Watts Regulator Co. 583 SouthMain**Stre~t** Franklin, NH 03235 ] ] ] ] ] FINAL RACT ORDERISSUED March 21, 2007 ARD07-001 Amended April 20, 2007 Amended August21, 2015**~~~~~~~- ]**  A. Introduction This RACT Order is issued by the NewHampshire Department ofEnvironmental Services, Air Resources Division, to Watts Regulator Co., pursuantto RSA 125-C. B. Parties I. The NewHampshire Department ofEnvironmental Services, Air Resources Division (DES), is a duly constituted administrative agency ofthe State ofNewHampshire having its principal offices at 29 Hazen Drive, Concord, NH 03302, telephone number (603) 271-1370. 2. Watts Regulator Co. (Watts), formerly known as Webster Valve, Inc. (Webster Valve), is a New Hampshire corporation doing business at the mailing address of583 SouthMain Street, Franklin, NH 03235, telephone number (603) 934-1327. C. Statements ofFact and Law 1. Watts owns and operates a facility located at 583 South Main Street in Franklin, NHprimarily engaged in the manufacturing ofvalves, regulators and backflowprevention devices for plumbing and heating and water quality applications. Operations at the facility include coating ofthe metal parts in one ofsix spray booths. 2. Watts submitted a VOC RACT compliance plan on October 26, 1994 stating that a regenerative thermal oxidizer (RTO) along with emissions averaging would be used to comply withthe requirements ofEnv-A 1204.15. 3. OnApril 25, 2001, Watts submitted a modified VOC RACT compliance plan, proposing to discontinue the use ofthe RTO and use Discrete Emission Reductions (DERs) to comply with the requirements ofEnv-A 1204.15. 4. On May 21, 2001, Watts acquired 120 DERs (60 ozone season DERs and 60 non-ozone season DERs) from Public Service ofNewHampshire, as generated in accordance with the federally enforceable RACT OrderNo. ARD-98-001, approved as part ofthe State Implementation Plan in the Federal Register Volume 65, page 68078 dated November 14, 2000. 5. OnMay24, 2001, DES approved Watts' modified VOC RACT compliance plan. 6. Effective December 31, 2002, DES re-adopted the NewHampshire Code ofAdministrative Rules Env-A 1204, Stationary Sources ofVolatile Organic Compounds (VOCs) with amendments. This part defines the sources that are subject to Reasonably Available Control Technology (RACT) requirements and specifies the RACT requirements.RACTOrderNo. ARD07-001 Watts Regulator Co. August21, 2015 Page2 of6 7. Watts is subject to Env-A 1212.01,ApplicabilityandExemptions for Coating of Miscellaneous Metal andPlastic Parts.andProducts, because**th~** combined actual**emissic~ns,** before controls, during any consecutive 12-monthperiod are 3 tons or more ofnon-exempt voes.. 8. OnJune 23, 2006, Watts submitted an application to obtain a VOC RACT Order for the use of DERs for compliance. 9. Watts was issued RACT Order ARD07-001 on March 21, 2007. The RACT Order allows the use ofdiscrete emission reductions (DERs) to comply with VOC Emission Limitations. 10. The coating 'operations, including the use ofDERs, are currently' covered under a State Permit to. Operate. 11. Effective June 1, 2011, DES readopted Env-A 1200 (formerly Env-A 1204) with amendments. 12. On December 22, 2014, Watts submitted a request to revise RACT Order ARD07-001 to reflect updates to Env-A 1212 that become effective on January 1, 2016. D. Order Based on the statements offact and law, DES hereby orders Watts, effective upon issuance ofthis Order, to comply with the following requirements as RACT: 1. Miscellaneous Metal and Plastic Parts and Products Coating under Env-A 1212:

a. For thoseprocesses applying a coating onto metal and/orplastic parts and products, Watts shall comply with the following emission limits for each coating used. All limits are in units ofpounds ofvoeper gallon ofcoating, as applied, excluding water and exempt compounds. Emissions in excess ofthese limits shall be offset bythe use ofDERs in accordance with Part E below: (i) Until January 1, 2016, the content limit for the following coatings shall be as specified: 1. For air-dried general, one component and general, multi-component coatings, equivalentto 3.5 lbs VOC/gallon; and 2. For baked general, one component and general, multi-component coatings shall be equivalent to 3.0 lb VOC/gallon. (ii) Beginning January 1, 2016, the VOC content for miscellaneous metal parts coatings shall be limited as specified for the applicable coating categories listed in Table 1212-1 ofEnv-A 1212.04. b. Ifmore than one emission limit in D.l.a applies to a specific coating, thenthe least stringent emission limitation shall be applied. 2. Calculation ofEmission Standard On a Solids Basis For determining the amount ofDERs to be used in accordance with Part E below, the emission rate limit shall be determined on a solids basis, as specified below: (i) "S"means the VOC emission standard interms ofpounds VOC per gallon ofcoating solids; (ii) "Ee" means the VOC emission limit as stated in Part D.1, above; andRACTOrderNo. ARD07-001 Watts Regulator Co. August21, 2015 Page3 of6 (iii) "dA" means the actual mass density ofthe VOC in the applied surface coating formulation in terms oflb VOC/gal VOC; and



