18May2004Mr. George A. LePageMaintenance & Engineering

Coordinator PLIANT CORPORATION 770 Douglas

PikeHarrisville, Rl 02830 Dear Mr. LePage:The Department

of Environmental

Management,

Office of Air Resources

has reviewed

and approved your application

for the installation

of fuel burning equipment

at your facility, located at 770 Douglas

Pike, Harrisville,

RI.Enclosed1803). is a minor source permit pursuant

to our review of your application

(Approval

No. During the course of our review of your application,

we determined

that the fuel burning equipment was installed

in 2003. Pliant Corp. failed to obtain a preconstruction

permit prior to the installation of this equipment

as required by RI Air Pollution

Control Regulation

No. 9. Be advised that issuance

of this permit does not limit or otherwise

preclude

the RI DEM from pursuing enforcement

actions to address the violations

stated above. If there are any questions

concerning

this permit, please contact me at 222-2808,

extension

7011. Sincerely,
Douglas L. McVayAssociate Supervising

Engineer Office of Air Resources

cc: Harrisville

Building

OfficialSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES MINOR SOURCE

PERMIT PLIANT CORPORA

TION APPROVAL NO. 1803 Pursuant to the provisions

of Air Pollution

Control

Regulation

No. 9, this minor source permit is issued to: Pliant Corporation For the following:Installation of a Burnham

Industrial

l O0-hp firetube

boiler, Model No. 4FL-450-45. The fuel burning equipment

shall be fired with No. 4fuel oil containing

1.0 percent sulfur, by weight, or less.

Located at: 770 Douglas

Pike, Harr&ville

This permit shaft be effective

from the date of its issuance

and shall remain in effect until revoked by or surrendered

to the Department.

This permit

does not relieve Pliant Corporation from compliance

with applicable

state and federal air pollution

control rules and regulations.

The design, construction

and operation

of this equipment

shall be subject to the attached

permit conditions

and emission

limitations.
Stephen Majkut,

Chief Office of Air Resources Date of IssuanceSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES Permit Conditions

and Emission

Limitations PLIANT CORPORATION Approval No. 1803 Ao Emission

Limitations 1. Oil Firing

a, Nitrogen

Oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere from the boiler shall not exceed 0.13 lb per million BTU heat input or 0.56 lbs/hr, whichever

is more stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere from the boiler shall not exceed 0.033 lb per million BTU heat input or 0.14 lb/hr, whichever

is more stringent.

c. Sulfur Dioxide

(SO2)(i) All fuel burned in the boiler shall contain no more than 1.0 percent sulfur by weight. (ii) The emission

rate of sulfur dioxide discharged

.to the atmosphere from the boiler shall not exceed 4.41 lbs/hr. d. Particulate

MatterThe emission

rate of particulate

matter discharged

to the atmosphere from the boiler shall not exceed 0.1 lb per million BTU heat input or 0.42 lb/hr, whichever

is more stringent.

e. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere

from the boiler shall not exceed 0.002 lb per million BTU heat input or 0.0! lb/hr, whichever

is more stringent. Page of 4Visible emissions

from the boiler exhaust flue shall not exceed 10% opacity (six-minute

average).
Bo Operating

Requirements 1. The maximum

firing rate of the boiler shall not exceed 29.1 gal/hr of No. 4 fuel oil.

Do Continuous

MonitorsContinuous emission

monitoring

equipment

shall be installed,

operated

and maintained for opacity. Fuel Oil TestingCompliance

with fuel oil sulfur limit may be determined

based On a certification from the fuel supplier. 2. Fuel supplier certification

shall include the following

information:

a. The name of the oil supplier; b. The sulfur and nitrogen

content of the oil;
Co The location of the oil when the sample was drawn for analysis

to determine the sulfur and nitrogen

content of the oil; specifically including whether

the oil was sampled

as delivered

to Pliant Corporation or whether

the sample was drawn from oil in storage at the oil supplier's

or oil refiner's

facility or another location; do The method used to determine

the sulfur and nitrogen

content of the oil.As an alternative

to fuel supplier certification,

the owner/operator

may elect to sample the fuel prior to combustion.

Sampling

and analysis shall be conducted for the oil in the initial tank ofoil to be fired in the boiler and after each new shipment

of oil is received.

Samples

shall be collected

from the fuel tank immediately

after the fuel tank is filled and before any oil is combusted.Each fuel supplier certification

or each fuel oil analysis must demonstrate that the fuel oil for the boiler contains

1.0 percent sulfur by weight or less.
Page 2 of 4Record Keeping

and Reporting The owner/operator

shall, on a monthly basis, no later than 5 days after the first of the month, determine

the total quantity

of No. 4 fuel oil combusted in the boiler. The owner/operator

shall keep records of this determination and provide such records to the Office of Air Resources

upon request. The owner/operator

shall notify the Office of Air Resources

in writing of any planned physical

or operational

change to any equipment

that would:
a. Change the representation

of the facility in the application. Alter the applicability

of any state or federal air pollution

rules or regulations.

c. Result in the violation

of any terms or conditions

of this permit. d. Qualify as a modification

under APC Regulation

No. 9. Such notification

shall include:

• Information

describing

the nature of the change. Information describing

the effect of the change on the emission

of any air contaminant.

• The scheduled

completion

date of the planned

change. Any such change shall be consistent

with the appropriate

regulation

and have the prior approval

of the Director. The owner/operator

shall retain copies of all fuel supplier certifications

or fuel .oil analyses

for each calendar

quarter. These records shall be made accessible for review by the Office of Air Resources

or EPA. This quarterly record shall include a certified

statement,

signed by the owner/operator,

that the records of fuel supplier certifications

submitted

represent

all of the fuel combusted during the quarter. The owner/operator

shall notify the Office of Air Resources

of any anticipa,ted noncompliance

with the terms of this permit or any other applicable air pollution

control rules and regulations. The owner/operator

shall notify the Office of Air Resources,

in writing, of any noncompliance

with the terms of this permit within 30 calendar

days of becoming

aware of such occurrence

and supply the Director

with the following information:

Page 3 of 4a. The name and location of the facility; bo The subject source(s)

that caused the noncompliance

with the permit term;
Co The time and date of first observation

of the incident of noncompliance; do The cause and expected

duration

of the incident of noncompliance; The estimated

rate of emissions

(expressed

in lbs/hr or lbs/day) during the incident and the operating

data and calculations

used in estimating the emission

rate. The proposed

corrective

actions

and schedule

to correct the conditions causing the incidence

of noncompliance. All records required

in this permit shall be maintained

for a minimum

of five years after the date of each record and shall be made available

to representatives of the Office of Air Resources

upon request. Fo Other Permit ConditionsTo the extent consistent

with the requirements

of this permit and applicable federal and state laws, the facility shall be designed,

constructed

and operated in accordance

with the representation

of the facility in the permit application dated 1 January 2004. Employees of the Office of Air Resources

and its authorized

representatives shall be allowed to enter the facility at all times for the purpose of inspecting any air pollution

source, investigating

any condition

it believes may be causing air pollution

or examining

any records required

to be maintained

by the Office of Air Resources. At all times, including

periods of startup, shutdown

and malfunction,

the owner/operator shall, to the extent practicable,

maintain

and operate this boiler in a manner consistent

with good air pollution

control practice

for minimizing emissions.

Determination

of whether

acceptable

operating and maintenance

procedures

are being used will be based on information available to the Office of Air Resources

which may include, but is not limited to, monitoring

results, opacity observations,

review of operating and maintenance

procedures

and inspection

of the source. 2004/Pliant.doc Page 4 of 46 June 2007

Mr. Gregory J. Laramie Chair, Foster-Glocester

Regional

Building

Committee Foster-Glocester Regional

School District 1145 Putnam PikeChepachet, RI 02814 Dear Mr. Laramie:The Department

of Environmental

Management,

Office of Air Resources,

has reviewed

and approved your application

for the installation

of fuel burning equipment

and air pollution control equipment

at Ponaganset

Middle School located at 7 Rustic Hill Road, Glocester. Enclosed is a minor source permit issued pursuant

to our review of your application (Approval Nos. 1989 & 1990). If there are any questions

concerning

this permit, please contact me at 222-2808,

extension 7011.Sincerely,Douglas L. McVayAssociate Supervising.

Engineer Office of Air Resources

CC: Glocester

Building

Official John Hinckley

RSGSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES MINOR SOURCE

PERMIT FOSTER-GLOCESTER REGIONAL

SCHOOL

DISTRICT APPROVAL NOs. 1989 & 1990
Pursuant to the provisions

of Air Pollution

Control

Regulation

No; 9, this minor source permit is issued to: Foster-Glocester

Regional

School District For the following:Installation of a Chiptec (Phoenix

Series Gasifier)

102-hp firetube

boiler (Approval

No. 1989). The fuel burning equipment

shall be fired with wood chips. The boiler shall contain ahighefficiency multicyclone

to control emissions

of particulate

matter(Approval

No. 1990).

Located at:

Ponaganset

Middle School, 7 Rustic Hill Road, Glocester

This permit shall be effective

from the date of its issuance

and shall remain in effect until revoked

by or surrendered

to the Department.

This permit does not relieveFosterGlocester Regional

School District from compliance

with applicable

state and federal air pollution control rules and regulations.

The design, construction

and operation

of this equipment shall be subject to the attached

permit conditions

and emission

limitations.
Stephen Majkut,

Chief Office of Air Resources Date of issuanceSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES Permit Conditions

and Emission

Limitations Foster-Glocester Regional

School District APPROVAL NOs. 1989 & 1990 Emission Limitations

The following

emission

limitations

are applicable

to the Chiptec (Phoenix

Series Gasifier)

102-HP firetube boiler, capable of burning wood chips. The maximum

heat input capacity

of this boiler shall be 4.56 million BTUs per hour while burning wood chips having a heat content of 5,013 BTUs per pound. 1. Wood Chip Firing

a. Nitrogen

Oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere from the boiler shall not exceed 0.28 lb per million BTU heat input or 1.3 lb/hr, whichever

is more,stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere from the boiler shall not exceedO.

18 lb per million BTU heat input or 0.82 lb/hr, whichever

is. more stringent.

c. Sulfur Dioxide

(SO2) The emission

rate of sulfur dioxide discharged

to the atmosphere from the boiler shall not exceed 0.025 lb per million BTU heat input or 0.11 ib/hr, whichever

is more stringent. d. Particulate

Matter (as PM10) The emission

rate of particulate

matter discharged

to the atmosphere from the boiler shall not exceed 0.20 lb per million BTU heat input or 0.91 lb/hr, whichever

is more stringent.

e. Particulate

Matter (as PM2.5) The emission

rate of particulate

matter discharged

to the atmosphere from the boiler shall not exceed 0.18 lb per million BTU heat input or 0.84 lb/hr, whichever

is more stringent.
Page of 9Bo

Do f. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere

from the boiler shall not exceed 0.017 lb per million BTU heat input or 0.078 lb/hr, whichever

is more stringent. g. Listed Toxic Air Contaminants The emissions

of air contaminants

discharged

to the atmosphere from the boiler shall not exceed the limitations

in Table 1. These limitations were established

to ensure that emissions

from this facility do not exceed any of the Acceptable

Ambient

Levels (AALs) listed in Air Pollution

Control Regulation

No. 22. The limitations shown in pounds per year are calculated

on a 12-month rolling basis. Visible emissions

from the boiler exhaust flue shall not exceed 10% opacity (6-minute average). Operating RequirementsThe owner/operator

shall limit the quantity

of wood chips bumed in the wood-fired boiler to 1,000 tons or less, on a wet as-fired basis, in any consecutive 12-month

period• The maximum

firing rate of the boiler shall not exceed 910 pounds per hour of wood chips adjusted

to a 40% moisture

content. Continuous MonitorsContinuous emission

monitoring

equipment

shall be installed,

operated

and maintained for opacity when the boiler is operating. Stack TestingWithin

180 days of startup of the boiler, performance

testing shall be conducted to demonstrate

compliance

with the emission

limitations

for nitrogen oxides, carbon monoxide,

sulfur dioxide, PM10, PM2.5 and total nonmethane hydrocarbons.

Additionally

testing shall be conducted

to measure emissions

of the following

listed toxic air contaminants

for comparison to the emission

rates used in the air quality modeling:

acrolein, arsenic benzene,

hexavalent

chromium,

formaldehyde,

manganese, phosphorus and polycyclic

organic matter.

Page 2 of 9Eo A stack testing protocol

shall be submitted

to the Office of Air Resources

for review and approval

at least 60 days prior to the performance

of any stack tests. The owner/operator

shall provide the Office of Air Resources

at least 60 days prior notice of any stack test. All test procedures

used for stack testing shall be approved

by the Office of Air Resources

prior to the performance

of any stack tests. The owner/operator

shall install any and all test ports or platforms

necessary

to conduct the required

stack testing, provide safe access to any platforms

and provide the necessary

utilities for sampling

and testing equipment. All testing shall be conducted

under operating

conditions

deemed acceptable and representative

for the purpose of assessing

compliance

with the applicable emissions limitations. A final report of the results of stack testing shall be submitted

to the Office of Air Resources

no later than 60 days following

completion

of testing. All stack testing must be observed

by the Office of Resources

or its authorized representatives to be considered

acceptable,

unless the Office of Air Resources provides authorization

to the owner/operator

to conduct the stack testing without an observer

present. Combustion Efficiency

Testing The owner/operator

shall perform

combustion

efficiency

tests on the boiler by measuring

the concentrations

of carbon dioxide (CO2) and carbon monoxide (CO) in the exhaust gas. Testing shall be performed

in the first month of operation

for each heating season. The CO2 and CO concentrations

may be on a wet or dry basis as long as they are both on the same basis. Any instruments

and/or equipment

used for testing, such as a portable

combustion

analyzer,

shall be calibrated

and maintained in accordance

with the manufacturer's

recommendations. The owner/operator

shall calculate

and record the combustion

efficiency

of the boiler each time testing of the boiler exhaust gas is conducted

to determine the concentrations

of CO2 and CO.

Page 3 of 9Fo 4. The combustion

efficiency

shall be calculated

using the following

equation: ce( ) co2 x 100CO 2 + CO where:CE combustion

efficiency C02 % by volume of C02 in the exhaust gas CO % by volume of CO in the exhaust gas Record Keeping

and Reporting The owner/operator

shall, on a monthly

basis, no later than 5 days after the first of the month, determine

and record the total quantity

of wood chips combusted in the boiler. This requirement

can be met with fuel delivery records. The owner/operator

can request approval

of an alternative

method from the Director.

