### The State of New Hampsh, 

# Department of Environmental Services Thomas S. Burack , Commissioner Celebrating 25 years of protecting New Hampshire's environment. October 19 ,20 12 

# RECEIVED OCT 3 0 20f2 Mr. 

### Curt Spalding, Administrator USEP A Region 1 5 Post Office Square Suite 100 OFFICE OfTH£RtGIONALADMINISTRATOR 

### Boston, MA 02109-3912 Re: SIP Revision Proposal for**~Ox** 

### RACT Order No. ARD

- 97

- 003 Gorham Paper and T issue, LLC 72 Cascade Flats, Gorham, NH Facility Identification #3300706001, Application# 12

- 0015 

### Dear Mr. Spalding: Pursuant to section 110 ofthe Clean Air Act and as Governor John Lynch's designee, I 

### hereby submit for your approval a proposed revision to the New Hampshire State Implementation Plan (SIP). An electronic version ofthis submittal, which is an exact duplicate of the paper version, is enclosed on a disk
. This revision involves the amendment of a Nitrogen Oxide (NOx) Reasonably Available Control Technology (RACT) Order in accordance with the New Hampshire Code of Administrative Rules, Env-A 1211
. 18 (renumbered as 

### 1316.06), Issuance of NOx RACT Order, 

### and Env-A 1211.14 (renumbered as 1314 .01 ), Emission Standards and Control Options for Miscellaneous Stationary Sources, 

### to Gorham Paper and Tissue, LLC (GPT) for its facility in Gorham, New Hampshire. Effect ive May 20, 1994, DES adopted Part Env-A 1211, Nitrogen Oxides (NOx) 

### of the New Hampshire Code ofAdministrative Rules, which established procedures for meeting the requirements of Reasonably Available Control Technology (RACT) for NOx, including schedules for compliance. Part Env-A 1211.14, Emission Standards and Control Options for Miscellaneous Stationary Sources 

### and Part Env

- A 1211. 15, Alternative RA CT Emission Limits 

### allowed an 

### owner or operator of a stationary source subject to Env-A 1211 to apply for and obtain a RACT order in accordance with Part Env-A 1211.18 , Procedure for Issuance of a RACT Order. 

### Crown Vantage was the owner and operator ofthe Berlin Pulp Mill and Gorham Paper Mill in 1994 when the NOx RACT rules were first promulgated. On- September 16, 

### 1994, Crown Vantage submitted a NOx RACT Assessment Report pursuant to Part Env-A 1211.18. On September 24, 1997 , DES issued RACT Order# ARD

- 97

-003 to Crown Vantage. On September 24, 1997, DES submitted to the United States Environmental Protection Agency (USEPA) NOx RACT Order# ARD

- 97

-003 as a revision to the New Hampshire SIP
. On May 13, 1998, USEPA approved the SIP revision for the NOx RACT Order for Crown Vantage and published the approval in the Federal Register. Since 1999, the Berlin Pulp Mill 

### and Gorham Paper Mill have undergone a series of ownership changes, and on April28, 2006, the Berlin Pulp Mill ceased operation. On May 13 ,2011, GPT took ownership of the Gorham Paper Mill. On January 20, 2012, GPT submitted a NOx RACT Analysis and RACT Order Application pursuant to TP-0080 for the new tissue machine dryer. This proposed SIP revis ion amends the NOx RACT Order for Crown Vantage that was approved by USEPA on May 13, 1998.



### www .des.nh.gov 29 

### Hazen Drive • PO Box 95 • 

### Concord, NH 03302-0095 (603) 271-3503 • TDD Access: 

### Relay NH 1-800-735-2964Mr
. Curt Spalding October 19 , 2012 Page3 SIP Revision Proposal (or NOx RACT Order No. ARD-97-003

Response: The 1997 NOx RACT order was silent on the issue of monitoring and testing of Boilers #1, #2 and #3 because NOx was being monitored with a Continuous E mi ssio n Monitor (CEM) at the time. In Temporary Permit TP-B-0534, DES allowed the facility to remove the CEM and replace it with annual NOx stack testing requirements. DES has removed the generic statement regarding compliance with the testing and monitoring provisions of Env-A 800 from the NOx RACT order and replaced it with specific NOx RACT stack testing requirements for eac h of these boilers on each fuel that the boilers are permitted to bum when stack testing is necessary to ensure compliance with an emission limitation for NOx RACT. Additional stack testing requirements, unrelated to NOx RACT compliance, are contained in the revision to Temporary Permit TP-0080 and were a result of negotiations between the Facility, DES and USEPA. No public hearing was requested for the proposed NOx RACT Order. Note also that this proposed SIP revision will not result in an increase in emissions. Therefore, no technical documentation is necessary . Should you require further information, please contact Catherine Beahm of the Air Resources Division, Permitting and Environmental Health Bureau at (603) 271-2822 or via e-mail at catherin e.beahm@des.nh.gov.

CAW /cab Enclosures
cc: David Conroy, USEPA Region I (via e-mail) Anne Arnold, US EPA Region I (via e-mail) Donald Dahl, US EPA Region I (via e-mail) Ryan Carrier, Gorham Paper and Tissue, LLC Joanna B. Tourangeau, Drummond Woodsum Town ofGorham Sincerely,

# ~0~61:- Crai g A
. Wright Acting Director Air Resources DivisionMr
. Curt Spaldi ng October 19 , 2012 Page 3 SIP R evision Proposalfo r NOx RACT Order No
. A RD-9 7 -003

Response: The 1997 NOx RACT order was silent on the iss ue of moni to ring and testing ofBoiler s #1, #2 and #3 because NOx was being monit o red with a Continuous Emiss io n Monitor (CEM) at the time. In Temporary Permit TP-B

- 053 4, DES allowed the facility to remove the CEM and replace it with annual NOx stack testi n g requirements. D ES has removed the generic sta tement regarding compliance with the testing and monitoring provisions ofEnv-A 800 from the NOx RACT order and replaced it with specific NOx RACT stack testing requirements for each of these boilers on each fuel that the bo ilers are permitted to burn when stack testing is 'necessary to ensure compliance with an emission limitation for NOx RACT. Additional stack testing requirements, unrelated to NOx RACT compliance, are contained in the revision to Temporary Permit TP-0080 and were a result of negot iations between the Facility, DES and USEPA. No public hearing was requested for the proposed NOx RACT Order. Note also that this proposed SIP revi sion will not result in an increase 

### in emissions. Therefore, no technical documentation is necessary. Should you require further information, please contact Catherine Beahm of the Air Resources Division , Permitting and E nvironmental Health Bureau at (603) 271-2822 or via e-mail at catherine
.beahm@des.nh.gov
. 

# .

CAW /cab Enclosures
cc: David Conroy, USEPA Region I (via e- mail) Anne Arnold, US EPA Reg ion I (via e -mail) Donald Dahl, US EPA Region I (via e-mail) Ryan Carrier, Gorham Paper and Tissue, LLC Jo anna B. Tourangeau, Drummond Woodsum Town ofGorham Sincerely ,

# &uao**y;-** Craig A. Wright Acting Director Air Re sources Division