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New Hampshire Department of Environmental Services

Frequently Asked Questions
  • Why did NHDES change the VOC RACT rules and add new source categories?
    Federal law (section 184 of the Clean Air Act) requires states that are in Ozone Transport Region, like New Hampshire, to adopt rules implementing any applicable Control Techniques Guidelines (CTGs) issued by EPA. In 2006, 2007 and 2008, EPA issued new CTGs for 11 source categories, nine of which affect sources in New Hampshire.
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  • What are the nine source categories the control techniques for which were incorporated into the VOC RACT rules?
    AThe nine sources categories are paper-fabric-film-foil substrate coating; metal furniture coating; miscellaneous metal and plastic parts and products coating; offset lithographic and letter press printing; flexible packaging printing; flat wood paneling; fiberglass boat manufacturing materials; industrial cleaning solvents; and miscellaneous industrial adhesives.
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  • When will the new VOC RACT standards take effect?
    The compliance date for existing sources is January 1, 2016 for most of the new emission limits. However, work practice standards went into effect on June 1, 2011, and sources that begin operation after June 1, 2011 will be required to meet the new or modified standards at startup.
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  • If the standards that the facility is currently meeting and which are in the facility's permit are changed as a result of the rule, will the revised standards supersede the limits in the facility's permit?
    Yes. The emission limits for existing sources take effect January 1, 2016. These limits will be revised when the permit is renewed. However, some source categories work practice standards took effect June 1, 2011. Existing permit holders will need to meet requirements now, even though the requirements are not written in the current permit.
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  • What are the options if the facility can not meet the proposed standards?
    Contact NHDES and speak to a permit engineer to discuss options that might be available for the facility. For example, Env-A 1205 RACT Procedures contains alternative compliance options and provisions for obtaining a RACT order.
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  • For the digital printing operations category, are inkjet printers, used to print product codes, included?
    Yes, inkjet printers are digital printers and exempt from the rule.
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  • Would a metal furniture coating source with 2 tons of emissions from coating and cleaning operations, and 2 tons of emissions from other industrial cleaning activities, be subject Env-A 1221.05 Applicability Criteria for the Use of Industrial Cleaning Solvents, which has an applicability threshold of 3 tpy?
    It depends on the amount of emissions from the metal furniture source's cleaning operations. Both the metal furniture coating rules and the industrial cleaning solvents rules have applicability thresholds of 3 tpy actual emissions before controls. Thus, under the scenario, the metal furniture operation would not be subject to the metal furniture rules. In this case, the exemption in Env-A 1221.06(a)(2) for cleaning activities associated with metal furniture coating would not apply. Therefore, the VOC emissions from all cleaning activities at the facility must be totaled to determine whether the threshold for the industrial cleaning solvents requirements was met. If emissions from the "cleaning" component of the metal furniture operation were 1 tpy or more, then all of the facility's cleaning operations would be subject to Env-A 1221.05 – Env-A 1221.07 Compliance Standards for the Use of Industrial Cleaning Solvents, because the total VOC emissions from cleaning operations would meet or exceed the 3 tpy threshold. If the amount of emissions from the metal furniture cleaning operations were less than 1 tpy, neither the metal furniture operations nor the other industrial cleaning activities would be subject to their respective VOC RACT rules.
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  • If a facility has controls to get actual emissions below 3 tpy, can the facility get a permit and opt out?
    Yes. In the memo titled "RACT Qs & As – Reasonably Available Control Technology (RACT): Questions and Answers" Adobe Acrobat Reader Symbol dated May 18, 2006, EPA states: "Where a source has a federally enforceable limit on emissions or a federally enforceable restriction on the hours of operation, then the analysis of whether the source is subject to RACT would be based on emissions considering those restrictions."
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NH Department of Environmental Services | 29 Hazen Drive | PO Box 95 | Concord, NH 03302-0095
(603) 271-3503 | TDD Access: Relay NH 1-800-735-2964 | Hours: M-F, 8am-4pm

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