Kalwall Corporation 

1111 Candia Road 

P.O. Box237 

Manchester, NH 03105 

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PROPOSED REVISION TO 

FINAL RACT ORDER ISSUED 

September 10, 1996 

ARD-95-010 

June 25, 1999 

A. Introduction 

This VOC RACT Order ARD-99-001, is issued by the New Hampshire Department of 

Enviromnental Services, Air Resources Division, to Kalwall Corporation - Panels & Accessories 

Division, 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 64 North Main Street, Concord, NH 03302-2033, telephone number 

(603) 271-1370. 

2. Kalwall Corporation ("Kalwair'), is a New Hampshire corporation, having a mailing address 

of P.O. Box 237, Manchester, NH 03105, telephone number (603) 627-3861. 

C. Statements of Fact and J,aw 

1. Kalwall owns and operates the following processes located at its Panels and Accessories 

Division Plant at 1111 Candia Road in Manchester, NH ("the Facility"): 

a. The continuous 1-Beam Sizer and Spreader ("IBSS") process; 

b. The Kalwall Weatherable surface ("KWS") Coating Spray process; and 

c. The Kalwall Corrosion Resistant Finish ("KCRF") process. 

2. Effective August 31, 1995, the DES re-adopted Rule PART Env-A 1204 VOLATILE 

ORGANIC COMPOUNDS (VOCs) with amendments. 

3. Kalwall ftled a "Reasonable Available Control Technology (RACT) Statement" on May 

31,1995 for the Facility. 

4. The DES issued a Letter oflnsufficiency dated July 28, 1995. 

5. Kalwall filed amendments, in response to the DES letter of insufficiency, to its original 

"Reasonable Available Control Technology (RACT) Statement" on September 29,1995 for 

the Facility. 
Final VOC RACT Order ARD-99-001 

June 25, 1999 

Page2 

6. Kalwallreported to the DES (see Appendix B of the May, 1995 RACT Statement) that the 

estimated total1990 annual VOC emissions were 150,912 pounds. 

7. Kalwall initially proposed the following measures as RACT in its May 31, 1995 submittal: 

a. For the KCRF process, comply with the provisions of Env-A 1204.15 Emission 

Standards for Coating of Miscellaneous Metal Parts and Prodncts, including Env-A 

1204.15(c) which limits the VOC emission rate at all times to 3.5 lb VOC/gal of 

coating, as applied, excluding water and exempt compounds; 

b. For the KWS process, comply with the provisions ofEnv-A 1204.16 Emission 

Standards for Plastic Parts Coating, including Env-A 1204.16(g), which limits the 

VOC emission rate at all times to 4.3 lb VOC/gal of coating, as applied, excluding 

water and exempt compounds; 

c. For the IBSS process, comply with the following provisions: 

1. Maintain the VOC content of the proprietary bonding agent at no more than 

4.0 lb VOC/gal, as applied, excluding water and exempt compounds and 

continue to search for a low-VOC resin system; 

11. Minimize the usage of the proprietary adhesive by controlling the thickness 

of application and monitoring blend consumption by process operators; 

111. Reduce off-line manual application and improve the efficiency of the 

spreader equipment by machine upgrade to simultaneous 2-sided sizing and 

spreading by late 1996; and 

1v. Keep records, available to the regulatory authority, on request, of monthly 

consumption ofiBSS process materials and report this information annually. 

