___________________________________ 

] 

Parker Hannifin Corporation ] FINAL RACT ORDER

Chomerics Division ] July 18, 2002

16 Flagstone Drive ] ARD-03-001

Hudson, NH 03051 ] 

___________________________________ ] 

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 6 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 is subject to Env-A 1204.10, Applicability Criteria and Compliance Standards 

for Coating of Paper, Fabric, Film and Foil Substrates, because their Theoretical Potential 

Emissions (TPEs) equal or exceed 10 tons of non-exempt VOCs during any consecutive 12-

month period. 
RACT Order No. ARD-03-001 July 17, 2002 

Parker Hannifin Corporation Page 2 of 6 

4. Chomerics filed an application for a Modification for their Temporary Permit (Permit 

Number FP-T-0016) on February 9, 2001. 

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 

Destruction Removal Efficiency (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. 

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

slipstream from the main sample line. 

b. The first DRE test on a fresh catalyst bed shall be conducted within a period from the 

date of installation not to exceed 90, 8-hour work shifts in which the CATOX system is 

operated. 

c. As long as the measured DRE remains above 93%, subsequent DRE testing shall be 

conducted at a frequency not to exceed every 90, 8-hour work shifts that the CATOX 

system operates. 

d. If the measured DRE is equal to or less than 93% then testing will be conducted at a 

frequency not to exceed every 45, 8-hour work shifts. 

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

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

spent catalyst with new catalyst. 

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

temperature of the catalytic incinerator bed. 

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

Pollution Control. 

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

Env-A 1204, 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; 
RACT Order No. ARD-03-001 July 17, 2002 

Parker Hannifin Corporation Page 3 of 6 

(ii) "Ec" 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 

of Env-A 1204; and 

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

formulation in terms of lb/gal or kg/l. For those stationary sources that have 

multiple coating lines feeding add-on control equipment, dA means the weightedaverage actual mass density of the VOC in the applied surface coatings in terms of 

lb/gal or kg/l. 

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

and dA, as in the following equation: 

[1 E / d ]

E S c A

c

− =

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 of Env-A 1204.10. 

a. Calculation of Allowable VOC Emissions per Coating per Day 

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

(i) “Eal” means the allowable VOC emission rate of a given coating in units of lbs/day 

or kg/day; 

(i) "S" means the VOC emission standard in terms of lb 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 l solids/l coating as determined by calculation using the 

formulation; and 

(v) " Eal" 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: 

Eal = 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. Chomerics shall use the results of DRE testing as specified in Part 

D.1 of this Order and assume that there is a linear rate of degradation of the catalyst 

between test dates for each day the CATOX is operated. The DRE shall be calculated for 
RACT Order No. ARD-03-001 July 17, 2002 

Parker Hannifin Corporation Page 4 of 6 

each day that the CATOX operated using the method of linear interpolation between the 

two test dates and corresponding DRE’s. 

The exception to the linear interpolation calculation will be for the period immediately 

following the installation of a fresh catalyst bed. Because testing is not required on a 

fresh bed, there are not two points to use for the linear interpolation. In this case, 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 of lbs 

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 

(v) “Eac” shall be equal to the product of W and WV multiplied by the DRE subtracted 

from one, as in the following equation: 

Eac = W*WV*(1-DRE) 

d. Emission Credit Use and Generation Calculations

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

emission rate (Eal) to 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 of VOC RACT and the amount equal to the difference between Eal 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 Eal

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 1204.03, 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. 
RACT Order No. ARD-03-001 July 17, 2002 

Parker Hannifin Corporation Page 5 of 6 

(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 1204.03, Definitions, do not 

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

be allowed to bypass these emissions from the CATOX. 

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

meet the requirements of VOC 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. 

(i) 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 

(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. Chomerics shall have 30 days from the time that the coating is first used after 

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

c. All DRE test data and results conducted in conjunction with Part D.1; and 

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

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

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 of this 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. Within 90 days of issuance of this RACT Order (ARD-03-001) by DES, Chomerics shall 

acquire 4 DERs (2 ozone season credits and 2 non-ozone season credits) to reserve in a bank 

for future compliance with the requirements in Part D, above. Also, Chomerics shall acquire 
RACT Order No. ARD-03-001 July 17, 2002 

Parker Hannifin Corporation Page 6 of 6 

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 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 of Env-A 3103.08, 

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

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

following: 

Ms. Barbara Dorfschmidt 

NHDES, Air Resources Division 

Stationary Source Management Bureau 

6 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

(603) 271-6796 

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

following: 

 Mr. Joe Fontaine 

NHDES, Air Resources Division 

6 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

(603) 271-6794 

 

_____________________________ 

Robert R. Scott 

 Chief Air Programs Manager 

Air Resources Division 

cc: Timothy Drew, PIP Office 

Ann Arnold, USEPA 

Town of Hudson