Amended VOC RACT Order ARD-96-001 

Textile Tapes Corporation 

Textile Tapes Corporation 

I 04 Pickering Road 

Gonic, NH 03839 

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Page 1 ofJJ 

FINAL RACT ORDER ISSUED 

DECEMBER 9, 1996 

ARD-96-001 

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AMENDED AUGUST 10,2007 

AMENDED NOVEMBER 16, 2012 

A. Introduction 

This proposed revised RACT Order is issued by the New Hampshire Depmiment of Environmental 

Services, Air Resources Division, to Textile Tapes Corporation, pursuant to RSA 125-C. 

B. Parties 

1. The New Hampshire Department of Environmental Services, Air Resources Division ("DES"), 

is a duly constituted administrative agency of the State of New Hampshire having its principal 

offices at 29 Hazen Drive, Concord, NH, telephone number (603) 271-1370. 

2. Textile Tapes Corporation ("Textile Tapes") is a New Hampshire corporation, having a mailing 

address of 104 Pickering Road, Rochester, NH 03867-4604, telephone number (603) 332-5816. 

C. Statements of Fact and Law 

1. Textile Tapes owns and operates the following processes located at its Gonic Plant at 104 

Pickering Road in Gonic, NH ("the Facility"): 

a. Line lA, Fabric Coating Line (removed in 1999); 

b. Line lB, Fabric Coating Line; 

c. Line 1 C, Hot Melt Coating Line (installed in 1993). 

2. Textile Tapes reported to DES that 1990 total VOC emissions were 90 tons and noted that the 

facility was operated by a compm1y other than Textile Tapes in 1990. 

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

15, 1993 for the facility. 

4. DES issued a Letter of Insufficiency dated May 19, 1993. 

5. Textile Tapes filed a VOC RACT compliance schedule, in response to DES's Letter of 

Insufficiency, on June 10, 1993 as mnendment to the March 15, 1993 submittal. 

6. Textile Tapes initially, in letters dated March 15, 1993 and June 10, 1993, proposed the 

following measures as RACT: 

a. For Line lA, Line lB, and Line 1 C (with the exception stated in pmi C.6.b below) comply 

with the provisions of Env-A 1204.10, Applicability Criteria and Compliance Standards for 

Coating of Paper, Fabric, Film and Foil Substrates, which limits the emission rate ofVOC 

at all times to 2.9 lb/gallon of coating; as applied, excluding water and exempt compounds; 

and 
Amended VOC RACTOrderARD-96-001 

Textile Tapes C01poration Page 2 of!! 

b. For the coating described as "5000 series adhesive" utilized on Line 1A and lB: 

1. Reformulate the "5000 series adhesive" to comply with the emissions limitation in part 

C.6.a., above; or 

11. Install a thermal oxidizer to control VOC emissions equivalent to the emissions 

limitation in part C.6.a.; or 

111. Subcontract all coatings activities, which would result in emission rates exceeding the 

emission limitation in part C.6.a. 

7. DES issued a letter on February 8, 1995 requesting an updated VOC RACT plan. 

8. Textile Tapes filed further revisions to update its VOC RACT plan as requested by DES on 

February 24, 1995. 

9. Effective August 19, 1995, DES re-adopted Rule Env-A 1204 Stationary Sources of Volatile 

Organic Compounds (VOCs) with amendments. 

10. Textile Tapes filed an evaluation of RACT control options and an application for a RACT order 

pursuant to ENV-A 1204.05 on December 7, 1995. 

11. Textile Tapes ultimately proposed the following measures as RACT in its December 7, 1995 

application for RACT order: 

a. For Line 1A, Line 1B, and Line 1C (with the exception stated in part C.6.b) comply with the 

provisions of Env-A 1204.10, Applicability Criteria and Compliance Standards for Coating 

of Paper, Fabric, Film and Foil Substrates, which limits the emissions rate ofVOC al all 

times to 2.9lb VOC/gallon of coating; as applied, excluding water and exempt compounds; 

b. For the coating described as "5000 series adhesive," utilized on Line 1A and 1B: 

1. Increase solids content of"5000 series adhesive" from 33% by weight to 40% by weight; 

and 

11. Limit the emission rate of VOC resulting from the application of the "5000 series 

adhesive" at all times to 4. 7 Jb VOC/gallon of coating, as applied, less water and exempt 

compounds; 

c. Limit facility-wide VOC emissions to 70 tons, on a 12-month rolling basis; and 

d. File annual reports detailing efforts to meet emission limitation in C.ll.a. for all coatings. 

