___________________________________ 

TFX Medical, Inc. ] FINAL RACT ORDER

50 Plantation Drive ] August 7, 2007

Jaffrey, NH 03452 ] ARD07-002

 ] 

___________________________________ ] 

A. Introduction

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

Resources Division, to TFX Medical, 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. TFX Medical, Inc. (TFX) is a New Hampshire corporation doing business at the mailing address 

of 50 Plantation Drive, Jaffrey, NH 03452, telephone number (603) 532-7706. 

C. Statements of Fact and Law

1. TFX owns and operates a facility located at 50 Plantation Drive in Jaffrey, NH primarily 

engaged in the manufacturing of tubing for automotive and medical applications and medical 

devices. The tubing is manufactured by extruding a mixture of polytetrafluoroethylene (PTFE) 

resin with a hydrocarbon solvent and curing the tubing in ovens. 

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 applicable RACT requirements. 

3. TFX is subject to Env-A 1204.49, Compliance Options for Miscellaneous and Multicategory 

Stationary VOC Sources, because the theoretical potential to emit (TPE) exceeds 50 tons of nonexempt VOCs during any consecutive 12-month period.

4. TFX has extruder lines and curing ovens that are ducted to a common header and exhausted 

through a recuperative thermal oxidizer (RTO). An etch process is also exhausted through the 

RTO. VOC emissions are also emitted, uncontrolled, from other minor core activities. 

5. The printing, medical device assembly and sand bath processes are defined as minor core 

activities under Env-A 1204.03(bi), Definitions, because their actual VOC emissions do not 

exceed a total of five tons per year. Pursuant to Env-A 1204.02(d), Scope, these minor core 

processes are exempt from the provisions of VOC RACT. 

6. TFX is complying with the requirements of Env-A 1204.49 with the use of the RTO, to reduce 

facility-wide VOC emissions by at least 81%, calculated on a daily basis. 

7. The extruder process, including the RTO, and the etch process are currently covered under State 

Permit to Operate FP-S-0091 issued on September 24, 2004. 
RACT Order No. ARD07-002 August 7, 2007 

TFX Medical, Inc. Page 2 of 5 

8. On December 1, 2006, DES issued a Letter of Deficiency (LOD), No. ARD 06-029, stating that 

TFX emitted 3.87 tons of excess VOC emissions due to malfunctions of the RTO during the 

calendar years 2001 to 2005. The LOD required TFX to submit an application to obtain a 

RACT Order for compliance purposes when the RTO shuts down due to a malfunction or for 

maintenance. 

9. On December 13, 2006, TFX submitted an application for a VOC RACT Order that would allow 

TFX to generate and use Discrete Emissions Reductions (DERs) in order to comply with the 

daily VOC reduction requirements during periods when the RTO can not meet the VOC 

reduction requirement. 

D. Order

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

Order, to comply with the following requirements as RACT: 

1. Except as specified in 2., below, TFX shall comply with the VOC control standards specified in 

Env-A 1204.49, Compliance Options for Miscellaneous and Multicategory Stationary VOC 

Sources by operating a capture and control system that results in the facility-wide reduction of 

the actual uncontrolled VOC emission rate from non-exempt processes, calculated on a daily 

basis, by at least 81%. 

2. For times that the capture and control system is unable to meet the 81% reduction requirement 

specified in Env-A 1204.49, TFX shall be allowed to use discrete emissions reductions (DERs) 

in accordance with Condition D.3. of this Order, for the purpose of complying with the VOC 

RACT requirements by self-generating DERs in accordance with Env-A 3100, Discrete 

Emissions Reduction Trading Program. 

