Watts Regulator Co. 

583 South Main Stre~t 

Franklin, NH 03235 

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FINAL RACT ORDER ISSUED 

March 21, 2007 

ARD07-001 

Amended April 20, 2007 

Amended August 21, 2015 

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A. Introduction 

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

Resources Division, to Watts Regulator Co., pursuant to RSA 125-C. 

B. Parties 

I. 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. Watts Regulator Co. (Watts), formerly known as Webster Valve, Inc. (Webster Valve), is a New 

Hampshire corporation doing business at the mailing address of 583 South Main Street, 

Franklin, NH 03235, telephone number (603) 934-1327. 

C. Statements of Fact and Law 

1. Watts owns and operates a facility located at 583 South Main Street in Franklin, NH primarily 

engaged in the manufacturing of valves, regulators and backflow prevention devices for 

plumbing and heating and water quality applications. Operations at the facility include coating 

of the metal parts in one of six 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 with the 

requirements ofEnv-A 1204.15. 

3. On April 25, 2001, Watts submitted a modified VOC RACT compliance plan, proposing to 

discontinue the use of the 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 of New Hampshire, as generated in accordance with the federally 

enforceable RACT Order No. ARD-98-001, approved as part of the State Implementation Plan 

in the Federal Register Volume 65, page 68078 dated November 14, 2000. 

5. On May 24, 2001, DES approved Watts' modified VOC RACT compliance plan. 

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

Rules Env-A 1204, Stationary Sources of Volatile 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. 
RACTOrder No. ARD07-001 

Watts Regulator Co. 

August 21, 2015 

Page2 of6 

7. Watts is subject to Env-A 1212.01, Applicability and Exemptions for Coating of Miscellaneous 

Metal and Plastic Parts. and Products, because th~ combined actual emissic~ns, before controls, 

during any consecutive 12-month period are 3 tons or more of non-exempt voes .. 

8. On June 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 of discrete 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 of fact and law, DES hereby orders Watts, effective upon issuance of this 

Order, to comply with the following requirements as RACT: 

1. Miscellaneous Metal and Plastic Parts and Products Coating under Env-A 1212: 

a. For those processes applying a coating onto metal and/or plastic parts and products, Watts 

shall comply with the following emission limits for each coating used. All limits are in units 

of pounds of voe per gallon of coating, as applied, excluding water and exempt 

compounds. Emissions in excess of these limits shall be offset by the use of DERs 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, 

equivalent to 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 

of Env-A 1212.04. 

b. If more than one emission limit in D. l.a applies to a specific coating, then the least stringent 

emission limitation shall be applied. 

2. Calculation of Emission 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 in terms of pounds VOC per gallon of coating 

solids; 

(ii) "Ee" means the VOC emission limit as stated in Part D.1, above; and 
RACT Order No. ARD07-001 

Watts Regulator Co. 

August 21, 2015 

Page3 of6 

(iii) "dA" means the actual mass density of the VOC in the applied surface coating 

formulation in terms of lb VOC/gal VOC; and . . . 

(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: 

3. Calculation of Allowable VOC Emissipns per Coating . . The allowable VOC emissions shall be calculated for each coating as follows: 

(i) "Eai" means the allowable VOC emission rate of a given coating in units of lb/month or 

kg/month; 

(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 lb/month or kg/month; 

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

kg/I 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 I solids/I coating as determined by calculation using the formulation; and 

(v) "Eai" 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) 

4. Calculation of Actual VOC Emissions per Coating 

The 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 lb/month; 

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

day in units of lb/month; 

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

coating as determined by calculation using the formulation; and 

(iv) "Eac" shall be equal to the product of Wand WV, as in the following equation: 

Eac=W*WV 

5. Calculation of Excess Emissions per Coating 

The amount ofVOC emissions emitted in excess of the applicable limit for each coating (E) 

shall be equal to the difference between the actual VOC emission rate (Eac) and the allowable 

VOC emission rate (Ea1), as in the following equation: 

E = Eac - Eal 

If the calculated excess emission rate is a negative number, no additional calculation is required. 
RACT Order No. ARD07-001 

Watts Regulator Co. 

