Amended VOC RACT Order ARD-96-001

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___________________________________ Textile Tapes Corporation ] FINAL RACT ORDER ISSUED 104 Pickering Road ] DECEMBER 9, 1996 Gonic, NH 03839 ] ARD-96-001 ] AMENDED AUGUST 10, 2007 ___________________________________ ]

A. Introduction This proposed revised RACT Order is issued by the N ew Hampshire Department of Environmental Services, Air Resources Division, to Textile Tapes Corporation, pursuant to RSA 125-C.

B. Parties 1. The New Hampshire Department of Environmental Se rvices, 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, telephone n umber (603) 271-1370. 2. Textile Tapes Corporation (“Textile Tapes”) is a New Hampshire corporation, having a mailing address of 104 Pickering Road, Rochester, NH 03867- 4604, telephone number (603) 332-5816.

C. Statements of Fact and Law

1. Textile Tapes owns and operates the following proce sses located at its Gonic Plant at 104 Pickering Road in Gonic, NH (“the Facility”):

a. Line 1A, Fabric Coating Line (removed in 1999);
b. Line 1B, Fabric Coating Line;

c. Line 1C, Hot Melt Coating Line (installed in 1993).
2. Textile Tapes reported to DES that 1990 total VOC e missions were 90 tons and noted that the facility was operated by a company other than Texti le Tapes in 1990.
3. Textile Tapes filed a “Reasonably Available Control Technology (RACT) Statement” on March 15, 1993 for the facility.
4. DES issued a Letter of Insufficiency dated May 19, 1993.
5. Textile Tapes filed a VOC RACT compliance schedule, in response to DES’s Letter of Insufficiency, on June 10, 1993 as amendment to the March 15, 1993 submittal.
6. Textile Tapes initially, in letters dated March 15, 1993 and June 10, 1993, proposed the following measures as RACT:

a. For Line 1A, Line 1B, and Line 1C (with the excepti on stated in part C.6.b below) comply with the provisions of Env-A 1204.10, Applicability Criteria and Compliance Standards for Coating of Paper, Fabric, Film and Foil Substrates, which limits the emission rate of VOCAmended VOC RACT Order ARD-96-001

Textile Tapes Corporation Page 2 of 11 at all times to 2.9 lb/gallon of coating; as applie d, excluding water and exempt compounds; and
b. For the coating described as “5000 series adhesive” utilized on Line 1A and 1B:
i. Reformulate the “5000 series adhesive” to comply wi th the emissions limitation in part C.6.a., above; or
ii. Install a thermal oxidizer to control VOC emissions equivalent to the emissions limitation in part C.6.a.; or
iii. Subcontract all coatings activities, which would re sult in emission rates exceeding the emission limitation in part C.6.a.
7. DES issued a letter on February 8, 1995 requesting an updated VOC RACT plan.
8. Textile Tapes filed further revisions to update its VOC RACT plan as requested by DES on February 24, 1995.
9. Effective August 19, 1995, DES re-adopted Rule Env- A 1204 Stationary Sources of Volatile Organic Compounds (VOCs) with amendments.
10. Textile Tapes filed an evaluation of RACT control o ptions and an application for a RACT order pursuant to ENV-A 1204.05 on December 7, 1995.
11. Textile Tapes ultimately proposed the following mea sures as RACT in its December 7, 1995 application for RACT order:

a. For Line 1A, Line 1B, and Line 1C (with the excepti on stated in part C.6.b) comply with the provisions of Env-A 1204.10, Applicability Criteria and Compliance Standards for Coating of Paper, Fabric, Film and Foil Substrates, which limits the emissions rate of VOC at all times to 2.9lb VOC/gallon of coating; as applied, e xcluding water and exempt compounds;
b. For the coating described as “5000 series adhesive, ” utilized on Line 1A and 1B:
i. Increase solids content of “5000 series adhesive” f rom 33% by weight to 40% by weight; and
ii. Limit the emission rate of VOC resulting from the a pplication of the “5000 series adhesive” at all times to 4.7 lb VOC/gallon of coat ing, as applied, less water and exempt compounds;

c. Limit facility-wide VOC emissions to 70 tons, on a 12-month rolling basis; and
d. File annual reports detailing efforts to meet emiss ion limitation in C.11.a. for all coatings.
12. On June 28, 1996, DES received Textile Tapes’ appli cation for a Title V Permit as required by Env-A 609. The application included a request to include the limits specified by the VOC RACT Order in the Title V permit once issued.
13. DES issued a RACT Order ARD-96-001 (“The Order”) on December 9, 1996.
14. On March 5, 1998, DES received Textile Tapes’ requ est for a modification to the Order issued December 9, 1996 to include a provision for the use of a generic release coating on line 1C, which was not addressed in the original Order.Amended VOC RACT Order ARD-96-001

