___________________________________ ] 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 Hampshir e Department of Environmental Services, Air Resources Division, to Parker Hannifin Corpor ation, Chomerics Division (Chomerics), pursuant to RSA 125-C.

B. Parties

1. The New Hampshire Department of Environmen tal 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 ope rating 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 wo rk 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) "E c " 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) "d A " 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, d A 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 E c divided by the difference between one and the quotient of E c and d A , as in the following equation:

] d / E 1 [ E S

A c 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) “E al ” 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) " E al " 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:

E al = 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 forRACT 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) “E ac ” 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) “E ac ” shall be equal to the product of W and WV multiplied by the DRE subtracted from one, as in the following equation:

E ac = W*WV*(1-DRE)

d. Emission Credit Use and Generation Calculations
Chomerics shall subtract the actual VOC emission rate (E ac ) from the allowable VOC emission rate (E al ) 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 E al and E ac 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 E al and E ac 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 acquireRACT 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