The owner/operator

shall keep records of this determination and provide such records to the Office of Air Resources

upon request.The owner/operator

shall notify the Office of Air Resources,

in writing within 15 days, whenever

the total quantity

of wood chips combusted

in the boiler exceeds

1,000 tons, on a wet as-fired basis, in any consecutive

12- month period.The owner/operator

shall maintain

copies of all wood fuel delivery

records and these copies shall be made accessible

for review by the Office of Air Resources or its authorized

representative

and EPA. These records shall include a certified

statement,

signed by the owner/operator

of the facility, that the records represent

all of the fuel combusted

in the boiler. The owner/operator

shall maintain

records of the results of combustion efficiency testing conducted

on the boiler. These records shall include the test date, identification

of boiler tested, a measurement

of the load on the boiler (such as fuel feed rate or hot water production

rate), the concentrations of oxygen, carbon monoxide

and carbon dioxide in the exhaust gas as well as the combustion

efficiency,

calculated

according

to condition E.4 of this permit. The owner/operator

shall develop and implement

an operation

and maintenance (O&M) plan for the wood-fired

boiler prior to the 1 November 2007. The O&M plan shall include, but not be limited to:

a. Descriptions

of routine maintenance

and inspection

procedures;

Page 4 of 9bo A description

of the procedure

for and frequency

of ash removal from the boiler and the particulate

matter control device; and,
Co Provisions

for maintaining

records of maintenance

and inspection procedures, including

both routine activities

and actions taken in response to observations

of low combustion

efficiency. The O&M plan shall be present at the facility at all times and shall be made available to representatives

of the Office of Air Resources

upon request. The owner/operator

shall revise this plan at the Office of Air Resources' request or as the owner/operator

deems necessary

based on operating experience, or to reflect equipment

or operational

changes. The owner/operator

shall notify the Office of Air Resources

in writing of the date of actual initial start-up of the boiler no later than fifteen days after such date.The owner/operator

shall notify the Office of Air Resources

in writing of any physical

or operational

change to any equipment

that would:

a. Change the representation

of the facility in the application. b° Alter the applicability

of any state of federal air pollutionrules

or regulations.

c. Result in the violation

of any terms or conditions

of this permit. d. Qualify as a modification

trader APC Regulation

No. 9. Such notification

shall include:

• Information

describing

the nature of the change. Information describing

the effect of the change on the emission

of any air contaminant.

• The scheduled

completion

date of the planned change. Any such change shall be consistent

with the appropriate

regulation

and have the prior approval

of the Director. The owner/operator

shall notify the Office of Air Resources

of any anticipated noncompliance

with the terms of this permit or any other applicable air pollution

control rules and regulations.

Page 5 of 910. The owner/operator

shall notify the Office of Air Resources,

in writing, of any noncompliance

with the terms of this permit within 30 calendar

days of becoming aware of such occurrence

and supply the Director

with the following information:

a. The name and location of the facility; b0

Co The subject source(s)

that caused the noncompliance

with the permit term;The time and date of first observation

of the incident of noncompliance; d. The cause and expected

duration

of the incident of noncompliance; The estimated

rate of emissions

(expressed

in lbs/hr or lbs/day) during the incident and the operating

data and calculations

used in estimating the emission

rate; The proposed

corrective

actions and schedule

to correct the conditions causing the incidence

of noncompliance. All records required

in this permit shall be maintained

for a minimum

of five years after the date of each record and shall be made available

to representatives of the Office of Air Resources

upon recluest. Other Permit ConditionsTo the extent consistent

with the requirements

of this approval

and applicable federal and state laws, the facility shall be designed,

constructed and operated

in accordance

with the representation

of the facility in the permit application.Employees of the Office of Air Resources

and its authorized

representatives shall be allowed to enter the facility at all times for the purpose of inspecting any air pollution

source, investigating

any condition

it believes may be causing air pollution

or examining

any records required

to be maintained by the Office of Air Resources. At all times, including

periods of startup, shutdown

and malfunction,

the owner/operator shall, to the extent practicable,

maintain

and operate the facility in a manner consistent

with good air pollution

control practice

for minimizing emissions.

Determination

of whether

acceptable

operating

and maintenance procedures

are being used will be based on information available to the Office of Air Resources

which may include, but is not limited to, monitoring

results, opacity observations,

review of operating

and
Page 6 of 9maintenance procedures

and inspection

of the source. There shall be no bypassing

of the high-efficiency

multicyclone

while the wood-fired boiler is in operation. The owner/operator

shall not bum "wood residue"

without prior authorization from the Office of Air Resources.

"Wood residue"

means a waste by-product

of the pulp and paper industry which consists of bark, sawdust, slabs, chips, shavings

and mill trims. The term "pulp and paper industry" consists of those industries

that have a two digit Standard Industrial Code (SIC) code of 26 or a three digit North American

Industry Classification System (NAICS)

code of 322. The emission

and dispersion

characteristics

of the wood-fired

boiler shall be consistent with the parameters

used in the air quality modeling

to demonstrate that the emissions

from the facility do not cause or contribute

to air pollution in violation

of any national ambient air quality standard

or do not cause an impact which exceeds the Acceptable

Ambient

Level for any air toxic contaminant. The Office of Air Resources,

in its sole discretion,

may reopen this minor source permit if it determines

that the emission

and dispersion characteristics have changed

significantly

and that emission

limitations

must be revised and/or added to this permit to ensure that the facility does not cause or contribute

to air pollution

in violation

of any national ambient air quality standard or any Acceptable

Ambient

Level. MalfunctionsMalfunction means a sudden and unavoidable

breakdown

of process or control equipment.

In the case of a malfunction

of any air pollution

control system, all reasonable

measures

shall be taken to assure resumption

of the designed control efficiency

as soon as possible.

In the event that the malfunction of an air pollution

control system is expected

or may reasonably be expected

to continue

for longer than 24 hours and if the owner or operator

wishes to operate the source on which it is installed

at any time beyond that period, the Director

shall be petitioned

for a variance under Section 23-23-15

of the General Laws of Rhode Island, as amended. Such petition shall include, but is not limited to, the following; Identification of the specific air pollution

control system and source on which it is installed; bo The expected

period of time that the air pollution

control system will be malfunctioning

or out of service; The nature and quantity

of air contaminants

likely to be emitted during said period;
Page 7 of 9d. Measures

that will be taken to minimize

the length of said period;

eo The reasons that it would be impossible

or impractical

to cease the source operation

during said period. The owner/operator

may seek to establish

that a malfunction

of any air pollution control system that would result in noncompliance

with any of the terms of this permit or any other applicable

air pollution

control rules and regulations was due to unavoidable

increases

in emissions

attributable

to the malfunction. To do so, the owner/oPerator

must demonstrate

to the Office of Air Resources

that:

ao The malfunction

was not attributable

to improperly

designed

air pollution control equipment,

lack of preventative

maintenance, careless or improper

operation,

or operator

error; bo The malfunction

was not part of a recurring

pattern indicative

of inadequate design, operation,

or maintenance;
Co Repairs were performed

in an expeditious

fashion. Off-shift

labor and overtime

should be utilized,

to the extent practicable,

to ensure that such repairs were completed

as expeditiously

as practicable. d° All possible

steps were taken to minimize

emissions

during the period of time that the repairs were performed.

eo Emissions

during the period of time that the repairs were performed will not:(1) Cause an increase in the ground level ambient concentration

at or beyond the property

line in excess of that allowed by Air Pollution Control Regulation

No. 22 and any Calculated Acceptable Ambient

Levels; and (2) Cause or contribute

to air pollution

in violation

of any applicable state or national ambient air quality standard. The reasons that it would be impossible

or impractical

to cease the source operation

during said period. The owner/operator's

action in response

to the excess emissions were documented

by properly

signed, contemporaneous

operating logs or other relevant

evidence.

Page 8 of 9This demonstration

must be provided

to the Office of Air Resources,

in writing, within two working

days of the time when the malfunction occurred and contain a description

of the malfunction,

any steps taken to minimize emissions

and corrective

actions taken. The owner/operator

shall have the burden of proof in seeking to establish that noncompliance

was due to unavoidable

increases

in emissions attributable to the malfunction.

PollutantAcroleinArsenicBenzeneChromium VIFormaldehydeManganese Table 1.

PhosphorusPolycyclic organic matter Emission

Limitations

for Listed Air ToxicsEmission Limitation

Polychlorinated dibenzo-dioxins (PCDDs)• polychlorinated

dibenzofurans (PCDFs)

and dioxin-like polychlorinated biphenyls

(PCBs)

pounds/hour

pounds/day 0.002 0.05

pounds/year

0.005 0.7 4.66 74

377 0.3 0.3 1.16 98

302 0.12 151 0.17 2

0.17

1Annual limit is more stringent than the daily limit (2.6) back calculated

from the AAL 2Daily limit is more stringent than the l•ourly limit (0.47) back calculated

from the AAL 0.34
0.00001

PCM1N-PONAGANSETMIDSCHOOL

07

Page 9 of 97

June 2004
Mr. David P. Gibbons Environmental Director Bradford Dyeing Assocation,

Inc. P.O. Box 539Westerly, RI 02891 Dear Mr. Gibbons:The Department

of Environmental

Management,

Office of Air Resources

has reviewed

and approved your application

for the installation

of fuel burning

equipment

at your facility; located at 460 Bradford

Road, Bradford,

RI. Enclosed is a minor source permit issued pursuant

to our review of your application

(Approval No. 1804).If there are any questions

concerning

this permit, please contact me at 222-2808,

extension

7011. Sincerely,
Douglas L. McVay Associate Supervising

Engineer Office of Air Resources

cc: Westerly

Building

OfficialSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES MINOR SOURCE

PERMIT BRADFORD DYEING

ASSOCIATION,

INC.
APPROVAL NO. 1804
Pursuant to the provisions

of Air Pollution

Control Regulation

No. 9, this minor source permit is issued to:

For the following: Bradford

Dyeing Association,

lnc.

Installation of a Cleaver Broolc• 21.28 MMBtu/hr

boiler. The fi•el burning equipment shah be fired with No. 6 fuel oil containing

1. O percent sulfur, bv weight, or less.

Located at:

460 Bradford

Road, Bradford

This permit shall be effective

from the date of its issuance

and shall remain in effect until revoked by or surrendered

to the Department.

This permit does not relieve Bradford Dyeing Association

from compliance

with applicable

state and federal air pollution

Control rules and regulations.

The design, construction

and operation

of this equipment

shall be subject to the attached

permit conditions

and emission

limitations.
Stephen Majkut,

Chief Office of Air Resources Date of IssuanceSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES Permit Conditions

and Emission

Limitations Bradford Dyeing Association Approval No. 1804 Emission Limitations 1. Nitrogen

Oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere

from the boiler shall not exceed 0.5 lbs per million BTU heat input or 10.46 lbs/hr whichever

is more stringent. 2. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere

from the boiler shall not exceed 0.08 lbs per million BTU heat input or 0.70 lbs/hr whichever is more stringent. Sulfur Dioxide

(SO2)

ao All fuel burned in the boiler shall contain no more than 1.0 percent sulfur by weight.bo The emission

rate of sulfur dioxide discharged

to the atmosphere

from the boiler shall not exceed 21.90 lbs/hr. Particulate MatterThe emission

rate of particulate

matter discharged

to the atmosphere

from the boiler shall not exceed 0.1 lbs per million BTU heat input or 2.1 lbs/hr whichever is more stringent.Volatile Organic

Compounds

(VOC) The emission

rate of volatile organic compounds

discharged

to the atmosphere from the boiler shall not exceed 0.002 lbs per million BTU heat input or 0.04 lbs/hr, whichever

is more stringent.

Page of 5Visible emissions

from the boiler exhaust flue shall not exceed 10% opacity(sixminute average).Operating Requirements 1. The maximum

firing rate of the boiler shall not exceed 139.5 gal/hr of No. 6 fuel oil. 2. The owner/operator

shall limit the quantity of No. 6 fuel oil combusted

in this boiler to 496,815 gallons or less for any consecutive

12-month

period. 3. The owner/operator

shall tune the boiler at least once each year of operation,

in accordance with the procedure

described

in Appendix

A of APC Regulation

No. 27
Co Continuous

Monitors 1. Continuous

emission

monitoring

equipment

shall be installed,

operated

and maintained for opacity. 2. Fuel oil flow for the boiler shall be continuously

measured

and recorded.
Fuel Oil TestingCompliance

with fuel oil sulfur limits may be determined

based on a certification from the fuel supplier. 2. Fuel supplier certification

shall include the following

information: The name of the oil supplier; The sulfur and nitrogen

content of the oil; The location

of the. oil when the sample was drawn for analysis to determine the sulfur and nitrogen

content of the oil; specifically

including whether the oil was sampled

as delivered

to Bradford

Dyeing Association or whether

the sample was drawn from oil in storage at the oil supplier's
or oil refiner's

facility or another location; The method used to determine

the sulfur and nitrogen

content of the oil. As an alternative

to fuel supplier certification,

the owner/operator

may elect to sample the fuel prior to combustion.

Sampling

and analysis shall be conducted

for the oil in the initial tank of oil to be fired in the boiler and after each new shipment

Page 2 of 5ofoil is received.

Samples

shall be collected

from the fuel tank immediately

after the fuel tank is filled and before any oil is eombusted. Each fuel supplier certification

or each fuel oil analysis must demonstrate

that the oil contains

1.0 percent sulfur by weight or less.
Eo Record Keeping

and Reporting The owner/0perator

shall, on a monthly

basis, no later than 5 days after the first of the month, determine

the total quantity

of No. 6 fuel oil combusted

in the boiler for the previous

12 months.

The owner/operator

shall keep records of this determination and provide such records to the Office of Air Resources

upon request. The owner/operator

shall notify the Office of Air Resources,

jin writing within 30 days, whenever

the quantity

of No. 6 fuel oil combusted

in this boiler exceeds 496,815 gallons for any consecutive

12-month

period.. The owner/operator

shall notify the Office of Air Resources,

in writing, of the date of actual initial start-up of the boiler no later than fifteen days after such date. The owner/operator

shall notify the Office of Air Resources

in writing of any planned physical

or operational

change to any equipment

that would:

a. Change the representation

of the facility in the application. bo Alter the applicability

of any state or federal air pollution

rules or regulations.

c. Result in the violation

of any terms or conditions

of this permit. d. Qualify as a modification

under APC Regulation

No. 9. Such notification

shall include:

• Information

describing

thenature

of the change. Information describing

the effect of the change on the emission

of any air contaminant.

