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] Hutchinson Sealing Systems North America Inc. ] Final RACT ORDER 171 Route 85 ] March 22, 2012 PO Box 169 ] ARD-11-001 Newfields, NH 03856 ] __________________________________________]

A. Introduction
This RACT Order is issued by the New Hampshire Depa rtment of Environmental Services, Air Resources Division, to Hutchinson Sealing Systems N orth America Inc., pursuant to RSA 125-C.

B. Parties

1. The New Hampshire Department of Environmental Servi ces, 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, telep hone number (603) 271-1370.
2. Hutchinson Sealing Systems, Inc. (“HSS”) is a Delaw are corporation, having a mailing address of 1060 Centre Road, Auburn Hills, MI.

C. Statements of Fact and Law

1. HSS owns and operates a facility located on Route 8 5 in Newfields, NH.
2. HSS is primarily engaged in the production of seali ng systems that are designed for use in automotive and various other applications. The sea ling strips are produced by several complex processes involving metal roll forming, rubber and plastic extruding, flocking (or the application of a low-friction coating) and curing, followed by certain secondary operations including but not limited to trimming, notching, saw cutting, stretch bending, molding and assembly.
3. On August 8, 2002, DES issued RACT Order # ARD-01-0 02 to HSS for the sealing systems production operations. The RACT Order required HSS to:

a. Terminate the Body Stock Preparation Process operat ions, and the Metal Parts Painting Operations; and
b. Continue to research and test water-based and/or hi gh solids adhesives and low friction primer and top coatings as new products become avai lable in search of RACT-compliant coatings (3.5 pounds of VOCs per gallon of coating excluding water and exempt VOC compounds as applied); and/or obtain credits or use its own shutdown ERCs to comply with the VOC RACT requirements of 3.5 pounds of VOC s per gallon of coating excluding water and exempt VOC compounds as applied
4. On August 8, 2002, DES submitted to United States E nvironmental Protection Agency (USEPA) VOC RACT Order # ARD-01-002 as a revision t o the New Hampshire State Implementation plan (SIP).RACT Order No. ARD-11-001 March 22, 2012

Hutchinson Sealing Systems, Inc. Page 2 of 5
5. Effective July 1, 1979, DES adopted PART Env-A 1200 STATIONARY SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOCs). Effective June 1, 2011, DES revised and adopted Env-A 1220.
6. On November 9, 2009, HSS submitted an application f or renewal of State Permit to Operate FP-S-0255.
7. On August 11, 2011, HSS submitted an addendum to th e permit renewal application to include a modification to Thermoplastics Extrusion Line #9 [T PV Line #9] and the installation of an associated control device (catalytic oxidizer).
8. On October 3, 2011, HSS submitted a request for a m odification to VOC RACT Order ARD-01-002 to be allowed to generate DERs for the o ver control of VOCs generated from the modification to TPV Line #9 and the installation of the catalytic oxidizer.
9. On March 22, 2012, HSS will be issued a renewal of its State Permit to Operate for the Sealing System Production Operations, which will allow HSS to modify the “front end” of TPV#9, and install and operate a catalytic oxidizer to control those VOC emissions.
10. HSS’ current VOC emitting sources subject to this O rder include the following:

Emission Unit ID Process/Device Identification
EU01 Extrusion Line #12
EU02 Extrusion Line #13
EU03 Extrusion Line #14
EU04 Extrusion Line #15 EU07 Thermoplastics Extrusion Line #7 EU08 Thermoplastic Vulcanizates Line #8 EU09 Thermoplastic Vulcanizates Line #9
11. DES will submit a request to withdraw RACT Order # ARD-01-002 to EPA to be replaced with this RACT Order ARD-11-001 as a SIP revision

D. Order
Based on the above findings and determinations, DES hereby orders HSS as follows:
1. Comply with the VOC limit codified in Env-A 1220.02 of 6.3 lbs VOC/gallon of coating as applied, excluding water and exempt VOC compounds, as a monthly average for all motor vehicle weather-strip adhesive coatings applied by using credits in accordance with D.4. below.
2. Continue to research and test water-based and/or hi gh solids coatings as new products become available;
3. HSS shall be allowed to use discrete emissions redu ctions (DERs) or emissions reductions credits (ERCs) for the purpose of complying with VO C RACT by acquiring DERs or ERCs on the open market or by self-generating ERCs in accor dance with Chapter Env-A 3000 and in accordance with HSS’ June 30, 1998 Notice of ERC Ge neration and the accompanying protocols dated June 7, 1999 (i.e., substitute NOx for VOC credits, ration 1:1) or by selfgenerating DERs in accordance with Chapter Env-A 31 00 and in accordance with the provisions in Part E of this Order for self-generation of DERs

.RACT Order No. ARD-11-001 March 22, 2012

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4. As an alternative to the emission rate limit stated in D.1. above, HSS may use add-on control, bubbling, DERs/ERCs or any combination of the previ ous methods, and comply with a solidsbased emission rate limit as calculated below:

a. Emission standard on a solids basis shall be determ ined as specified below:
i. "E c " means the VOC emission limit as stated in Part D. 1., above; and ii. "d A " means the actual mass density of the VOC in the a pplied surface coating formulation in terms of lbs VOC/gal VOC; and iii. "S" means the VOC emission standard in terms of lbs VOC/gallon of coating solids as applied; and shall be equal to E c divided by the difference between one and the quotient of E c and d A , as in the following equation:

     

