Summary

Beginning in late 1996, the New Hampshire Department of Environmental Services (DES) modified the requirements for anyone with actual total nonexempt volatile organic compound (VOC) emissions of 10 tons or more per year. The new regulation replaces a 1500 gallon per year VOC replacement rate listed in EnvA 607.01 g.

What Sources Are Affected?

Any stationary source, area source, or device with total photochemically-reactive VOC emissions of 10 tons or more per year. This includes any existing, new or modified sources. Photochemically-reactive VOCs are typically found in petroleum crudes, petroleum fractions, petrochemicals, solvents, diluents, thinners, and degreasers. Exempt VOCs include ethane, methane, acetone and many chlorinated and fluorinated compounds. About 400 manufacturing facilities were permitted under the old rule.

Why the Change?

The old version of the regulation was based on chemical usage, which is not necessarily representative of actual emissions and impact on ambient air quality. The new emission-based regulation better addresses the effects on ambient air quality.

Steps to Compliance

All sources exceeding the 10 ton limit must apply for a permit. The source owner must:

file a compliance permit application package,
model the impacts of any toxic air pollutants on the ambient air,
take actions to come into compliance if ambient air limits are exceeded.

Note that this is a facility-wide permitting threshold. Its applicability is unrelated to any past or current air quality impact modeling performed on the device or source. Companies may also request that DES do the modeling for them.

Fees

There is no permit application fee, but an annual emission-based fee is charged each year once a permit is issued. The 1996 fee was about $45.50 per ton.

For more information on air quality compliance, contact us at 800-725-2550.