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15. On March 10, 1998, The United States Environmental Protection Agency (“EPA”) approved the Order into the New Hampshire State Implementation P lan (“SIP”).
16. DES issued an amended Order on September 8, 1998.
17. On October 1, 1998, DES submitted the amended Ord er to EPA as a SIP revision.
18. On September 24, 1999, Textile Tapes submitted an application for installation of the recuperative thermal oxidizer (“RTO”) and dryer rep lacement on coating line 1B. Coating line 1A was eliminated.
19. On January 18, 2000, Temporary Permit TP-BP-651 wa s issued to Textile Tapes for the RTO on coating line 1B.
20. On February 19, 2002, Textile Tapes requested the second modification of the Order to include the RTO.
21. On March 27, 2002, DES received comments from the EPA on the proposed February 19, 2002 modification to the Order. EPA asked DES to wi thdraw the previous Textile Tapes SIP submittal dated October 1, 1998 and state in the ne w SIP submittal that the revised Order supersedes the previous orders.
22. On April 23, 2002, DES submitted the revised Order as a revision to the SIP; EPA deemed the submittal complete on May 28, 2002.
23. Effective December 31, 2002, DES re-adopted Rule En v-A1204, Stationary Sources of Volatile Organic Compounds (VOCs) with amendments.
24. On or about September 25, 2006, Textile Tapes notif ied DES via phone and email of a potential business opportunity to coat product with a new coating known as Chemlok TS3320- 19 Primer (“Chemlok”). The new coating exceeds the 2.9 lb/gal VOC standard required by Env-A 1204.10 (c) and the Order.
25. Textile Tapes indicated to DES that the new coating can not be applied on the RTO-controlled Line 1B due to physical properties of the non-compl iant Chemlok coating. DES directed Textile Tapes to:

a. Purchase Discrete Emissions Reduction (“DER”) credi ts as described in Env-A 3100 for the excess emissions generated by applying the non-comp liant Chemlok coating; b. Modify the Order to allow the application of non-co mpliant Chemlok coating on Line 1C; and

c. Modify Title V Permit TV-OP-009 (“the Permit”) to i nclude the application of noncompliant Chemlok coating on Line 1C.

26. On October 24, 2006, in accordance with Env-A 3104. 08, MacMillan & Donnelly, Inc. (“M&D”) submitted a “Notice of Intent to Use Discre te Emission Reduction Credits” for the period of October 25, 2006 to December 31, 2007, on behalf of Textile Tapes, for the predicted generation of excess emissions when using the non-c ompliant Chemlok coating on Line 1C.
27. M&D estimated the excess emissions from the non-com plaint Chemlok coating to be approximately 3.6 tons per year.Amended VOC RACT Order ARD-96-001

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28. Textile Tapes provided the purchase contract from P ublic Service of New Hampshire (“PSNH”), dated October 3, 2006, documenting the pu rchase of a total of 4 DER credits (2 ozone season credits and 2 non-ozone season), the s erial numbers, and associated cost of the credits.
29. Textile Tapes began applying the non-compliant Chem lok coating on Line 1C on October 25, 2006.
30. On December 28, 2006, DES received applications fro m Textile Tapes to amend the Order and the Permit to allow Textile Tapes to use DERs to co mply with VOC RACT and to generate DERs in the future through the operation of the RTO

. 31. On January 17, 2007, Textile Tapes entered into Adm inistrative Order by Consent No. AO ARD 07-003 with DES, allowing Textile Tapes to use DERs until such time as the Order and Permit are modified.

