Metal Works, Inc. 

22 Industrial Drive 

Londonderry, NH 03053 

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FINAL RACT ORDER 

December 22, 2004 

ARD-05-001 

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A. Introduction 

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

Resources Division, to Metal Works, Inc., pursuant to RSA 125-C. 

B. Parties 

1. The New Hampshire Department of Environmental Services, Air Resources Division (DES), is 

a duly constituted adnllnistrative agency of the State of New Hampshire having its principal 

offices at 6 Hazen Drive, Concord, NH 03302, telephone number (603) 271-1370. 

2. Metal Works, Inc. (Metal Works) is a New Hampshire-based corporation doing business in New· 

Hampshire at the mailing address of 22 Industrial Drive, Londonderry, NH 03053, telephone 

number (603) 669-6180. 

C. Statements of Fact and Law 

1. Metal Works owns and operates a facility located on Industrial Drive in Londonderry, NH 

primarily engaged in the fabrication of sheet metaL Operations at the facility include paint 

spraying of the metal sheets in one of five spray booths. 

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 part defmes the sources that are subject to Reasonably Available Control Technology 

(RACT) requirements and specifies the RACT requirements. 

3. Metal Works is subject to Env-A 1204.15, Applicability Criteria and Compliance Standards for 

Coating of Miscellaneous Metal Parts and Products, because their TPEs exceeded 10 tons of 

non-exempt VOCs during any .consecutive 12-month period. 

4. On March 18, 2003, DES conducted a compliance inspection and noted that coatings used by 

Metal Works were in compliance with Env-A 1204.15. 

5. Metal Works filed an application for a State Permit to Operate on September 30, 2003. The 

coatings-listed in the application were different than coatings in use at the time of the 

March 18, 2003 compliance inspection. 

6. Metal Works filed supplemental information for their application for a State Permit to Operate 

on January 5, 2004. In this submittal Metal Works calculated the VOC content of their coating 

as applied and found that one coating exceeds the emission limit in Env-A 1204.15. Metal 

Works proposed, in the same submittal, the use of emission credits for compliance with RACT. 
RACT Order No. ARD-05-001 

Metal Works, Inc. 

D. Order 

December 22, 2004 

Page2of5 

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

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

1. Coating of Miscellaneous Metal Parts and Products under Env-A 1204.15: 

a. For those processes applying a protective, decorative or functional coating onto metal parts 

and products, Metal Works shall comply with the following eniission limits for each coating 

used. All limits are in units of pounds ofVOC per gallon of coating, as applied, excluding 

water and exempt compounds. Emissions in excess of these limits shall be offset by the use 

ofDERs in accordance with PartE below: 

(i) For a coating that is a clear or transparent top coat, as defined in Env-A 1204.03, 4.3 lbs 

VOC/gal coating; 

(ii) For a coating that is used in extreme environmental conditions, as defined irr 

Env-A 1204.15, 3.5 lbs VOC/gal coating; 

(iii) For a coating that is air dried, as defined in Env-A 1204.15, 3.5 lbs VOC/gal coating; 

and 

(iv) For all other coatings, 3.0 lbs VOC/gal coating. 

b. If more than one emission limit in D.l.a applies to a specific coating, then the least stringent 

emission limitation shall be applied. 

2. Calculation of Emission Standard On a Solids Basis 

For determining the amount ofDERs to be used in accordance with PartE below, 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.l, above; and 

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

formulation in terms oflb VOC/gal VOC; and 

(iv) S shall be equal to Ec divided by the difference between one and the quotient ofEc and 

dA, as in the following equation: 

S= E, 

[1-E,!dJ 

3. Calculation of Allowable VOC Emissions per Coating per Day 

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

(i) "Ea~" 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!b VOC/gal or kg VOC/1 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 oflbs/day or kg/day; 
RACTOrder No. ARD-05-001 December 22,2004 

Metal Works, Inc. Page 3 of 5 

(iii) "D" means the density of the coating or dilution solvent in units oflbs/gal coating, or 

kg/1 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 I solids/! coating as determined by calculation using the formulation; and 

(v) " E.," 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.,= S*VS*(W/D) 

4. Calculation of Actual VOC Emissions per Coating per Day 

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

(i) "Eao" means the actual VOC emission rate of a given coating in units oflbs/day; 

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

day in units oflbs/day; 

(iii) "WV" means the weight fraction ofVOC content of the coating, in units oflbs VOC/lb 

coating as determined by calculation using the formulation; and 

(iv) "Eao" shall be equal to the product ofW and WV, as in the following equation: -. - - -- .. 

