission Statements Recordkeeping Requirements 

If the actual annual VOC emissions from the Facility are 

greater than or equal to I 0 tpy, then record the following 

information: 

a. Identification of each VOC-emitting process or device; 

b. The operating schedule during the high ozone season 

(June I through August 31) for each VOC-emitting 

process or device identified in Table 6, Item 3a. above, 

including: 

I. Typical hours of operation per day; and 

2. Typical days of operation per calendar month. 

Retain for a 

minimum of 

5 years 

Monthly 

Maintain 

Data for 

Annual 

Report 

Facility 

Wide 

EUOIEU06 

EUOIEU06 

Env-A 902 

Env-A 903.02 

Env-A 904 
SP-0285 

Parker-Hannifin Corp., Chomerics Division 

·, F , 

Requirement 5 · ., · · " ' ' =, ;.:<> '. ,, . ' 

3 c. The following VOC emission data from all VOC-

( cont.) emitting processes or devices identified in Table 6, Item 

3.a above, including: 

4 

J . Actual VOC.emissfon.s for; 

i. The calendar year, in tons; and 

ii. A typical high ozone season day during that 

calendar year, in pounds per day; and 

2. The emission factors and the origin of the emission 

factors used to calculate the voe emissions. 

VOC Recordkeeping (or Surface Coating and Printing 

Operations 

If the actual annual VOC emissions from the Facility are 

greater than or equal to 10 tpy, then record the following 

information for each coating operation identified in Table 6, 

Item 3, above: 

a. Coating formulation and analytical data, as follows: 

1. Supplier; 

2. Name and color; 

3. Type; 

4. Identification number; 

5. Density described as lb/gal; 

6. Total volatile content described as weight percent; 

7. Water content described as weight percent; 

8. Exempt solvent content described as weight 

percent; 

9. voe content described as volume percent; 

10. Solids content described as volume percent; 

11. Diluent name and identification number; 

12. Diluent solvent density described in lb/gal; 

13. Diluent VOC content described as weight percent; 

14. Diluent exempt solvent content described as weight 

percent; 

15. Volume of diluent VOC described as gal; and 

16. Diluent/solvent ratio described as gal diluent 

solvent per gal coating. 

b. The number of gallons of each coating, including 

solvents and diluents, utilized during a typical high 

ozone season day; and 

c. Process information for a typical high ozone season 

day, including: 

1. Method of application; 

2. Number of coats; 

3. Drying method; and 

4. Substrate type and form. 

Maintain 

Data for 

Annual 

Report 

EU01 -

EU06 

Page 8of15 

Env-A 904.03 
5 

6 

SP-0285 

er-Hannifin Corp., Chomerics 

., ;.· ,., ~equire.ii'~nt. " · }. ·' . ~ .,..• ....... . 

Format for Recording Information 

The information recorded pursuant to Table 6, Item 4 shall 

be recorded on standard forms included in the 

Recordkeeping Guida.nee Docume,l)t for Surface Coating 

Operations and the Graphic Arts Industry, USEPA, July 

1988, or alternative forms that contain all the data recorded 

pursuant to Table 6, Item 4. 

Recordkeeping for Devices with Add-on VOC Air Pollution 

Control 

If the actual annual voe emissions from the Facility are 

greater than or equal to 10 tpy, then record the following: 

a. The air pollution control device identification number, 

type, model number and manufacturer; 

b. Installation date; 

c. Processes or devices controlled; 

d. The type and location of the capture system, capture 

efficiency percentage, and method of determining 

capture efficiency; 

e. Information as to whether or not the control device is 

always in operation when the processes or devices are in 

operation; 

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

control equipment, including: 

1. Destruction removal efficiency, in percent; 

2. Date tested; 

3. The emissions test results, if tested, including: 

i. The inlet voe concentration in ppm; 

ii. The outlet voe concentration in ppm; and 

iii. The method of determination of the 

concentrations in a and b above; and 

4. The method of determining destruction efficiency, if 

not tested; 

g. For the catalytic oxidizer: 

1. The design exhaust gas temperature in degrees F; 

2. The design temperature rise across the catalyst bed 

in degrees F; 

