Kalwall Corporation 1111 CandiaRoad P.O. Box237 Manchester, NH 03105 

### l l l l l PROPOSED REVISION TO FINAL RACT ORDERISSUED 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, pursuantto RSA 125-C. B. Parties 1. The New Hampshire Department of Environmental Services, Air Resources Division ("DES"), is a duly constituted administrative agency ofthe State ofNewHampshirehaving its principal offices at 64 North Main Street, Concord, NH 03302-2033, telephone number (603) 271-1370. 2. Kalwall Corporation ("Kalwair'), is a NewHampshire corporation, having amailing address of P.O. Box237, Manchester, NH03105, telephone number (603) 627-3861. C. Statements ofFact and J,aw 1. Kalwall owns and operates the following processes located at its Panels and Accessories DivisionPlant at 1111 CandiaRoad in Manchester, NH ("the Facility"):

a. The continuous 1-Beam Sizer and Spreader ("IBSS") process; b. TheKalwallWeatherable surface ("KWS") Coating Sprayprocess; and

c. TheKalwall CorrosionResistantFinish ("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. TheDES issued a Letter oflnsufficiency dated July 28, 1995. 5. Kalwall filed amendments, in response to the DES letter ofinsufficiency, to its original "Reasonable Available Control Technology (RACT) Statement" on September 29,1995 for the Facility.Final VOC RACT OrderARD-99-001 June 25, 1999 Page2

6. Kalwallreported to the DES (see AppendixB ofthe 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 ofEnv-A 1204.15 Emission Standards for Coating ofMiscellaneous MetalParts 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 emissionrate at all times to 4.3 lb VOC/gal ofcoating, as applied, excluding water and exempt compounds;

c. Forthe IBSS process, complywith the following provisions:

1. Maintain the VOC content ofthe proprietarybonding agent at no morethan 4.0 lb VOC/gal, as applied, excluding water and exempt compounds and continue to searchfor a low-VOC resin system;

11. Minimize the usage ofthe proprietary adhesive by controlling the thickness ofapplication and monitoring blend consumptionby 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, onrequest, ofmonthly consumption ofiBSS process materials and reportthis information annually. 8. Kalwa!!ultimatelyproposed the following measures as RACT:

a. For the KCRF process, comply with the provisions ofEnv-A 1204.15 Emission Standards for Coating ofMiscellaneous MetalParts 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 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 ofcoating, as applied, excluding water and exempt compounds;Final VOC RACT OrderARD-99-001 June 25, 1999 Page 3

c. Forthe IBSS process, comply withthe following provisions:

1. Maintainthe VOC content ofthe proprietarybonding agent at no morethan 4.5 lb VOC/gal, as applied, excluding water and exempt compounds (increase fromMay 31, 1995 submittalresulted from the exclusion ofacetone);

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, ofmonthly consumption ofiBSS process materials and reportthis information annually. 9. The DES issued a Determination ofSufficiency and Proposed RACT Order dated January 4, 1996. 10. ·The DES held a public hearing to receive testimonyrelative to Kalwall's proposed RACT Order onFebruary 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 provento betechnically infeasible. 12. On June 28, 1996, the DES received the Kalwall application for Title V permitting as requiredbyEnv-A 609. This application included a request for permit amendment to include the linlits specified inVOC RACT Order ARD-95-010 in the Title V permit once issued. 13. The DES issued theFinal RACT Order#ARD-95-01 0 on September 10, 1996, to Kalwa]! 14. TheDES sent aletter 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 TradingProgram 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. Calculationto Support Determination ofthe Infeasibility ofBubbling h. Selected VOC Rules from Wisconsin, and the Mojave Desert, Sacramento Metropolitan, and BayArea Air Quality Management Districts ofCaliforniaFinal VOC RACT Order ARD-99-001 June 25, 1999 Page 4

15. The DES sent arevisionto its SIP to the EPA, dated October 24, 1996 whichincluded the Reasonably Available Control Technology (RACT) Order to reduce VOC emissions from Kalwall in Manchester, NH. 16. The DES received a letter datedNovember 13, 1996 from Susan Studlien acknowledging the receipt ofthe SIP revisionletter and notified theDES thatthe submittalwas administratively and technically complete. 17. USEPA approval ofOctober 24, 1996 SIP revision was recorded in theFederalRegister 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 letterfor the Title V PermitApplication submittal from Kalwall, requesting supplementalinformationto fulfil the requirements ofEnv-A 1700. 20. On January 31, 1997, theDES received documentation from Kalwall addressing Env-A 1700 requirements for their Title V Permit Application submittal 21. Representatives ofKalwalland DES met onJanuary 9, 1998, atKalwall's request, to discuss and review Kalwall's compliance withits 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 operatingpermit (FESOP) for the interimperiod prior to a Title V Permit issuance. 23. Meetings wereheld onAugust 19, 1998 and September 2, 1998 to discuss issues involving the current VOC RACT Order for theFacility. 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 substrateinplace ofaprimer coat and use ofwaterbased primers. Thetrials conducted with themediablasting proved unsuccessful in the bonding ofthe 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 ofthe water from the primer priorto coating application. Consistent availability and supply ofthe waterbased pretreat primers was also identified as a problem. Making process changes and adding an oven for drying ofthewaterbased pretreatprimer 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 beFinal VOC RACT Order ARD-99-001 June 25, 1999 Page 5 economically not feasible orviable. 25. Kalwall submitted the following VOC RACT Proposal for the KCRF pretreat primer:

a. Limitthe VOC emissionrate ofthe primerused in theKCRF process to 6.3 lb VOC/ gallon ofprimer, as applied, excluding water and exempt compounds at all times. b. Kalwall shall maintainrecords ofthe monthlyusage 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 ofEnv-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 ofaluminum metal substrate, therefore this data can not be maintained and reported.)

