COMPILATION OF PUBLIC COMMENTS AND NEW 

HAMPSHIRE'S RESPONSE THERETO 

40 CFR Part 51, Appendix V, 2.1(h) 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

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 of Environmental Services 

6 Hazen 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 the proposed 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 auxiliary boilers that must meet the NOx RACT 

limit of 0.201b per million Btu . This revision makes the NOx RACT requirements for 

smaller sized auxiliary boilers consistent with the requirements for industrial boilers of the 

same size. However, it also removes the existing requirement that auxiliary boilers in the 

5,000,000 to 50,000,000 Btu per hour size range meet the NOx RACT limit of 0 .201b per 

million Btu. 

Since the proposed revision provides far less stringent NOx RACT for smaller auxiliary 

boilers, it would be considered a relaxation of the 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 could not 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. If you would like to 

discuss them in more detail, please contact Dan Brown at (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 (Minimum 30% 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, MA 02114-2023 

Dear Ms. Arnold: 

This letter is in response to a letter of October 26, 2004, in which Robert McConnell, 

then Acting Manager of the Air Quality Planning Unit, EPA Region 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 50 million Btus per 

hour), it would be considered a relaxation of the 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 SIP unless it is accompanied by a justification for relaxing the 0.201b per 

million Btu limit on auxiliary boilers in the 5 million to 50 million Btu per hour size 

range. Because EPA has recently requested that New Hampshire submit the 2004 

revisions to Env-A 1211 for SIP approval as part of the state's 8-hr Ozone NOx RACT 

SIP, we now offer the following justification 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 auxiliary boilers 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 of size . 

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 50 million 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 optimum efficiency will generate sufficiently low NOx 

emissions to be considered RACT. 

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 
Anne 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 of this 

unit have been less than 0.05 tons, New Hampshire considers the effect of the rule change 

to be insignificant. If you 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