3. The anticipated frequency of catalyst change; and 

4. Any actual catalyst changes. 

Maintain 

Data For 

Annual 

Report 

Maintain 

Data for, 

Annual 

Report 

EUOJ -

EU06 

PeEOl 

Page 9of15 

Env-A 904.04 

Env-A 904.07 
SP-0285 Page 10of15 

Parker-Hannifin Corp., Chomerics Division 

7 Regulated Toxic Air Pollutants Update Facility Env-A 902.01 

Maintain records documenting compliance with Env-A prior to Wide (State-only 

1400. process Requirement) . changes and Compliance was demonstrnted-"1!t'tbe'time of:-permit within 90 issuance as described in the Division's Application Review days of each Summary for application 13-0155. The source must update revision of the compliance demonstration using one of the methods Env-A 1400 provided in Env-A 1405 if: 

a. There is a revision to the list of RTAPs lowering the 

AAL or Deminimis Value for any 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., use of a coating will increase); 

c. An RTAP that was not evaluated in the Application 

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

will be used); or 

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

9 Additional Recordkee12.ing Requirements: Pollution control As specified PCEOl Env-A 906 

equi12.ment in Table 5 

Maintain records of all air pollution control equipment 

activities required in Table 5, including: 

a. All test data for testing conducted pursuant to RACT 

Order ARD-03-001; 

b. Temperature readings of the catalytic oxidizer; 

c. Air pollution control equipment maintenance activities, 

including catalysts changes and annual inspections; and 

d. Corrective actions taken to raise the temperature of the 

inlet to the catalytic oxidizer bed. 

10 Additional RecordkeeQing Requirements: Facility_-wide Monthly Facility Env-A 906, 

emission limitations wide Env-A 

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

emissions ofVOCs and HAPs, which shall include and 

emissions from non-permitted devices, for the purpose of Env-A 

demonstrating that the total emissions of these pollutants 1207.03{c) 

are below the emission limitations in Table 4, Item 1. 

11 NSPS Recordkee12.ing Requirements fjJr Pressure Sensitive Maintain EU03 40CFR 

Taee and Label Sur[_ace Coating 0Qerations current data 60.445(d) 

Maintain records. of actual 12-month VOC used for the (Subpart RR) 

manufacture of pressure sensitive tapes and label surfaces. 
12 

SP-0285 

er-Hannifin Corp., Chomerics 

NSPS RecordkeepingRequirements for Polymeric Coating 

of Supporting Substrates 

Maintain the following records: 

a. Semiannual estimates _Q(.p_rQ,iected annual VOC to be 

used for the manufacture of polymeric coated 

substances; and 

b. Actual I 2-month VOC used for the manufacture of 

polymeric coated substances. 

. Frequency 

Maintain EU03, 

current data EU04, and 

EU05 

Page 11 of 15 

40CFR 

60.744(b) 

(Subpart 

VVV) 

VIII. Reporting Requirements 

A. Pursuant to Env-C 203.02(b), Date of Issuance or 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. 

Annual Emissions Report 

Submit an annual emissions report which shall 

include the following information: 

a. Actual calendar year emissions from each 

emission unit of NOx, CO, S02, TSP and VOCs 

(coating materials speciated by individual 

VOC), HAPs (coating materials speciated by 

individual HAP), and RTAPs (coating materials 

speciated by individual RTAP); 

b. The methods used in calculating such emissions 

in accordance with Env-A 705 .02, 

Determination of Actual Emissions for Use in 

Calculating Emission-Based Fees; and 

c. All information recorded in accordance with 

Table 6, Item 2. 

Annually (no later 

than April 15th of 

the following year) 

EUOl -

EU06 

Env-A 907.01 
2 

3 

4 

SP-0285 

Parker-Hannifin Corp., Chomerics Division 

VOC Emission Statements Reporting Requirements 

If the actual annual VOC emissions for th_e Facility 

are greater than or equal to.l-0 ~Y~ .then,.jncludeJ:he 

following information with the annual emission 

report: 

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, Item 3. 

Additional Reporting Requirements 

Submit a report detailing the results of all testing 

conducted in accordance with RACT Order ARD03-001. 