• The scheduled

completion

date of the planned

change. Any such change shall be consistent

with the appropriate

regulation

and have the prior approval

of the Director.

Page 3 of 5The owner/operator

shall retain copies of all fuel supplier certifications

or fuel oil analyses for each calendar

quarter. These records shall be made accessible

for review by the Office of Air Resources

or EPA. This quarterly

record shall include a certified statement,

signed by the owner/operator,

that the records of fuel supplier certifications submitted

represent

all of the fuel combusted

during the quarter. The owner/operator

shall maintain

records verifying

that a ttme-up has been performed in accordance

with Condition

B.3 of this permit. These records shall include the following

information:

a. The date the tune-up was performed, b. The name of the person who performed

the tune-up,

c. The final excess oxygen setting, and do The O2/CO curve or O2/smoke

curve that has been developed

as part of a tune-up procedure. The owner/operator

shall notify the Office of Air Resources

of any anticipated noncompliance with the terms of this permit or any other applicable

air pollution control rules and regulations. The owner/operator

shall notify the Office of Air Resources,

in writing, of any noncompliance with the terms of this permit within 30 calendar

days of becoming aware of such occurrence

and supply the Director

with the following

information:

a. The name and location of the facility; b. The subject source(s)

that causedthe

noncompliance

with the permit term;

c. The time and date of first observation

of the incident of noncompliance; do

eo The cause and expected

duration

of the incident of noncompliance; The estimated

rate of emissions

(expressed

in lbs/hr or lbs/day) during the incident and the operating

data and calculations

used in estimating

the emission rate; f. The proposed

corrective

actions and schedule

to correct the conditions causing the incidence

of noncompliance. All records required

in this permit shall be maintained

for a minimum

of five years after the date of each record and shall be made available

to representatives of the Office of Air Resources

upon request.

Page 4 of 5Fo Other Permit ConditionsTo the extent consistent

with the requirements

of this permit and applicable

federal and state laws, the facility shall be designed,

constructed

and operated

in accordance with the representation

of the facility in the permit application

dated 16 February 2004.Employees of the Office of Air Resources

and its authorized

representatives

shall be allowed to enter the facility at all times for the purpose of inspecting

any air pollution source, investigating

any condition

it believes may be causing air pollution or examining

any records required

to be maintained

by.the Office of Air Resources. At all times, including

periods of startup, shutdown

and malfunction,

the owner/operator shall, to the extent practicable,

maintain

and operate this boiler in a manner consistent

with good air pollution

control practice

for minimizing emissions. Determination

of whether

acceptable

operating

and maintenance procedures are being used will be based on information

available

to the Office of Air Resources

which may include, but is not limited to, monitoring

results, opacity observations,

review of operating

and maintenance

procedures

and inspection of the source.

Page 5 of 519 November

2004

Mr. Guy EriceMgr. of Engineering

and Maintenance ROGER WILLIAMS

MEDICAL

CENTER 825 Chalkstone

AvenueProvidence, RI 02908 Dear Mr. Erice:The Department

of Environmental

Management,

Office of Air Resources

has reviewed

and approved your application

for the installation

of fuel burning

equipment

at your facility, located at 825 Chalkstone

Avenue,

Providence,

RI. Enclosed is a minor source permit issued pursuant

to our review 6f your application

(Approval No. 1820).If there are any questions

concerning

this permit, please contact me at 222-2808,

extension

7011. Sincerely,
Douglas L. McVayAssociate Supervising

Engineer Office of Air Resources

CC: Providence

Building

Official Andrew Lombard

Fuss & O'Neill Inc.STATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES MINOR SOURCE

PERMIT ROGER WILLIAMS

MEDICAL

CENTER
APPROVAL NO. 1820
Pursuant to the provisions

of Air Pollution

Control Regulation

No. 9, this minor source permit is issued to: Roger Williams

Medical

Center For the following: A Cleaver Brooke Model No. CBLE 400-600

boiler. The fuel burnin E equipment

shall befired with either natural gas or No. 6_fuel oil containing

0.5percent

sulfur, t•v weight, or less.

Located at: 825 Chalkstone

Avenue,

Providence

This permit shall be effective

from the date of its issuance

and shall remain in effect until revoked by or surrendered

to the Department.

This permit does not relieve Roger Williams Medical Center from compliance

with applicable

state and federal air pollution

control rules and regulations.

The design, construction

and operation

of this equipment

shall be subject to the attached

permit conditions

and emission

limitations.
Stephen Majkut,

Chief Office of Air Resources Date of IssuanceSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES Permit Conditions

and Emission

Limitations Roger Williams

Medical

Center Approval No. 1820

mo Emission

Limitations 1. Natural Gas Firing

a. Nitrogen

Oxides (as nitrogen

dioxide (NO2) The emission

rate of nitrogen

oxides discharged

to the atmosphere

from the boiler shall not exceed 0.035 lbs per million BTU heat input or 0.86 lb/hr, whichever

is more stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere

from the boiler shall not exceed 0.109 lbs per million BTU heat input or 0.89 lb/hr, whichever

is more stringent.

c. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere from the boiler shall not exceed 0.016 lbs per million BTU heat input or 0.392 lb/hr, whichever

is more stringent. 2. Oil Firing

a. Nitrogen

Oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere

from the boiler shall not exceed 0.426 lbs per million BTU heat input or 10.44 lbs/hr whichever

is more stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere

from the boiler shall not exceed 0.075 lbs per million BTU heat input or 1.84 lbs/hr whichever

is more stringent.
Page of 5c. Sulfur Dioxide

(SO2)(i) All fuel burned in the boiler shall contain no more than 0.5 percent sulfur by weight.(ii) The emission

rate of sulfur dioxide discharged

to the atmosphere from the boiler shall not exceed 12.61 lbs/hr. d. Particulate

MatterThe emission

rate of particulate

matter discharged

to the atmosphere

from the boiler shall not exceed 0.073 lbs per million BTU heat input or 1.79 lbs/hr whichever

is more stringent.

e. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere from the boiler shall not exceed 0.035 lbs per million BTU heat input or 0.857 lbs/hr, whichever

is more stringent. Visible emissions

from the boiler exhaust flue shall not exceed 10% opacity(sixminute average).

B. Operating

RequirementsThe maximum

t'Ldng rate of the boiler shall not exceed 163 gal/hr of No. 6 fuel oil or 24,494 ft3/hr of natural gas. The flue gas recirculation

system for the boiler shall be in full operation

whenever the boiler is in operation. The owner/operator

shall conduct a complete

annual inspection

of the flue gas recirculation s•cstem and its components.

The owner/operator

shall check for proper operation and compare

all internal and external control and drive linkage settings with those established

by Cleaver Brooks. The owner/operator

shall note and correct any deviations

prior to operating

the boiler after each such annual inspection.
C. Continuous

MonitorsContinuous emission

monitoring

equipment

shall be installed,

operated

and maintained for opacity when the boiler is operating

on fuel oil.

Page 2 of 5Natural gas and fuel oil flow for the boiler shall be continuously

measured

and recorded.
Do Fuel Oil TestingCompliance

with fuel oil sulfur limits may be determined

based on a certification from the fuel supplier. 2. Fuel supplier certification

shall include the following

information:

a. The name of the oil supplier; b. The sulfur content of the oil;
Co The location

of the oil when the sample was drawn for analysis

to determine the sulfur content of the oil; specifically

including

whether

the oil was sampled

as delivered

to Roger Williams

Medical

Center or whether the sample was drawn from oil in storage at the oil supplier's

or oil refiner's

facility or another location; d. The method used to determine

the sulfur content of the oil. As an alternative

to fuel supplier certification,

the owner/operator

may elect to sample the fuel prior to combustion.

Sampling

and analysis shall be conducted

for the oil in the initial tank ofoil to be fired in the boiler and after each new shipment of oil is received.

Samples

shall be collected

from the fuel tank immediately

after the fuel tank is filled and before any oil is combusted. Each fuel supplier certification

or each fuel oil analysis must demonstrate

that the oil for the Cleaver Brooks boiler contains

0,5 percent sulfur by weight or less. E° Record Keeping

and Reporting The owner/operator

shall notify the Office of Air Resources

in writing of the date of actual initial start-up of the boiler no later than fifteen days after such date. The owner/operator

shall, on a monthly

basis, no later than 5 days after the In'st of the month, determine

the total quantity

of No. 6 fuel oil and natural gas combusted in the Cleaver Brooks boiler, The owner/operator

shall keep records of this determination and provide such records to the Office of Air Resources

upon request. All fuel combusted

in this boiler shall be included

in the determination

of fuel use for the entire facility under Condition

C. 1 of its Emissions

Cap.

Page 3 of 5The owner/operator

shall notify the Office of Air Resources

in writing of any planned physical

or operational

change to any equipment

that would:

a. Change the representation

of the facility in the application. bo Alter the applicability

of any state or federal air pollution

rules or regulations.

c. Result in the violation

of any terms or conditions

of this permit. d. Qualify as a modification

under APC Regulation

No. 9. Such notification

shall include:

• Information

describing

the nature of the change. Information describing

the effect of the change on the emission

of any air contaminant.

• The scheduled

completion

date of the planned change. Any such change shall be consistent

with the appropriate

regulation

and have the prior approval

of the Director. The owner/operator

shall maintain

records of the annual visual inspection

of the flue gas recirculation

system and its components. The owner/operator

shall retain copies of all fuel supplier certifications

or fuel oil analyses for each calendar

quarter. These records shall be made accessible

for review by the Office of Air Resources

or EPA. This quarterly

record shall include a certified statement,

signed by the owner/operator,

that the records of fuel supplier certifications submitted

represent

all of the fuel combusted

during the quarter. The owner/operator

shall notify the Office of Air Resources

of any anticipated noncompliance with the terms of this permit or any other applicable

air pollution control rules and regulations. The 0wner/operator

shall notify the Office of Air Resources,

in writing, of any noncompliance with the terms of this permit within 30 calendar

days of becoming
aware of such occurrence

and supply the Director

with the following

information:

a. The name and location of the facility; b. The subject source(s)

that caused the noncompliance

with the permit term;

c. The time and date of first observation

of the incident of noncompliance;
Page 4 of 5d. The cause and expected

duration

of the incident of noncompliance;

eo The estimated

rate of emissions

(expressed

in lbs/hr or lbs/day) during the incident and the operating

data and calculations

used in estimating

the emission rate. The proposed

corrective

actions and schedule

to correct the conditions

causing the incidence of noncompliance. All records required

in this permit shall be maintained

for a minimum

of five 'years after the date of each record and shall be made available

to representatives of the Office of Air Resources

upon request.
Fo Other Permit ConditionsTo the extent consistent

with the requirements

of this permit and applicable

federal and state laws, the facility shall be designed,

constructed

and operated

in accordance with the representation

of the facility in the permit application

dated 21 July 2004. Employees of the Office of Air Resources

and its authorized

representatives-shall

be allowed to enter the facility at all times for the purpose of inspecting

any air pollution source, investigation

any condition

it believes may be causing air pollution or examining

any records required

to be maintained

by the Office of Air Resources. At all times, including

periods of startup, shutdown

and malftmction,

the owner/operator shall, to the extent practicable,

maintain

and operate this boiler in a manner consistent

with good air pollution

control practice

for minimizing emissions. Determination

of whether

acceptable

operating

and maintenance procedures are being used will be based on information

available

to the Office of Air Resources

which may include, but is not limited to, monitoring

results, opacity observations,

review of operating

and maintenance

procedures

and inspection of the source. The boiler is subject to the requirements

of the Federal New Source Performance Standards 40 CFR 60, Subparts

A (General

Provisions),

and Dc (SmallIndustrialCommercial-Institutional Steam Generating

Units). Compliance

with all applicable provisions of these regulations

is required.

RogerWilliams fpermit).doc

Page 5 of 519 November

2004

Mr. Marc Marandola Plant ManagerVICTORY FINISHING

TECHNOLOGIES,

INC. 145 Globe StreetProvidence, RI 02903
Dear Mr. Marandola: The Department

of Environmental

Management,

Office of Air Resources

has reviewed

and approved your application

for the installation

of fuel burning equipment

at your facility, located at 145 Globe Street, Providence,

RI. Enclosed is a minor source permit issued pursuant

to our review of your application

(Approval No. 1821).If there are any questions

concerning

this permit, please contact me at 222-2808,

extension

7011. Sincerely,
Douglas L. McVay Associate Supervising

Engineer Office of Air Resources

cc: Providence

Building

OfficialSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES MINOR SOURCE

PERMIT Victory Finishing

Technologies,

Inc.
APPROVAL NO. 1821
Pursuant to the provisions

of Air Pollution

Control Regulation

No. 9, this minor source permit is issued to: Victory Finishing

Technologies,

lnc. For.the following: A Cleaver Brook, v 12.56 MMBtu/hr

boiler: Model No. CBLE 200-300.

The fuel burning equipment shall be •red With either natural gas or No. 2 fuel oil containing

O. 3 percent sulfur, by weight, or less.

Located at: 145 Globe Street, Providence

This permit shall be effective

from the date of its issuance

and shall remain in effect until revoked by or surrendered

to the Department.

This permit does not relieve Victory Finishing Technologies,

Inc. from compliance

with applicable

state and federal air pollution control rules and regulations.

