Amended VOC RACTOrderARD-96-001 Textile Tapes Corporation

Textile Tapes Corporation I04 PickeringRoad Gonic, NH 03839 

## l l l l Page 1 ofJJ

FINAL RACT ORDER ISSUED DECEMBER9, 1996 ARD-96-001



## ------------- l AMENDED AUGUST 10,2007 AMENDED NOVEMBER 16, 2012

A. Introduction This proposed revised RACT Order is issued by the New Hampshire Depmiment ofEnvironmental Services, Air Resources Division, to Textile Tapes Corporation, pursuant to RSA 125-C.

B. Parties 1. The NewHampshire Department ofEnvironmental Services, AirResources Division ("DES"), is a duly constituted administrative agency ofthe State ofNewHampshire having its principal offices at29 Hazen Drive, Concord, NH, telephone number (603) 271-1370. 2. Textile Tapes Corporation ("Textile Tapes") is a NewHampshire corporation, having a mailing address of 104 Pickering Road, Rochester, NH 03867-4604, telephone number (603) 332-5816.
C. Statements ofFact and Law
1. Textile Tapes owns and operates the following processes located at its Gonic Plant at 104 Pickering Road in Gonic, NH ("the Facility"): a. Line lA, Fabric Coating Line (removed in 1999); b. Line lB, Fabric Coating Line;

c. Line 1 C, Hot Melt Coating Line (installed in 1993). 2. Textile Tapes reported to DES that 1990 total VOC emissions were 90 tons and notedthatthe facility was operated bya compm1y otherthan Textile Tapes in 1990. 3. Textile Tapes filed a "Reasonably Available Control Technology (RACT) Statement" on March 15, 1993 for the facility. 4. DES issued a Letter ofInsufficiencydated May 19, 1993. 5. Textile Tapes filed a VOC RACT compliance schedule, inresponse to DES's Letter of Insufficiency, on June 10, 1993 as mnendment to the March 15, 1993 submittal. 6. Textile Tapes initially, in letters dated March 15, 1993 and June 10, 1993, proposed the following measures as RACT:

a. For Line lA, Line lB, and Line 1 C (with the exception stated in pmi C.6.b below) comply with the provisions ofEnv-A 1204.10,Applicability Criteria and Compliance Standardsfor Coating of Paper, Fabric, Film andFoil Substrates, which limits the emission rate ofVOC at all times to 2.9 lb/gallon ofcoating; as applied, excluding water and exempt compounds; andAmended VOCRACTOrderARD-96-001 Textile Tapes C01poration Page 2 of!! b. Forthe coating described as "5000 series adhesive" utilized onLine 1A and lB:

1. Reformulate the "5000 series adhesive" to comply withthe emissions limitation in part C.6.a., above; or
11. Install a thermal oxidizerto control VOC emissions equivalent to the emissions limitation inpart C.6.a.; or
111. Subcontract all coatings activities, which would result in emission rates exceeding the emission limitation in part C.6.a. 7. DES issued a letter onFebruary 8, 1995 requesting an updated VOC RACTplan. 8. Textile Tapes filed further revisions to update its VOC RACTplan as requested by DES on February 24, 1995. 9. Effective August 19, 1995, DES re-adopted Rule Env-A 1204 Stationary Sources of Volatile Organic Compounds (VOCs) with amendments. 10. Textile Tapes filed an evaluation ofRACT control options and an application for a RACT order pursuant to ENV-A 1204.05 on December 7, 1995. 11. Textile Tapes ultimatelyproposed the following measures as RACT in its December 7, 1995 application for RACT order:
a. For Line 1A, Line 1B, and Line 1C (withthe exception stated inpart C.6.b) comply withthe provisions ofEnv-A 1204.10,Applicability Criteria and Compliance Standards for Coating of Paper, Fabric, Film andFoil Substrates, which limits the emissions rate ofVOC al all times to 2.9lb VOC/gallon ofcoating; as applied, excluding water and exempt compounds; b. For the coating described as "5000 series adhesive," utilized on Line 1A and 1B:

1. Increase solids content of"5000 series adhesive" from 33%by weightto 40% by weight; and

11. Limit the emissionrate ofVOC resulting from the application ofthe "5000 series adhesive" at all times to 4.7 Jb VOC/gallon ofcoating, as applied, less water and exempt compounds;

c. Limitfacility-wide VOC emissions to 70 tons, on a 12-monthrolling basis; and d. File annual reports detailing efforts to meet emission limitation in C.ll.a. for all coatings. 12. On June 28, 1996, DES received Textile Tapes' application for a Title V Permit as required by Env-A 609. The application included a request to include the limits specified by the VOC RACT Order in the Title V permit once issued. 13. DES issued a RACT OrderARD-96-001 ("The Order") onDecember 9, 1996. 14. On March 5, 1998, DES received Textile Tapes' request for a modificationto the Order issued December 9, 1996 to include a provisionfor the use ofa generic release coating on line 1 C, which was not addressed inthe original Order. 15. On March 10, 1998, The United States Environmental Protection Agency ("EPA") approved the Order into the NewHampshire State Implementation Plan ("SIP"). 16. DES issued an amended Order on September 8, 1998.Amended VOC RACTOrderARD-96-001 Textile Tapes Corporation 

### 17. On October 1, 1998, DES submitted the amended Order to EPA as a SIP revision.Page 3ofll



### 18. On September 24, 1999, Textile Tapes submitted an application for installation ofthe recuperative thermal oxidizer ("RTO") and dryer replacement on coating line lB. Coating line lAwas eliminated. 19. On Janumy 18, 2000, TemponuyPermit TP-BP-651 was issued to Textile Tapes for the RTO on coating line IB. 20. On February 19, 2002, Textile Tapes requested the second modification ofthe Order to include the RTO. 21. On March 27,2002, DES received comments from the EPA on the proposed February 19, 2002 modificationto the Order. EPA asked DES to withdraw the previous Textile Tapes SIP submittal dated October I, 1998 and state in the new SIP submittal that the revised Order supersedes the previous orders. 22. On April23, 2002, DES submittedthe revised Order as a revision to the SIP; EPA deemed the submittal complete on May 28, 2002. 23. Effective December 31, 2002, DES re-adopted Rule Env-Al204, StationarySources ofVolatile Organic Compounds 

### (VOCs) with amendments. 24. On or about September 25, 2006, Textile Tapes notified DES via phone and email ofa potential business opportunity to coatproduct with a new coating known as Chemlok TS3320- 19 Primer ("Chemlok"). The newcoating exceeds the 2.9lb/gal VOC standard required by Env-A 1204.10 (c) and the Order. 25. Textile Tapes indicated to DES that the newcoating can not be applied on the RTO-controlled Line IB due to physical properties ofthe non-compliant Chemlok coating. DES directed Textile Tapes to:

a. Purchase Discrete Emissions Reduction ("DER") credits as described inEnv-A 3100 for the excess emissions generated by applying the non-compliant Chemlok coating; b. ModifY the Order to allow the application ofnon-compliant Chemlok coating on Line IC; and c. ModifY Title V Permit TV-OP-009 ("the Permit") to include the application ofnoncompliant Chemlok coating on Line !C.
26. On October 24, 2006, in accordance withEnv-A 3104.08, MacMillan & Donnelly, Inc. ("M&D") submitted a "Notice oflntentto Use Discrete Emission Reduction Credits" for the period ofOctober 25, 2006 to December 31, 2007, onbehalfofTextile Tapes, for the predicted generation ofexcess emissions whenusing the non-compliant Chemlok coating on Line 1 C. 27. M&D estimated the excess emissions fi·mn the non-complaint Chemlok coatingto be approximately 3.6 tons per year. 28. Textile Tapes providedthe purchase contract from Public Service ofNewHampshire ("PSNH"), dated October 3, 2006, documenting the pmchase ofa total of4 DER credits (2 ozone season credits and 2 non-ozone season), the serial numbers, and associated cost ofthe credits.Amended VOC RACTOrderARD-96-001 Textile Tapes Corporation Page 4 ofll 29. Textile Tapes began applying the non-compliant Chemlok coating onLine ICon October 25, 2006. 30. On December 28, 2006, DES received applications from Textile Tapes to amend the Order and the Permit to allow Textile Tapes to use DERs to comply with VOC RACT and to generate DERs inthe future through the operation ofthe RTO. 31. OnJanuary 17, 2007, Textile Tapes entered into Administrative Order by ConsentNo. AO ARD 07-003 with DES, allowing Textile Tapes to use DERs until suchtime as the Order and Permit me modified. 32. On August 10, 2007, DES issued an amended RACT Order which allowed for the use ofDERs. 33. On May 6, 2011, Textile Tapes submitted an application to replace the existing RTO with a new RTO. Temporary Permit, TP-0086, was issued onJuly 8, 2011 for the installation ofa 3.0 MMBtu/hr natural gas fired TANN Lanbein Engelbracht AmericaRegenerative Thermal Oxidizer. 34. On October 5, 2011, Textile Tapes conducted stacktesting on the RTO. The RTO demonstrated compliance withthe 95% destruction efficiency at 1568 °F which is higherthan the temperature listed in RACT Order ARD-96-00!lastissued on August 10, 2007 of 1250 °F. 35. OnAugust 3, 2012, Textile Tapes submitted an application, requesting an amendmentto link the minimum temperature requirement to stacktest conditions for the Textile Tapes RTO in RACT Order ARD-96-00I. Textiles Tapes proposed to maintainthe destruction efficiency requirement of95% which would be demonstrated through periodic stacktesting. 36. OnNovember 16, 2012, ARD-96-001 was revised to replace the minimum temperature requirement of 1250 °F with the requirements that the RTO temperature will not drop below the average temperature at whichthe facility has demonstrated compliance through the most recent DES approved stack testing. D. Order 1. Based onthe above findings and determinations, DES hereby orders Textile Tapes to implement the following as RACT:
a. For Line lB and Line 1 C, when applying compliant coatings, (as defined in Env-A l204.03(q)) the Facility shall comply with the provisions ofEnv-A 1204.10(c),Applicability Criteria and Compliance Standards for Coating of Paper, Fabric, Film andFoil Substrates, which limits the emission rate ofVOC, at all times, to 2.9 lb VOC/gallon ofcoating; as applied, excluding water and exempt compounds; b. For line IB, when applying non-compliant coatings, (as defined inEnv-A 1204.03(az)) the Facility shall demonstrate compliance withthe provisions ofEnv-A 1204.10(c) as specified in D.I.a. above by:
1. Venting all emissions from non-compliant coatings to the thermal oxidizer; or
11. Using the daily weighted average procedure described as follows: 1. "VOCw" means the daily-weighted average VOC content ofcoatings, as applied, used on a given coating line, in units ofpmmds ofVOCper gallon ofcoating, minus water and exempt compounds;Amended VOCRACTOrderARD-96-001 Textile Tapes -Corporation Page 5 of 11 

### 2. "n"means the number ofdifferent coatings, as applied, used each day on a coating line; 3. "V;'' means the volume ofthe i11I 

### coating, as applied, used each day on a coating line, inunits ofgallons, minus water and exempt compounds; 4. "C;" means the VOC content ofthe i1 1I 

### coating, as applied, used each day on a coating line in units ofpounds ofVOCper gallon ofcoating, minus water and exempt compound; 5. "VT" means the total volume ofall coating, as applied, used each day on a coating line in units ofgallons, minus water and exempt compounds; and 6. The "VOCw" shall be equal to the sum, over then coatings used on a given coating line, ofthe products ofeach V; and C;, divided by Y.r, as in the following equation: " l)ViCi) VOCw**~J""- ---,­**  Vr



### c. For Line lC, when applying non-compliant coatings otherthan generic release coatings, the Facility shall comply with the provisions ofEnv-A 1204.10(c) as specified in D.l.a. above eitherby:
1. 

### Using the daily weighted average procedure as described in D.l.b.ii. above; or
11. 

### Using generated or purchased DERs to offset excess emissions in accordance with Condition D.6; d. For any generic release coating utilized on Line 1 C, the Facility shall:

1. 

### Limitthe emissionrate ofVOC resulting fi·om the application ofthe generic release coating, at all times, to 5.9lb VOC/gallon ofcoating applied, less water and exempt compounds; and

11. 

