Metal Works, Inc. 22 Industrial Drive Londonderry, NH 03053 

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## l l FINAL RACT ORDER December 22, 2004 ARD-05-001

### ------------~-------] A. Introduction This RACT Order is issuedbythe New HampshireDepartment ofEnvironmental Services, Air Resources Division, to Metal Works, Inc., pursuant to RSA 125-C. B. Parties 1. The NewHampshire Department ofEnvironmental Services, AirResources Division (DES), is a duly constituted adnllnistrative agency ofthe State ofNew 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 of22 Industrial Drive, Londonderry, NH 03053, telephone number (603) 669-6180. C. Statements ofFact and Law 1. Metal Works owns and operates a facility located onIndustrial Drive in Londonderry, NH primarilyengaged inthe fabrication ofsheet metaL Operations at the facility include paint spraying ofthe metal sheets in one offive spray booths. 2. Effective August 19, 1995, DES re-adopted the New Hampshire Code ofAdministrative 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 Standardsfor Coating of Miscellaneous Metal Parts andProducts, because their TPEs exceeded 10 tons of non-exempt VOCs during any .consecutive 12-monthperiod. 4. OnMarch 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 ofthe 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 oftheir 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 ofemission credits for compliance withRACT.RACTOrderNo. ARD-05-001 Metal Works, Inc. 

### D. Order December22, 2004 Page2of5

Based on the statements offact and law, DES hereby orders Metal Works, effective upon issuance ofthis Order, to comply with the following requirements as RACT: 1. Coating ofMiscellaneous Metal Parts and Products under Env-A 1204.15:

a. Forthoseprocesses applying a protective, decorative or functional coating onto metalparts andproducts, Metal Works shall complywiththe following eniission limits for each coating used. All limits are in units ofpounds ofVOC per gallon ofcoating, as applied, excluding water and exempt compounds. Emissions in excess ofthese limits shall be offset bythe use ofDERs in accordance with PartE below: (i) For a coating that is a clear or transparent top coat, as defined inEnv-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. Ifmore than one emission limit in D.l.a applies to a specific coating, then the least stringent emission limitation shall be applied. 2. Calculation ofEmission 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 ofpounds VOC per gallon ofcoating solids; (ii) "Ec" means the VOC emission limit as stated in Part D.l, above; and (iii) "dA" means the actual mass density ofthe VOC in the applied surface coating formulation in terms oflb VOC/gal VOC; and (iv) S shall be equal to Ec divided bythe difference between one and the quotient ofEc and dA, as in the following equation: 

### S= E, [1-E,!dJ 3. Calculation ofAllowable VOC Emissions per CoatingperDay The daily allowable VOC emissions shall be calculated for each coating as follows: (i)**"Ea~"** means the allowable VOC emission rate ofa given coating in units oflbs/day or kg/day; (i) "S" means the VOC emission standard in terms of!b VOC/gal orkgVOC/1 ofcoating solids, as calculated in Part D.2, above; (ii) "W" means the weight ofcoating or dilution solvent used inthe coating line on a given day inunits oflbs/day orkg/day;RACTOrderNo. ARD-05-001 December22,2004 MetalWorks, Inc. Page 3 of 5 (iii) "D" means the density ofthe 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 ofthe coating, inunits ofgal solids/gal coating orI solids/! coating as determinedby calculation using the formulation; and (v) " E.," shall be equal to the product ofS, VS andW dividedbyD for each coating or dilution solvent used, as inthe following equation: E.,= S*VS*(W/D) 4. Calculation ofActual VOC Emissions per Coatingper Day The daily VOC emissions shallbe calculated for each coating as follows: (i) "Eao" means the actual VOC emission rate ofa given coating in units oflbs/day; (ii) "W" means the weight ofcoating or dilution solvent used inthe coating line on a given dayinunits oflbs/day; (iii) "WV"means the weight fraction ofVOC content ofthe coating, inunits oflbs VOC/lb coating as determined by calculation using the formulation; and (iv) "Eao" shallbe equal to the product ofW and WV, as in the following equation:

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.. Eao=W*WV 5. Recordkeeping Requirements Metal Works shall maintain the following records in order to demonstrate compliance with this Order. Eachrecord shall be kept for a period ofat least five years.

a. All coatings used at the facility after the issuance ofthis RACT order shall be either tested using Methods below or the facility will retain sufficient records for prima facie evidence in support ofdemonstrating compliance with the VOC RACT limit. (i) Method 24, 40 CFRPart 60, Appendix A at 1-hourbake time, or an alternative test method approved bythe Director and EPA; or (ii) Method 24A, 40 CFRPart 60, Appendix A, or an alternative test method approved by the Director and EPA. (iii) Prima facie evidence shall include all ofthe information required bythe VOC data sheet found on eitherpage II-2 or IIl-2, as applicable, ofEPA document EPA-450/3-84-019, Procedures for CertifYing Quantity ofVolatile Organic Compounds Emitted 

### by Paint, Ink, and Other Coatings, dated 1984. Ifthere is a discrepancy between the formulation data and the results ofthe Method 24 or 24A analysis, compliance shall bebased on the results from the Method 24 or 24A analysis. b. Maintain records in accordance with Env-A 904, VOCEmission Statements Recordkeeping Requirements, and submit reports in accordance with Env-A 908, VOCEmission Statements ReportingRequirements.RACTOrderNo. 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 therequirements ofthis Order by acquiring DERs from Public Service ofNew Hampshire, as generated in accordance with the federally enforceable RACT Order No. ARD-98-001, approved as part ofthe State Implementation Plan in the Federal Register Volume 65, pagenumber 220 dated November 14,2000. 2. Within90 days ofissuance ofthis RACT Order (ARD-05-001) byDES, Metal Works shall acquire, or demonstratethat it alreadypossesses, 2 ozone-season DERs for compliance withthe requirements inPart D, for the calendar years 2003 and 2004. 3. Armually byNovember 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 ofthe user; b. A copy ofthe Notice and Certification ofGeneration submittedby the generator source to the State (for paperwork reduction purposes, a certified statement that the notice is on file withDES 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 AirPollutants. 4. ArmuallybyAprillS, Metal Works shall submit a report to DES on the balance ofcredits for the previous calendar year. This report shall meet the requirements ofEnv-A 3104.09, Notice and Certification ofUse, including the following information:

a. The name and location ofthe owner or operator ofthe user source; b. The cost ofthe DERs;

c. The amount ofDERs used and the associated serial numbers assigned by the DES; d. A calculation ofthe amount ofDERsrequired 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 byan environmental benefit factor of0.9 as in the following formula: VOC DERs, tons= (Eac- E,,) I 0.9

• e. A statement that due diligence was made to veii.fy thatthe DERs were notpreviouslyused, and not generated as a result ofactions prohibitedunder the regulations 

### qr other provisions oflaw; f. A statement that the DERs were not used in a manner prohibited under the regulation or otherprovisions oflaw; and g. A copy ofthe relevant Notice and Certification ofGeneration (for paperworkreduction purposes, a certified statement that the notice is on file with DES will suffice). h. TheNotice ofCertification ofUse shall contain a certification by a responsible official of truth, accuracy and completeness and shall state that:RACTOrderNo. ARD-05-001 December 22, 2004 Metal Work<, Inc. Page 5 of 5 (i) Based on information and beliefformed after reasonable inquiry, the statements and information in the document are true, accurate and complete; and (ii) Theuser 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 inreference to this Proposed Order to the following: Ms. Barbara Dorfschmidt NHDES, 

### Air Resources Division Stationary Source ManagementBureau 29 HazenDrive 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, AirResources Division 29 HazenDrive P.O.Box95 Concord, NH 03302-0095 (603) 271-6794

cc: TimothyDrew, PIP Office Ann Arnold, USEPA Town ofLondonderry Robert R. Scott Director AirResources Division

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