12. On June 28, 1996, DES received Textile Tapes' application for a Title V Permit as required 

by Env-A 609. The application included a request to include the limits specified by the VOC 

RACT Order in the Title V permit once issued. 

13. DES issued a RACT Order ARD-96-001 ("The Order") on December 9, 1996. 

14. On March 5, 1998, DES received Textile Tapes' request for a modification to the Order issued 

December 9, 1996 to include a provision for the use of a generic release coating on line 1 C, 

which was not addressed in the original Order. 

15. On March 10, 1998, The United States Environmental Protection Agency ("EPA") approved the 

Order into the New Hampshire State Implementation Plan ("SIP"). 

16. DES issued an amended Order on September 8, 1998. 
Amended VOC RACT Order ARD-96-001 

Textile Tapes Corporation 

17. On October 1, 1998, DES submitted the amended Order to EPA as a SIP revision. 

Page 3 ofll 

18. On September 24, 1999, Textile Tapes submitted an application for installation of the 

recuperative thermal oxidizer ("RTO") and dryer replacement on coating line lB. Coating line 

lA was eliminated. 

19. On Janumy 18, 2000, Temponuy Permit TP-BP-651 was issued to Textile Tapes for the RTO 

on coating line I B. 

20. On February 19, 2002, Textile Tapes requested the second modification of the Order to include 

the RTO. 

21. 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. 

22. On April23, 2002, DES submitted the revised Order as a revision to the SIP; EPA deemed the 

submittal complete on May 28, 2002. 

23. Effective December 31, 2002, DES re-adopted Rule Env-Al204, Stationary Sources of Volatile 

Organic Compounds (VOCs) with amendments. 

24. On or about September 25, 2006, Textile Tapes notified DES via phone and email of a 

potential business opportunity to coat product with a new coating known as Chemlok TS3320-

19 Primer ("Chemlok"). The new coating exceeds the 2.9lb/gal VOC standard required by 

Env-A 1204.10 (c) and the Order. 

25. Textile Tapes indicated to DES that the new coating can not be applied on the RTO-controlled 

Line IB due to physical properties of the non-compliant Chemlok coating. DES directed 

Textile Tapes to: 

a. Purchase Discrete Emissions Reduction ("DER") credits as described in Env-A 3100 for the 

excess emissions generated by applying the non-compliant Chemlok coating; 

b. ModifY the Order to allow the application of non-compliant Chemlok coating on Line I C; 

and 

c. ModifY Title V Permit TV -OP-009 ("the Permit") to include the application of noncompliant Chemlok coating on Line !C. 

26. On October 24, 2006, in accordance with Env-A 3104.08, MacMillan & Donnelly, Inc. 

("M&D") submitted a "Notice oflntent to Use Discrete Emission Reduction Credits" for the 

period of October 25, 2006 to December 31, 2007, on behalf of Textile Tapes, for the predicted 

generation of excess emissions when using the non-compliant Chemlok coating on Line 1 C. 

27. M&D estimated the excess emissions fi·mn the non-complaint Chemlok coating to be 

approximately 3.6 tons per year. 

28. Textile Tapes provided the purchase contract from Public Service of New Hampshire 

("PSNH"), dated October 3, 2006, documenting the pmchase of a total of 4 DER credits (2 

ozone season credits and 2 non-ozone season), the serial numbers, and associated cost of the 

credits. 
Amended VOC RACT Order ARD-96-001 

Textile Tapes Corporation Page 4 ofll 

29. Textile Tapes began applying the non-compliant Chemlok coating on Line ICon October 25, 

2006. 

30. On December 28, 2006, DES received applications from Textile Tapes to amend the Order and 

the Permit to allow Textile Tapes to use DERs to comply with VOC RACT and to generate 

DERs in the future through the operation of the RTO. 