### Limitthe facility-wide use ofthe generic release coatingto less than 5 tons during any consecutive 12-monthperiod;
e. Limit facility-wide VOC emissions to 63.8 tons, on a 12-monthrolling basis; and f. 

### As part ofthe Annual Emissions Report submitted annually by Aprill5 1 h 

### ofthe following yem, include information detailing efforts to meet the emission limitationinD.I.a. for a generic release coating including:

1. 

### A technical evaluation ofeach alternative coating considered and basis for acceptance or rejection; or
11. 

### A statement indicating thatno coatings were evaluated during the time period covered by the report. 2. Priorto the use ofany new coating, Textile Tapes shall demonstrate compliance by one ofthe following options:
a. Chemical manufacturers Material Safety Data Sheet (MSDS) information (density and weight percentVOC content) along with the Facility coating formulation recipe informationAmended VOCRACTOrderARD-96-001 Textile Tapes Cmporation Page 6 ofll

Where: (gallons ofeach ingredient, i.e. coatings, diluent solvent, and exempt diluent solvent; density ofeach ingredient; and weight percent VOC content ofeach ingredient). The Facility shall calculate the pounds VOC per gallon coating as applied, minus water and exempt compounds using the following formula: 

### P*X 

### (1-Yw-Ye)

"P"means the density ofthe mixed coating as applied (pounds coating/gallon coating); "X" means the weight fi·action ofVOC in the mixed coating; "Y,v'' means the volmne fraction ofwater in the mixed coating; and "Ye"means the volume fraction ofexemptcompounds inthe mixed coating. When using this option, the Facility shall maintainthe calculation sheets and records for each coating formulation; or b. The referee liquid VOC test method specified as follows:
1. Method 24, 40 CFRpmt 60, Appendix A for all coatings as applicable using the 60- minute bake time procedure; or
u. Method 24A, 40 CFR Pmi 60, Appendix A as applicable.
c. DES reserves the right to have the facility performMethod 24 testing on any coatings for formal demonstration ofcompliance. d. All Method 24 analyses and/or calculation sheets for newcoatings shall be submitted in the aruma! VOC report. 3. Textile Tapes is subjectto Env-A 1204.10,Applicability Criteria and Compliance Standards for Coating of Paper, Fabric, Film andFoil Substrates and has chosen to comply withthis section for its non-compliant coatings onLine 1B by implementing an add-on control system as specified in D.1.b.i. Textile Tapes is required to comply with the more stringent of:

a. A VOC emissionreduction efficiency of95%, as specified in D.4.a; b. An overall VOC emission reduction efficiency determined as follows:
1. The VOC emission rate limit, when operating with the thermal oxidizer, shall be determined, on a solid basis, by the following equation in accordance withEnv-a 1204.04:

Where: "S" means the VOC emission rate limit interms oflbs VOC/gal ofcoating solids;Amended VOC RACTOrderARD-96-001 1'e:ttile Tapes Corporation Page 7 of II "dA" means the actual density ofVOC for convertingthe emission limitation to a solids basis in lbs/gal. The Permittee has an option to use the density value of7.36lb/gal if running more than one coating; "Ec" means the emission rate limit prescribed for the applicable coating category. For thoseprocesses 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, Ec shall be equal to 2.9 lbs VOC/gal ofcoating, as applied to the substrate; and ii. The required overall emissionreduction efficiency, E, shall be determinedbythe following equation: 

### E-(VOCa-S\

- .. VOCa 

# lO%

Where: S =TheVOC emission rate limit in terms oflbs VOC/gal ofcoating solids; VOCa =The maximum VOC content ofthe coatings used in lb VOC/gal solids or the daily weighted average VOC content ofthe coatings used in lb VOC/gal solids; or 4. Textile Tapes shall performthe following monitoring and testing ofthe RTO:
a. Minimum destruction efficiency for the RTO shall be at least 95% and the RTO combustion temperatme shall not drop belowthe average temperature at which Textile Tapes has demonstrated compliance through the mostrecent DES approved stacktesting with the 95% efficiency. b. Textile Tapes shall conduct compliance stack testing once every 5 years within 90 days of the anniversmy ofthe previous stacktest. For stack testing purposes only, Textile Tapes shall be allowed to operate at a lower temperatme than identified initem 4.a above in an effortto demonstrate compliancewiththe RACT Order RTO 95% efficiency requirement. In the eventthat Textile Tapes does not meetthe provisions ofthe RACT order during the stacktest, then Textile Tapes shall be allowed to use DERs as described initem 5 belowfor RACT compliance dming the stacktesting period.