3. Generation and Use of DERs: 

TFX shall be allowed to self-generate DERs for VOC emission reductions that are achieved in 

excess of the reductions required in Part D.1 of this Order. TFX shall be allowed to use the selfgenerated DERs for RACT compliance in accordance with D.2 of this Order. The following 

calculations shall be used to determine the amount of DERs generated and/or used on a given 

day. 

a. Calculation of Allowable VOC Emissions per Day

For the purposes of complying with the VOC RACT requirement specified in Env-A 

1204.49, TFX shall calculate the daily allowable VOC emission rate as follows: 

“Eal” means the allowable VOC emission rate; 

“A” means the actual, uncontrolled emission rate from the extruders; 

“B” means the actual, uncontrolled emission rate from the etch process; and 

“Eal” shall be calculated as in the following equation:

Eal = (A + B)*(1-0.81) 
RACT Order No. ARD07-002 August 7, 2007 

TFX Medical, Inc. Page 3 of 5 

b. Calculation of Actual VOC Emissions per Day

TFX shall calculate the daily actual VOC emission rate from the processes as follows: 

“Eac” means the actual VOC emission rate; 

“AC” means the actual, controlled emission rate from the extruders; 

“Bc” means the actual, controlled emission rate from the etch process; and 

“Eac” shall be equal to the sum of AC and B, as in the following equation: 

Eac = AC + Bc

c. Emission Credit Use and Generation Calculations

To determine if TFX will either generate DERs or need to use DERs for compliance with 

RACT on a given day, TFX shall subtract the actual VOC emission rate (Eac) as calculated 

in accordance with 3.a. of this Order, from the allowable VOC emission rate (Eal) as 

calculated in accordance with 3.b. of this Order. 

(i) Generation of DERs: 

 If the result of the subtraction is a positive number, then the emissions are below the 

requirements of RACT and the amount equal to the difference between Eal and Eac will 

count towards the generation of DERs. The actual DERs shall be calculated by taking 

the amount of credited emissions and multiplying them by a safety factor of 0.9. 

(ii) Use of DERs: 

If the result of the subtraction is a negative number, then the emissions exceed the 

VOC RACT requirements and emission credits equal to the difference between Eal and 

Eac shall be used to offset these excess emissions. The actual DERs required to offset 

the excess emissions shall be calculated by dividing the excess emissions by an 

environmental benefit factor of 0.9.

4. Recordkeeping Requirements

TFX shall maintain all records of the calculation related to the generation and use of DERs as 

specified in Condition D.3. to demonstrate compliance with this Order. Each record shall be 

kept for a period of at least five years. 

5. Reporting Requirements

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

a. Annually by November 30, TFX 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: 

(i.) The name and location of the user; 

(ii.) 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); 

(iii.) The protocol used to document the amount of DERs needed to demonstrate 

compliance; and 
RACT Order No. ARD07-002 August 7, 2007 

TFX Medical, Inc. Page 4 of 5 

(iv.) Information documenting that TFX is in compliance with Env-A 1400, Regulated 

Toxic Air Pollutants. 

b. Annually by April 15, TFX 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: 

(i.) The name and location of the owner or operator of the source; 

(ii.) A brief description of the generation activity; 

(iii.) A list of the source’s applicable allowable emission rates; 

(iv.) The amount of DERs generated each month; 

(v.) A calculation of the amount of DERs generated; 

(vi.) The amount of DERs used each month; 

(vii.) A calculation of the amount of DERs required to demonstrate compliance with the 

emission limits stated in Part D, above. 

(viii.) A statement that the reductions were calculated in accordance with Env-A 3103.07; 

(ix.) A statement that the DERs were not generated in whole or in part from actions 

prohibited pursuant to Env-A 3103.07; 

(x.) 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; 

(xi.) A statement that the DERs were not used in a manner prohibited under the regulation 

or other provisions of law; and 

(xii.) The report shall contain a certification by a responsible official of truth, accuracy and 

completeness and shall state that: 

(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 Order to the following: 

Ms. Barbara Dorfschmidt 

NHDES, Air Resources Division 

Bureau of Permitting and Environmental Health 

29 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

(603) 271-6796 
RACT Order No. ARD07-002 August 7, 2007 

TFX Medical, Inc. Page 5 of 5 

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 

Ann Arnold, USEPA 

Town of Jaffrey 

H:\Permitting\Source Files\TFX Medical\VOC RACT Order\TFX_RACT Order ARD07-0002_final.doc