8. Kalwa!! ultimately proposed the following measures as RACT: 

a. For the KCRF process, comply with the provisions ofEnv-A 1204.15 Emission 

Standards for Coating of Miscellaneous Metal Parts and Products, including Env-A 

l204.15(c) which limits the VOC emission rate at all times to 3.5 lb VOC/gal of 

coating, as applied, excluding water and exempt compounds; 

b. For the KWS process, comply with the provisions of Env-A 1204.16 Emission 

Standards for Plastic Parts Coating, including Env-A 1204.16(g), which limits the 

VOC emission rate at all times to 4.3 lb VOC/gal of coating, as applied, excluding 

water and exempt compounds; 
Final VOC RACT Order ARD-99-001 

June 25, 1999 

Page 3 

c. For the IBSS process, comply with the following provisions: 

1. Maintain the VOC content of the proprietary bonding agent at no more than 

4.5 lb VOC/gal, as applied, excluding water and exempt compounds (increase 

from May 31, 1995 submittal resulted from the exclusion of acetone); 

11. Reduce off-line manual application and inlprove the efficiency of the 

spreader equipment by machine upgrade to sinlultaneous 2-sided sizing and 

spreading by late 1996; and 

111. Keep records, available to the regulatory authority, on request, of monthly 

consumption ofiBSS process materials and report this information annually. 

9. The DES issued a Determination of Sufficiency and Proposed RACT Order dated January 

4, 1996. 

10. ·The DES held a public hearing to receive testimony relative to Kalwall's proposed RACT 

Order on February 16, 1996. 

11. In a letter dated May 8, 1996, Kalwall amended its RACT proposal to exclude any 

requirement for two sided sizing and spreading, stating that such an operation had proven to 

be technically infeasible. 

12. On June 28, 1996, the DES received the Kalwall application for Title V permitting as 

required by Env-A 609. This application included a request for permit amendment to include 

the linlits specified in VOC RACT Order ARD-95-010 in the Title V permit once issued. 

13. The DES issued the Final RACT Order #ARD-95-01 0 on September 10, 1996, to Kalwa]! 

14. The DES sent a letter dated September 10, 1996 to David Comoy, USEPA- Region I, with 

the following enclosures: 

a. Final RACT Order 

b. Responses to EPA Comments 

c. Env-A 1204.14, Applicability Criteria and Compliance Standards for Coating of 

Miscellaneous Metal Parts and Products 

d. RSA 125-J, Emission Reduction Credits Trading Program 

e. July 20, 1995 Letter of Governor Stephen Merrill to EPA Administrator Carol 

Browner 

f Bay Area and South Coast Air Quality Management Districts of California VOC 

Rules Pertaining to Adhesives and Sealants 

g. Calculation to Support Determination of the Infeasibility of Bubbling 

h. Selected VOC Rules from Wisconsin, and the Mojave Desert, Sacramento 

Metropolitan, and Bay Area Air Quality Management Districts of California 
Final VOC RACT Order ARD-99-001 

June 25, 1999 

Page 4 

15. The DES sent a revision to its SIP to the EPA, dated October 24, 1996 which included the 

Reasonably Available Control Technology (RACT) Order to reduce VOC emissions from 

Kalwall in Manchester, NH. 

16. The DES received a letter dated November 13, 1996 from Susan Studlien acknowledging the 

receipt of the SIP revision letter and notified the DES that the submittal was administratively 

and technically complete. 

17. USEPA approval of October 24, 1996 SIP revision was recorded in the Federal Register on 

March 10, 1998: Volume 63; No. 46; pages 11600 through 11605. 

18. The DES received a compliance certification statement in written correspondence from 

Kalwall dated June 21, 1996. 

19. On November 5, 1996, the DES sent an administrative completeness letter for the Title V 

Permit Application submittal from Kalwall, requesting supplemental information to fulfil the 

requirements ofEnv-A 1700. 

20. On January 31, 1997, the DES received documentation from Kalwall addressing Env-A 1700 

requirements for their Title V Permit Application submittal 

21. Representatives ofKalwall and DES met on January 9, 1998, at Kalwall's request, to discuss 

and review Kalwall's compliance with its expired State Operating Permits and VOC RACT 

Order. 

22. On July 31, 1998, the DES received a facility-wide permit application from Kalwall for a 

federally enforceable state operating permit (FESOP) for the interim period prior to a Title 

V Permit issuance. 

23. Meetings were held on August 19, 1998 and September 2, 1998 to discuss issues involving 

the current VOC RACT Order for the Facility. 

