__________________________________________ 

 ] 

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 Department of Environmental Services, Air 

Resources Division, to Hutchinson Sealing Systems North America Inc., 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. Hutchinson Sealing Systems, Inc. (“HSS”) is a Delaware 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 85 in Newfields, NH. 

2. HSS is primarily engaged in the production of sealing systems that are designed for use in 

automotive and various other applications. The sealing 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-01-002 to HSS for the sealing systems 

production operations. The RACT Order required HSS to: 

a. Terminate the Body Stock Preparation Process operations, and the Metal Parts Painting 

Operations; and 

b. Continue to research and test water-based and/or high solids adhesives and low friction 

primer and top coatings as new products become available 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 VOCs per gallon of coating excluding 

water and exempt VOC compounds as applied 

4. On August 8, 2002, DES submitted to United States Environmental Protection Agency 

(USEPA) VOC RACT Order # ARD-01-002 as a revision to 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 for renewal of State Permit to Operate 

FP-S-0255. 

7. On August 11, 2011, HSS submitted an addendum to the permit renewal application to include a 

modification to Thermoplastics Extrusion Line #9 [TPV Line #9] and the installation of an 

associated control device (catalytic oxidizer). 

8. On October 3, 2011, HSS submitted a request for a modification to VOC RACT Order 

ARD-01-002 to be allowed to generate DERs for the over 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 Order 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 high solids coatings as new products become 

available; 

3. HSS shall be allowed to use discrete emissions reductions (DERs) or emissions reductions 

credits (ERCs) for the purpose of complying with VOC RACT by acquiring DERs or ERCs on 

the open market or by self-generating ERCs in accordance with Chapter Env-A 3000 and in 

accordance with HSS’ June 30, 1998 Notice of ERC Generation 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 3100 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

Hutchinson Sealing Systems, Inc. Page 3 of 5

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 previous methods, and comply with a solidsbased emission rate limit as calculated below: 

a. Emission standard on a solids basis shall be determined as specified below: 

i. "Ec" means the VOC emission limit as stated in Part D.1., above; and 

ii. "dA" means the actual mass density of the VOC in the applied 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 Ec divided by the difference between one and the 

quotient of Ec and dA, 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, as calculated in Part D.4.a. above; 

ii. "VS" means the volume fraction solids content of the coating as applied, in units of gal 

solids/gal coating or l solids/l coating as determined 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. "Eal" 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, VS and the quotient of W and D for each coating, as in the following 

equation: 

Eal = S ∗Vs ∗G

c. Actual VOC emissions for each coating as applied shall be calculated as follows: 

i. "Wv" means the weight fraction of VOC content of the coating minus water and 

exempt VOC compounds, in units of lbs VOC/gal coating 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. " Eunc" means the actual, uncontrolled VOC emission rate of a given coating as 

applied minus water and exempt VOC compounds in units of lbs VOC/day; and shall 

be equal to the product of WV and G, as in the following equation: 

Eunc = Wv∗G
RACT Order No. ARD-11-001 March 22, 2012

Hutchinson Sealing Systems, Inc. Page 4 of 5

iv. "DRE" means the destruction removal efficiency of the pollution control device as 

measured during the most recent emissions testing of the unit.1

v. "Ec" 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 Eunc and one minus the DRE, as in 

the following equation: 

E E ( DRE) c = unc ∗ 1−

d. Bubble and Use of DERs - Emission credit use calculations shall be done on a daily basis 

as follows: 

i. HSS shall be allowed to bubble the emissions from multiple coatings and/or use DERs 

to offset excess emissions. 

ii. Excess emissions shall be calculated for each coating by subtracting the actual 

emissions from the allowable emissions (Eal – Eunc for coatings that are not controlled 

by the control device, or Eal – Ec. for coatings that are controlled). The excess 

emissions from all the coatings shall be added together (bubbling), and based on the 

results, one of the following shall be required: 

1. If the result of the bubble calculation is a positive number, then the source is in 

compliance with the emission limits and no further action is required. 

2. If the result of the bubble calculation is a negative number, then actual emissions 

exceed the allowable emission rates and need to be offset with the use of credits. 

 The actual DERs required shall be calculated by taking the absolute value of the 

total excess emissions and dividing by an environmental benefit factor of 0.9. 

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 compliance 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 reporting 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 reporting 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 efficiency 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 rate 

 

1

 Prior to the initial compliance test of the control 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 conditions 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 preserve 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, then no DER credits would be generated. 

3. Calculation of the uncontrolled facility-wide emissions 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 Reporting condition 1 of Table 7 of the permit. 

The daily allowable emissions rate for credit generation 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