The design, construction

and operation

of this equipment shall be subject to the attached

permit conditions

and emission

limitations.
Stephen Majkut,

Chief Office of Air Resources Date of IssuanceSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES Permit Conditions

and Emission

Limitations Victory Finishing

Technologies,

Inc. Approval No. 1820 Emission Limitations 1. Natural Gas Firing

a. Nitrogen

Oxides (as nitrogen

dioxide (NO2) The. emission

rate of nitrogen

oxides discharged

to the atmosphere

from the boiler shall not exceed 0.036 lbs per million BTU heat input or 0.44 lb/hr, whichever

•s more stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere

from the boiler shall not exceed 0.109 lbs per million BTU heat input or 0.46 lb/hr, whichever

is more stringent.

c. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere from the boiler shall not exceed 0.016 lbs per million BTU heat input or 0.2 lb/hr, whichever

is more stringent. 2. Oil Firing

a. Nitrogen

Oxides (as nitrogen

dioxide (NO2)) The. emission

rate of nitrogen

oxides discharged

to the atmosphere

from the boiler shall not exceed 0.19 lbs per million BTU heat input or 2.33 lbs/hr whichever

is more stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere

from the boiler shall not exceed 0.07 lbs per million BTU heat input or 0.88 Ibs/hr whichever

is more stringent.
Page of 5c. Sulfur Dioxide

(SO2)(i) All fuel burned in the boiler shall contain no more than 0.3 percent sulfur by weight. (ii) The emission

rate of sulfur dioxide discharged

to the atmosphere from the boiler shall not exceed 3.79 lbs/hr. d. Particulate

MatterThe emission

rate of particulate

matter discharged

to the atmosphere

from the boiler shall not exceed 0.024 lbs per million BTU heat input or 0.302 lbs/hr whichever

is more stringent.

e. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere from the boiler shall not exceed 0.03 lbs per million BTU heat input or 0.377 lbs/hr, whichever

is more stringent. Visible emissions

from the boiler exhaust flue shall not exceed 10% opacity (six- minute average).
B. Operating

RequirementsThe maximum

fLring rate of the boiler shall not exceed 89.7 gal/hr of No. 2 fuel oil or 12,440 ft3/hr of natural gas. The flue gas recirculation

system for the boiler shall be in full operation

whenever the boiler is in operation. The owner/operator

shall conduct a complete

annual inspection

of the flue gas recirculation system and its components.

The owner/operator

shall check for proper operation and compare

all internal and external control and drive linkage settings with those established

by Cleaver Brooks. The owner/operator

shall note and correct any deviations

prior to operating

the boiler after each such annual inspection.
C. Continuous

MonitorsContinuous emission

monitoring

equipment

shall be installed,

operated

and maintained for opacity when the boiler is operating

on fuel oil.

Page 2 of 5Natural gas and fuel oil flow for the boiler shall be continuously

measured

and recorded.
Do Fuel Oil TestingCompliance

with fuel oil sulfur limits may be determined

based on a certification from the fuel supplier. 2. Fuel supplier certification

shall include the following

information:

a. The name of the oil supplier; b. The sulfur content of the oil; The location of the oil when the sample was drawn for analysis to determine the sulfur content of the oil; specifically

including

whether

the oil was sampled

as delivered

to Victory Finishing

Technologies,

Inc. or whether the sample was drawn from oil in storage at the oil supplier's

or oil refiner's

facility or another location; d. The method used to determine

the sulfur content of the oil. As an alternative

to fuel supplier certification,

the owner/operator

may elect to sample the fuel prior to combustion.

Sampling

and analysis shall be conducted

for the oil in the initial tank ofoil to be fired in the boiler and after each new shipment ofoil is received.

Samples

shall be collected

from the fuel tank immediately

after the fuel tank is filled and before any oil is combusted. Each fuel supplier certification

or each fuel oil analysis

must demonstrate

that the oil for the Cleaver Brooks boiler contains

0.5 percent sulfur by weight or less. Record Keeping

and Reporting The ownel:/operator

shall notify the Office of Air Resources

in writing of the date of actual start-up of the boiler no later than fifteen days after such date, The owner/operator

shall, on a monthly basis, no later than 5 days after the first of the month, determine

the total quantity

of No. 2 fuel oil and natural gas combusted in the Cleaver Brooks boiler. The owner/operator

shall keep records of this determination and provide such records to the Office of Air Resources

upon request The owner/operator

shall notify the Office of Air Resources

in writing of any planned physical

or operational

change to any equipment

that would:

Page 3 of 5a. Change the representation

of the facility in the application. b. Alter the applicability

of any state or federal air pollution

rules or regulations.

c. Result in the violation

of any terms or conditions

of this permit. d. Qualify as a modification

under APC Regulation

No. 9. Such notification

shall include:

• Information

describing

the nature of the change.

• Information

describing

the effect of the change on the emission

of any air contaminant.

• The scheduled

completion

date of the planned

change. Any such change shall be consistent

with the appropriate

regulation

and have the prior approval

of the Director. The owner/operator

shall maintain

records of the annual visual inspection

of the flue gas recirculation

system and its components. The owner/operator

shall retain copies of all fuel supplier certifications

or fuel oil analyses for each calendar

quarter. These records shall be made accessible

for review by the Office of Air Resources

or EPA. This quarterly

record shall include a certified statement,

signed by the owner/operator,

that the records of fuel supplier certifications submitted

represent

all of the fuel combusted

during the quarter. The owner/operator

shall notify the Office of Air Resources

of any anticipated noncompliance with the terms of this permit or any other applicable

air pollution control rules and regulations. The owner/operator

shall notify the Office of Air Resources,

in writing, of any noncompliance with the terms of this permit within 30 calendar

days of becoming aware of such occurrence

and supply the Director

with the following

information:

a. The name and location of the facility; b. The subject source(s)

that caused the noncompliance

with the permit term;

c. The. time and date of first observation

of the incident of noncompliance; d. The cause and expected

duration

of the incident

of noncompliance;

Page 4 of 5eo The estimated

rate of emissions

(expressed

in lbs/hr or lbs/day) during the incident and the operating

data and calculations

used in estimating

the emission rate. The proposed

corrective

actions and schedule

to correct the conditions

causing the incidence of noncompliance. All records required

in this permit shall be maintained

for a minimum

of five years after the date of 6ach record and shall be made available

to representatives of the Office of Air Resources

upon request. Other1. Permit ConditionsTo the extent consistent

with the requirements

of this permit and applicable

federal and state laws, the facility shall be designed,

constructed

and operated

in accordance with the representation

of the facility in the permit application

dated 5 October 2004. Employees of the Office of Air Resources

and its authorized

representatives

shall be allowed to enter the facility at all times for the purpose of inspecting

any air pollution source, investigation

any condition

it believes may be causing air pollution or examining

any records required

to be maintained

by the Office of Air Resources. At all times, including

periods of starmp, shutdown

and malfunction,

the owner/operator shall, to the extent practicable,

maintain

and operate this boiler in a manner consistent

with good air pollution

control practice for minimizing emissions. Determination

of whether

acceptable

operating

and maintenance procedures are being used will be based on information

available

to the Office of Air Resources

which may include, but is not limited to, monitoring

results, opacity observations,

review of operating

and maintenance

procedures

and inspection of the source. The existing 12.5 MMBtu/hr

York Shipley,

Model EA-300 boiler shall be removed from service and rendered

inoperable

effective

with the startup of the 12.56 MMBtu/hr Cleaver Brooks, Model CBLE 200-300 boiler. The boiler is subject to the requirements

of the Federal New Source Performance Standards 40 CFR 60, Subparts

A (General

Provisions),

and Dc (SmallIndustrialCommercial-Institutional Steam Generating

Units). Compliance

with all applicable provisions of these regulations

is required.
Victory(permit).doc

Page 5 of 526

June 2006Mr. Russell KarianPresidentRuss-Russ Realty/Robin

Rug 125 Thames StreetBristol, RI 02809Dear Mr. Karian:The Department

of Environmental

Management,

Office of Air Resources

has reviewed

and approved your application

for the installation

of fuel burning equipment

at your facility, located at 125 Thames

Street, Bristol, RI. Enclosed is a minor source permit issued pursuant

to our review of your application

(Approval No. 1894).During the course of our review of your application,

we determined

that the fuel burning equipment located at 125 Thames Street was installed

in 1998. Russ-Russ

Realty/Robin

Rug failed to obtain a preconstruction permit prior to the installation

of this equipment

as required by RI Air Pollution Control Regulation

No. 9. Be advised that issuance

of this permit does not limit or otherwise

preclude

the RI DEM from pursuing enforcement

actions to address the violations

stated above. If there are any questions

concerning

this permit, please contact me at 222-2808,

extension

7011. Sincerely,
Douglas L. McVay Associate Supervising

Engineer Office of Air ResourcesSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTALMANAGEMENT OFFICE OF AIR RESOURCES MINOR SOURCE

PERMIT R USS-R USS REAL TY/ROBIN

RUG
APPROVAL NO. 1894
Pursuant to the provisions

of Air Pollution

Control

Regulation

No. 9, this minor source permit is issued to:

Russ-Russ

Realty

Rug For the following:Installation of a Kewanee

150-hp firetube

boiler, Model No. H35-150-G06. The fuel burning equipment

shall be fired with No. 4fuel oil containing

1. O percent sulfur, by weight, or less.

Located at: 125 Thames Street, Bristol

This permit shall be effective

from the date of its issuance

and shall remain in effect until revoked by or surrendered

to the Department.

This permit does not relieve Russ-Russ Realty Rug from compliance

with applicable

state and federal air pollution

control rules and regulations.

The design, construction

and operation

of this equipment

shall be subject to the attached

permit conditions

and emission

limitations.
Stephen Majkut,

Chief Office of Air Resources Date of IssuanceSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES Permit Conditions

and Emission

Limitations RUSS-RUSS REALTY/ROBIN

RUG Approval No. 1894 Emission Limitations 1. Oil Firing

a. Nitrogen

Oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere from the boiler shall not exceed 0.55 lb per million BTU heat input or 3.46 lbs/hr, whichever-is

more stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere from the boiler shall not exceed 0.03 lb per million BTU heat input or 0.21 lbs/hr, whichever

is more stringent.

c. Sulfur Dioxide

(SO2)(1) All fuel burned in the boiler shall contain no more than 1.0 percent sulfur by weight. (2) The emission

rate of sulfur dioxide discharged

to the atmosphere from the boiler shall not exceed 6.36 lbs/hr. d. Particulate

MatterThe emission

rate of particulate

matter discharged

to the atmosphere from the boiler shall not exceed 0.1 lb per million BTU heat input or 0.63 lb/hr, whichever

is more stringent.

e. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere

from the boiler shall not exceed 0.005 lb per million BTU heat input or 0.03 lb/hr, whichever

is more stringent. Page 1 of 5Visible emissions

from the boiler exhaust flue shall not exceed 10% opacity (six-minute

average). Operating RequirementsThe maximum

fn'ing rate of the boiler shall not exceed 42 gal/hr of No. 4 fuel oil.The combined

quantity of 1,0% sulfur residual fuel oil combusted

at this facility shall be limited to 1,300,000

gallons. Residual

fuel oil means No. 4, No. 5 or No. 6 fuel oil. Continuous Monitors 1. Continuous

emission

monitoring

equipment

shall be installed,

operated

and maintained for opacity.
Do Fuel Oil TestingCompliance

with fuel oil sulfur limit may be determined

based on a certification from the fuel supplier. 2. Fuel supplier certification

shall include the following

information:

a. The name of the oil supplier; b. The sulfur and nitrogen

content of the oil;
Co The location of the oil when the sample was drawn for analysis to determine the sulfur and nitrogen

content of the oil; specifically including whether

the oil was sampled

as delivered

to Russ-Russ Realty/Robin Rug or whether

the sample was drawn from oil in storage at the oil supplier's

or oil refiner's

facility or another location;The method used to determine

the sulfur and nitrogen

content of the oil.As an alternative

to fuel supplier certification,

the owner/operator

may elect to sample the fuel prior to combustion.

Sampling

and analysis shall be conducted for the oil in the initial tank ofoil to be fired in the boiler and after each new shipment

of oil is received.

Samples

shall be collected

from the
Page 2 of 5fuel tank immediately

after the fuel tank is filled and before any oil is combusted.Each fuel supplier certification

or each fuel oil analysis must demonstrate that the fuel oil for the boiler contains

1.0 percent sulfur by weight or less.
Eo Record Keeping

and Reporting The owner/operator

shall, on a monthly

basis, no later than 5 days after the first of the month, determine

the total quantity

of residual fuel oil combusted in the boiler. The owner/operator

shall keep records of this determination and provide such records to the Office of Air Resources

upon request.The owner/operator

shall notify the Office of Air Resources

in writing within 30 days, whenever

its fuel usage for the entire facility for any 12 month period exceeds 1,300,000

gallons of residual fuel oil. The owner/operator

shall notify the Office of Air Resources

in writing of any planned physical

or operational

change to any equipment

that would:

a. Change the representation

of the facility in the application. bo Alter the applicability

of any state or federal air pollution

rules or regulations.

c. Result in the violation

of any terms or conditions

of this permit. d. Qualify as a modification

under APC Regulation

No. 9. Such notification

shall include:

• Information

describing

the nature of the change. Information describing

the effect of the change on the emission

of any air. contaminant.

• The scheduled

completion

date of the planned

change. Any such change shall be consistent

with the appropriate

regulation

and have the prior approval

of the Director. The owner/operator

shall retain copies of all fuel supplier certifications

or fuel oil analyses

for each calendar

quarter. These records shall be made accessible for review by the Office of Air Resources

or EPA. This quarterly Page 3 of 5record shall include a certified

statement,

signed by the owner/operator,

that the records of fuel supplier certifications

submitted

represent

all of the fuel combusted during the quarter. The owner/operator

shall notify the Office of Air Resources

of any anticipated noncompliance

with the terms of this permit or any other applicable air pollution

control rules and regulations. The owner/operator

shall notify the Office of Air Resources,

in writing, of any noncompliance

with the terms of this permit within 30 calendar

days of becoming

aware of such occurrence

and supply the Director

with the following information:

a. The name and location of the facility; bo The subject source(s)

that caused the noncompliance

with the permit term;
Co The time and date of first observation

of the incident of noncompliance; d. The cause and expected

duration

of the incident of noncompliance; The estimated

rate of emissions

(expressed

in lbs/hr or lbs/day) during the incident and the operating

data and calculations

used in estimating the emission

rate. f. The proposed

corrective

actions

and schedule

to correct the conditions causing the incidence

of noncompliance. All records required

in this permit shall be maintained

for a minimum

of five years after the date of each record and shall be made available

to representatives of the Office of Air Resources

upon request.
Fo Other Permit ConditionsTo the extent consistent

with the requirements

of this permit and applicable federal .and state laws, the facility shall be designed,

constructed

and operated in accordance

with the representation

of the facility in the permit application dated 10 January 2006. Employees of the Office of Air Resources

and its authorized

representatives shall be allowed to enter the facility.at

all times for the purpose of inspecting any air pollution

source, investigating

any condition

it believes may be
Page 4 of 5causing air pollution

or examining

any records required

to be maintained

by the Office of Air Resources. At all times, including

periods of startup, shutdown

and malfunction,

the owner/operator shall, to the extent practicable,

maintain

and operate this boiler in a manner consistent

with good air pollution

control practice

for minimizing emissions.