24. On December 8, 1998, the DES received a request to revise the VOC RACT Order from 

Kalwall for the pretreat primer used in the KCRF process. Alternatives for a compliant 

primer were investigated by Kalwall and included the use of media blasting of metal 

substrate in place of a primer coat and use of water based primers. The trials conducted with 

the media blasting proved unsuccessful in the bonding of the coatings to the metal substrate 

without the pretreat primer application. The use of water based primers required 

substantially increased production time to allow for removal of the water from the primer 

prior to coating application. Consistent availability and supply of the water based pretreat 

primers was also identified as a problem. Making process changes and adding an oven for 

drying of the water based pretreat primer added a cost of $500,000.00 for decreasing VOC 

emissions by 3 tons per year to within the VOC RACT limits and was determined to be 
Final VOC RACT Order ARD-99-001 

June 25, 1999 

Page 5 

economically not feasible or viable. 

25. Kalwall submitted the following VOC RACT Proposal for the KCRF pretreat primer: 

a. Limit the VOC emission rate of the primer used in the KCRF process to 6.3 lb VOC/ 

gallon of primer, as applied, excluding water and exempt compounds at all times. 

b. Kalwall shall maintain records of the monthly usage and emissions ofVOC from the 

KCRF process (i.e. priming and top coat). 

c. Kalwall shall determine compliance with the above VOC limit by testing methods 

specified in Env-803.03 (USEPA Metbod 24, or equivalent) on a yearly basis. 

d. Kalwall shall comply with the record keeping and reporting requirements of Env-A 

901.04 and Env-A 901.05 (Kalwall can not efficiently record the raw material 

aluminum entering the KCRF process in square footage, due to the extreme 

differences in sizes and shapes of aluminum metal substrate, therefore this data can 

not be maintained and reported.) 

e. Kalwall proposed that sections D.2, D.3, D.4, D.5, and D.6 from RACT Order ARD95-0 10 only apply to the KCRF process. Furthermore, Kalwall proposed that section 

D.4 of RACT Order ARD-95-010 is unnecessary in light of analytical results 

submitted in September 1998 to the DES for all coatings used at the Facility and in 

proposed condition c. above for yearly Method 24 analyses to be conducted for all 

coatings, as applied. 

26. On January 7, 1999, February 22, 1999, and March 26, 1999, the DES sent a preliminary 

proposed VOC RACT Order to Kalwall for review and comments. 

27. The DES received written comments from Kalwall on January 29, 1999 and March 18, 1999 

in regards to the preliminary proposed VOC RACT Order. The DES also received oral 

comments from Kalwall during teleconference calls held on April 1, 1999 and April 7, 1999. 

DES and Kalwall staff convened on April 14, 1999 to review potential alternative methods 

to provide prima facie evidence as to compliance of custom color coatings used in the KCRF 

process. 

28. A public hearing was held on May 24, 1999 at the DES. A summary testimony was given 

by the Air Resources Division on the Proposed VOC RACT Order. In comments after the 

testimony, the DES requested Kalwall to submit additional information including use of 

emissions reductions credits to fulfill their technical and economical feasibility study of 

available VOC control techniques, pursuant to the New Hampshire Code of Administrative 

Rules Env-A 1204.05(c)(4)a. The written comment period was extended one week from 

June 1 to June 8, 1999 to allow Kalwa!! the opportunity to assess the use of emissions 

reductions credits. 
Final VOC RACT Order ARD-99-001 

June 25, 1999 

Page 6 

29. On June 7, 1999, the DES received written connents on the proposed VOC RACT Order 

for the Kalwall facility. Kalwall submitted typographical and phrase changes to the proposed 

VOC RACT Order and included a "Supplemental VOC RACT Evaluation of Alternatives -

Use of Nitrogen Oxide (NOx) Discrete Emissions Reductions (DER) Credits". DES has 

evaluated this information and believes it substantively completes Kalwall's obligation to 

evaluate the use of emissions reductions credits to fulfill their technical and economical 

feasibility study of available VOC control techniques. 

