### COMPILATION OF PUBLIC COMMENTS AND NEW HAMPSHI RE'S RESPONSE THERETO 40 CFRPart 51, Appendix V, 2.1(h)UNITED STATES ENVIRONMENTAL PROTECTIONAGENCY REGION 1 1 CONGRESS STREET, SUITE 1100 BOSTON, MASSACHUSETTS 02114-2023 

### RECEIVED NEW HAMPSHIRE October 26, 2004 

## OCT 2 9 2004 Barbara Hoffinan 

### AIR RESOURCES DIVISION Air Resources Division Department ofEnvironmental Services 6Hazen Drive 

### P.O . Box 95 Concord, NH 03302-0095 RE: Comments on Env-A 1211 Dear Ms. Hoffinan: We received the September 3, 2004 rulemaking notice regarding the changes to the auxiliary boiler provisions in Env-A 1211, New Hampshire's Nitrogen Oxides (NOx) Reasonably Available Control Technology (R.ACT) rule. We have reviewed theproposed changes to Env-A 1211 and have the following comment: The proposed paragraph 1211 .12(c) revises existing paragraph 1211 .12(b) by adding a size threshold of 50,000,000 Btu per hour for auxiliaryboilers that must meet the NOx RACT limit of0

.201b permillion Btu. This revision makes the NOx RACT requirements for smaller sized auxiliaryboilers consistent withthe requirements for industrial boilers of the same size. However, it also removes the existing requirementthat auxiliary boilers in the 5,000,000to 50,000,000 Btuper hour size range meet the NOx RACT limit of0.201b per million Btu. Since the proposed revision provides far less stringent NOx RACT for smaller auxiliary boilers, it would be considered arelaxation ofthe version of Env-A 1211 adopted by New Hampshire on May 20, 1994; and, approved into New Hampshire's State Implementation Plan (SIP) on April 9, 1997. Therefore, the proposed revision couldnot be approved into NH's SIP unless it is accompanied by a justification for relaxing the limit that also addresses backsliding concerns. We appreciate having the opportunity to provide these comments. Ifyouwould like to discuss themin more detail, please contact Dan Brownat (617) 918-1532. Sincerely, 

# _I~A rcm Robert McConnell, Acting Manager Air Quality Planning Unit

Toll Free " 1-888-372-7341 Internet Address (URL) " http://www .epa.gov/regionl RecycledlRecyclable -Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum30%Postconsumer). 

# ES The State of New Hampshire DEPARTMENT OF ENVIRONMENTAL SERVICES

Thomas S. Burack, Commissioner

March 1, 2007 Anne Arnold, Manager Air Quality Planning Unit U .S. Environmental Protection Agency Region I . 1 Congress Street, Suite 1100 Boston, MA02114-2023 Dear Ms. Arnold: This letter is in response to a letter ofOctober 26, 2004, in which Robert McConnell, then Acting Manager ofthe Air Quality Planning Unit, EPARegion 1, offered EPA's comments on New

Hampshire's 2004 changes to our Nitrogen Oxides (NOx) Reasonably Available Control Measures (RACT) rule, Env-A 1211 . Mr . McConnell's letter expressed concern that, because the revision to Env-A 1211 provides for less stringent NOx RACT for smaller auxiliary boilers (between 5 million and 50million Btus per hour), it would be considered a relaxation ofthe version of Env-A 1211 adopted by New Hampshire on May 20, 1994, and approved into New Hampshire's State Implementation Plan (SIP) on April 9, 1997. Therefore, the revision could not be approved into New Hampshire's SIPunless it is accompanied by ajustification for relaxing the 0 .201b per million Btu limit on auxiliary boilers in the 5 million to 50million Btu per hour size range. Because EPAhas recently requested that New Hampshire submit the 2004 revisions to Env-A 1211 for SIP approval as part ofthe state's 8-hr Ozone NOx RACT SIP, we now

offer the followingjustification for the 2004 revision in Env-A 1211 : New Hampshire's NOx RACT limitation for auxiliary boilers was modified in 2004 by adding a minimum

size threshold of 50 million Btu per hour for auxiliaryboilers that must meet the 0

.20 lbs per million Btu input limit. Prior to this change, all auxiliary boilers were required to meet the 0 .201b per /million Btu limitation and perform compliance testing every three years, regardless ofsize. This change was made in order to make the Auxiliary Boiler NOx RACT standard consistent with the NOx standard for Utility Boilers (Env-A 1211 .03), Steam Electric Boilers (Env-A 1211 .04), and Industrial Boilers (Env-A 1211 .05) . In these cases the NOx RACT limit for this small boiler heat input category (greater than 5 million Btu per hour but less than 50million Btu per hour) was determined to be a boiler tune-up following the requirements specified in the three boiler categories (note that the requirements are identical in each section) . The logic behind the change is that a small, well-tuned boiler operating at optimumefficiency will generate sufficiently low NOx emissions to be considered RACT. DESWebsite: 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 1-800-735-2964Anne Arnold NOx SIP letter 2

March 1, 2007
Given that there is only one auxiliary boiler in New Hampshire falling into the small boiler heat input category (Newington Energy), and that the annual NOx emissions ofthis unit have been less than 0 .05 tons, New

Hampshire considers the effect of the rule change to be insignificant
. Ifyou have further questions regarding this matter, please contact Jack Glenn at 603-271-6546, or i lenn(a-,des .state .nh.us. Thank you. Sincerely,
Craig A . Wright, Administrator Bureau of Permitting and Environmental Health