___________________________________ 

Polyonics, Inc. ] FINAL RACT ORDER

867 Route 12, Unit 4 ] December 28, 2007

Westmoreland, NH 03467 ] ARD07-004

 ] 

___________________________________ ] 

A. Introduction

This RACT Order is issued by the New Hampshire Department of Environmental Services, Air 

Resources Division, to Polyonics, Inc., 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 29 Hazen Drive, Concord, NH 03302, telephone number (603) 271-1370. 

2. Polyonics, Inc. (Polyonics) is a New Hampshire corporation doing business at the mailing 

address of 867 Route 12, Unit 4, Westmoreland, NH 03467, telephone number (603) 352-1415. 

C. Statements of Fact and Law

1. Polyonics owns and operates a facility located on Route 12 in Westmoreland, NH primarily 

engaged in the manufacturing of pressure sensitive tagging and labeling materials. The coating 

process consists of two 12-inch web coaters that apply coatings onto non-paper webs. 

2. Effective December 31, 2002, DES re-adopted the New Hampshire Code of Administrative 

Rules Env-A 1204, Stationary Sources of Volatile Organic Compounds (VOCs) with 

amendments. This part defines the sources that are subject to Reasonably Available Control 

Technology (RACT) requirements and specifies the RACT requirements. 

3. Env-A 1204.10, Applicability Criteria and Compliance Standards for Coating of Paper, Fabric, 

Film and Foil Substrates, applies to any source whose paper, fabric, film, or foil coating 

operations, including specialty printing, have a combined potential to emit, during any 

consecutive 12-month period, of at least 10 tons of VOC. 

4. Polyonics has estimated that the Facility has a potential to emit approximately 30 tons of VOCs 

per year. 

5. In the cover letter to the permit application received by DES on May 8, 2001, Polyonics 

requested an annual facility-wide limit of 10 tons of VOC emissions. 

6. On February 20, 2002, DES issued State Permit to Operate No. FP-S-0171 to Polyonics for a 

five-year term. Condition V of the permit exempts Polyonics from the requirements of Env-A 

1204.10 provided that the combined, actual VOC emissions from all coating operations do not 

exceed 10 tons during any consecutive 12-month period. 

7. From the time that Polyonics started operating in 1996 to August 2006, actual VOC emissions 

have been less than 10 tpy. 
RACT Order No. ARD07-004 December 28, 2007 

Polyonics, Inc. Page 2 of 6 

8. Polyonics’ actual VOC emissions exceeded the 10 ton permit limit at the end of August 2006, 

making them subject to Env-A 1204.10. 

9. On May 1, 2007, DES and Polyonics executed an Administrative Order by Consent (AOC) No. 

ARD 07-002 (as amended on July 16, 2007). The AOC, as amended, required Polyonics to 

purchase and retire Discrete Emission Reductions (DERs) for excess emissions in 2006 and for 

estimated excess emissions that will occur in 2007. The AOC also listed compliance deadlines 

for the installation of pollution control equipment. 

10. On May 10, 2007, Polyonics submitted an application for the installation of a catalytic 

oxidizer. The application also served as an application for a VOC RACT Order that will allow 

for the generation and use of DERs for VOC RACT compliance. 

11. On July 18, 2007, DES issued Temporary Permit, FP-T-0152, which allows Polyonics to install 

and operate a catalytic oxidizer to control VOC emissions from its two web gravure coaters. 

D. Order

Based on the statements of fact and law, DES hereby orders Polyonics, effective upon issuance of 

this Order, to comply with the following requirements as RACT: 

1. Coating of Paper, Fabric, Film and Foil Substrates under Env-A 1204.10:

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, 

Polyonics shall comply with the following emission limit for each coating used: 2.9 pounds of 

VOC per gallon of coating, as applied, excluding water and exempt compounds. 

2. Alternative Methods of Complying with Env-A 1204.10

As an alternative to the emission rate limit stated in D.1 above, Polyonics may use add-on 

controls, bubbling, DERs or any combination of the previous methods, and comply with a solidsbased emission rate limit as calculated in D.4. 

3. Catalytic Oxidizer Operation

Polyonics shall operate a catalytic oxidizer (oxidizer) at all times that the coaters are in operation

except during times of malfunction or maintenance. The oxidizer shall be operated pursuant to 

the following conditions: 

 (i) The oxidizer shall be operated at a minimum combustion chamber temperature of 650°F. 

 (ii) The oxidizer shall be maintained in a manner consistent with the manufacturer’s 

recommendations; and 

 (iii) Polyonics shall operate and maintain equipment to continuously monitor and record the 

temperature of the oxidizer’s combustion chamber and the exhaust. 
RACT Order No. ARD07-004 December 28, 2007 

Polyonics, Inc. Page 3 of 6 

4. Calculation of Emission Standard On a Solids Basis

The emission rate limit shall be determined on a solids basis, as specified below: 

(i) “S” means the VOC emission standard in terms of pounds VOC per gallon of coating 

solids; 

(ii) “Ec” means the VOC emission limit as stated in Part D.1, above; and 

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

formulation in terms of lb VOC/gal VOC; and 

(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: 

[ ] c A

c

1 E d/

E

S

−

=

5. Calculation of Allowable VOC Emissions per Coating 

The 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 lb/day or 

kg/day; 

(ii) "S" means the VOC emission standard in terms of lb VOC/gal or kg VOC/l of coating 

solids, as calculated in Part D.4, above; 

(iii) "W" means the weight of coating or dilution solvent used in the coating line on a given 

day in units of lb/day or kg/day; 

(iv) "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 analysis; 

(v) "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 

(vi) " 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) 

6. Calculation of Actual VOC Emissions per Coating

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

(i) “Eunc” means the actual, uncontrolled VOC emission rate of a given coating in units of 

lb/day; 