D. Order

1. Based on the above findings and determinations, DES hereby orders Textile Tapes to implement the following as RACT:

a. For Line 1B and Line 1C, when applying compliant co atings, (as defined in Env-A 1204.03(q)) the Facility shall comply with the prov isions of Env-A 1204.10(c), Applicability Criteria and Compliance Standards for Coating of Pa per, Fabric, Film and Foil Substrates, which limits the emission rate of VOC, at all times , to 2.9 lb VOC/gallon of coating; as applied, excluding water and exempt compounds;
b. For line 1B, when applying non-compliant coatings, (as defined in Env-A 1204.03(az)) the Facility shall demonstrate compliance with the prov isions of Env-A 1204.10(c) as specified in D.1.a. above by:
i. Venting all emissions from non-compliant coatings t o the thermal oxidizer; or
ii. Using the daily weighted average procedure describe d as follows:
1. “VOC
w ” means the daily-weighted average VOC content of coa tings, as applied, used on a given coating line, in units of pounds of VOC per gallon of coating, minus water and exempt compounds;
2. “n” means the number of different coatings, as appl ied, used each day on a coating line;
3. “V i ” means the volume of the i th coating, as applied, used each day on a coating li ne, in units of gallons, minus water and exempt compoun ds;
4. “C i ” means the VOC content of the i th coating, as applied, used each day on a coating line in units of pounds of VOC per gallon of coatin g, minus water and exempt compound;
5. “V T ” means the total volume of all coating, as applied , used each day on a coating line in units of gallons, minus water and exempt co mpounds; andAmended VOC RACT Order ARD-96-001

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6. The “VOC
w ” shall be equal to the sum, over the n coatings us ed on a given coating line, of the products of each V i and C i , divided by V T , as in the following equation:

c. For Line 1C, when applying non-compliant coatings o ther than generic release coatings, the Facility shall comply with the provisions of Env-A 1204.10(c) as specified in D.1.a. above either by:
i. Using the daily weighted average procedure as descr ibed in D.1.b.ii. above; or
ii. Using generated or purchased DERs to offset excess emissions in accordance with Condition D.6;
d. For any generic release coating utilized on Line 1C , the Facility shall:
i. Limit the emission rate of VOC resulting from the a pplication of the generic release coating, at all times, to 5.9 lb VOC/gallon of coat ing applied, less water and exempt compounds; and
ii. Limit the facility-wide use of the generic release coating to less than 5 tons during any consecutive 12-month period;

e. Limit facility-wide VOC emissions to 63.8 tons, on a 12-month rolling basis; and
f. As part of the Annual Emissions Report submitted an nually by April 15 th of the following year, include information detailing efforts to meet the emission limitation in D.1.a. for a generic release coating including:
i. A technical evaluation of each alternative coating considered and basis for acceptance or rejection; or
ii. A statement indicating that no coatings were evalua ted during the time period covered by the report.
2. Prior to the use of any new coating, Textile Tapes shall demonstrate compliance by one of the following options:

a. Chemical manufacturers Material Safety Data Sheet ( MSDS) information (density and weight percent VOC content) along with the Facility coating formulation recipe information (gallons of each ingredient, i.e . coatings, diluent solvent, and exempt diluent sol vent; density of each ingredient; and weight percent VOC content of each ingredient). The Facility shall calculate the pounds VOC per gallon coating as appl ied, minus water and exempt compounds using the following formula:Amended VOC RACT Order ARD-96-001

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Where: “P” means the density of the mixed coat ing as applied (pounds coating/gallon coating); “X” means the weight fraction of VOC in the mixed coating;
“Y w ” means the volume fraction of water in the mixed c oating; and
“Y e ” means the volume fraction of exempt compounds in the mixed coating. When using this option, the Facility shall maintain the calculation sheets and records for each coating formulation; or
b. The referee liquid VOC test method specified as fol lows:
i. Method 24, 40 CFR part 60, Appendix A for all coati ngs as applicable using the 60- minute bake time procedure; or
ii. Method 24A, 40 CFR Part 60, Appendix A as applicabl e.

c. DES reserves the right to have the facility perform Method 24 testing on any coatings for formal demonstration of compliance.
d. All Method 24 analyses and/or calculation sheets fo r new coatings shall be submitted in the annual VOC report.
3. Textile Tapes is subject to Env-A 1204.10, Applicability Criteria and Compliance Standards for Coating of Paper, Fabric, Film and Foil Substrates and has chosen to comply with this section for its non-compliant coatings on Line 1B by implem enting an add-on control system as specified in D.1.b.i. Textile Tapes is required to comply with the more stringent of:

a. A VOC emission reduction efficiency of 95%, as spec ified in D.4.a;
b. An overall VOC emission reduction efficiency determ ined as follows:
i. The VOC emission rate limit, when operating with th e thermal oxidizer, shall be determined, on a solid basis, by the following equa tion in accordance with Env-a 1204.04:

Where:
“S” means the VOC emission rate limit in terms of l bs VOC/gal of coating solids;
“d A ” means the actual density of VOC for converting th e emission limitation to a solids basis in lbs/gal. The Permittee has an option to us e the density value of 7.36 lb/gal if running more than one coating;
“E c ” means the emission rate limit prescribed for the applicable coating category. For those processes applying a coating to any woven or non-woven, fibrous or non- fibrous substrate, including paper, fabric, glass matting, plastic film, ribbon, and magnetic tapes, E c shall be equal to 2.9 lbs VOC/gal of coating, as ap plied to the substrate; andAmended VOC RACT Order ARD-96-001

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ii. The required overall emission reduction efficiency, E, shall be determined by the following equation:

Where:
S = The VOC emission rate limit in terms of l bs VOC/gal of coating solids;
VOC a = The maximum VOC content of the coatings used in lb VOC/gal solids or the daily weighted average VOC content of the coatings used i n lb VOC/gal solids; or
4. Textile Tapes shall perform the following monitorin g and testing of the RTO:

a. Minimum destruction efficiency for the RTO shall be at least 95% and the RTO combustion temperature shall not drop below 1250 ̊F while the u nit is in operation.
b. The combustion temperature of the RTO shall be moni tored and recorded continuously.

c. The Facility shall operate low-temperature lockout, a low temperature alarm, or a temperature chart which shall be examined at least once every 24 hours to ensure compliance with the minimum combustion temperature of 1250 ̊F. Records of all temperature monitoring shall be maintained at the f acility for inspection for at least 5 years.
d. Compliance with the monitoring requirement to reduc e VOC emissions from the dryer exhaust by a minimum of 95% shall be demonstrated u sing the applicable procedure(s) described in Env-A 804.12, Compliance Stack Testing for VOCs and in accordance with the Permit

.

e. Textile Tapes shall be allowed to generate DERs for emission reductions that are achieved in excess of the reductions required in Part D.3 or th e lowest applicable allowable emissions rate limit, as specified in Env-A 3103.02.
5. Textile Tapes shall be allowed to use DERs for RACT compliance during times that it is unable to meet the maximum emission rate stated in Part D. 1.a. The following calculations will be used to determine the amount of credits generated o n a given day:

a. Calculation of Allowable VOC Emissions per Day
“E al ” means the allowable VOC emission rate;
“E pre ” means the actual emission rate from line 1B befor e entering the thermal oxidizer; “E” means the required overall reduction efficiency (expressed as a decimal) as determined in Part D.3; and
“E al ” shall be calculated as in the following equation:

E al = E pre * (1-E)

b. Actual VOC Emissions per Day
“E ac ” means the actual VOC emission rateAmended VOC RACT Order ARD-96-001

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c. Emission Credit Generation Calculation Textile Tapes shall subtract the actual VOC emissio n rate (E ac ) from the allowable VOC emission rate (E al );
E al - E ac to determine if emission credits will be generated on a given day using the following criteria:
i. If the result of the subtraction is a positive numb er, then the emissions are

below the requirements of RACT and the amount equal to the difference between E al and E ac will count towards emission credits;
ii. Actual emission credits shall be calculated by taki ng the amount of credited emissions in part D.5.c.i and multiplying them by a safety factor of 0.9; and
iii. In no instance should generated DERs plus Textile T apes’ actual emissions in any 12-month period exceed the annual VOC emissions limit stated in the Permit.
6. Textile Tapes shall be allowed to use generated or purchased DERs to comply with VOC RACT according to the following:

a. Non-compliant coatings shall only be applied on Coa ting Line 1C when there is a physical limitation preventing Textile Tapes from applying t he coatings on Coating Line 1B;
b. DERs shall only be used to achieve compliance when the RTO is out of service due to a malfunction or routine maintenance, or when a non-c ompliant coating must be applied on Coating Line 1C;

c. The amount of DERs required to achieve compliance s hall be calculated according to the following:
i. The emission rate limit shall be determined on a so lids basis, according to the equation in D.3.b.i.
ii. The Allowable VOC Emissions per Coating shall be ca lculated for each coating as follows:
1. “E al ” means the allowable VOC emission rate of a given coating in units of lb/month or kg/month;
2. “S” means the VOC emission standard in terms of lb VOC/gal or kg VOC/l of coating solids, as calculated in item 6.c.i, above; 3. “W” means the weight of coating or dilution solv ent used in the coating line in units of pounds or kg; 4. “D” means the density of the coating or dilution solvent in units of lb/gal coating, or kg/l coating as determined from Method 24 or 24A an alysis;
5. “V S ” means the volume fraction of the solids content o f the coating, in units of gal solids/gal coating or l solids/l coating as determi ned by calculation using the formulation; andAmended VOC RACT Order ARD-96-001