e. Kalwallproposedthat sections D.2, D.3, D.4, D.5, and D.6 from RACT Order ARD95-010 only applyto theKCRF process. Furthermore, Kalwall proposedthat 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 Orderto Kalwallfor 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 onApril 1, 1999 and April 7, 1999. DES and Kalwall staffconvened onApril 14, 1999 to review potential alternative methods to provide primafacie evidence as to compliance ofcustom color coatings used in the KCRF process. 28. A public hearing was held onMay 24, 1999 at the DES. A summary testimony was given bythe AirResources Division onthe 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 NewHampshire Code ofAdministrative 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 onthe proposed VOC RACT Order for the Kalwallfacility. Kalwall submitted typographical and phrase changes to theproposed VOC RACT Order and included a "Supplemental VOCRACT Evaluation ofAlternatives

- Use ofNitrogen 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 studyofavailable VOC control techniques. 30. TheEPAfaxed written connents onthe proposed VOC RACT Orderto theDES on June 8, 1999. In its response, EPA stated "EPAis strongly encouraging New Hampshire, and other states, to discontinue the issuance of source-specific variances from RACT requirements fur facilities that canfeasibly 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 ofemissionreduction credits from another facility". 31. Thefollowing areproposed changes to the existing RACT Order:

a. Ratherthanrevisethe currentRACT OrderARD-95-010, taking outreferences to the KCRF process, and issuing a new RACT Order solely for the KCRF process and the pretreatprimer specifically, the DES has instead, drafted a single VOC RACT Order to replace the current one, and includes conditions specific to the pretreatprimer and KCRF process. In addition, the new proposed VOC RACT Order includes VOC RACT limits for dull and clear coats used inthe 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 ofeach year detailing all efforts to reduce VOC emissions facility wide during the preceding calendar year, including, ifapplicable, any examinations or evaluations undertaken ofalternative adhesives orcoatings foruse as a low-VOC replacement for the TBSS adhesive orthe KCRF pretreat primer respectively."

c. Inorderto address concerns regardingrecord keeping requirements ofEnv-A 901.04 and 901.06, specifically, measuring, recording, and reporting ofthe square footage ofraw 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 spraybooths permit limit of30 tons per year ofVOC emissions (for the three spraybooths in the KCRF process), the 100 ton peryear facility wide VOC emissions limit contained inFinalVOCRACT OrderARD-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 VOCRACT Order has the following language added to PartD - Item 7, which states thefollowing: "Suchinformationwill 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 inEnv-A 1204, as applied, for each coating used in each classifiable process.". As was previously accepted in the existing RACT Order, coatings used intheKWS process wereto be limited to a 4.3 lb VOC/gallonlimit as referenced in Env-A 1204.16(g)(1), which is for soft, specialtyprotective, decorative, orfunctional coatings onto plastic substrates. The dull and clear coat coatings used in the KWS process are notbydefinition soft and do notfit in any ofthe listed subcategories of theplastics parts coating categoryfound in Env-A 1204.16. Kalwall applies a single layer, less than50 mils thickness, ofthe dull or clear coat to the surface offiberglass 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 shallbe suchthat theKWS process shall be limited at all times to 4.3 lb VOC/gallonofcoating, as applied, excluding water and exempt compounds. The DES feels this emission standard is technicallyjustified when compared to similar materials, i.e. specialty coatings to plastic components ofautomobile exteriors and protective, decorative, or functional coatings onto metal parts that are clear or transparent top coats, which each have emission limits of4.3 lb VOC/gallon of coating as applied.

