\ 

### The State of New Hampshire 

# Department of Environmental Services

Mr. Curt Spalding, Admini strator USEPA Reg i on 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 16,20 1 2



### Rc : SIP Revision Proposal for VOC RACT Order No. ARD -96-0 01 

### Textile Tapes Corporation 

### 104 Pickering 

### Road, Gon ic, NH Facility Identification #3301700039, Application# 1 2-01 35 Dear Mr. Spaldin g: 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 th e State Imp l ementation Plan (SIP). An electronic version of this submittal, which is an exact duplicate of the paper version , is enclosed o n a disk. T hi s rev i sion invo l ves administrative changes of a Vo latile Organic Compound (VOC) Reasonably Availab le Contro l Technology (RACT) Order in accordance w i th the revised New Hampshire Code of Administrative Rules, Env

- A 1207.03, Emission Rate Limits for Coating of Paper, Fabric , Film and Foil Substrates ( form erly Env-A 1204.10), to Textile Tapes Corporation for its facility in Gonic, New Hampsh ire. Texti le 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 Ju ne 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 US EPA, DES r ece ived a reque st from Textil e Tapes for a revi sion to the Order. On October 1,**199~ ,**  .>ES sub mitted the amended Order to USEPA as a SlP revision. On February 19, 2002, Texti le Tapes requested the second mod i ficat ion of the Order to include the recuperative therm al oxidizer (RTO). On March 27,

. 2002, DES received comments f ro m the EPA on the proposed February 19 , 2002 modification to the Order. EPA

### ~ asked DES to withdraw the previous Texti l e Tapes SIP s ubmittal dated October I , 1998 and state in the new SIP ' submittal that the revi se d Orde r su persedes the prev io u s order s. On December 28 , 2006 , DES recei ved applications from Textile Ta pe s to amend the Order and the Perm i t to allow Textile Tapes to use discrete emiss ions reductions (DERs) to comp ly with VOC RACT and to generate DERs in the future through the operation ofthe RTO. On**~ugust** 10, 2007 ) the Order was amended and sent to EPA as a revised SIP s ubmittal. On May 6, 201 1 , Texti l e Tapes submi tted an app licat i on to replace the exi sting RTO w i th a new RTO. Temporary Permit, TP-0086 , was is sued 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. T he RTO demon strated compliance wit h the 95% destruction efficiency at 1568 °F whic h is higher than the temperatu r e of 1250**~** listed i n RACT Order ARD-96-00 I last issued on August I0 , 2007. On August 3 , 2012 , Textil e Tapes submitted an application , reque sting 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

- 735-2964Mr
. Curt Spalding Nov e mber 16, 2012 Page2 SIP R evision Proposal fo r VOC RACT Order No. ARD-96-001 temperature requirement for Textile Tapes RTO in RACT Order ARD-96 -001. Textiles Tapes proposed retaining the destruction effic i ency requirement of95% , to be demonstrated through periodic stack testing. T his propos ed SIP revision supersedes all previous SIP revis io n proposals submitted for this VOC RACT Order and includes the following documentation:
• DES final VOC RACT Order i ssuance letter dated November 16 , 2012; • Final VOC RACT Order i ssued on November 16, 2012; and • A redlined version of the RACT Order. Si nce the last SIP revision submittal o n August 10, 2007 , the most recent VOC RACT Order has chan ged 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 combu stion 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 Text ile 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 prov i sions ofthe RACT order duri ng the s tack test, then Textile Tapes s hall be allowed to u se DERs as described in item 5 ofthe RACT Order for RACT compliance during the stack testing period. Technical support documents are not included in th is submittal s ince 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 ofthe Air Resources Division , Permitting and Environmental Health Bureau at (603) 271-6893 or via e-mail at sarita.croce @ des

. nh

. gov.

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AW /sse E nclo sures cc: Dav id Conroy , USEPA City Clerk

- Rochester; NH Tim Drew

- PIP ' John Simmers

- Textile

. Tapes Corp. VP Tim Donnelly

. - Consu ltant Ida McDonneii

-USEPA Sincerely,

# ~(}{<)15}j Cra ig A. Wright Acting Director Air Resources Division