Air Plan Approval; New Hampshire; Single Source VOC RACT Order for Hutchinson Sealing Systems

ENVIRONMENTAL PROTECTION AGENCY <CFR>40 CFR Part 52</CFR> <DEPDOC>[EPA-R01-OAR-2025-1741; FRL-13115-01-R1]</DEPDOC> <SUBJECT>Air Plan Approval; New Hampshire; Single Source VOC RACT Order for Hutchinson Sealing Systems</SUBJECT> <HD SOURCE="HED">AGENCY:</HD> Environmental Protection Agency (EPA). <HD SOURCE="HED">ACTION:</HD> Proposed rule. <SUM> <HD SOURCE="HED">SUMMARY:</HD> The Environmental Protection Agency (EPA) is proposing to approve a State Implementation Plan (SIP) revision submitted by the State of New Hampshire. This revision proposes to approve a revised reasonable available control technology (RACT) order for Hutchinson Sealing Systems, Inc., located in Newfields, New Hampshire. This action is being taken under the Clean Air Act. </SUM> <EFFDATE> <HD SOURCE="HED">DATES:</HD> Written comments must be received on or before January 12, 2026. </EFFDATE> <HD SOURCE="HED">ADDRESSES:</HD> Submit your comments, identified by Docket ID No. EPA-R01-OAR-2025-1741 at <E T="03">https://www.regulations.gov,</E> or via email to Meredith Gutierrez at: <E T="03">gutierrez.meredith@epa.gov</E> . For comments submitted at <E T="03">Regulations.gov</E> , follow the online instructions for submitting comments. Once submitted, comments cannot be edited or removed from <E T="03">Regulations.gov</E> . For either manner of submission, the EPA may publish any comment received to its public docket. Do not submit electronically any information you consider to be Confidential Business Information (CBI) or other information whose disclosure is restricted by statute. Multimedia submissions (audio, video, etc.) must be accompanied by a written comment. The written comment is considered the official comment and should include discussion of all points you wish to make. The EPA will generally not consider comments or comment contents located outside of the primary submission ( <E T="03">i.e.</E> on the web, cloud, or other file sharing system). For additional submission methods, please contact the person identified in the “For Further Information Contact” section. For the full EPA public comment policy, information about CBI or multimedia submissions, and general guidance on making effective comments, please visit <E T="03">https://www.epa.gov/dockets/commenting-epa-dockets</E> . Publicly available docket materials are available at <E T="03">https://www.regulations.gov</E> or at the U.S. Environmental Protection Agency, EPA Region 1 Regional Office, Air and Radiation Division, 5 Post Office Square—Suite 100, Boston, MA. EPA requests that, if at all possible, you contact the contact listed in the <E T="02">FOR FURTHER INFORMATION CONTACT</E> section to schedule your inspection. <FURINF> <HD SOURCE="HED">FOR FURTHER INFORMATION CONTACT:</HD> Meredith Gutierrez, Energy and Resilience Branch (ERB), Air and Radiation Division (ARD) (Mail Code 5-MD), U.S. Environmental Protection Agency, Region 1, 5 Post Office Square, Suite 100, Boston, Massachusetts, 02109-3912; (617) 918-1193; <E T="03">gutierrez.meredith@epa.gov</E> . </FURINF> <SUPLINF> <HD SOURCE="HED">SUPPLEMENTARY INFORMATION:</HD> Throughout this document whenever “we,” “us,” or “our” is used, we mean EPA. <HD SOURCE="HD1">Table of Contents</HD> <EXTRACT> <FP SOURCE="FP-2">I. Background and Purpose</FP> <FP SOURCE="FP-2">II. Proposed Action</FP> <FP SOURCE="FP-2">III. Incorporation by Reference</FP> <FP SOURCE="FP-2">IV. Statutory and Executive Order Reviews</FP> </EXTRACT> <HD SOURCE="HD1">I. Background and Purpose</HD> Hutchinson Sealing Systems, Inc. (HSS) produces sealing systems, body seals, and soft rubber glass-run channels used in automobiles and various other applications. HSS owns and operates a facility located at 171 Exeter Road in Newfields, New Hampshire. The sealing strips are produced by several complex processes involving metal roll foaming, rubber and plastic extruding, flocking (or the application of a low-friction coating), and curing, followed by certain secondary operations including but not limited to trimming, notching, saw cutting, stretch bending, molding, and assembly. The New Hampshire Department of Environmental Services (NH DES) submitted Reasonably Available Control Technology (RACT) Order ARD-11-001 to the EPA as a State Implementation Plan (SIP) revision on March 23, 2012. RACT Order ARD-11-001 required HSS to comply with a volatile organic compound (VOC) content limit of 6.3 lb. VOC/gallon of coating as applied (excluding water and exempt VOC compounds) for motor vehicle weatherstrip adhesive coatings, as specified in Env-A 1220.02, <E T="03">Compliance Standards for Miscellaneous Industrial Adhesives</E> . <SU>1</SU> <FTREF/> Order ARD-11-001 contained an allowance for alternate compliance to be met by using add-on controls, bubbling, discrete emissions reductions (DERs), emissions reduction credits (ERCs), or any combination of the previous methods to comply with the limit. In addition, Order ARD-11-001 indicated that