e. Kalwall uses clear and transparent topcoats in the KCRF process. Clear or transparent coatings used as aprotective, decorative orfunctional coating onto metal parts and products have a VOC emissions limit of4.3 lb VOC/gal ofcoating, as applied, excluding water and exempt compounds as stated inEnv-A 1204.15(c)(!), versus the 3.5 lb VOC/gal ofcoating, 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 ofclear ortransparent topcoats used in theKCRF process. f Kalwall was concerned about imposition of a 30 ton per year VOC limit for the KCRFprocess referenced in Item 7- PartD. (FormerlyItem 6.) in an earlier draft of the proposed revised VOC RACT Order which called for daily record keeping of coating usage and daily calculation ofVOC emissions for each ofthe KCRF spray booths for the purpose ofkeeping a running total ofVOC emissions to benchmark continuous compliance with the 30 ton per year limit. The DES has modified ItemFinal VOC RACT OrderARD-99-001 June 25, 1999 Page 8 7.- PartD. to require Kalwallto maintainrecords ofthemonthlyusage and emissions of all VOCs from each operation individually and from combined operations as stated intheprevious VOC RACT OrderARD 95-010, noting that "Suchinformation willbeused to determine compliance with all existing individual process permits and any future permits to be issued." g. Kalwall expressed concern overhavingMethod 24 testing completed prior to theuse ofcustom colors for its KCRF fmish. Inthese situations Kalwall cooperates withits vendor to match the specified color using the existing Kalwall base formulations. Dueto the lengthoftime that it takes to have aMethod 24 analysis performed, there is insufficienttime to complete Method 24 testing, formulate sufficient quantities of coating for the specifiedjob, and fabricate thejob for delivery before delivery dates typically requestedbycustomers. Forthis reason, theDES has included the option of either performing Method 24 analyses or prima facie evidence of the actual content ofthe coating as specified in the text found in Item 8.- PartD. h. Item 5.

- PartD. has been changed to reflect the use ofemissions reductions credits ratherthan the alternative VOC RACT limit of63 lb VOC/gallon ofpretreatprimer 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 ofbonding agent, as applied, excluding water and exempt compounds, at all times. 2. For the KWS process, Kalwall shallmeet the following requirement as RACT:

a. Limitthe VOC emissionrate to 43 lb VOC/gallon ofcoating, 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 ofMiscellaneous Metal Parts and Products, which limits the VOC emission rate to 3.5 lb VOC/gallon ofcoating, as applied, excluding water and exempt compounds, at all times, for air dried coatings as aprotective, decorative or functional coating onto metalparts 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 ofMiscellaneous Metal Parts and Products, which limits the VOC emission rate to 4.3 lb VOC/gallon ofcoating, asFinal VOC RACT OrderARD-99-001 June 25, 1999 Page9 applied, excluding water and exempt compounds, at all times, for clear or transparent topcoats as a protective, decorative orfunctional coating onto metalparts and products. 5. For pretreat primer applied in the KCRF process, comply with the provisions ofEnv-A 1204.15(c)(3) Emissions Standardsfor Coating ofMiscellaneous MetalParts and Products, which limits the VOC emission rate to 3.5 lb VOC/ gallon ofcoating, as applied, excluding water and exempt compounds, at all times, for a coating that is used in extreme environmental conditions. Ifthe facility is unable to meet this VOC RACT limit, it shall comply with the applicable requirements contained in Env-A 3100 Discrete Emissions Reductions TradingProgram. 6. Kalwall shall use Best Workpractice Standards in use ofMEK for wipe down ofmetal substrate. This requires use ofbench cans for application ofMEK to wipe down rags and the use ofclosed containers for the storage ofcontaminated wipe down rags that are not in use. 7. Kalwall shall maintain records ofthe monthly usage and emissions ofall 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. Priorto the use ofany new coatings and primers at the facility, Kalwall must demonstrate compliance with D.1, D.2, D.3, D.4, orD.5, as applicable, by one ofthe following options:

a. Prima facie evidence

- Use ofchemical manufacturers Material Safety Data Sheet (MSDS) information (density and weightpercent VOC content) along with Kalwall coating formulation recipe information (gallons ofeach ingredient, i.e. resins, cure, diluent solvent, and exempt diluent solvent; density ofeach ingredient; and weight percent VOC content ofeach ingredient). Kalwall shall calculate the pounds VOC per gallon coating minus water and exempt compounds for the coating as applied via use ofthe following formula: (P 

## *X)/(1

- Yw- Ye) Where: P= X= Yw= Ye= Density ofthe mixed coating as applied (pounds coating/gallon coating) Weight fraction ofVOCinthe mixed coating Volume fraction ofwater in the mixed coating Volume fraction ofexempt 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 inthe annual VOC report; ORFinal VOC RACT Order ARD-99-001 June 25, 1999 Page 10 b. For sources subjectto Env-A 1204, whenformal 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 CFRPart 60, Appendix A for all coatings as applicable using the 60-minute baketime procedure; or (2) Method 24A, 40 CFRPart 60, Appendix A as applicable.

c. The DES reserves the right to have Kalwa!! perform Method 24 testing on any coatings for formal demonstration ofcompliance. 9. Kalwall shall submit an annual report, no later than April 15th ofeach year, detailing all efforts to reduce VOC emissions facility-wide during thepreceding calendaryear, including, ifapplicable, any examinations or evaluations undertaken ofalternative 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 ofEnv-A 901.04 and Env-A 901.06. 11. Kalwall shall comply with the permits issued by theDES. Please address any correspondence and co=unicationin reference to this Order to: Mr. Douglas C. Laughton NHDES, Air Resources Division 64 N. Main St., P.O. box 2033 Concord, NH03302-2033

# ~~ KennethA Colburn, Director AirResources Division

cc: Bob Cheney, SPB+G MaryRue!, DES Craig Wright, DES h:\laughton\conespo\kalwal-m\vocracLful Final VOC RACT Order 06/25/99