Determination

of whether

acceptable

operating and maintenance

procedures

are being used will be based on information available to the Office of Air Resources

which may include, but is not limited to, monitoring

results, opacity observations,

review of operating and maintenance

procedures

and inspection

of the source. 2006/Russ-Russ Realty/Robin

Rug-blr

Page 5 of 52 October 2006Mr. George Papanier BLB Investors,

LLC Lincoln Park Raceway 1600 Louisquisset

Pike Lincoln, RI 02865 Dear Mr. Ahles:The Department

of Environmental

Management,

Division

of Air Resources

has reviewed

and approved your application

for the installation

of fuel burning equipment

at your facility located at 1600 Louisquisset

Pike, Lincoln, RI. Enclosed is a minor source permit issued pursuant to our review of your application

(Approval Nos. 1914-1920).During the.course

of our review of your application,

we determined

that the 1000 kW emergency generator located at 1600 Louisquisset

Pike was installed in February 2005. Lincoln Park Raceway failed to obtain a preconstruction

permit prior to the installation

of this equipment

as required by R1 Air Pollution

Control Regulation

No. 9. The issuance of this minor source permit will now bring Lincoln Park Raceway

into compliance with the requirement,

to obtain a preconstruction

permit. The issuance of this permit does not limit or otherwise

preclude the R/DEM from pursuing enforcement

actions to address the failure to obtain a preconstruction

permit prior to the installation

of the equipment. If there are any questions

concerning

this permit, please contact me at 222-2808,

extension

7011. Sincerely,Douglas L. McVay Associate Supervising

Engineer Office of Air Resources

cc: Lincoln Building

Official David Ahles BLB Eric Epner Fuss & O'NeillSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES MINOR SOURCE

PERMIT LINCOLN PARK RA CEWA Y
APPROVAL NOS. 1914-1920
Pursuant to the provisions

of Air Pollution

Control

Regulation

No. 9, this minor source permit is issued to:

Lincoln Park Raceway For the following:lnxtallation of three(3).lohnxton

Boiler Co. 11.2 MMBtu/hr

hoilers• Model No.PFXT-250- 3X125 W (Approval

Nos. 1914-1916)

three (3) 1500 k W Caterpillar

emergent_

diesel generators, Model No. 3512B; (Approval

Nos. 1917-1919)

and one (1) 1000 k W Caterpillar emergency diesel generator,

Model No. 3508B (Approval

No. 1920). The fuel burning equipment xhall he fired with •6•el oil eont.•inin•

0 0 q% .•,,1•t• hy u,pi•ht, t•v less
Located at: 1600 Louisquisset

Pike, Lincoln This permit shall be effective

from the date of its issuance

and shall remain in effect until revoked by or surrendered

to the Department.

This permit does not relieve Lincoln Park Raceway from compl.iance

with applicable

state and federal air pollution

control rules and regulations. The design, construction

and operation

of this equipment

shall be subject to the attached

permit conditions

and emission

limitations. Stephen Majkut,

Chief Office of Air Resources Date of IssuanceSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES Permit Conditions

and Emission

Limitations LINCOLN PARK RACEWAY APPROVAL NOS. 1914-1920

mo Emission

Limitations 1. Boilers

a. Nitrogen

Oxides (as nitrogen

dioxide (NO2)) .The emission

rate of nitrogen

oxides discharged

to the atmosphere from each boiler shall not exceed 0.14 lb per million BTU heat input or 1.6 lbs/hr, whichever

is more.stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere from each boiler shall not exceed 0.04 lb per million BTU heat input or 0.4 lbs/hr, whichever

is more stringent.

c. Sulfur Dioxide

(SO2)(1) All fuel burned in each boiler shall contain no more than 0.05 percent sulfur by weight. (2) The emission

rate of sulfur dioxide .discharged

to the atmosphere from each boiler shall not exceed 0.58 lbs/hr. d. Particulate

MatterThe emission

rate of particulate

matter discharged

to the atmosphere from each boiler shall not exceed 0.02 lb per million BTU heat input or 0.26 lb/hr, whichever

is more stringent.

e. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere

from each boiler shall not exceed 0.003 lb per million BTU heat input or 0.03 lb/hr, whichever

is more stringent.
Page of 7Visible emissions

from the boiler stack shall not exceed 10% opacity (six-minute

average). Emergency Generators

a. Sulfur DioxideAll diesel fuel burned in each engine/generator

set shall contain no more than 0.05 percent sulfur by weight. bo Visible emissions

from each engine/generator

set shall not exceed t 0% opacity except for a pei'iod or periods aggregating

no more than three minutes

in any one-hour,

This visible emission limitation shall not apply during startup of the engine. Engine startup shall be defined as the first ten minutes of firing following the initiation

of firing. Facility-wide

ao All distillate

or diesel fuel oil burned in any fuel burning device shall contain no more than 0.05% sulfur, by weight.
Bo Operating

Requirements 1, Boilers
a° The maximum

firing rate of each boiler shall not exceed 80 gal/hr of No. 2 fuel oil. b° The owner/operator

shall limit the total combined

quantity

of No, 2 fuel oil combusted

in the boilers to 750,000 gallons or less for any consecutive 12-month

period, Emergency Generators

ao The maximum

firing rate for each 1500 kW engine/generator

set shall not exceed 104 gallons per hour. The maximum

firing rate for the 1000 kW engine/generator

set shall not exceed 72.5 gallons per hour.
Co Each engine/generator

set shall not operate more than 400 hours in any consecutive

12-month

period,

Page 2 of 7Each engine/generator

set shall be operated

only to provide emergency electrical

power in the event of a power outage or for maintenance purposes

to assure that the equipment

is in working order.The engine/generator

sets shall not be used in conjunction

with any utility voluntary

demand reduction

program.
Co Continuous

MonitorsContinuous emission

monitoring

equipment

shall be installed,

operated and maintained

for opacity from the boilers. Each of the emergency

generators

shall be equipped

with non-resetable elapsed time meters to indicate,

in cumulative

hours, the elapsed engine operating time.
Do Fuel Oil TestingCompliance

with the fuel oil sulfur limits may be determined

based on a certification from the fuel supplier.

Fuel supplier

certifications

shall include the following

information:

a. The name of the fuel supplier; bo .The sulfur content of the fuel from which the shipment

came or the shipment itself;
Co The location of the fuel when the sample was drawn for analysis

to determine the sulfur content

of the fuel, specifically

including whether the fuel was sampled

as delivered

to Lincoln

Park Raceway or whether

the sample was drawn from fuel in storage at the fuel supplier's

facility or another location; d. The method used to determine

the sulfur content of the fuel. As an alternative

to fuel supplier

certification,

the owner/operator

may elect to sample the fuel prior to combustion.

Sampling

and analysis

shall be conducted

for the fuel in the initial tank(s) of fuel to be fired in each boiler, generator,

pump engine or hot water heater and after each new shipment of fuel is received.

Samples

shall be collected

from the fuel tank immediately after the fuel tank is filled and before any fuel is combusted.

Page 3 of 7Each fuel supplier

certification

or each fuel oil analysis

must demonstrate that the fuel oil contains

0.05 percent sulfur by weight, or less. Record Keeping

and Reporting The owner/operator

shall, on a monthly

basis, no later than 5 days after the first of the month, determine

the total quantity

of fuel oil combusted

by the boilers during the previous

12 months.

The owner/operator

shall keep records 0fthis determination

and provide such records to the Office of Air Resources upon request. The owner/operator

shall notify the Office of Air Resources

in writing, within 15 days, whenever

the total combined

quantity of fuel oil combusted in the boilers exceeds 750,000 gallons for any consecutive

12 month period. The owner/operator

shall, on a monthly

basis; no later than 5 days after the first of each month, determine

and record the hours of operation

and fuel use for each emergency

generator

during the previous

12 month period. The owner/operator

shall notify the Office of Air Resources,

in writing, within 15 days, whenever

the hours of operation

of any emergency generator exceeds 400 hours for any consecutive

12 month period. The owner/operator

shall, on a monthly

basis, no later than 5 days after the first of each month, determine

and record the hours of operation

and fuel use for the Detroit Diesel Fire Pump engine during the previous

12 month period.The owner/operator

shall notify the Office of Air Resources,

in writing, within 15 days, whenever

the hours of operation

of the Detroit Diesel Fire Pump engine exceeds 500 hours for any consecutive

12 month period. The owner/operator

shall notify the Office of Air Resources,

in writing, of the actual initial start-up of the boilers, no later than 15 days after such date.The owner/operator

shall notify the Office of Air Resources,

in writing, of the date of actual initial start-up of the three 1500 kW engine/generator

sets, no later than 15 days after such date. The owner/operator

shall maintain

copies of all fuel supplier certifications or fuel analyses

and these copies shall be made accessible

for review by the Office of Air Resources

or its authorized

representative

and EPA. These records

shall include

a certified

statement,

signed by the

Page 4 of 711.

12.10. owner/operator

of the facility, that the records represent

all of the fuel combusted at the facility The owner/operator

shall notify the Office of Air Resources

in writing of any planned physical or operational

change to any equipment

that would:

a. Change the representation

of the facility in the application. bo Alter the applicability

of any state or federal air pollution

rules or regulations.

c. Result in the violation

of any terms or conditions

of this permit. d. Qualify as a modification

under APC Regulation

No. 9. Such notification

shall include:

• Information

describing

the nature of the change. Information describing

the effect of the change on the emission

of any air contaminant.

• The scheduled

completion

date of the planned

change. Any such change shall be consistent

with the appropriate

regulation

and have the prior approval

of the Director. The owner/operator

shall notify the Office of Air Resources

of any anticipated noncompliance

with the terms of this permit or any other applicable air pollution

control rules and regulations. The owner/operator

shall notify the Office of Air Resources,

in writing, of any noncompliance

with the terms of this permit within 30 calendar

days of becoming

aware of such occurrence

and supply the Director

with the following information:

a. The name and location

of the facility; bo The subject source(s)

that caused the noncompliance

with the permit term;
Co The time and date of first observation

of the incident of noncompliance; d. The cause and expected

duration

of the incident of noncompliance;

Page 5 of 713. The estimated

rate of emissions

(expressed

in lbs/hr or lbs/day) during the incident and the operating

data and calculations

used in estimating the emission

rate. The proposed

corrective

actions and schedule

to correct the conditions causing the incidence

of noncompliance. All records

required

as a condition

of this approval

must be made available to the Office of Air Resources

or its representative

upon request. These records must be maintained

fora minimum

of five years after the date of each record.
Other Permit ConditionsTo the extent consistent

with the requirements

of this approval

and applicable Federal

and State laws, the fuel burning

equipment

shall be designed, constructed

and operated

in accordance

with the representation of the facility in the permit application. Employees of the Office of Air Resources

and its authorized representatives shall be allowed

to enter the facility at all times for the purpose of inspecting

any air pollution

source, investigating

any condition it believes

may be causing air pollution

or examining

any records required to be maintained

by the Office of Air.Resources. At all times, including

periods of startup, shutdown

and malfunction,

the owner/operator shall, to the extent practicable,

maintain

and operate the facility in a manner consistent

with good air pollution

control practice

for minimizing emissions.

Determination

of whether

acceptable

operating

and maintenance procedures

are being used will be based on information available to the Office of Air Resources

which may include,

but is not limited to, monitoring

results, opacity observations,

review of operating

and maintenance procedures

and inspection

of the source. Operation of the three 1500 kW emergency

generators

shall not commence and operation

of the 1000 kW emergency

generator

shall not continue until the stack height for each of the units is extended

to 30 feet above ground level. Each boiler is subject to the requirements

of the Federal New Source Performance Standards

40 CFR 60, Subparts

A (General

Provisions),

and Dc (Small Industrial-Commercial-Institutional Steam Generating

Units). Compliance with all applicable

provisions

of these regulations

is required.

Page 6 of 7The emission

and dispersion

characteristics

of the three boilers and the four engine/generator sets at the facility shall be consistent

with the parameters used in the air quality modeling

to demonstrate

that the emissions

from the facility do not cause or contribute

to air pollution

in violation

of any national ambient air quality standard.

The Office of Air Resources,

in its sole discretion, may reopen this minor source permit if it determines

that the emission and dispersion

characteristics

have changed

significantly

and that emission limitations

must be revised and/or added to this permit to ensure that the facility does not cause or contribute

to air pollution

in violation

of any national ambient air quality standard.

Page 7 of 712 February

2007
Mr. George C. CarasRaytheon Company 1847 West Main RoadPortsmouth, RI 02871 DearMr. Caras:The Department

of Environmental

Management,

Office of Air Resources,

has reviewed

and approved your application

for the installation

of fuel burning equipment

at your facility located at 1847 West Main Road, Portsmouth. Enclosed is a minor source permit issued pursuant

to our review of your application

(Approval

Nos. 1956-1957).During the course of our review of your application,

we determined

that the fuel burning equipment located at 1847 West Main Road was installed

in 2001 and 2002. Raytheon

Company

failed to obtain a preconstruction

permit prior to the installation

of this equipment

as required

by RI Air Pollution Control Regulation

No. 9. The issuance

of this permit does not limit or otherwise

preclude

the RI DEM from pursuing enforcement actions to address the violations

stated above. If there are any questions

concerning

this permit, please contact me at 222-2808,

extension

7011. Sincerely,Douglas L. McVay Associate Supervising

Engineer Office of Air Resources

cc: Portsmouth

Building

OfficialSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES
MINOR SOURCE

PERMIT RAYTHEON COMPANY
APPROVAL NOs. 1956-1957
Pursuant to the provisions

of Air Pollution

Control

Regulation

No. 9, this minor source permit is issued to: Raytheon

Company
For the following:Installation of a Cleaver Brooks Model CBI-200-200

boiler in the Nimitz Building

to be fired with either natural gas or No. 2fuel oil containing

0.3 percent sulfur, by weight, or less (Approval

No. 1956). Installation

of a Cleaver Brooks Model CEW-200-200

boiler in the Providence

Building
to be fired with either natural gas or No. 2fuel oil containing

0.3percent

sulfur, by weight, or less (Approval No. 1957).

Located at: Raytheon

Company This permit shah be effective

from the date of its issuance

and shall remain in effect until revoked by or surrendered

to the Department.