the company will install and operate a catalytic oxidizer to control VOC emissions from emissions unit Thermoplastics Extrusion Line #9 (TPV Line #9) at the facility. On August 28, 2012, HSS submitted a permit application to NH DES to allow for the modification of Thermoplastics Extrusion Line #6 (TPV Line #6) and the installation of a catalytic oxidizer control device to control HAP emissions. The adhesives used in TPV Line #6 are subject to the VOC content limits in the RACT order. <FTNT> <SU>1</SU>  These standards are approved in the NH SIP as part of Env-A 1200, <E T="03">Volatile Organic Compounds (VOCs) Reasonably Available Control Technology (RACT)</E> (see 77 FR 66388, November 5, 2012; and 87 FR 26999, May 6, 2022). </FTNT> On November 5, 2012, the EPA approved New Hampshire's March 23, 2012 submittal for a single source order requiring RACT at HSS into the New Hampshire SIP. <SU>2</SU> <FTREF/> Subsequently, on December 21, 2012, NH DES issued permit TP-0115 to HSS requiring the use of a catalytic oxidizer to control emissions from TPV Line #6. Although RACT Order ARD-11-001 allows the facility to use an add-on control device as a compliance option for the emission limit, the requirement to use a catalytic oxidizer to control emissions from TPV Line #6 was only included in NH DES's December 21, 2012 permit and was not part of EPA's 2012 approval of RACT Order ARD-11-001 into the SIP. <FTNT> <SU>2</SU>  See 77 FR 66388. </FTNT> On April 24, 2023, HSS submitted a request to NH DES for a modification to its State Permit to Operate (SP-0141) to, among other items, remove TPV Line #9 and its associated control device from the permit, since that process no longer emits VOCs. On September 29, 2023, HSS submitted a permit application to NH DES for the renewal of SP-0141, which included a request to remove the required use of the catalytic oxidizer associated with TPV Line #6 since the motor vehicle weatherstrip adhesives used in the process meet the VOC content limit without the need for additional control. The revised RACT Order ARD-11-001, issued on January 24, 2025, by NH DES, maintains the existing RACT requirement for HSS to comply with the VOC limit of 6.3 lb. VOC/gallon for motor vehicle weatherstrip coatings. The Order specifies that HSS shall continue to research and test water-based and/or high solids coatings as new products become available. The Order also outlines the processes through which HSS shall be allowed to use DERs, ERCs, and/or bubbling for the purpose of complying with VOC RACT. <SU>3</SU> <FTREF/> Furthermore, the Order removes the alternate compliance option to use an add-on control device as an alternative to meet the VOC limit. In addition, the Order removes the allowance for HSS to generate discrete emission reduction credits due to the removal of the catalytic oxidizer. On April 17, 2025, NH DES submitted a revision to its SIP consisting of the revised RACT Order ARD-11-001, which is intended to limit emissions of VOCs from the facility. <FTNT> <SU>3</SU>  Hutchinson only needs to use credits when non-compliant coatings are employed, which is on an infrequent basis and is being phased out over time, though no anticipated deadline has been given for the removal of these coatings from their processes. </FTNT> According to Economic Incentive Program Rules (59 FR 16690), the ability of RACT sources to meet RACT requirements through RACT or non-RACT trading shall result in “an exceptional environmental benefit,” which can be demonstrated through “a trading ratio of 1.1 to 1, at a minimum.” This is further clarified in Env-A 3100, <E T="03">Discrete Emissions Reductions Trading Program,</E> which states that users of DERs “shall permanently retire ten percent of all DERs dedicated to that particular use, such that the amount of DERs required to demonstrate compliance shall equal the source's calculated need divided by 0.9.” HSS was issued an ERC certificate (98VHSS01C) on August 1, 2002, that allows them to generate 22 tons of VOC credits per year from the permanent shutdown of the Body Stock Preparation Process and the Metal Parts Painting Operation (also referred to as the “King-Way Line”). These 22 tons per year are the difference between the baseline before the shutdown of those two processes and the facility-wide emissions after the shutdown. HSS is allowed to use these credits each year, but unused credits do not roll over to succeeding years. Additionally, these credits cannot be sold, transferred, or traded. The use of these credits, ERCs generated by other facilities, or DERs for the purpose of complying with VOC RACT shall comply with recordkeeping and reporting requirements outlined in Env-A 3000, <E T="03">Emissions Reduction Credits Trading Program,</E> and Env-A 3100, <E T="03">Discrete Emissions Reductions Trading Program.</E> ━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━ Preview showing 10k of 17k characters. Full document text is stored and available for version comparison. ━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━