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### . (iv) S shall be equal to Ee divided by the difference between one and the quotient ofEe and dA, as inthe following equation:

3. Calculation ofAllowable VOC Emissipns per Coating



## . . The allowable VOC emissions shall be calculated for each coating as follows: (i) "Eai" means the allowable VOC emission rate ofa given coating inunits oflb/month or kg/month; (i) "S" means the VOC emission standard in terms oflb VOC/gal orkg VOC/l ofcoating solids, as calculated in Part D.2, above; (ii) "W" means the weight ofcoating ordilution solvent used inthe coating line on a given day in units oflb/month or kg/month; (iii) "D" means the density ofthe coating ordilution solvent inunits oflb/gal coating, or kg/I coating as determined from Method 24 or 24A analysis; (iv) "VS" means the volume fraction solids content ofthe coating, in units ofgal solids/gal coating orI solids/I coating as determined by calculation using the formulation; and (v) "Eai" shall be equal to the product ofS, VS and W divided by D for each coating or dilution solvent used, as in the following equation: Ea1 = S*VS*(W/D) 4. Calculation ofActual VOC Emissions per Coating The VOC emissions shall be calculated for each coating as follows: (i) "Eac" means the actual VOC emission rate ofa given coating in units oflb/month; (ii) "W" means the weight ofcoating or dilution solvent used in the coating line on a given day in units oflb/month; (iii) "WV"means the weight fraction ofVOC content ofthe coating, in units oflb VOC/lb coating as determined by calculation using the formulation; and (iv) "Eac" shall be equal to the product ofWand WV, as in the following equation: Eac=W*WV 5. Calculation ofExcess Emissions per Coating The amount ofVOC emissions emitted in excess ofthe applicable limit for each coating (E) shall be equal to the difference between the actual VOC emission rate (Eac) and the allowable VOC emissionrate (Ea1 ), as in the following equation: E = Eac

- Eal Ifthe calculated excess emissionrate is a negative number, no additional calculation is required

.RACTOrderNo. ARD07-001 Watts Regulator Co. August21, 2015 Page 4 o/6 Ifthe calculated excess emission rate is a positive number, the excess emission rate shall be

.**divide~** by an environmeptal benefit factor of0.9

..

' ' 6. Demonstration ofCompliance Watts shall either test all coatings using the Methods described below, orretain sufficient records for primafacie evidence in support ofdemonstrating compliance with the VOC RACT limit.

a. Method 24, 40 CFRPart 60, Appendix A at 1-hourbake time, or an alternative test method approved'by the Director and EPA;·or b. Method 24A, 40 CFRPart 60, Appendix A, or an alternative test method approved by the Director and EPA. Prima facie evidence shall include all ofthe information required by the VOC data sheet found on eitherpage II-2 or III-2, as applicable, ofEPA document EPA-450/3-84-019, Procedures for Certifying Quantity ofVolatile Organic Compounds EmittedbyPaint, Ink, and Other Coatings, dated 1984. Ifthere is a discrepancy between the formulation data and the results ofthe Method 24 or 24A analysis, compliance shall be based on the results from the Method 24 or 24A analysis. 7. Recordkeeping Requirements Watts shall maintainthe following records in order to demonstrate compliance with this order. Each record shall be kept for a period ofat least five years.
a. Records oftests conducted pursuant to Part D.5, above. b. Records ofprimafacie evidence gathered pursuantto Part D.5, above.

c. Records required to be maintained pursuant to Env-A 904, VOC Emission Statements RecordkeepingRequirements, except that actual VOC emissions shall be recorded on a monthly basis instead ofan annual basis. 8. Reporting Requirements Watts shall submit the following reports:
a. Emissionreports in accordance with Env-A 908, VOC Emission Statements Reporting Requirements; and b. Discrete Emissions Reductions reports in accordance with Part E. 9. Work Practice Standards for Miscellaneous Metal and Plastic Parts and Products Coating

a. Watts shall control VOC emissions from VOC-containing coatings, thinners, and coatingsrelated waste materials shall by using the following work practices:

1. Storing all VOC-containing coatings, thinners, and coatings-related waste materials in closed containers;

11. Keeping mixing and storage containers closed at all times except when depositing or removing voe-containing coatings, thinners, and coatings-related waste materials;

111. Minimizing spills ofVOC-containing coatings, thinners, and coatings-related waste materials; andRACTOrderNo. ARD07-00I Watts Regulator Co. August 21, 2015 Page 5 o/6 iv. Conveying voe-containing coatings, thinners, and coatings-related waste materials from one location to another in closed containers orpipes.