31. On January 17, 2007, Textile Tapes entered into Administrative Order by Consent No. AO 

ARD 07-003 with DES, allowing Textile Tapes to use DERs until such time as the Order and 

Permit me modified. 

32. On August 10, 2007, DES issued an amended RACT Order which allowed for the use ofDERs. 

33. On May 6, 2011, Textile Tapes submitted an application to replace the existing RTO with a 

new RTO. Temporary Permit, TP-0086, was issued on July 8, 2011 for the installation of a 3.0 

MMBtu/hr natural gas fired T ANN Lanbein Engelbracht America Regenerative Thermal 

Oxidizer. 

34. On October 5, 2011, 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 listed in RACT Order ARD-96-00!last issued on August 10, 2007 of 1250 °F. 

35. On August 3, 2012, Textile Tapes submitted an application, requesting an amendment to link 

the minimum temperature requirement to stack test conditions for the Textile Tapes RTO in 

RACT Order ARD-96-00 I. Textiles Tapes proposed to maintain the destruction efficiency 

requirement of 95% which would be demonstrated through periodic stack testing. 

36. On November 16, 2012, ARD-96-001 was revised to replace the minimum temperature 

requirement of 1250 °F with the requirements that the RTO temperature will not drop below the 

average temperature at which the facility has demonstrated compliance through the most recent 

DES approved stack testing. 

D. Order 

1. Based on the above findings and determinations, DES hereby orders Textile Tapes to implement 

the following as RACT: 

a. For Line lB and Line 1 C, when applying compliant coatings, (as defined in Env-A 

l204.03(q)) the Facility shall comply with the provisions ofEnv-A 1204.10(c), Applicability 

Criteria and Compliance Standards for Coating of Paper, Fabric, Film and Foil Substrates, 

which limits the emission rate ofVOC, at all times, to 2.9 lb VOC/gallon of coating; as 

applied, excluding water and exempt compounds; 

b. For line IB, when applying non-compliant coatings, (as defined in Env-A 1204.03(az)) the 

Facility shall demonstrate compliance with the provisions ofEnv-A 1204.10(c) as specified 

in D .I.a. above by: 

1. Venting all emissions from non-compliant coatings to the thermal oxidizer; or 

11. Using the daily weighted average procedure described as follows: 

1. "VOCw" means the daily-weighted average VOC content of coatings, as applied, used 

on a given coating line, in units of pmmds ofVOC per gallon of coating, minus water 

and exempt compounds; 
Amended VOC RACT Order ARD-96-001 

Textile Tapes -Corporation Page 5 of 11 

2. "n" means the number of different coatings, as applied, used each day on a coating 

line; 

3. "V;'' means the volume of the i

1

1I coating, as applied, used each day on a coating line, 

in units of gallons, minus water and exempt compounds; 

4. "C;" means the VOC content of the i

1

1I coating, as applied, used each day on a coating 

line in units of pounds ofVOC per gallon of coating, minus water and exempt 

compound; 

5. "VT" means the total volume of all coating, as applied, used each day on a coating 

line in units of gallons, minus water and exempt compounds; and 

6. The "VOCw" shall be equal to the sum, over then coatings used on a given coating 

line, of the products of each V; and C;, divided by Y.r, as in the following equation: 

" l)ViCi) 

VOCw ~J""----,­

Vr 

c. For Line lC, when applying non-compliant coatings other than generic release coatings, the 

Facility shall comply with the provisions ofEnv-A 1204.10(c) as specified in D.l.a. above 

either by: 

1. Using the daily weighted average procedure as described in D.l.b.ii. above; or 

11. Using generated or purchased DERs to offset excess emissions in accordance with 

Condition D.6; 

d. For any generic release coating utilized on Line 1 C, the Facility shall: 

1. Limit the emission rate ofVOC resulting fi·om the application of the generic release 

coating, at all times, to 5.9lb VOC/gallon of coating applied, less water and exempt 

compounds; and 

11. Limit the facility-wide use of the generic release coating to less than 5 tons during any 

consecutive 12-month period; 

e. Limit facility-wide VOC emissions to 63.8 tons, on a 12-month rolling basis; and 

f. As part of the Annual Emissions Report submitted annually by Aprill51

h of the following 

yem, include information detailing efforts to meet the emission limitation in D .I.a. for a 

generic release coating including: 

1. A technical evaluation of each alternative coating considered and basis for acceptance or 

rejection; or 

11. A statement indicating that no coatings were evaluated during the time period covered by 

the report. 