c. The Facility shall maintain copies ofcompliance stacktest records on site. These records shall be made available to DES/USEPA uponrequest. d. The combustion temperatme ofthe RTO shall be monitored and recorded continuously.
e. The Facility shall operate low-temperature lockout, a low temperature alarm, or a temperature chmt which shall be examined at least once eve1y 24 hours to ensure compliance with the minimum combustion temperature identified in item 4.a above. Records ofall temperature monitoring shall be maintained at the facility for inspection for at least 5 years. f. Compliancewiththe monitoring requirement to reduce VOC emissions from the d1yer exhaust by a minimum of95% shall be demonstrated using the applicable procedme(s) described inEnv-A 804, Volatile Organic Compound Testing, and in accordance withthe Permit.Amended VOCRACTOrderARD-96-001 TexHle Tapes Cmporation Page 8 of 11
g. Textile Tapes shall be allowedto generate DERs for emission reductions that are achieved in excess ofthereductions required in Part D.3 or the lowest applicable allowable emissions rate limit, as specified in Env-A 3103.02. 5. Textile Tapes shall be allowed to use DERs for RACT compliance during times that it is unable to meetthe maximum emissionrate stated in Part D.l.a. The following calculations will be used to determine the amount ofcredits generated on a given day:

a. Calculation ofAllowable VOC Emissions per Day "E,," means the allowable VOC emission rate; "Ep,e" means the actual emission rate from line 1 B before entering the thermal oxidizer; "E"means the required overall reduction efficiency (expressed as a decimal) as determined in Part D.3; and "E,," shall be calcnlated as in the following equation: Eal = Er« 

## * (1-E) b. Actual VOC Emissions per Day "Eao" means the actual VOC emission rate
c. Emission Credit Generation Calculation Textile Tapes shall subtractthe actual VOC emission rate (Eac) fi-om the allowable VOC emissionrate (E, 1 );

to determine ifemission credits will be generated on a given day using the following criteria:
1. Ifthe result ofthe subtraction is apositive number, thenthe emissions are belowthe requirements ofRACT and the amount equal to the difference between E, 1and Eac will count towards emission credits;
11. Actual emission credits shall be calculated by taking the amount ofcredited emissions inpmi D.5.c.i and multiplying themby a safety factor of0.9; and
111. In no instance should generated DERs plus Textile Tapes' actual emissions in any 1 2-month period exceed the mmual VOC emissions limit stated inthe Permit. 6. Textile Tapes shall be allowed to use generated or purchased DERs to comply with VOC RACT according to the following:

a. Non-compliant coatings shall only be applied on Coating Line 1 C when there is a physical limitationpreventing Textile Tapes from applying the coatings on CoatingLine lB; b. DERs shall only be used to achieve compliance when the RTO is out ofservice due to a malfunction or routine maintenance, or when a non-compliant coating must be applied on Coating Line IC;
c. The amount ofDERs required to achieve compliance shall be calculated according to the following:Amended VOCRACTOrderARD-96-001 Textile Tapes Corporation Page 9 of 11 1. The emission rate limit shall be determined on a solids basis, according to the equation 

### in DJ.b.i. 11. The Allowable VOC Emissions per Coating shall be calculated for each coating as follows: 1. "E,( means the allowable VOC emissionrate ofa given coating inunits oflb/month or kg/month; 2. "S"means the VOC emission standard in te1ms oflbVOC/gal or kg VOC/1 of coating solids, as calculated in item 6.c.i, above; 3. "W" means the weight ofcoating or dilution solventused in the coating line in units ofpounds or kg; 4. "D"means the density ofthe coating or dilution solvent in units oflb/gal coating, or kg/! coating as determined from Method 24 or 24A analysis; 5. "Vs" means the volume fraction ofthe solids content ofthe coating, inunits ofgal solids/gal coating or 1solids/! coating as determinedby calculationusing the formulation; and 6. "E,( shall be equalto the product ofS, VS and W dividedby D for each coating or dilution solventused, as in the following equation:
E,1 = S* Vs *(W/D)
iii. The Actual VOC Emissions per Coating shall be calculated for each coating as follows: 1. "Eac" means the actual VOC emissionrate ofa given coating in units ofpounds; 2. "W" means the weight ofcoating or dilution solvent used in the coating line in units ofpounds; 3. "Wv" means the weight fraction ofVOC content ofthe coating, inunits oflb VOC/lb coating as determinedby calculation using the formulation; and 4. "Eac" shall be equal to the product ofW and Wv, as in the following equation: E,c=W* Wv