This permit does not relieve. Raytheon Company from compliance

with applicable

state and federal air pollution

control rules and. regulations. The design, construction

and operation

of this equipment

shall be subject to the attached permit conditions

and emission

limitations. Stephen Majkut,

Chief Office of Air Resources Date of IssuanceSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES Permit Conditions

and Emission

Limitations RAYTHEON COMPANY APPROVAL NOs. 1956-1957 Emission LimitationsThe following

emission

limitations

are applicable

to the Cleaver Brooks Model No. CBI-200-200

boiler (B001) located in the Nimitz Building

(Building

No. 1).

a. Natural Gas Firing(1) Nitrogen

oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere from the boiler shall not exceed 0.10 lb per million BTU heat input or 0.82 lb/hr, whichever

is more stringent. (2) Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere from the boiler shall not exceed 0.08 lb per million BTU heat input or 0.69 lb/hr, whichever

is more stringent. (3) Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of to•al nonmethane

hydrocarbons

discharged

to the atmosphere

from the boiler shall not exceed 0.006 lb per million BTU heat input or 0.04 lb/hr, whichever

is more stringent. b. Oil Firing(1) Nitrogen

Oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere from the boiler shall not exceed 0.14 lb per million BTU heat input or 1.16 lb/hr, whichever

is more stringent.

Page of 6(2) Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere from the boiler shall not exceed 0.036 lb per million BTU heat input
or 0.29 lb/hr, whichever

is more stringent. (3) Sulfur Dioxide

(SO2)(a) All fuel burned in the boiler shall contain no more than 0.3 percent sulfur by weight. The emission

rate of sulfur dioxide discharged

to the atmosphere from the boiler shall not exceed 2.47 lbs/hr. (4) Particulate

MatterThe emission

rate of particulate

matter discharged

to the atmosphere from the boiler shall not exceed 0.024 lb per million BTU heat input
or 0.19 lb/hr, whichever

is more stringent. (5) Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane.hydrocarbons discharged

to the atmosphere

from the boiler shall not exceed 0.001 lb per million BTU heat input or 0.012 lb/hr, whichever

is more stringent. The following

emission

limitations

are applicable

to the Cleaver Brooks Model No. CEW-200-200

boiler (B006) located in the Providence

Building

(Building No. 2).

a. Natural Gas Firing(1) Nitrogen

oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere from the boiler shall not exceed 0.10 lb per million BTU heat input
or 0.84 lb/hr, whichever

is more stringent. (2) Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere from the boiler Shall not exceed 0.08 lb per million BTU heat input
or 0.70 lb/hr, whichever

is more stringent.

Page 2 of 6(3) Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere

from the boiler shall not exceed 0.006 lb per million BTU heat input or 0.05 lb/hr, whichever

is more stringent. b. Oil Firing(1) Nitrogen

Oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere from the boiler shall not exceed 0.14 lb per million BTU heat input or 1.20 lb/hr, whichever

is more stringent. (2) Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere from the boiler shall not exceed 0.036 lb per million BTU heat input or 0.30 lb/hr, whichever

is more stringent. (3) Sulfur Dioxide

(SO2)(a) All fuel burned in the boiler shall contain no more than 0.3 percent sulfur by weight. The emission

rate of sulfur dioxide discharged

to the atmosphere from the boiler shall not exceed 2.56 lbs/hr. (4) Particulate

MatterThe emission

rate of particulate

matter discharged

to the atmosphere from the boiler shall not exceed 0.024 lb per million BTU heat input or 0.20 lb/hr, whichever

is more stringent. (5) Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere

from the boiler shall not exceed 0.001 lb per million BTU heat input or 0.012 lb/hr, whichever

is more stringent. Visible emissions

from each boiler stack shall not exceed 10% opacity (6-minute average).

Page 3 of 6Co

E° Operating

RequirementsThe maximum

firing rate of B001 shall not exceed 8,164 ff3/hr of natural gas or 58 gal/hr of No. 2 fuel oil. The maximum

firing rate of B006 shall not exceed 8,369 ft3/hr of natural gas or 60 gal/hr of No. 2 fuel oil. Continuous MonitorsContinuous emission

monitoring

equipment

shall be installed,

operated

and maintained for opacity when the boilers are operating

on fuel oil. Fuel Oil TestingCompliance

with the fuel oil sulfur limits maybe determined

based on a certification from the fuel supplier.

Fuel supplier certifications

shall include the following information:

a. The. name of the fuel supplier; b° The sulfur content of the fuel from which the shipment

came or the shipment itself;
Co The location of the fuel when the sample was drawn for analysis to determine the sulfur content of the fuel; specifically

including

whether

the fuel was sampled

as delivered

to Raytheon

Company

or whether

the sample was drawn from fuel in storage at the fuel supplier's

facility or another location; d. The method used to determine

the sulfur content of the fuel. As an alternative

to fuel supplier certification,

the owner/operator

may elect to sample the fuel prior to combustion.

Sampling

and analysis

shall be conducted for the fuel in the initial tank(s) of fuel to be fired in each fuel burning device and after each new shipment

of fuel is received.

Samples

shall be collected

from the fuel tank immediately

after the fuel tank is filled and before any fuel is combusted.Each fuel supplier certification

or each fuel oil analysis must demonstrate

that the oil contains

0.3 percent sulfur by weight or less. Record Keeping

and Reporting The owner/operator

shall, on a monthly

basis, no later than 5 days after the first of the month, determine

the total quantity

of No. 2 fuel oil and natural gas combusted in each boiler. The owner/operator

shall keep records of this Page 4 of 6determination and provide such records to the Office of Air Resources

upon request.The owner/operator

shall retain copies of all fuel supplier certifications

for each calendar quarter. These records shall be made accessible

for review by the Office of Air Resources

or EPA. This quarterly

record shall include a certified

statement, signed by the owner/operator,

that the records of fuel supplier certifications submitted represent

all of the fuel combusted

during the quarter. The owner/operator

shall notify the Office of Air Resources

in writing of any planned physical

or operational

change to any equipment

that would:

a. Change the representation

of the facility in the application. Alter the applicability

of any state or federal air pollution

rules or regulations.

c. Result in the violation

of any terms or conditions

of this permit. d. Qualify as a modification

under APC Regulation

No. 9. Such notification

shall include: Information describing

the nature of the change. Information describing

the effect of the change onthe emission

of any air contaminant.

• The scheduled

completion

date of the planned change. Any such change shall be consistent

with the appropriate

regulation

and have the prior approval

of the Director. The. owner/operator

shall notify the Office of Air Resources

of any anticipated noncompliance with the terms of this permit or any other applicable

air pollution control rules and regulations. The owner/operator

shall notify the Office of Air Resources,

in writing, of any noncompliance with the terms of this permit within 30 calendar

days of becoming aware of such occurrence

and supply the Director

with the following

information:

a, The name and location of the facility; b. The subject source(s)

that caused the noncompliance

with the permit term;

c. The time and date of first observation

of the incident of noncompliance;

Page 5 of 6d. The cause and expected

duration

of the incident of noncompliance; The estimated

rate of emissions

(expressed

in lbs/hr or lbs/day) during the incident and the operating

data and calculations

used in estimating

the emission rate;The proposed

corrective

actions and schedule

to correct the conditi6ns causing the incidence

of noncompliance. All records required

in .this permit shall be maintained

for a minimum

of five years after the date of each record and shall be made available

to representatives

of the Office of Air Resources

upon request. Other Permit ConditionsTo the extent consistent

with the requirements

of this permit and applicable

federal and state laws, the facility shall be designed,

constructed

and operated

in accordance with the representation

of the facility in the permit application. Employees of the Office of Air Resources

and its authorized

representatives

shall be allowed to enter the facility at all times for the purpose

of inspecting

any air pollution source, investigating

any condition

it believes

may be causing air pollution or examining

any records.required

to be maintained

by the Office of Air Resources.At all times, including.periods

of startup, shutdown

and malfunction,

the owner/operator shall, to the extent practicable,

maintain

and operate the boilers identified in this permit in a manner consistent

with good air pollution

control practice for minimizing

emissions.

Determination

of whether

acceptable operating and maintenance

procedures

are being used will be based on information available

to the Office of Air Resources

which may include, but is not limited to, monitoring

results, opacity observations,

review of operating

and maintenance procedures

and inspection

of the source.

PCMIN-RAYTHEON

06

Page 6 of 66June 2007

Mr. George C. CarasRaytheon Company 1847 West Main RoadPortsmouth, RI 02871 Dear Mr. Caras:The Department

of Environmental

Management,

Office of Air Resources,

has reviewed

and approved your application

for the installation

of fuel burning equipment

at your facility located at 1847 West Main Road, Portsmouth. Enclosed is a minor sourcepermit

issued pursuant

to our review of your application

(Approval

No. 1988).If there are any questions

concerning

this permit, please contact me at 222-2808,

extension

7011. Sincerely,Douglas L. McVay Associate Supervising

Engineer Office of Air Resources

cc: Portsmouth

Building

OfficialSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES
MINOR SOURCE

PERMIT RAYTHEON COMPANY
APPROVAL NO. 1988
Pursuant to the provisions

of Air Pollution

Control

Regulation

No. 9, this minor source permit is issued to: Raetheon

Company For the following:Installation of a Cleaver Brooks Model CE(LE) 200-125-125

boiler in the Nimitz West (1 W) Building to be.fired with either natural gas or No. 2fuel oil containing

0.3 percent sulfur, by weight,

or less.

Located at: Raytheon

Company This permit shall be effective

from the date of its issuance

and shall remain in effect until revoked by or surrendered

to the Department.

This permit does not relieve Raytheon Company from compliance

with applicable

state and federal air pollution

control rules and regulations. The design, construction

and operation

of this equipment

shall be subject to the attached permit conditions

and emission

limitations.
Stephen Maj kut, Chief Office of Air Resources Date of IssuanceSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES Permit Conditions

and Emission

Limitations RAYTHEON COMPANY APPROVAL NO. 1988 Emission Limitations 1. Natural Gas Firing

a. Nitrogen

oxides (as nitrogen dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere

from the boiler shall not exceed 0.035 lb per million BTU heat input or 0.18 lb/hr, whichever is more stringent. b. Carbon Monoxide

(CO) The. emission

rate of carbon monoxide

discharged

to the atmosphere

from the boiler shall not exceed 0.11 lb per million BTU heat input or 0.19 lb/hr, whichever is more stringent.

c. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere from the boiler shall not exceed 0.02 lb per million BTU heat input or 0.08 lb/hr, whichever

is more stringent. 2. Ftml Oil Firing

a. Nitrogen

Oxides (as nitrogen dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere

from the boiler shall not exceed 0.19 lb per million BTU heat input or 0.97 lb/hr, whichever is more stringent. b. Carbon Monoxide

(CO) The. emission

rate of carbon monoxide

discharged

to the atmosphere

from the boiler shall not exceed 0,07 lb per million BTU heat input or 0.37 lb/hr, whichever is more stringent.

Page

of 5c. Sulfur Dioxide

(S02)(1) All fuel burned in the boiler shall contain no more than 0.3 percent sulfur by weight. (2) The emission

rate of sulfur dioxide discharged

to the atmosphere from the boiler shall not exceed 1.54 lbs/hr. d. Particulate

MatterThe emission

rate of particulate

matter discharged

to the atmosphere

from the boiler shall not exceed 0.02 lb per million BTU heat input or 0.13 lb/hr, whichever is more stringent.

e. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere from the boiler shall not exceed 0.03 lb per million BTU heat input or 0.16 lb/hr, whichever

is more stringent. Visible emissions

from the boiler stack shall not exceed 10% opacity (6-minute average). B. Operating

RequirementsThe maximum

firing rate of the boiler shall not exceed 5,230 t•3/hr of natural gas or 36.4 gal/hr of No. 2 fuel oil. C. Continuous

MonitorsContinuous emission

monitoring

equipment

shall be installed,

operated

and maintained for opacity when the boiler is operating

on fuel oil. D. Fuel Oil TestingCompliance

with the fuel oil sulfur limits may be determined

based on a certification from the fuel supplier.

Fuel supplier certifications

shall include the following information:

a. The name of the fuel supplier; b° The sulfur content of the fuel from which the shipment

came or the shipment itself;
Co The location of the fuel when the sample was drawn for analysis to determine the sulfur content of the fuel, specifically

including

whether

the
Page 2 of 5Eo fuel was sampled

as delivered

to Raytheon

Company

or whether

the sample was drawn from fuel in storage at the fuel supplier's

facility or another location; d. The method used to determine

the sulfur content of the fuel. As an alternative

to fuel supplier certification,

the owner/operator

may elect to sample the fuel prior to combustion.

Sampling

and analysis

shall be conducted for the fuel in the initial tank(s) of fuel to be fired in each fuel burning device and after each new shipment

of fuel is received.

Samples

shall be collected

from the fuel tank immediately

after the fuel tank is filled and before any fuel is combusted.Each fuel supplier certification

or each fuel oil analysis must demonstrate

that the oil contains

0.3 percent sulfur by weight or less. Record Keeping

and Reporting The owner/operator

shall, on a monthly

basis, no later than 5 days after the first of the month, determine

the total quantity

of No. 2 fuel oil and natural gas combusted in the boiler. The owner/operator

shall keep records of this determination and provide such records to the Office of Air Resources

upon request.The owner/operator

shall retain copies of all fuel supplier certifications

for each calendar quarter. These records shall be made accessible

for review by the Office of Air Resources

or EPA. This quarterly

record shall include a certified

statement, signed by the owner/operator,

that the records of fuel supplier certifications submitted represent

all of the fuel combusted

during the quarter. The owner/operator

shall notify the Office of Air Resources

in writing of the date of actual initial start-up of the boiler no later than fifteen days after such date. The owner/operator

shall notify the Office of Air Resources

in writing of any planned physical

or operational

change to any equipment

that would:

a. Change the representation

of the facility in the application. bo Alter the applicability

of any state or federal air pollution

rules or regt•lations.

c. Result in the violation

of any terms or conditions

of this permit. d. Qualify as a modification

under APC Regulation

No. 9. Such notification

shall include:
Page

3 of 5• Information

describing

the nature of the change.

• Information

describing

the effect of the change on the emission

of any air contaminant.

