The State of New Hampshire DEPARTMENT OF ENVIRONMENTAL SERVICES 

## HDES N

_ 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 ofthis revision, which consists ofthe 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 from9 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-A800and Env-A 900 ; and (3) clarify the procedures arid criteria for issuance ofa 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 Afor your review : a. Evidence of the rule's adoption b. Evidence of legal authority c. Acopy 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. Acompilation of public comnietits and the State's responses thereto

DESWeb 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 " TDDAccess: Relay NH 1-800-735-2964Mr. H . Curtis Spalding, Regional Administrator Page 2 SIP Revision Submittal Jul 26 2011

One of the requirements ofAppendix Vis 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 fromthe DES Commissioner to the Director of the OLS, documenting the adoption of the rule, as well as written documentation fromthe OLS as to the filing and effective dates ofthe rule. In addition to the required administrative materials, Attachment Bis 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