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6. “E al ” shall be equal to the product of S, VS and W divi ded by D for each coating or dilution solvent used, as in the following equation :

E al = S* V S *(W/D)

iii. The Actual VOC Emissions per Coating shall be calcu lated for each coating as follows:
1. “E ac ” means the actual VOC emission rate of a given coa ting in units of pounds;
2. “W” means the weight of coating or dilution solvent used in the coating line in units of pounds;
3. “W V ” means the weight fraction of VOC content of the c oating, in units of lb VOC/lb coating as determined by calculation using t he formulation; and
4. “E ac ” shall be equal to the product of W and W V , as in the following equation:
E ac = W* W V

iv. The Excess Emissions per Coating shall be equal to the difference between the actual VOC emissions (E ac ) and the allowable VOC emissions (E al ).

Excess Emissions = E ac - E al

v. At the time of use, Textile Tapes shall permanently retire ten percent of all DERs dedicated to that particular use, such that the amo unt of DERs required to demonstrate compliance shall equal the excess emissions calcula ted in item iv above divided by an environmental benefit factor of 0.9.
7. Textile Tapes shall comply with recordkeeping requi rements of Env-A 904.03, and Env-A 904.07 for an add-on pollution control device, spec ifically the RTO.
8. Annually by November 30, Textile Tapes shall submit a report to DES on the projected use of credits for the upcoming year. This report shall m eet 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 Generatio n submitted by the generator source to the State (for paperwork reduction purposes, a cert ified statement that the notice is on file with DES will suffice);

c. The protocol used to document the amount of DERs ne eded to demonstrate compliance; and
d. Information documenting that Textile Tapes is in co mpliance with Env-A 1400, Regulated Toxic Air Pollutants.
9. Annually by April 15, Textile Tapes 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 , including the following information:

a. The name and location of the owner or operator of t he source;Amended VOC RACT Order ARD-96-001

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b. A brief description of the generation activity;

c. A list of the source’s applicable allowable emissio n rates; d. The amount of DERs generated each month;

e. A calculation of the amount of DERs generated;
f. The amount of DERs used each month;

g. A calculation of the amount of DERs required to dem onstrate compliance with the emission limits stated above;
h. A statement that the reductions were calculated in accordance with Env-A 3103.07;
i. A statement that the DERs were not generated in who le or in part from actions prohibited pursuant to Env-A 3103.07; j. A statement that due diligence was made to verify t hat the DERs were not previously used, and not generated as a result of actions prohibited under the regulations or other provisions of law;
k. A statement that the DERs were not used in a manner prohibited under the regulations or other provisions of law; and
l. A certification by a responsible official of truth, accuracy, and completeness that states:
i. Based on information and belief formed after reason able inquiry, the statements and information in the document are true, accurate, and complete; and
ii. The user source in compliance with all National Amb ient Air Quality Standards, except ground level ozone, and all Ambient Air Limits for Regulated Toxic Air Pollutants.
10. Textile Tapes shall comply with all terms and condi tions contained in permits to be issued by DES.

Please address any correspondence and communication in reference to this Order to: Karen L. Rantamaki, P.E. Permitting & Environmental Health Bureau NHDES, Air Resources Division 29 Hazen Drive., P.O. Box 95 Concord, NH 03302-0095 (603) 271-1385 Please address any correspondence and communication in reference to the DERs to: Joseph T. Fontaine Technical Services Bureau NHDES, Air Resources Division 29 Hazen Drive., P.O. Box 95 Concord, NH 03302-0095 (603) 271-6794Amended VOC RACT Order ARD-96-001

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_______________________________ Robert R. Scott, Director
Air Resources Division

cc: Timothy Drew, PIP Office Anne Arnold, US EPA City of Rochester Tim Donnelly, MacMillan & Donnelly