lV. The Excess Emissions per Coating shall be equal to the difference between the actual VOC emissions (E,c) andthe allowable VOC emissions (E,1).

Excess Emissions = E,c

- E,1

v. At the time ofuse, Textile Tapes shall permanentlyretire tenpercent ofall DERs dedicated to thatparticular use, suchthat the amount ofDERs required to demonstrate compliance shall equal the excess emissions calculated initem iv above divided by an environmental benefit factor of0.9. 7. Textile Tapes shall comply withrecordkeeping requirements ofEnv-A 904.03, and Env-AAmended VOC RACTOrderARD-96-001 Textile Tapes Cmporation 904.07 for an add-on pollution control device, specifically the RTO. Page 10 ofll

8. Annually by November 30, Textile Tapes shall submit a report to DES onthe projected use of credits for the upcoming year. This report shall meet the requirements ofEnv-A 3104.08, Notice oflntent to Use DERs, including the following information:
a. The name and location ofthe user; b. A copy ofthe Notice and Certification ofGeneration submitted by the generator source to the State (for paperworkreduction purposes, a certified statementthat 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 documenting that Textile Tapes is in compliance with Env-A 1400, Regulated Toxic AirPollutants. 9. Annually by Aprill5, Textile Tapes shall submit a reportto DES onthe balance ofcredits for the previous calendaryear. This report shall meet the requirements ofEnv-A 3103.08,Notice and Certification a_{Generation and Env-A 3104.09, Notice and Certification ofUse, including the following information:
a. The name and location ofthe owner or operator ofthe source; b. A briefdescription ofthe generation activity;
c. A list ofthe source's applicable allowable emission rates; d. The amount ofDERs generated each month;
e. A calculation ofthe amount ofDERs generated; f. The amount ofDERs used eachmonth; g. A calculation ofthe amount ofDERsrequired to demonstmte compliance with the emission limits stated above; h. A statement that the reductions were calculated in accordance with Env-A 3103.07;
1. A statement that the DERs were not generated inwhole or in part from actions prohibited pursuant to Env-A 3103.07; 

### J. A statementthat due diligence was made to verify that the DERs were notpreviously used, and not generated as a result ofactions prohibited under the regulations or otherprovisions oflaw; 

### k. A statement that the DERs were not used in a mannerprohibited under the regulations or other provisions oflaw; and l. A certificationby a responsible official oftruth, accuracy, and completeness that states:
1. Based on information and beliefformed after reasonable inquiry, the statements and information in the document are true, accurate, and complete; and
11. The user source in compliance with all National Ambient Air Quality Standards, except ground level ozone, and all AmbientAirLimits for Regulated Toxic Air Pollutants. 10. Textile Tapes shall complywith all terms and conditions contained inpermits to be issuedbyAmended VOCRACTOrderARD-96-001 Textile Tapes Corporation DES. Please address any correspondence and communication in reference to this Order to: Air Permit Programs Manager Permitting & Environmental Health Bureau NHDES, AirResources Division

29 Hazen Drive., P.O. Box 95

Concord, NH 03302-0095 (603) 271-1370 Please address any COJTespondence and communication in reference to the DERs to: Joseph T. Fontaine Teclmical Services Bureau NHDES, Air Resomces Division

29 Hazen Drive., P.O. Box 95

Concord, NH 03302-0095 (603) 271-6794

# ~ 

# ·a

# w-!6VI
Craig

# ~right, Acting Director Air Resources Division

cc: Timothy Drew, PIP Office Anne Amold, US EPA City ofRochester Tim Donnelly, MacMillan & Donnelly Page JJ ofll