(ii) "W" means the weight of coating or dilution solvent used in the coating line on a given 

day in units of lb/day; 

(iii) “WV” means the weight fraction of VOC content of the coating, in units of lb VOC/lb 

coating as determined by calculation using the formulation; and 

(iv) “Eunc” shall be equal to the product of W and WV, as in the following equation: 

Eunc = W*WV
RACT Order No. ARD07-004 December 28, 2007 

Polyonics, Inc. Page 4 of 6 

(v) “Ec” means the actual, controlled VOC emission rate of a given coating in units of 

lb/day; 

(vi) “DRE” means the destruction removal efficiency of the pollution control device as 

measured during the most recent emissions testing of the unit.1

(vii) “Ec” shall be equal to the product of Eunc and one minus the DRE, as in the following 

equation: 

Ec = Eunc * (1 – DRE) 

7. Emission Credit Use and Generation Calculations

The calculations for generation or use of DERs shall be done on a daily basis. 

(i) Control Device Operating - Generation of DERs: 

 a. Compliant Coatings: 

 When a coating that meets the emission limits of D.1 is in use, emission credits may 

only be generated for the amount of emissions that are controlled by the control 

device. The amount of credits generated for a compliant coating shall equal the 

difference between the actual uncontrolled and controlled emission rates as 

calculated in D.5, above (Eunc – Ec). 

 b. Non-Compliant Coatings: 

 When a coating is used that does not meet the emission limits of D.1, the amount of 

credits generated shall equal the difference between the actual, controlled emissions 

and the allowable emissions (Eal – Ec). 

 c. Calculation of DERs: 

 DERs shall be calculated by multiplying the total amount of credited emissions 

calculated for the individual coatings by a safety factor of 0.9. 

(ii) Control Device Not Operating – Bubble and Use of DERs: 

For times that the control device is shut down due to malfunction or maintenance, 

Polyonics shall be allowed to bubble the emissions from multiple coatings and/or use 

DERs to offset excess emissions. 

Excess emissions shall be calculated for each coating by subtracting the actual 

emissions from the allowable emissions (Eal – Eunc). The excess emissions from all the 

coatings shall be added together (bubbling), and based on the results, one of the 

following shall be required: 

a. If the result of the bubble calculation is a positive number, then the source is in 

compliance with the emission limits and no further action is required. 

b. If the result of the bubble calculation is a negative number, then actual emissions 

exceed the allowable emission rates and need to be offset with the use of credits. 

The actual DERs required shall be calculated by taking the absolute value of the 

total excess emissions and dividing by an environmental benefit factor of 0.9.

 

1

 Prior to the initial compliance test of the control device, DRE shall be equal to 99.0%. 
RACT Order No. ARD07-004 December 28, 2007 

Polyonics, Inc. Page 5 of 6 

8. Recordkeeping Requirements

Polyonics shall maintain the following records in order to demonstrate compliance with this 

order. Each record shall be kept for a period of at least five years. 

(i) Records of all air pollution control equipment activities, including: 

 a. Records of temperature readings taken on the oxidizer; 

 b. A log of operating times of the oxidizer; and 

 c. All pollution control equipment maintenance records, including preventative 

maintenance and annual visual inspections. Records shall include the date and 

duration of any outages. 

(ii) Polyonics shall maintain all records of the calculations related to the generation and use of 

DERs as specified in Condition D.7. 

9. Reporting Requirements

 Polyonics shall submit the following reports to demonstrate compliance with this Order: 

(i) Annually by November 30, Polyonics shall submit a report to DES on the projected use of 

credits for the upcoming year. This report shall meet 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 Generation submitted by the generator source 

to the State (for paperwork reduction purposes, a certified statement that the notice is on 

file with DES will suffice); 

c. The protocol used to document the amount of DERs needed to demonstrate 

compliance; and 

d. Information documenting that Polyonics is in compliance with Env-A 1400, Regulated 

Toxic Air Pollutants. 

(ii) Annually by April 15, Polyonics 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 the source; 

b. A brief description of the generation activity; 

A list of the source’s applicable allowable emission rates; 

c. The amount of DERs generated each month; 

d. A calculation of the amount of DERs generated;

e. The amount of DERs used each month; 

f. A calculation of the amount of DERs required to demonstrate compliance with the 

emission limits stated in Part D, above. 

g. A statement that the reductions were calculated in accordance with Env-A 3103.07; 
RACT Order No. ARD07-004 December 28, 2007 

Polyonics, Inc. Page 6 of 6 

h. A statement that the DERs were not generated in whole or in part from actions 

prohibited pursuant to Env-A 3103.07; 

i. A statement that due diligence was made to verify that the DERs were not previously 

used, and not generated as a result of actions prohibited under the regulations or other 

provisions of law; 

j. A statement that the DERs were not used in a manner prohibited under the regulation or 

other provisions of law; and 

k. The report shall contain a certification by a responsible official that states: 

(1) Based on information and belief formed after reasonable inquiry, the statements 

and information in the document are true, accurate and complete; and 

(2) The user source is in compliance with all National Ambient Air Quality 

Standards, except ground level ozone, and all Ambient Air Limits for Regulated 

Toxic Air Pollutants. 

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

Ms. Barbara Dorfschmidt 

NHDES, Air Resources Division 

Permitting and Environmental Health Bureau 

29 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 

29 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

(603) 271-6794 

_____________________________ 

Robert R. Scott 

 Director 

Air Resources Division 

cc: Timothy Drew, PIP Office 

Anne Arnold, USEPA 

Town of Westmoreland 

Barry Needleman, McLane, Graf, Raulerson & Middleton Professional Association 

Howard Plante, GZA GeoEnvironmental, Inc.