2. Prior to the use of any new coating, Textile Tapes shall demonstrate compliance by one of the 

following options: 

a. Chemical manufacturers Material Safety Data Sheet (MSDS) information (density and 

weight percent VOC content) along with the Facility coating formulation recipe information 
Amended VOC RACT Order ARD-96-001 

Textile Tapes Cmporation Page 6 ofll 

Where: 

(gallons of each ingredient, i.e. coatings, diluent solvent, and exempt diluent solvent; density 

of each ingredient; and weight percent VOC content of each ingredient). The Facility shall 

calculate the pounds V OC per gallon coating as applied, minus water and exempt 

compounds using the following formula: 

P*X 

(1-Yw-Ye) 

"P" means the density of the mixed coating as applied (pounds coating/gallon coating); 

"X" means the weight fi·action of V OC in the mixed coating; 

"Y,v'' means the volmne fraction of water in the mixed coating; and 

"Ye" means the volume fraction of exempt compounds in the mixed coating. 

When using this option, the Facility shall maintain the calculation sheets and records for each 

coating formulation; or 

b. The referee liquid VOC test method specified as follows: 

1. Method 24, 40 CFR pmt 60, Appendix A for all coatings as applicable using the 60-

minute bake time procedure; or 

u. Method 24A, 40 CFR Pmi 60, Appendix A as applicable. 

c. DES reserves the right to have the facility perform Method 24 testing on any coatings for 

formal demonstration of compliance. 

d. All Method 24 analyses and/or calculation sheets for new coatings shall be submitted in the 

aruma! VOC report. 

3. Textile Tapes is subject to Env-A 1204.10, Applicability Criteria and Compliance Standards for 

Coating of Paper, Fabric, Film and Foil Substrates and has chosen to comply with this section 

for its non-compliant coatings on Line 1B by implementing an add-on control system as 

specified in D.1.b.i. Textile Tapes is required to comply with the more stringent of: 

a. A VOC emission reduction efficiency of95%, as specified in D.4.a; 

b. An overall VOC emission reduction efficiency determined as follows: 

1. The VOC emission rate limit, when operating with the thermal oxidizer, shall be 

determined, on a solid basis, by the following equation in accordance with Env-a 

1204.04: 

Where: 

"S" means the VOC emission rate limit in terms of lbs VOC/gal of coating solids; 
Amended VOC RACT Order ARD-96-001 

1'e:ttile Tapes Corporation Page 7 of II 

"dA" means the actual density ofVOC for converting the emission limitation to a solids 

basis in lbs/gal. The Permittee has an option to use the density value of7.36lb/gal if 

running more than one coating; 

"Ec" means the emission rate limit prescribed for the applicable coating category. For 

those processes applying a coating to any woven or non-woven, fibrous or non- fibrous 

substrate, including paper, fabric, glass matting, plastic film, ribbon, and magnetic tapes, 

Ec shall be equal to 2.9 lbs VOC/gal of coating, as applied to the substrate; and 

ii. The required overall emission reduction efficiency, E, shall be determined by the 

following equation: 

E-(VOCa-S\ 

- .. VOCa lO% 

Where: 

S =The VOC emission rate limit in terms of lbs VOC/gal of coating solids; 

VOCa =The maximum VOC content of the coatings used in lb VOC/gal solids or the daily 

weighted average VOC content of the coatings used in lb VOC/gal solids; or 

4. Textile Tapes shall perform the following monitoring and testing of the RTO: 

a. Minimum destruction efficiency for the RTO shall be at least 95% and the RTO combustion 

temperatme shall not drop below the average temperature at which Textile Tapes has 

demonstrated compliance through the most recent DES approved stack testing with the 95% 

efficiency. 