Eao=W*WV 

5. Recordkeeping Requirements 

Metal Works 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. 

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) Prima facie evidence shall include all of the information required by the VOC data sheet 

found on either page II-2 or IIl-2, as applicable, of EPA document EPA-450/3-84-019, 

Procedures for CertifYing Quantity of Volatile Organic Compounds Emitted by Paint, 

Ink, and Other Coatings, dated 1984. 

If there is a discrepancy between the formulation data and the results of the Method 24 or 

24A analysis, compliance shall be based on the results from the Method 24 or 24A analysis. 

b. Maintain records in accordance with Env-A 904, VOC Emission Statements Recordkeeping 

Requirements, and submit reports in accordance with Env-A 908, VOC Emission Statements 

Reporting Requirements. 
RACT Order No. ARD-05-001 

Metal Works, Inc. 

E. Emissions Reductions Credits 

December 22, 2004 

Page 4 of5 

1. Metal Works shall be allowed to use discrete emissions reductions (DERs) for the purpose of 

satisfYing the requirements of this Order by acquiring DERs from Public Service of New 

Hampshire, as generated in accordance with the federally enforceable RACT Order No. 

ARD-98-001, approved as part of the State Implementation Plan in the Federal Register Volume 

65, page number 220 dated November 14,2000. 

2. Within90 days of issuance of this RACT Order (ARD-05-001) by DES, Metal Works shall 

acquire, or demonstrate that it already possesses, 2 ozone-season DERs for compliance with the 

requirements in Part D, for the calendar years 2003 and 2004. 

3. Armually by November 30, Metal Works shall submit a report to DES on the projected use of 

credits for the upcoming year. This report shall meet the requirements ofEnv-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 ofDERs needed to demonstrate compliance; and 

d. Information that will allow DES to determine that Metal Works is in compliance with 

Env-A 1400, Regulated Toxic Air Pollutants. 

4. Armuallyby AprillS, Metal Works shall submit a report to DES on the balance of credits for 

the previous calendar year. This report shall meet the requirements ofEnv-A 3104.09, Notice 

and Certification of Use, including the following information: 

a. The name and location of the owner or operator of the user source; 

b. The cost of the DERs; 

c. The amount ofDERs used and the associated serial numbers assigned by the DES; 

d. A calculation of the amount ofDERs required to demonstrate compliance with the emission 

limits stated in Part D, above. DERs shall be equal to the difference between the actual 

VOC emission rate (Eac) from the allowable VOC emission rate E,, as calculated in Part D 

above. divided by an environmental benefit factor of 0.9 as in the following formula: 

VOC DERs, tons= (Eac- E,,) I 0.9 

• e. A statement that due diligence was made to veii.fy that the DERs were not previously used, 

and not generated as a result of actions prohibited under the regulations qr other provisions 

oflaw; 

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

other provisions of law; and 

g. A copy of the relevant Notice and Certification of Generation (for paperwork reduction 

purposes, a certified statement that the notice is on file with DES will suffice). 

h. The Notice of Certification of Use shall contain a certification by a responsible official of 

truth, accuracy and completeness and shall state that: 
RACT Order No. ARD-05-001 December 22, 2004 

Metal Work<, Inc. Page 5 of 5 

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

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

(ii) 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 Proposed Order to the 

following: 

Ms. Barbara Dorfschmidt 

NHDES, Air Resources Division 

Stationary Source Management Bureau 

29 Hazen Drive 

P.O.Box95 

Concord, NH 03302-0095 

(603) 271-6796 

Please address any correspondence and communication in reference to the ERCs orDERs to the 

following: 

Mr. Joe Fontaine 

NHDES, Air Resources Division 

29 Hazen Drive 

P.O.Box95 

Concord, NH 03302-0095 

(603) 271-6794 

cc: Timothy Drew, PIP Office 

Ann Arnold, USEPA 

Town of Londonderry 

Robert R. Scott 

Director 

Air Resources Division 

H:\Permitting\Source Files\Metal Works\VOC RACT Order\Metal Works Final RACT Order.doc