The State of New Hampsh, 

Department of Environmental Services 

Thomas S. Burack, Commissioner 

Celebrating 25 years of protecting 

New Hampshire's environment. 

October 19,2012 RECEIVED 

Mr. Curt Spalding, Administrator OCT 3 0 20f2 

USEP A Region 1 

5 Post Office Square 

Suite 100 

OFFICE Of TH£ RtGIONAL ADMINISTRATOR 

Boston, MA 02109-3912 

Re: SIP Revision Proposal for ~Ox RACT Order No. ARD-97-003 

Gorham Paper and Tissue, LLC 

72 Cascade Flats, Gorham, NH 

Facility Identification #3300706001, Application# 12-0015 

Dear Mr. Spalding: 

Pursuant to section 110 of the 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 

of this 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. 

Effective May 20, 1994, DES adopted Part Env-A 1211, Nitrogen Oxides (NOx) of the New Hampshire 

Code of Administrative 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 of the 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 revision 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 1-800-735-2964 
Mr. Curt Spalding October 19, 2012 

SIP Revision Proposal (or NOx RACT Order No. ARD-97-003 Page3 

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 Emission 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 each 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 catherine.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 of Gorham 

Sincerely, 

~0~61:- Craig A. Wright 

Acting Director 

Air Resources Division 
Mr. Curt Spalding October 19, 2012 

SIP Revision Proposal for NOx RACT Order No. ARD-97-003 Page 3 

Response: The 1997 NOx RACT order was silent on the issue of monitoring and testing ofBoilers #1, 

#2 and #3 because NOx was being monitored with a Continuous Emission 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 each of these boilers on each fuel that the 

boilers 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 

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 catherine. 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 of Gorham 

Sincerely, 

&uao y;- Craig A. Wright 

Acting Director 

Air Resources Division