− =

A

c c

d E E S 1

b. Allowable VOC emissions for each coating as applied shall be calculated as follows:
i. "S" means the VOC emission standard in terms of lbs VOC/gal coating solids as applied or kg VOC/l of coating solids as applied, a s calculated in Part D.4.a. above; ii. "V S " means the volume fraction solids content of the c oating as applied, in units of gal solids/gal coating or l solids/l coating as determi ned by calculation using the formulation; iii. "G" means the volume of coating as applied used in the coating line on a given day in units of gal/day or l/day; and iv. "E al " means the allowable VOC emission rate of a given coating as applied minus water and exempt VOC compounds in units of lbs/day or kg/day; and shall be equal to the product of S, V S and the quotient of W and D for each coating, as i n the following equation: 

### G V S E
s al 

### ∗ ∗ =

c. Actual VOC emissions for each coating as applied sh all be calculated as follows:
i. "W v " means the weight fraction of VOC content of the c oating minus water and exempt VOC compounds, in units of lbs VOC/gal coati ng as determined by calculation using the formulation; ii. "G" means the volume of coating as applied used in the coating line on a given day in units of gal/day or l/day; and iii. " E unc " means the actual, uncontrolled VOC emission rate of a given coating as applied minus water and exempt VOC compounds in uni ts of lbs VOC/day; and shall be equal to the product of W V and G, as in the following equation: 

## G W E
v unc 

## ∗ =RACT Order No. ARD-11-001 March 22, 2012

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iv. "DRE" means the destruction removal efficiency of t he pollution control device as measured during the most recent emissions testing o f the unit. 1

v. "E c " means the actual, controlled VOC emission rate of a given coating as applied in units of lbs/day; and shall be equal to the product of E unc and one minus the DRE, as in the following equation: 

# ( ) DRE E E
unc c 

### − ∗ = 1

d. Bubble and Use of DERs - Emission credit use calcul ations shall be done on a daily basis as follows:
i. HSS shall be allowed to bubble the emissions from m ultiple coatings and/or use DERs to offset excess emissions. ii. Excess emissions shall be calculated for each coati ng by subtracting the actual emissions from the allowable emissions (E al – E unc for coatings that are not controlled by the control device, or E al – E c . for coatings that are controlled). The excess emissions from all the coatings shall be added toge ther (bubbling), and based on the results, one of the following shall be required:

1. If the result of the bubble calculation is a positi ve number, then the source is in compliance with the emission limits and no further action is required.
2. If the result of the bubble calculation is a negati ve number, then actual emissions exceed the allowable emission rates and need to be offset with the use of credits. The actual DERs required shall be calculated by ta king the absolute value of the total excess emissions and dividing by an environme ntal benefit factor of 0.9.
5. HSS shall either test all coatings according to Env -A 804.04, or retain sufficient records for prima facie evidence in support of demonstrating co mpliance with the VOC RACT limit specified in D.1 above.
6. Annually by September 1, HSS shall continue to true up the balance of credits required for the previous year (for the period from June 1 to May 31 ) and shall report the balance to DES.
7. HSS shall comply with the recordkeeping and reporti ng requirements of New Hampshire Code of Administrative Rules Chapters Env-A 3000 and Env -A 3100 for ERC and DER generation and use.
8. HSS shall comply with the recordkeeping and reporti ng requirements of the New Hampshire Code of Administrative Rules Chapter Env-A 900.

E. Discrete Emissions Reductions (Credits)

1. HSS shall be allowed to generate DERs in accordance with Env-A 3100 for surplus reductions below the following emissions rates:

a. The alternative limit (an overall control efficienc y of at least 85%) to the VOC emission limit (6.3 lb/gal) for motor vehicle weather-strip adhesive listed in table 1220-1, in accordance with Env-A 1220.02(e)

. This is equivalent to a facility-wide emissions rat e

1 Prior to the initial compliance test of the cont rol device required in Section VI., Table 5, Item 5 of permit SP-0141, the DRE shall be equal to 95.0%.RACT Order No. ARD-11-001 March 22, 2012

Hutchinson Sealing Systems, Inc. Page 5 of 5

equal to 15% of uncontrolled emissions.
b. The emissions rate of 3.5 lb/gal included in condit ions D.2. and D.3. of RACT Order ARD-01-002 dated August 8, 2002; and

c. An emissions rate of 23 tons/year, in order to pres erve the previously agreed upon protocol for calculating the 22 ERCs that Hutchinson Sealing Systems (HSS) receives each year.
2. If HSS exceeds any of the above emissions rates, th en no DER credits would be generated.
3. Calculation of the uncontrolled facility-wide emiss ions shall be in accordance with Monitoring and Testing condition 4 of Table 5 of State Permit to Operate SP-0141. Actual calendar year emissions shall be reported in accordance with Repo rting condition 1 of Table 7 of the permit. The daily allowable emissions rate for credit gener ation shall be calculated by substituting 3.5 lb/gal for the VOC RACT limit of 6.3 lb/gal in the above VOC RACT compliance calculations in Part D. Please address any correspondence and communication in reference to this Order to the following:
Ms. Patricia North NHDES, Air Resources Division Permitting and Environmental Health Bureau 29 Hazen Drive P.O. Box 95 Concord, NH 03302-0095 (603) 271-1370 Please address any correspondence and communication in reference to the ERCs or DERs to the following:
Mr. Joe Fontaine NHDES, Air Resources Division Technical Services Bureau 29 Hazen Drive P.O. Box 95 Concord, NH 03302-0095 (603) 271-6794

Craig A. Wright, Assistant Director Department of Environmental Services Air Resources Division

cc: Johnny Ray Evans, Hutchinson Sealing Systems, Inc Timothy Drew, PIP Office David Conroy, USEPA Town of Newfields

CAW/prn