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### . b. Watts shall control voe materials from cleaning materials by using the following work practices:

i. Storing voe-containing cleaning materials and used shop towels in closed containers;

II. Keeping mixing and storage containers closed at all times except when depositing or removing voe-containingmaterials;

m. Minimizing spills ofVOe-containing deaning materials;

. IV. Conveying voe-containingcleaning materials from one location to another in closed containers orpipes; and

v. Minimizing VOC emissions from the cleaning ofstorage, mixing and conveying equipment by ensuring that: 1. An atomized mist ofspray gun cleaning solvent arid paint residue is not created outside ofa container that collects the used gun cleaning solvent; and 2. All spent solvent is captured in closed containers. 

### E. Emissions Reductions Credits 1. Watts shall be allowed to use discrete emissions reductions (DERs) for the purpose ofsatisfying the requirements ofthis Order by acquiring DERs from Public Service ofNew Hampshire, as generated in accordance with the federally enforceable RAeT OrderNo. ARD-98-001, approved as part ofthe State Implementation Plan in the Federal Register Volume 65, page number 68078 dated November 14, 2000, orother emission trading credits approved for use in New Hampshire. 2. DERs certified for reductions ofnitrogen oxides (NOx) may be substituted for voereductions in a ratio of 1: 1, or an alternative ratio approved by DES and EPA. 3. Annually by November 30, Watts shall submit a reportto DES onthe projected use ofcredits for the upcoming year. This report shall meet the requirements ofEnv-A 3104.08, Notice of Intent to Use DERs, including the following information:

a. The name and location ofthe user; b. A copy ofthe Notice and Certification ofGeneration submitted by the generator source to the State (forpaperwork reductionpurposes, a certified statementthat the notice is onfile with DES will suffice);

c. The protocol used to document the amount ofDERs needed to demonstrate compliance; and d. A certified statement attesting that Watts is in compliance with Env-A 1400, Regulated ToxicAirPollutants. 4. Annually by April 15, Watts shall submit a report to DES onthe balance ofcredits for the previous calendaryear. This report shall meet the requirements ofEnv-A 3104.09,Notice and Certification ofUse, including the following information:

a. The name and location ofthe owner or operator ofthe user source;RACTOrderNo. ARD07-00J Watts Regulator·Co. b. The cost ofthe DERs; August21, 2015 Page 6 o/6

c. The amount ofDERs used and the associated serial numbers assigned by the DES;

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### . . ' d. A calculation ofthe amount ofDERs required to demonstrate compliance with the emission limits stated in Part D, above. DERs shall be calculated on an annual basis by summingthe monthly excess emissions as calculated in Part D.5, above.

e. A statement that due diligence was made to verify that the DERs were not previously used, and not generated as a result ofactions prohibited under the regulations or other provisions 

### oflaw;.

. . . f. A statement thatthe DERs were not used in a manner prohibited under the regulation or otherprovisions oflaw; and g. A copy ofthe relevant Notice and Certification ofGeneration (for paperwork reduction purposes, a certified statement that the notice is on file with DES will suffice). h. The Notice ofCertification ofUse shall contain a certification by a responsible official of truth, accuracy and completeness and shall state that: (i) Based on information and beliefformed afterreasonable inquiry, the statements and information in the document are true, accurate and complete; and (ii) 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. Please address any correspondence and communication in reference to this Order to the following: Air Permits Programs Manager NHDES, Air Resources Division Stationary Source Management Bureau 29 Hazen Drive P.O. Box 95 Concord, NH 03302-0095 (603) 271-6796 (603) 271-1370RACTOrderNo. ARD07-001 Watts Regulator Co

. August 21, 2015 Page 7 of6

.

.Please address any correspondence and communication inreference to DERs to the following: Emissions Trading Program Manager NHDES, Air Resources Division 29 HazenDrive P.O. Box 95 Concord, NH 03302-0095 (603) 271-6794

cc: Timothy Drew, PIP Office Anne Arnold, USEPA Town ofFranklin Ken Boivin, GZA GeoEnvironmental 

# t.**C?q~** craigA.aright Director Air Resources Division'\**~** I •