30. The EPA faxed written connents on the proposed VOC RACT Order to the DES on June 

8, 1999. In its response, EPA stated "EPA is strongly encouraging New Hampshire, and 

other states, to discontinue the issuance of source-specific variances from RACT 

requirements fur facilities that can feasibly achieve RACT through state emissions reductions 

trading programs. Since New Hampshire has an Emission Reduction Credits Trading 

Program in place, we recommend that the RACT Order address Kalwall's pretreatment 

primer process by requiring the use of emission reduction credits from another facility". 

31. The following are proposed changes to the existing RACT Order: 

a. Rather than revise the current RACT Order ARD-95-010, taking out references to the 

KCRF process, and issuing a new RACT Order solely for the KCRF process and the 

pretreat primer specifically, the DES has instead, drafted a single VOC RACT Order 

to replace the current one, and includes conditions specific to the pretreat primer and 

KCRF process. In addition, the new proposed VOC RACT Order includes VOC 

RACT limits for dull and clear coats used in the KWS process, which do not fit into 

any specific VOC RACT source category in Env-A 1204. Furthermore, the new 

proposed VOC RACT Order more adequately addresses all process areas (IBSS 

process (lines #1 and #2), KWS process, and KCRF process (spray booths #1, #2, 

and #3)) with practically enforceable limits. 

b. The last sentence in the paragraph ofltem 9 - Part D has been revised to read as 

follows: "Kalwall shall submit an annual report no later than April 15 of each year 

detailing all efforts to reduce VOC emissions facility wide during the preceding 

calendar year, including, if applicable, any examinations or evaluations undertaken 

of alternative adhesives or coatings for use as a low-VOC replacement for the TBSS 

adhesive or the KCRF pretreat primer respectively." 

c. In order to address concerns regarding record keeping requirements ofEnv-A 901.04 

and 901.06, specifically, measuring, recording, and reporting of the square footage 

of raw materials entering the KCRF process, new language has been added to Part 

D - Item 7, which yields a more easily enforceable record keeping provision which 

both ensures that Kalwall does not exceed its current combined KCRF spray booths 

permit limit of30 tons per year ofVOC emissions (for the three spray booths in the 

KCRF process), the 100 ton per year facility wide VOC emissions limit contained in 
Final VOC RACT Order ARD-99-001 

June 25, 1999 

Page? 

each current individual permit, any future facility wide. VOC ermssmns limit 

contained in the Title V Operating Permit, and which can be better quantified. The 

proposed VOC RACT Order has the following language added to Part D - Item 7, 

which states the following: 

"Such information will be used to determine compliance with all existing individual 

process permits and any future permits to be issued." 

d. In the current VOC RACT Order ARD-95-010, Part D, Item 2, it states "For all 

remaining VOC emitting processes, Kalwall shall comply with the default emission 

standards listed in Env-A 1204, as applied, for each coating used in each classifiable 

process.". As was previously accepted in the existing RACT Order, coatings used 

in the KWS process were to be limited to a 4.3 lb VOC/gallon limit as referenced in 

Env-A 1204.16(g)(1), which is for soft, specialty protective, decorative, or functional 

coatings onto plastic substrates. The dull and clear coat coatings used in the KWS 

process are not by definition soft and do not fit in any of the listed subcategories of 

the plastics parts coating category found in Env-A 1204.16. Kalwall applies a single 

layer, less than 50 mils thickness, of the dull or clear coat to the surface of fiberglass 

reinforced polyester (FRP) incorporated into a composite building fenestration 

product composed of FRP and a metal substrate. 

