\ 

The State of New Hampshire 

Department of Environmental Services 

Mr. Curt Spalding, Administrator 

USEPA Region I 

5 Post Office Square 

Suite I 00 

Boston, MA 02109-3912 

Thomas S. Burack, Commissioner 

Celebrating 25 Years of Protecting 

New Hampshire's Environment 

November 16,2012 

Rc: SIP Revision Proposal for VOC RACT Order No. ARD-96-001 

Textile Tapes Corporation 

104 Pickering Road, Gonic, NH 

Facility Identification #3301700039, Application# 12-0135 

Dear Mr. Spalding: 

Pursuant to section II 0 of the Clean Air Act and as Governor John Lynch's designee, I hereby submit for 

your information a proposed revision to the 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 

administrative changes of a Volatile Organic Compound (VOC) Reasonably Available Control Technology 

(RACT) Order in accordance with the revised New Hampshire Code of Administrative Rules, Env-A 1207.03, 

Emission Rate Limits for Coating of Paper, Fabric, Film and Foil Substrates (formerly Env-A 1204.10), to Textile 

Tapes Corporation for its facility in Gonic, New Hampshire. 

Textile Tapes filed a "Reasonably Available Control Technology (RACT) Statement" on March 15, l993. 

Based on this application, the New Hampshire Department of Environmental Services, Air Resources Division 

(DES) issued a VOC RACT Order on June 28, 1996. On March I 0, 1998, the United States Environmental 

Protection Agency (USEPA) approved the Order into the NH SIP. On March 5, 1998, prior to the issuance of the 

apprr)Ved Order by USEPA, DES received a request from Textile Tapes for a revision to the Order. On October 1, 

199~ , .>ES submitted the amended Order to USEPA as a SlP revision. On February 19, 2002, Textile Tapes 

requested the second modification of the Order to include the recuperative thermal oxidizer (RTO). On March 27, 

. 2002, DES received comments from the EPA on the proposed February 19, 2002 modification to the Order. EPA 

~ asked DES to withdraw the previous Textile Tapes SIP submittal dated October I, 1998 and state in the new SIP 

' submittal that the revised Order supersedes the previous orders. On December 28, 2006, DES received applications 

from Textile Tapes to amend the Order and the Permit to allow Textile Tapes to use discrete emissions reductions 

(DERs) to comply with VOC RACT and to generate DERs in the future through the operation of the RTO. On 

~ugust 10, 2007) the Order was amended and sent to EPA as a revised SIP submittal. 

On May 6, 201 1, Textile Tapes submitted an application to replace the existing RTO with a new RTO. 

Temporary Permit, TP-0086, was issued on July 8, 20 II for the installation of a 3.0 MMBtu/hr natural gas fired 

TANN Lanbein Engelbracht America Regenerative Thermal Oxidizer. On October 5, 20 II, Textile Tapes 

conducted stack testing on the RTO. The RTO demonstrated compliance with the 95% destruction efficiency at 

1568 °F which is higher than the temperature of 1250 ~ listed in RACT Order ARD-96-00 I last issued on August 

I 0, 2007. On August 3, 2012, Textile Tapes submitted an application, requesting an amendment to the minimum 

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 November 16, 2012 

SIP Revision Proposal for VOC RACT Order No. ARD-96-001 Page2 

temperature requirement for Textile Tapes RTO in RACT Order ARD-96-001. Textiles Tapes proposed retaining 

the destruction efficiency requirement of95%, to be demonstrated through periodic stack testing. 

This proposed SIP revision supersedes all previous SIP revision proposals submitted for this VOC RACT 

Order and includes the following documentation: 

• DES final VOC RACT Order issuance letter dated November 16, 2012; 

• Final VOC RACT Order issued on November 16, 2012; and 

• A redlined version of the RACT Order. 

Since the last SIP revision submittal on August 10, 2007, the most recent VOC RACT Order has changed 

as follows: 

• The RTO minimum destruction efficiency temperature of 1250 °F has been removed from the Order 

and replaced with the following conditions: 

o The RTO combustion temperature shall not drop below the average temperature at which 

the facility has demonstrated compliance through the most recent DES approved stack 

testing with the 95% efficiency. 

o Textile Tapes shall conduct compliance stack testing once every 5 years within 90 days of 

the anniversary of the previous stack test. For stack testing purposes only, Textile Tapes 

shall be allowed to operate at a lower temperature than identified above in an effort to 

demonstrate compliance with the RACT Order RTO 95% efficiency requirement. In the 

event that Textile Tapes does not meet the provisions of the RACT order during the stack 

test, then Textile Tapes shall be allowed to use DERs as described in item 5 of the RACT 

Order for RACT compliance during the stack testing period. 

Technical support documents are not included in this submittal since the amendments to the RACT Order 

will not result in any increase in emissions. In addition, since the amendments would strengthen the facility's 

testing requirements, DES determined that the amendments are minor modifications for which public notice was 

not required. 

Should you require further information, please contact Sarita Croce of the Air Resources Division, 

Permitting and Environmental Health Bureau at (603) 271-6893 or via e-mail at sarita.croce@des.nh.gov. 

CAW/sse 

Enclosures 

cc: David Conroy, USEPA 

City Clerk - Rochester; NH 

Tim Drew - PIP ' 

John Simmers - Textile. Tapes Corp. VP 

Tim Donnelly.- Consultant 

Ida McDonneii -USEPA 

Sincerely, 

~(}{<)15}j 

Craig A. Wright 

Acting Director 

Air Resources Division