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

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

shall be allowed to operate at a lower temperatme than identified in item 4.a 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 below for 

RACT compliance dming the stack testing period. 

c. The Facility shall maintain copies of compliance stack test records on site. These records 

shall be made available to DES/USEP A upon request. 

d. The combustion temperatme of the RTO shall be monitored and recorded continuously. 

e. The Facility shall operate low-temperature lockout, a low temperature alarm, or a 

temperature chmt which shall be examined at least once eve1y 24 hours to ensure 

compliance with the minimum combustion temperature identified in item 4.a above. 

Records of all temperature monitoring shall be maintained at the facility for inspection for at 

least 5 years. 

f. Compliance with the monitoring requirement to reduce VOC emissions from the d1yer 

exhaust by a minimum of 95% shall be demonstrated using the applicable procedme(s) 

described in Env-A 804, Volatile Organic Compound Testing, and in accordance with the 

Permit. 
Amended VOC RACT Order ARD-96-001 

TexHle Tapes Cmporation Page 8 of 11 

g. Textile Tapes shall be allowed to generate DERs for emission reductions that are achieved in 

excess of the reductions required in Part D.3 or the lowest applicable allowable emissions 

rate limit, as specified in Env-A 3103.02. 

5. Textile Tapes shall be allowed to use DERs for RACT compliance during times that it is unable 

to meet the maximum emission rate stated in Part D .l.a. The following calculations will be 

used to determine the amount of credits generated on a given day: 

a. Calculation of Allowable VOC Emissions per Day 

"E,," means the allowable VOC emission rate; 

"Ep,e" means the actual emission rate from line 1 B before entering the thermal oxidizer; 

"E" means the required overall reduction efficiency (expressed as a decimal) as determined 

in Part D.3; and 

"E,," shall be calcnlated as in the following equation: 

Eal = Er« * (1-E) 

b. Actual VOC Emissions per Day 

"Eao" means the actual VOC emission rate 

c. Emission Credit Generation Calculation 

Textile Tapes shall subtract the actual VOC emission rate (Eac) fi-om the allowable VOC 

emission rate (E,1); 

to determine if emission credits will be generated on a given day using the following 

criteria: 

1. If the result of the subtraction is a positive number, then the emissions are 

below the requirements of RACT and the amount equal to the difference 

between E,1 and Eac will count towards emission credits; 

11. Actual emission credits shall be calculated by taking the amount of credited 

emissions in pmi D.5.c.i and multiplying them by a safety factor of 0.9; and 

111. In no instance should generated DERs plus Textile Tapes' actual emissions in 

any 1 2-month period exceed the mmual VOC emissions limit stated in the 

Permit. 

6. Textile Tapes shall be allowed to use generated or purchased DERs to comply with VOC RACT 

according to the following: 

a. Non-compliant coatings shall only be applied on Coating Line 1 C when there is a physical 

limitation preventing Textile Tapes from applying the coatings on Coating Line lB; 

b. DERs shall only be used to achieve compliance when the RTO is out of service due to a 

malfunction or routine maintenance, or when a non-compliant coating must be applied on 

Coating Line I C; 

c. The amount ofDERs required to achieve compliance shall be calculated according to the 

following: 
Amended VOC RACT Order ARD-96-001 

Textile Tapes Corporation Page 9 of 11 

1. The emission rate limit shall be determined on a solids basis, according to the equation 

in DJ.b.i. 

11. The Allowable VOC Emissions per Coating shall be calculated for each coating as 

follows: 

1. "E,( means the allowable VOC emission rate of a given coating in units of lb/month 

or kg/month; 

2. "S" means the VOC emission standard in te1ms oflb VOC/gal or kg VOC/1 of 

coating solids, as calculated in item 6.c.i, above; 

3. "W" means the weight of coating or dilution solvent used in the coating line in units 

of pounds or kg; 

4. "D" means the density of the coating or dilution solvent in units oflb/gal coating, or 

kg/! coating as determined from Method 24 or 24A analysis; 

5. "Vs" means the volume fraction of the solids content of the coating, in units of gal 

solids/gal coating or 1 solids/! coating as determined by calculation using the 

formulation; and 

6. "E,( shall be equal to the product of S, VS and W divided by D for each coating or 

dilution solvent used, as in the following equation: 

E,1 = S* Vs *(W/D) 

iii. The Actual VOC Emissions per Coating shall be calculated for each coating as follows: 

1. "Eac" means the actual VOC emission rate of a given coating in units of pounds; 

2. "W" means the weight of coating or dilution solvent used in the coating line in units 

of pounds; 

3. "Wv" means the weight fraction ofVOC content of the coating, in units oflb 

VOC/lb coating as determined by calculation using the formulation; and 

4. "Eac" shall be equal to the product ofW and Wv, as in the following equation: 

E,c=W* Wv 

lV. The Excess Emissions per Coating shall be equal to the difference between the actual 

VOC emissions (E,c) and the allowable VOC emissions (E,1). 