The DES has made a determination that the VOC RACT emission standard for the 

KWS process shall be such that the KWS process shall be limited at all times to 4.3 

lb VOC/gallon of coating, as applied, excluding water and exempt compounds. The 

DES feels this emission standard is technically justified when compared to similar 

materials, i.e. specialty coatings to plastic components of automobile exteriors and 

protective, decorative, or functional coatings onto metal parts that are clear or 

transparent top coats, which each have emission limits of 4.3 lb VOC/gallon of 

coating as applied. 

e. Kalwall uses clear and transparent topcoats in the KCRF process. Clear or 

transparent coatings used as a protective, decorative or functional coating onto metal 

parts and products have a VOC emissions limit of 4.3 lb VOC/gal of coating, as 

applied, excluding water and exempt compounds as stated in Env-A 1204.15( c)(!), 

versus the 3.5 lb VOC/gal of coating, as required by air dried coatings, covered by 

Env-A 1204.15(c)(2). Item 4., Part D., has been added to address VOC RACT 

requirements of clear or transparent topcoats used in the KCRF process. 

f Kalwall was concerned about imposition of a 30 ton per year VOC limit for the 

KCRF process referenced in Item 7- Part D. (Formerly Item 6.) in an earlier draft of 

the proposed revised VOC RACT Order which called for daily record keeping of 

coating usage and daily calculation of VOC emissions for each of the KCRF spray 

booths for the purpose of keeping a running total of VOC emissions to benchmark 

continuous compliance with the 30 ton per year limit. The DES has modified Item 
Final VOC RACT Order ARD-99-001 

June 25, 1999 

Page 8 

7.- Part D. to require Kalwall to maintain records of the monthly usage and emissions 

of all VOCs from each operation individually and from combined operations as 

stated in the previous VOC RACT Order ARD 95-010, noting that "Such information 

will be used to determine compliance with all existing individual process permits and 

any future permits to be issued." 

g. Kalwall expressed concern over having Method 24 testing completed prior to the use 

of custom colors for its KCRF fmish. In these situations Kalwall cooperates with its 

vendor to match the specified color using the existing Kalwall base formulations. 

Due to the length of time that it takes to have a Method 24 analysis performed, there 

is insufficient time to complete Method 24 testing, formulate sufficient quantities of 

coating for the specified job, and fabricate the job for delivery before delivery dates 

typically requested by customers. For this reason, the DES has included the option 

of either performing Method 24 analyses or prima facie evidence of the actual 

content of the coating as specified in the text found in Item 8.- Part D. 

h. Item 5. - Part D. has been changed to reflect the use of emissions reductions credits 

rather than the alternative VOC RACT limit of63 lb VOC/gallon of pretreat primer 

as applied, excluding water and exempt compounds. 

D. Order 

Based on the above findings and determinations, DES hereby orders Kalwall as follows: 

1. For the IBSS process (lines #1 and #2), Kalwall shall meet the following requirement as 

RACT: 

a. Limit the VOC emission rate to 4.5 lb VOC/gallon of bonding agent, as applied, 

excluding water and exempt compounds, at all times. 

2. For the KWS process, Kalwall shall meet the following requirement as RACT: 

a. Limit the VOC emission rate to 43 lb VOC/gallon of coating, as applied, excluding 

water and exempt compounds, at all times. 

3. For topcoats applied in the KCRF process, comply with the provisions of Env-A 

1204.15( c)(2) Emissions Standards for Coating of Miscellaneous Metal Parts and Products, 

which limits the VOC emission rate to 3.5 lb VOC/gallon of coating, as applied, excluding 

water and exempt compounds, at all times, for air dried coatings as a protective, decorative 

or functional coating onto metal parts and products. 

4. For. clear or transparent topcoats applied in the KCRF process, comply with the 

provisions ofEnv-A 1204.15(c)(1) Emissions Standards for Coating of Miscellaneous Metal 

Parts and Products, which limits the VOC emission rate to 4.3 lb VOC/gallon of coating, as 
Final VOC RACT Order ARD-99-001 

June 25, 1999 

Page9 

applied, excluding water and exempt compounds, at all times, for clear or transparent 

topcoats as a protective, decorative or functional coating onto metal parts and products. 