• The scheduled

completion

date of the planned change. Any such change shall be consistent

with the appropriate

regulation

and have the prior approval

of the Director. 5. The owner/operator

shall notify the Office of Air Resources

of any anticipated noncompliance with the terms of this permit.or

any othei" applicable

air pollution control rules and regulations. 6. The owner/operator

shall notify the Office of Air Resources,

in writing, of the date of removal of the existing Cleaver Brooks boiler in the Nimitz West Building

no later than fifteen days after such date. 7. The owner/operator

shall notify the Office of Air Resources,

in writing, of any noncompliance with the terms of this permit within 30 calendar

days of becoming aware of such occurrence

and supply the Director

with the following

information:

a. The name and location of the facility; b. The subject source(s)

that caused the noncompliance

with the permit term;

c. The time and date of first observation

of the incident of noncompliance; d. The cause and expected

duration

of the incident of noncompliance;

e. The estimated

rate of emissions

(expressed

in lbs/hr or lbs/day) during the incident and the operating

data and calculations

used in estimating

the emission rate; f. The proposed

corrective

actions and schedule

to correct the conditions causing the incidence

of noncompliance. 8. All records required

in this permit shall be maintained

for a minimum

of five years after the date of each record and shall be made available

to representatives

of the Office 0fAir Resources

upon request. Other Permit Conditions 1. To the extent consistent

with the requirements

of this permit and applicable

federal and state laws, the facility shall be designed,

constructed

and operated

in accordance with the representation

of the facility in the permit application.
Page 4 of 5Employees of the Office of Air Resources

•nd its authorized

representatives

shall be allowed .to enter the facility at all times for the purpose of inspecting

any air pollution source, investigating

any condition

it believes

may be causing air pollution or examining

any records required

to be maintained

by the Office of Air Resources.At all times, including

periods of startup, shutdown

and malfunction,

the owner/operator shall, to the extent practicable,

maintain

and operate the boilers identified in this permit in a manner consistent

with good air pollution

control practice for minimizing

emissions.

Determination

of whether

acceptable operating and maintenance

procedures

are being used will be based on information available

to the Office of Air Resources

which may include, but is not limited to, monitoring

results, opacity observations,

review of operating

and maintenance procedures

and inspection

of the source. The existing Cleaver Brooks boiler (Serial No. L-80232)

in the Nimitz West Building shall be removed

from service or rendered

inoperable

on or before the startup of the new boiler (Approval

No. 1988).

Page 5 of 529 August 2007
Mr. Mark BlaisFoam Technology/Symmetry Products 55 Industrial

CircleLincoln, 1ti 02865 Dear Mr. Blais:The Department

of Environmental

Management,

Office of Air Resources,

has reviewed

and approved your application

for the operation

of fuel burning equipment

at your facility located at 55 Industrial Circle, Lincoln. Enclosed is a minor source permit issued pursuant

to our review of your application

(Approval

No. 2005).During the course of our review of your application,

we determined

that the 150 HP Cleaver Brooks boiler located at 55 Industrial

Circle was installed in November

2006. Foam Technology

failed to obtain a preconstruction

permit prior to the installation

of this equipment

as required by RI Air Pollution Control Regulation

No. 9. The issuance

of this minol source permit will now bring Foam Technology

into compliance

with the requirement

to obtain a preconstruction

permit. The issuance

of this permit does not limit or otherwise preclude

the RI DEM from pursuing

enforcement

actions to address the failure to obtain a preconstruction

permit prior to the installation

of the equipment. If there are any questions

concerning

this permit, please contact me at 222-2808,

extension

7011. Sincerely,Douglas L. McVayAssociate Supervising

Engineer Office of Air Resources

cc: Lincoln Building

OfficialSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES
MINOR SOURCE

PERMIT FOAM TECHNOLOGY
APPROVAL NO. 2005
Pursuant to the provisions

of Air Pollution

Control

Regulation

No. 9, this minor source permit is issued to: Foam Technology
For the following:Operation of a Cleaver Brooks 150 hp, Model CB-200-150

boiler fired with 17o. 2fuel oil containing 0.3percent

sulfur, by weight, or less.

Located at: 55 Industrial

Circle, Lincoln This permit shall be effective

from the date of its issuance

and shall remain in effect until revoked by or surrendered

to the Department.

This permit does not relieve Foam Technology from compliance

with applicable

state and federal air pollution

control rules and regulations. The design, construction,

and operation

of this equipment

shall be subject to the attached permit conditions

and e•nission

limitations.
Stephen Majkut,

Chief Office of Air Resources Date of IssuanceAo STATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES Permit Conditions

and Emission

Limitations FOAM TECHNOLOGY APPROVAL NO. 2005 Emission Limitations 1. Fuel Oil Firing

a. Nitrogen

Oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere

from the Cleaver-Brooks boiler shall not exceed 0.25 lb per million BTU heat input or 1.57 lb/hr, whichever

is more stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere

from the Cleaver-Brooks

boiler shall not exce•xl 0.07 lb per million BTU heat input or 0.44 lb/hr, whichever

is more stringent.

c. Sulfur Dioxide

(SO2)(0 All fuel burned in the Cleaver-Brooks

boiler shall contain no more than 0.3 percent sulfur by weight. (2) The emission

rate of sulfur dioxide discharged

to the atmosphere from the Cleaver-Brooks

boiler shall not exceed 1.94 lbs/hr. d. Particulate

MatterThe emission

rate of particulate

matter discharged

to the atmosphere

from the Cleaver-Brooks

boiler shall not exceed 0.025 lb per million BTU heat input or 0.16 lb/hr, whichever

is more stringent.

e. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere from the Cleaver-Brooks

boiler shall not exceed 0.025 lb per million BTU heat input or 0.16 lb/hr, whichever

is more stringent.

Page 5 of 5Bo

EoD° Visible emissions

from the Cleaver-Brooks

boiler stack shall not exceed 10% opacity (6-minute

average). Operating RequirementsThe maximum

firing rate of the Cleaver-Brooks

boiler shall not exceed 45 gal/hr of No. 2 fuel oil. Continuous MonitorsContinuous emission

monitoring

equipment

shall be installed,

operated

and maintained for opacity when the Cleaver-Brooks

boiler is operating

on fuel oil. Fuel Oil TestingCompliance

with the fuel oil sulfur limits may be determined

based on a certification from the fuel supplier.

Fuel supplier certifications

shall include the following information:

a. The name of the fuel supplier; b° The sulfur content of the fuel from which the shipment

came or the shipment itself;
Co The location of the fuel when the sample was drawn for analysis to determine the sulfur content of the fuel, specifically

including

whether

the fuel was sampled

as delivered

to Foam Technology

or whether

the sample was. drawn from fuel in storage at the fuel supplier's

facility or another location;d. The method used to determine

the sulfur content of the fuel. As an alternative

to fuel supplier certification,

the owner/operator

may elect to sample the fuel prior to combustion.

Sampling

and analysis

shall be conducted for the fuel 'in the initial tank(s) of fuel to be fired in each fuel burning device and after each new shipment

of fuel is received.

Samples

shall be collected

from the fuel tank immediately

after the fuel tank is filled and before any fuel is combusted.Each fuel supplier certification

or each fuel oil analysis must demonstrate

that the oil contains

0.3 percent sulfur by weight or less. Record Keeping

and Reporting The owner/operator

shall, orl a monthly

basis, no later than 5 days after the first of the month, determine

the total quantity

of No. 2 fuel oil combusted

in theCleaverPage 5 of 5Brooks boiler. The owner/operator

shall keep records of this determination

and provide such records to the Office of Air Resources

upon request. The owner/operator

shall retain copies of all fuel supplier certifications

for each calendar quarter. These records shall be made accessible

for review by the Office of Air Resources

or EPA. This quarterly

record shall include a certified

statement, signed by the owner/operator,

that the records of fuel supplier certifications submitted represent

all of the fuel combusted

at the facility during the quarter. The owner/0perator

shall notify the Office of Air Resources

in writing of any planned physical

or operational

change to any equipment

that would:

a. Change the representation

of the facility in the application. Alter the applicability

of any state or federal air pollution

roles or rega4.1ations.

c. Result in the violation

of any terms or conditions

of this permit, d. Qualify as a modification

under APC Regulation

No. 9. Such notification

shall include:

• Information

describing

the nature of the change. Information describing

the effect of the change on the emission

of any air contaminant.

• The. scheduled

completion

date of the planned change. Any such change shall be consistent

with the appropriate

regulation

and have the prior approval

of the Director. The owner/operator

shall notify the Office of Air Resources

of any anticipated noncompliance with the terms of this permit or any other applicable

air pollution control rules and regulations. The owner/operator

shall notify the Office of Air Resources,

in writing, of any noncompliance with the terms of this permit within 30 calendar

days of becoming aware of such occurrence

and supply the Director

with the following

information:

a. The name and location of the facility; b. The subject source(s)

that caused the noncompliance

with the permit term;

c. The time and date of first observation

of the incident of noncompliance;

Page 5 of 5d. The cause and expected

duration

of the incidentof

noncompliance; The estimated

rate of emissions

(expressed

in lbs/hr or lbs/day) during the incident and the operating

data and calculations

used in estimating

the emission rate;The proposed

corrective

actions and schedule

to correct the conditions causing the incidence

of noncompliance. All records required

in this permit shall be maintained

for a minimum

of five years after the date of each record and shall be made available

to representatives

of the Office of Air Resources

upon request. Other Permit ConditionsTo the extent consistent

with the requirements

of this permit and applicable

federal and state laws, the facility shall be designed,

constructed

and operated

in accordance with the representation

of the facility in the permit application. Employees of the Office of Air Resources

and its authorized

representatives

shall be allowed to enter the facility at all times for the purpose of inspecting

any air pollution source, investigating

any condition

it believes

may be causing air pollution or examining

any records required

to be maintained

by the Office of Air Resources.At all times, including

periods of startup, shutdown

and malfunction,

the owner/operator shall, to the extent practicable,

maintain

and operate the boiler identified in this permit in a manner consistent

with good air pollution

control practice for m•nimizing

emissions.

Determination

of whether

acceptable operating and maintenance

procedures

are being used will be based on information available

to the Office of Air Resources

which may include, but is not limited to, monitoring

results, opacity observations,

review of operating

and maintenance procedures

and inspection

of the source.

Page 5 of 523 March 2007
Mr. Wayne Boisvert VP ManufacturingMurdock Webbing

Co., Inc. 27 Foundry StreetCentral Falls, RI 02863 Dear Mr. Boisvert: The Department

of Environmental

Management,

Office of Air Resources,

has reviewed

and approved your application

for the installation

of fuel burning equipment

at your facility located at 27 Foundry Street, Central Falls. Enclosed is a 1/linor source permit issued pursuant to our review of your application

(Approval

No. 1968).During the course of our review of your application,

we determined

that the boiler was installed in 2006. Murdock

Webbing

Co., Inc. failed to obtain a preconstmction

permit prior to the installation of this equipment

as required by RI Air Pollution

Control Regulation

No. 9. The issuance of this minor source permit will now bring Murdock

Webbing

Co., Inc. into compliance with the requirement

to obtain a preconstrucfion

permit for this boiler. The issuance of this permit does not limit or otherwise

preclude the RI DEM from pursuing

enforcement actions to address the failure to obtain a preconstruction

permit prior to the installation

of the boiler.If there are any questions

concerning

this permit, please contact me at 222-2808,

extension

7011. Sincerely,
Douglas L. McVayAssociate Supervising

Engineer Office of Air Resources

cc: Central Falls Building OfficialSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES MINOR SOURCE

PERMIT MU•OCK WEBBING

CO., INC.
APPROVAL NO. 1968
Pursuant to the provisions

of Air Pollution

Control Regulation

No. 9, this minor source permit is issued to:

Murdock

Webbing

Co., Inc. For the following:Installation of a Cleaver Brooks 16. 7 MMBtu/hr

firetube

boiler, Model No. CB-400-400-150ST. The boiler shall be fired with natural gas or No. 6fuel oil containing 0.5percent

sulfur, by weight, or less.

Located at: 27Foundry

Street, Central Falls

This permit shall be effective

from the date of its issuance

and shall remain in effect until revoked

by or surrendered

to the Department.

This permit does not relieve Murdock Webbing

Co., Inc. from compliance

with applicable

state and federal air pollution control rules and regulations.

The design, construction

and operation

of this equipment shall be subject to the attached

permit conditions

and emission

limitations.
Stephen Majkut,

Chief Office of Air Resources Date of issuanceSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES Permit Conditions

and Emission

Limitations Murdock Webbing

Co., Inc. APPROVAL NO. 1968

mo Emission

Limitations 1. Natural Gas Firing

a. Nitrogen

Oxides (as nitrogen dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere fi'om the boiler shall not exceed 0.12 lb per million BTU heat input or 1.96 lb/hr, whichever

is more stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere from the boiler shall not exceed 0.15 lb per million BTU heat input or 2.45 lbs/hr, whichever

is more stringent.

c. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere

from the boiler shall not exceed 0.016 lb per million BTU heat input or 0.26 lb/hr, whichever

is more stringent. 2. Fuel Oil Firing

a. Nitrogen

Oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere from the boiler shall not exceed 0.50 lb per million BTU heat input or 8.36 lbs/hr, whichever

is more stringent.

Page bf 5Bo b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere from the boiler shall not exceed 0.075 lb per million BTU heat input or 1.25 lbs/hr, whichever

is more stringent.

c. Sulfur Dioxide

(SOz)(1) All fuel burned in the boiler shall contain no more than 0.5 percent sulfur by weight. (2) The emission

rate of sulfur dioxide discharged

to the atmosphere from the boiler shall not exceed 8.86 lbs/hr. d. Particulate

MatterThe emission

rate of particulate

matter discharged

to the atmosphere from the boiler shall not exceed 0.1 lb per million BTU heat input or 1.67 lb/hr, whichever

is more stringent.

e. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere

from the boiler shall not exceed 0.035 lb per million BTU heat input or 0.58 lb/hr, whi6hever

is more stringent. 3. Visible emissions

from the boiler exhaust flue shall not exceed 10% opacity (6-minute

average). Operating Requirements 1. The maximum

firing rate of the boiler shall not exceed 111.5 gal/hr of No.6 fuel oil or 16,329 ft3/hr of natural gas. 2. The owner/operator

shall limit the combined

quantity

of No. 6 fuel oil and natural gas combusted

in the boiler to comply with the 1,250,000

gallon facility-wide cap limit of No. 6 fuel oil equivalents

or less for any consecutive 12 month period contained

in the facility's

Emission

Cap.