August 21, 2015 

Page 4 o/6 

If the calculated excess emission rate is a positive number, the excess emission rate shall be 

. divide~ by an environmeptal benefit factor of 0.9 .. ' ' 

6. Demonstration of Compliance 

Watts shall either test all coatings using the Methods described below, or retain sufficient 

records for prima facie evidence in support of demonstrating compliance with the VOC RACT 

limit. 

a. Method 24, 40 CFR Part 60, Appendix A at 1-hour bake time, or an alternative test method 

approved 'by the Director and EPA;· or 

b. Method 24A, 40 CFR Part 60, Appendix A, or an alternative test method approved by the 

Director and EPA. 

Prima facie evidence shall include all of the information required by the VOC data sheet found 

on either page II-2 or III-2, as applicable, of EPA document EPA-450/3-84-019, Procedures for 

Certifying Quantity of Volatile Organic Compounds Emitted by Paint, Ink, and Other Coatings, 

dated 1984. 

If there is a discrepancy between the formulation data and the results of the Method 24 or 24A 

analysis, compliance shall be based on the results from the Method 24 or 24A analysis. 

7. Recordkeeping Requirements 

Watts shall maintain the following records in order to demonstrate compliance with this order. 

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

a. Records oftests conducted pursuant to Part D.5, above. 

b. Records of prima facie evidence gathered pursuant to Part D.5, above. 

c. Records required to be maintained pursuant to Env-A 904, VOC Emission Statements 

Recordkeeping Requirements, except that actual VOC emissions shall be recorded on a 

monthly basis instead of an annual basis. 

8. Reporting Requirements 

Watts shall submit the following reports: 

a. Emission reports 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 of VOC-containing coatings, thinners, and coatings-related waste 

materials; and 
RACT Order No. 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 or pipes. . . . . 

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-containing materials; 

m. Minimizing spills ofVOe-containing deaning materials; . 

IV. Conveying voe-containing cleaning materials from one location to another in closed 

containers or pipes; and 

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

equipment by ensuring that: 

1. An atomized mist of spray gun cleaning solvent arid paint residue is not created 

outside of a 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 of satisfying 

the requirements of this Order by acquiring DERs from Public Service of New Hampshire, as 

generated in accordance with the federally enforceable RAeT Order No. ARD-98-001, approved 

as part of the State Implementation Plan in the Federal Register Volume 65, page number 68078 

dated November 14, 2000, or other emission trading credits approved for use in New 

Hampshire. 

2. DERs certified for reductions of nitrogen oxides (NOx) may be substituted for voe reductions 

in a ratio of 1: 1, or an alternative ratio approved by DES and EPA. 

3. Annually by November 30, Watts 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; 

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

the State (for paperwork reduction purposes, a certified statement that the notice is on file 

with DES will suffice); 

c. The protocol used to document the amount of DERs needed to demonstrate compliance; and 

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

Toxic Air Pollutants. 

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

previous calendar year. This report shall meet the requirements of 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 user source; 
RACT Order No. ARD07-00J 

Watts Regulator·Co. 

b. The cost of the DERs; 

August 21, 2015 

Page 6 o/6 

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

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

limits stated in Part D, above. DERs shall be calculated on an annual basis by summing the 

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 of actions prohibited under the regulations or other provisions 

oflaw;. . . . 

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

other provisions of law; and 

g. A copy of the relevant Notice and Certification of Generation (for paperwork reduction 

purposes, a certified statement that the notice is on file with DES will suffice). 

h. The Notice of Certification of Use shall contain a certification by a responsible official of 

truth, accuracy and completeness and shall state that: 

(i) Based on information and belief formed after reasonable 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) 271-1370 
RACT Order No. ARD07-001 

Watts Regulator Co . 

August 21, 2015 

Page 7 of6 . 

.Please address any correspondence and communication in reference to DERs to the following: 

Emissions Trading Program Manager 

NHDES, Air Resources Division 

29 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

(603) 271-6794 

cc: Timothy Drew, PIP Office 

Anne Arnold, USEPA 

Town of Franklin 

Ken Boivin, GZA GeoEnvironmental 

t. C?q~ craig A.aright 

Director 

Air Resources Division 
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