The State of New Hampshire 

DEPARTMENT OF ENVIRONMENTAL SERVICES 

_ 

N HDES 

Thomas S. Burack, Commissioner 

July 26, 2011 

H. Ctirtis Spalding, Regional Administrator 

U.S . Environmental Protection Agency, Region 1 

5 Post Office Square, Suite 100 

Boston, MA 02109-3912 

Re : State Implementation Plan Revision Submittal for Volatile Organic Compounds 

Reasonably Available Control Technology Rule : Env-A 1200 (formerly Env-A 

1204) 

Dear Administrator Spalding: 

Pursuant to section 110 of the federal. Clean Air Act as amended, the state of New 

Elampshire (NH) hereby submits for approval the subject proposed State Implementration Plan 

(SIP) revision and one electronic copy thereof As Governor John Lynch's designee, I am 

requesting EPA's prompt approval of this revision, which consists of the additions and 

amendments to the rule formerly known as Env-A 1204, which was renumbered in this 

ruiemaking to be Chapter Env-A 1200, holatile Organic Compounds (VC>C's) Reasonably 

Available Control Technology (RAC1) . Amendments were made to (1) incorporate emission 

Iii-nits, control technology requirements and work practice standards from 9 control techniques 

g idclines (CTGs) issue,' by EPA in 2006-2008 ; (2) consolidate the requiremeats for testing, ul U 

record1kceping, and reporting for RACT compliance, which cross-reference ~.o existing 

requirements in Env-A 800 and Env-A 900; and (3) clarify the procedures arid criteria for 

issuance of a F:ACT order. 

This submittal contains all documentation necessary to satisfy the SIP r- .oirrpleteness 

requirements pursuant to 40 ChR Part. 51, Appendix V. The following administrative materials 

are irncluded in Attacl.rncin A for your review: 

a. Evidence of the rule's adoption 

b . Evidence of legal authority 

c. A copy of the rule 

d. Evidence that al ; 11e State's legal requirements were followed in adopting the rule 

and submitting the SIP revision 

u . Evidence that the public notice was given in accordance with 1?1°!~ . procedures 

f. Certification that,-if ncquested, the public hearing was held in accordance with the 

public notice 

g . A compilation of public comnietits and the State's responses thereto 

DES Web site : www.des .nh.gov 

P.O. Box 95, 29 Hazen Drive, Concord, New Hampshire 03302-0095 

Telephone: (603) 271-1370 " Fax: (603) 271-1381 " TDD Access : Relay NH 1-800-735-2964 
Mr. H. Curtis Spalding, Regional Administrator Page 2 SIP Revision Submittal Jul 26 2011 

One of the requirements of Appendix V is that the documentation include the date of 

adoption, as well as the effective date, of the rule . In accordance with NH Revised Statutes 

Annotated (RSA) 541-A :14, an agency may adopt a rule after all procedures have been 

completed. The NH Department of Environmental Services (DES) adopts a rule on the day its 

Commissioner signs a letter advising that he has adopted the rule and files the adopted rule with 

the Director of the Office of Legislative Services (OLS). The rule takes effect the day after it is 

filed unless a different date is requested in the letter . The attachments hereto contain a letter 

from the DES Commissioner to the Director of the OLS, documenting the adoption of the rule, 

as well as written documentation from the OLS as to the filing and effective dates of the rule . 

In addition to the required administrative materials, Attachment B is a negative 

declaration for two CTGs - Large Appliance Coatings and Automobile and Light Duty Truck 

Assembly Coatings . No technical materials are included, as it is not anticipated that the enclosed 

rules will affect previous demonstrations regarding attainment of the national ambient air quality 

standards. 

Should you have any questions regarding this submittal, please contact Karla McManus, 

Planning and Rules Manager, at karla.mcmanusc)des .nh.gov or (603) 271-6854, or Barbara L . 

Hoffman, SIP Planning Manager, at barbara.hoffmann,des .nh.g,ov or (603) 271-7874. Thank 

you. 

Sincerely, 

Robert R. Scott 

Director 

Air Resources Division 

Enclosures 

ec : Dave Conroy, EPA 

Ida E. McDonnell, EPA 

Donald Dahl, EPA