Excess Emissions = E,c - E,1 

v. At the time of use, Textile Tapes shall permanently retire ten percent of all DERs 

dedicated to that particular use, such that the amount of DERs required to demonstrate 

compliance shall equal the excess emissions calculated in item iv above divided by an 

environmental benefit factor of0.9. 

7. Textile Tapes shall comply with recordkeeping requirements of Env-A 904.03, and Env-A 
Amended VOC RACT Order ARD-96-001 

Textile Tapes Cmporation 

904.07 for an add-on pollution control device, specifically the RTO. 

Page 10 ofll 

8. Annually by November 30, Textile Tapes shall submit a report to DES on the projected use of 

credits for the upcoming year. This report shall meet the requirements ofEnv-A 3104.08, 

Notice oflntent to Use DERs, including the following information: 

a. The name and location of the user; 

b. A copy of the Notice and Certification of Generation submitted by the generator source to 

the State (for paperwork reduction purposes, a certified statement that the notice is on file 

with DES will suffice); 

c. The protocol used to document the amount of DERs needed to demonstrate compliance; and 

d. Information documenting that Textile Tapes is in compliance with Env-A 1400, Regulated 

Toxic Air Pollutants. 

9. Annually by Aprill5, Textile Tapes shall submit a report to DES on the balance of credits for 

the previous calendar year. This report shall meet the requirements of Env-A 3103.08, Notice 

and Certification a_{ Generation and Env-A 3104.09, Notice and Certification of Use, including 

the following information: 

a. The name and location of the owner or operator of the source; 

b. A brief description of the generation activity; 

c. A list of the source's applicable allowable emission rates; 

d. The amount of DERs generated each month; 

e. A calculation of the amount ofDERs generated; 

f. The amount of DERs used each month; 

g. A calculation of the amount ofDERs required to demonstmte compliance with the emission 

limits stated above; 

h. A statement that the reductions were calculated in accordance with Env-A 31 03.07; 

1. A statement that the DERs were not generated in whole or in part from actions prohibited 

pursuant to Env-A 3103.07; 

J. A statement that due diligence was made to verify that the DERs were not previously used, 

and not generated as a result of actions prohibited under the regulations or other provisions 

of law; 

k. A statement that the DERs were not used in a manner prohibited under the regulations or 

other provisions of law; and 

l. A certification by a responsible official of truth, accuracy, and completeness that states: 

1. Based on information and belief formed after reasonable inquiry, the statements and 

information in the document are true, accurate, and complete; and 

11. The user source in compliance with all National Ambient Air Quality Standards, except 

ground level ozone, and all Ambient Air Limits for Regulated Toxic Air Pollutants. 

10. Textile Tapes shall comply with all terms and conditions contained in permits to be issued by 
Amended VOC RACTOrder ARD-96-001 

Textile Tapes Corporation 

DES. 

Please address any correspondence and communication in reference to this Order to: 

Air Permit Programs Manager 

Permitting & Environmental Health Bureau 

NHDES, Air Resources Division 

29 Hazen Drive., P.O. Box 95 

Concord, NH 03302-0095 

(603) 271-1370 

Please address any COJTespondence and communication in reference to the DERs to: 

Joseph T. Fontaine 

Teclmical Services Bureau 

NHDES, Air Resomces Division 

29 Hazen Drive., P.O. Box 95 

Concord, NH 03302-0095 

(603) 271-6794 

~ ·a w-!6 VI 

Craig ~right, Acting Director 

Air Resources Division 

cc: Timothy Drew, PIP Office 

Anne Amold, US EPA 

City of Rochester 

Tim Donnelly, MacMillan & Donnelly 

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