5. For pretreat primer applied in the KCRF process, comply with the provisions of Env-A 

1204.15( c)(3) Emissions Standards for Coating of Miscellaneous Metal Parts and Products, 

which limits the VOC emission rate to 3. 5 lb VOC/ gallon of coating, as applied, excluding 

water and exempt compounds, at all times, for a coating that is used in extreme 

environmental conditions. If the facility is unable to meet this VOC RACT limit, it shall 

comply with the applicable requirements contained in Env-A 3100 Discrete Emissions 

Reductions Trading Program. 

6. Kalwall shall use Best Workpractice Standards in use of MEK for wipe down of metal 

substrate. This requires use of bench cans for application of MEK to wipe down rags and 

the use of closed containers for the storage of contaminated wipe down rags that are not in 

use. 

7. Kalwall shall maintain records of the monthly usage and emissions of all VOCs from each 

operation individually and from combined operations. Such information will be used to 

determine compliance with all existing individual process permits and any future permits to 

be issued. 

8. Prior to the use of any new coatings and primers at the facility, Kalwall must demonstrate 

compliance with D.1, D.2, D.3, D.4, or D.5, as applicable, by one of the following options: 

a. Prima facie evidence - Use of chemical manufacturers Material Safety Data Sheet 

(MSDS) information (density and weight percent VOC content) along with Kalwall 

coating formulation recipe information (gallons of each ingredient, i.e. resins, cure, 

diluent solvent, and exempt diluent solvent; density of each ingredient; and weight 

percent VOC content of each ingredient). Kalwall shall calculate the pounds VOC 

per gallon coating minus water and exempt compounds for the coating as applied via 

use of the following formula: 

(P * X)/(1 - Yw- Ye) 

Where: 

P= 

X= 

Yw= 

Ye= 

Density of the mixed coating as applied (pounds coating/gallon coating) 

Weight fraction ofVOC in the mixed coating 

Volume fraction of water in the mixed coating 

Volume fraction of exempt compounds in the mixed coating 

When using prima facie evidence as obtained in the above fashion, Kalwall shall 

maintain the calculation sheets and records for each coating formulation. All Method 

24 analyses and prima facie evidence calculation sheets for new coatings shall be 

submitted in the annual VOC report; OR 
Final VOC RACT Order ARD-99-001 

June 25, 1999 

Page 10 

b. For sources subject to Env-A 1204, when formal compliance is demonstrated for the 

low VOC coatings, the referee liquid VOC test method for ultimate determination of 

compliance with VOC RACT shall be the EPA reference methods specified as 

follows: 

(I) Method 24, 40 CFR Part 60, Appendix A for all coatings as applicable using the 

60-minute bake time procedure; or 

(2) Method 24A, 40 CFR Part 60, Appendix A as applicable. 

c. The DES reserves the right to have Kalwa!! perform Method 24 testing on any 

coatings for formal demonstration of compliance. 

9. Kalwall shall submit an annual report, no later than April 15th of each year, detailing all 

efforts to reduce VOC emissions facility-wide during the preceding calendar year, including, 

if applicable, any examinations or evaluations undertaken of alternative adhesives or coatings 

for use as a low-VOC replacement for the IBSS adhesive or the KCRF pretreat primer, 

respectively. 

10. Kalwall shall comply with the record keeping requirements of Env-A 901.04 and Env-A 

901.06. 

11. Kalwall shall comply with the permits issued by the DES. 

Please address any correspondence and co=unication in reference to this Order to: 

Mr. Douglas C. Laughton 

NHDES, Air Resources Division 

64 N. Main St., P.O. box 2033 

Concord, NH 03302-2033 

~~ 

Kenneth A Colburn, Director 

Air Resources Division 

cc: Bob Cheney, SPB+G Mary Rue!, DES 

Craig Wright, DES 

h:\laughton\conespo\kalwal-m\vocracLful 

Final VOC RACT Order 06/25/99