Update to Air Pollution Dispersion Modeling 

Impact Analysis 

If an update to the facility's air pollution dispersion 

modeling impact analysis is required pursuant to 

Env-A 606.02, submit the information required 

pursuant to Env-A 606.04: 

a) With the permit application submitted for the 

change which triggered the analysis; or 

b) Within 15-days of completion of the change 

which triggered the analysis, if a permit 

application is not required. 

Annually (no later 

than April 15th of 

the following year) 

Annually (no later 

than April 15th of 

the following year) 

As specified 

EU01-

EU06 

PCEOl 

Facilitywide 

Page 12of15 

Env-A 908 

Env-A 910 

Env-A 910.01 
' 

SP-0285 Page 13of15 

er-Hannifin Corp., Chomerics 

:· t 

Item . '-

' # .. .. FreqU:enc~ 

t> ''i;\<'. ~- .;i 

5 Site SJ2.ecifj_c Monitoring Plan Within 30 days of PCEOJ Env-A 810.01 

The Owner or Operator shall submit an air pollution any change to the 

· control equipment monitoriq,gplan for each piece of plan 

air pollution control equipment which shall include: 

a. The type of control device; 

b. The manufacturer; 

c. The model and serial number (if known); 

d. The pollutant(s) controlled; 

e. A description of the control device and how it 

operates in the process; 

f The capture efficiency of the device and its 

method of determination; 

g. The control efficiency of the device and its 

method of determination; 

h. The operational parameters of the devices that 

are or will be monitored, such as temperature, 

pressure, differential pressure, pH, and 

flowrate; 

I. The normal range for each parameter 

monitored, and the range of each parameter 

during startup or shutdown conditions if 

different; and 

J. A catalyst management plan which describes 

the method for determination of catalyst 

activity and frequency of catalyst replacement. 

6 Permit Deviation Reeorting Requirements Within 24 hours of EUOl- Env-A 

Report permit deviations that cause excess discovery of excess EU06 911.04(b) 

emissions in accordance with Condition IX.B. em1ss1on 

7 Emission Based Fees Annually (no later EUOJ- Env-A 700 

Pay emission-based fees in accordance with than April 15th of EU06 

Condition XII. the following year) 

IX. 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. 
SP-0285 Page 14of15 

Parker-Hannifin Corp., Chomerics Division 

B. Env-A 91 l.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. 

X. 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. 

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 does not qualify as 

either an administrative or significant amendment. 

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

include the following: 

a. A description of the proposed change; and 

b. A description of any new applicable requirements that will apply ifthe change occurs. 

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

the minor permit amendment, but shall be subject to enforcement ifthe Division later determines 

that the change violated any applicable state or federal requirement. 

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 prior 

to the implementation of any proposed change which meets one of the following: 

a. Any proposed change that results in the following: 

i. Any increase in allowable hourly or annual emissions of NOx, S02, VOCs, HAPs or PM10; 

or 

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

b. Any proposed change to operating or emission limitations; 

c. Any proposed change in the type of pollution control equipment; or 

d. Any proposed change that results in an increase in previously-allowed loading of existing 

pollution control equipment by greater than 50%. 

2. A request for a significant permit amendment shall include the following: 
SP-0285 Page 15of15 

ar er-Hannifin Corp., Chomerics 

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 

c. Where air pollution dispersion modeling is required for a device pursuant to Env-A 606.02, the 

information required pursuant to Env-A 606.04. 

d. An air pollution contro! equipment monitoring plan or catalyst management plan pursuant to 

Env-A 810.01. 

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

amended permit. 

XI. Inspection and Entry 

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

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

and assuring compliance with any applicable requirement found in the New Hampshire Rules Governing 

the Control of Air Pollution and/or conditions of any permit issued pursuant to Chapter Env-A 600. 

XII. 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 devices listed in Condition II. 

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 devices listed in 

Condition II for each calendar year in accordance with the methods specified in Env-A 616, 

Determination of Actual Emissions. 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 XI.B; and 

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

with Env-A 705.03(e)5

• 

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 emissiorn 

during the previous calendar year. For example, the fees for calendar year 2013 shall be received on o 

before April 15, 2014. 

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

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