Page 2 of 5Co Continuous

Monitors 1. Continuous

emission

monitoring

equipment

shall be installed,

operated and maintained

for opacity when the boiler is operating

on fuel oil. 2. Natural gas and fuel oil flow for the boiler shall be continuously

measured and recorded.
Fuel Oil TestingCompliance

with fuel oil sulfur limits may be determined

based on a certification from the fuel supplier. 2. Fuel supplier certification

shall include the following

information:

a. The name of the oil supplier; bo The sulfur content of the fuel oil from which the shipment

came or of the shipment

itself; The location of the oil when the sample was drawn for analysis to determine the sulfur content of the oil, specifically

including

whether the oil was sampled as delivered

to Murdock

Webbing

Co., Inc. or whether the sample was drawn from oil in storage at the oil suppliers/refiners facility or another location; d. The method used to determine

the sulfur content of the oil. As an alternative

to fuel supplier certification,

the owner/operator

may elect to sample the fuel prior to combustion.

Sampling

and analysis

shall be conducted

for the oil in the initial tank of oil to be fired in the boiler and after each new shipment

of oil is received.

Samples

shall be collected from the fuel tank immediately

after the fuel tank is filled and before any oil is combusted.Each fuel supplier certification

or each fuel oil analysis must demonstrate that the oil for the boiler contains

0.5 percent sulfur by weight or less. Record Keeping

and Reporting The owner/operator

shall, on a monthly

basis, no later than 5 days after the first of the month, determine

the fuel use in the boiler for the previous

12 months. The owner/operator

shall keep records of this determination

and provide such records to the Office of Air Resources

upon request.

All fuel combusted in the boiler shall be included

in the determination

of fuel use Page 3 of 5for the entire facility under Condition

D. 1 of Murdock

Webbing Company's emission

cap. The owner/operator

shall notify the Office of Air Resources

in writing of any physical

or operational

change to any equipment

that would:

a. Change the representation

of the facility in the application. Alter the applicability

of any state of federal air pollution

rules or regulations.

Co Result in the violation

of any terms or conditions

of this permit. d. Qualify as a modification

under APC Regulation

No. 9. Such notification

shall include:

• Information

describing

the nature of the change. Information describing

the effect of the change on the emission

of any air contaminant.

• The scheduled

completion

date of the planned change. Any such change shall be consistent

with the appropriate

regulation

and have the prior approval

of the Director. The owner/operator

shall maintain

copies of all fuel supplier certifications or fuel analyses

and these copies shall be made accessible

for review by the Officeof

Air Resources

or its authorized

representative

and EPA. These records shall include a certified

statement,

signed by the owner/operator of the facility, that the records represent

all of the fuel combusted in the boiler. The owner/operator

shall notify the Office of Air Resources

of any anticipated noncompliance

with the terms of this permit or any other applicable air pollution

control rules and regulations. The owner/operator

shall notify the Office of Air Resources,

in writing, of any noncompliance

with the terms of this permit within 30 calendar

days of becoming

aware of such occurrence

and supply the Director

with the following information:

a. The name and location of the facility;

Page 4 of 5Fo Other1. bo The subject source(s)

that caused the noncompliance

with the permit term;
Co The time and date of first observation

of the incident of noncompliance; d. The cause and expected

duration

of the incident of noncompliance; The estimated

rate of emissions

(expressed

in lbs/hr or lbs/day) during the incident and the operating

data and calculations

used in estimating the emission

rate; f. The proposed

corrective

actions and schedule

to correct the conditions causing the incidence

of noncompliance. All records required

in this permit shall be maintained

for a minimum

of five years after the date of each record and shall be made available

to representatives of the Office of Air Resources

upon request. Permit ConditionsTo the extent consistent

with the requirements

of this approval

and applicable federal and state laws, the facility shall be designed, constructed and operated

in accordance

with the representation

of the facility in the permit application. Employees of the Office of Air Resources

and its authorized representatives shall be allowed to enter the facility at all times for the purpose of inspecting

any air pollution

source, investigating

any condition it believes

may be causing air pollution

or examining

any records required to be maintained

by the Office of Air Resources. At all times, including

periods of startup, shutdown

and malfunction,

the owner/operator shall, to the extent practicable,

maintain

and operate the facility in a maimer consistent

with good air pollution

control practice,

for minimizing emissions.

Determination

of whether

acceptable

operating

and maintenance procedures

are being used will be based on information available to the Office of Air Resources

which may include, but is not limited to, monitoring

results, opacity observations,

review of operating and maintenance

procedures

and inspection

of the source.. The boiler is subject to the requirements

of the Federal New Source Performance Standards

§ 40 CFR 60, Subparts

A (General

Provisions)

and Dc (Small Industrial-Commercial-Institutional steam Generating

Units). Compliance with all applicable

provisions

of these regulations

is required.

Page 5 of 519 March 2003Mr. Richard A. Leach Plant EngineerMicrofibres, Inc.1 Moshassuck

StreetPawtucket, RI 02862-1208
Dear Mr. Leach:The Department

of Environmental

Management,

Office of Air Resources

has reviewed and approved

your application

for the installation

of fuel burning equipment

at your facility located at 1125 Main Street, Pawtucket. Enclosed is a minor source permit issued pursuant

to our review of your application (Approval No. 1744).During the course of our review of your application,

we determined

that the fuel burning equipment was installed

in 2002. Microfibres,

Inc. failed to obtain a preconstruction

permit prior to the installation

of this equipment

as required by RI Air Pollution

Control Regulation No. 9.Be advised that issuance

of this permit does not limit or otherwise

preclude

the RI DEM from pursuing

enforcement

actions to address the violations

stated above. If there are any questions

concerning

this permit, please contact me at 222-2808,

extension 7011.Sincerely,Douglas L. McVayAssociate Supervising

Engineer Office of Air ResourcesSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES MINOR SOURCE

PERMIT MICROFIBRES, INC.
APPROVAL NO. 1744
Pursuant to the provisions

of Air Pollution

Control Regulation

No. 9, this minor source permit is issued to:

Microfibres,

Inc. For the following:Installation of a Cleaver Brooks 200-hp firetube boiler, Model No. CB-200 (Approval

No. 1744). The fuel burning equipment

shall be fired with either natural gas or No. 6fuel oil containing 1. O percent sulfur, by weight, or less.

Located at: 1125 Main Street, Pawtucket This permit shah be effective

from the date of its issuance

and shall remain in effect until revoked by or surrendered

to the Department.

This permit does not relieve Microfibres,

Inc. from compliance

with applicable

state and federal air pollution

control rules and regulations. The design, construction

and operation

of this equipment

shall be subject to the attached permit conditions

and emission

limitations. Stephen Majkut,

Chief Office of Air Resources Date of IssuanceSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES Permit Conditions

and Emission

Limitations MICROFIBRES, INC. APPROVAL NO. 1744
Ao Emission

Limitations

The following

emission

limitations

are applicable

to the Cleaver Brooks 200-hp boiler, Model No. CB-200,

capable of burning No. 6 fuel oil or natural gas. The maximum

capacity of this boiler shall be 8.4 MMBtu/hr. 1. Oil Firing

a. Nitrogen

Oxides (as nitrogen dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere from the boiler shall not exceed 0.50 lbs per million BTU heat input or 4.2 lbs/hr, whichever

is more stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere from the boiler shall not exceed 0.08 lbs per million BTU heat input or 0.67 lbs/hr, whichever

is more stringent.

c. Sulfur Dioxide

(SO2)(1) All fuel burned in the boiler shall contain no more than 1.0 percent sulfur by weight. (2) The emission

rate of sulfur dioxide discharged

to the atmosphere from the boiler shall not exceed 8.8 lbs/hr. d. Particulate

MatterThe emission

rate of particulate

matter discharged

to the atmosphere from the boiler shall not exceed 0.1 lbs per million BTU heat input or 0.84 lbs/hr, whichever

is more stringent.

Page of 5e. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere

from the boiler shall not exceed 0.035 lbs per million BTU heat input or 0.29 lbs/hr, whichever

is more stringent. Natural Gas Firing

a. Nitrogen

oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere from the boiler shall not exceed 0.12 lbs per million BTU heat input or 1.0 lbs/hr, whichever

is more stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere from the boiler shall not exceed 0.15 lbs per million BTU heat input or 1.26 lbs/hr, whichever

is more stringent.

c. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere

from the boiler shall not exceed 0.016 lbs per million BTU heat input or 0.13 lbs/hr, whichever

is more stringent. Visible emissions

from the boiler stack shall not exceed 10% opacity (6- minute average).
Bo Operating

RequirementsThe maximum

fLring rate of the boiler shall not exceed 56.0 gal/hr of No. 6 fuel oil or 8,370 ft3/hr of natural gas. The owner/operator

shall limit the quantity of No. 6 fuel oil and natural gas fired in this boiler to comply with the facility-wide

cap limit of 1,250,000 gallons or less of residual fuel oil equivalents

for any consecutive

12-month period, as contained

in Emission

Cap No. 01-64. Continuous Monitors l, Continuous

emission

monitoring

equipment

shall be installed,

operated

and maintained for opacity when the boiler is operating

on fuel oil.
Page 2 of 5Fuel Oil TestingCompliance

with the fuel oil sulfur limit may be determined

based on a certification from the fuel supplier.

Fuel supplier certifications

shall include the following

information:

a. The name of the fuel supplier; bo The sulfur content of the fuel from which the shipment

came or the shipment itself;The location of the fuel when the sample was drawn for analysis to determine the sulfur content of the fuel, specifically

including whether the fuel was sampled as delivered

to Microfibres,

Inc. or whether the sample was drawn from fuel in storage at the fuel supplier's facility or another location; d. The method used to determine

the sulfur content of the fuel. As an alternative

to fuel supplier certification,

the owner/operator

may elect to sample the fuel prior to combustion.

Sampling

and analysis shall be conducted for the fuel in the initial tank of fuel to be fired in the boiler and after each new shipment

of fuel is received.

Samples

shall be collected from the fuel tank immediately

after the fuel tank is filled and before any fuel is combusted.Each fuel supplier certification

or each fuel oil analysis must demonstrate that the'oil contains

1.0 percent sulfur by weight or less. Record Keeping

and Reporting The owner/operator

shall, on a monthly

basis, no later than 5 days after the first of the month, determine

and record the total quantity

of No. 6 fuel oil and natural gas combusted

in the boiler. All fuel combusted

in this boiler shall be included

in the determination

of fuel use for the entire facility under Condition C. 1 of Emissions

Cap No. 01-64. The owner/operator

shall notify the Office of Air Resources,

in writing within 30 days, whenever

the fuel usage for the entire facility for any 12- month period exceeds

1,250,000

gallons of residual fuel oil equivalents

for the combined

quantity of No. 6 fuel oil and natural gas.

Page 3 of 5The owner/operator

shall maintain

copies of all fuel supplier certifications or fuel analyses

and these copies shall be made accessible

for review by the Office of Air Resources

or its authorized

representative

and EPA. These records shall include a certified

statement,

signed by the owner/operator of the facility, that the records represent

all of the fuel combusted in the boiler. The owner/operator

shall notify the Office of Air Resources

in writing of any planned physical

or operational

change to any equipment

that would:

a. Change the representation

of the facility in the application. b° Alter the applicability

of any state or federal air pollution

rules or regulations.

c. Result in the violation

of any terms or conditions

of this permit. d. Qualify as a modification

under APC Regulation

No. 9. Such notification

shall include:

• Information

describing

the nature of the change.

• Information

describing

the effect of the change on the emission

of any air contaminant.

• The scheduled

completion

date of the planned

change. Any such change shall be consistent

with the appropriate

regulation

and have the prior approval

of the Director. The owner/operator

shall notify the Office of Air Resources

of any anticipated noncompliance

with the terms of this permit or any other applicable air pollution

control rules and regulations. The owner/operator

shall notify the Office of Air Resources

of any noncompliance with the terms of this permit, in writing, within 5 days of the occurrence.All records required

as a condition

of this approval

must be made available to the Office of Air Resources

or its representative

upon request. These records must be maintained

fbr a minimum

of five years after the date of each record.

Page 4 of 5F. Other Permit ConditionsTo the extent consistent

with the requirements

of this approval

and applicable Federal and State laws, the facility shall be designed,

constructed and operated

in accordance

with the representation

of the facility in the permit application.Employees of the Office of Air Resources

and its authorized representatives shall be allowed to enter the facility at all times for the purpose of inspecting

any air pollution

source, investigating

any condition it believes

may be causing air pollution

or examining

any records required to be maintained

by the Office of Air Resources. At all times, including

periods of startup, shutdown

and malfunction,

the owner/operator shall, to the extent practicable,

maintain

and operate the facility in a manner consistent

with good air pollution

control practice for minimizing emissions.

Determination

of whether acceptable

operating

and maintenance procedures

are being used will be based on information available to the Office of Air Resources

which may include, but is not limited to, monitoring

results, opacity observations,

review of operating

and maintenance procedures

and inspection

of the source.

2003/Microfibres-boiler.doc Page 5 of 54

September

2003

Mr. Michael L. RicciardiEngineering ManagerHindley Mfg. Co., Inc. 9 Havens StreetCumberland, RI 02864 Dear Mr. Ricciardi: The Department

of Environmental

Management,

Office of Air Resources

has reviewed

and approved your application

for the installation

of fuel burning equipment

at your facility, located at 9 Havens Street, Cumberland. Enclosed is a minor source permit pursuant

to our review of your application

(Approval

No. 1760).If there are any questions

concerning

this permit, please contact me at 222-2808,

extension

7011. Sincerely,
Douglas L. McVay Associate Supervising

Engineer Office of Air Resources

cc: Cumberland

Building

OfficialSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES MINOR SOURCE

PERMIT HINDLEY MFG. CO., INC.
APPROVAL NO. 1760
Pursuant to the provisions

of Air Pollution

Control

Regulation

No. 9, this minor source permit is issued to:

Hindley Mfg. Co., Inc. For the following:Installation of a Cleaver Brooks 125-hp firetube

boiler, Model No. CB-800-125-150

ST (Approval No. 1760). The fuel burning equipment

shall be fired with No. 4fuel oil containing 1.0percent sulfur, by weight, or less.

Located at: 9 Havens Street, Cumberland

This permit shall be effective

from the date of its issuance

and shall remain in effect until revoked by or surrendered

to the Department.

This permit does not relieve Hindley

Mfg. Co., Inc. from compliance

with applicable

state and federal air pollution

control rules and regulations. The design, construction

and operation

of this equipment

shall be subject to the attached

permit conditions

and emission

limitations.
Stephen Maj kut, Chief Office of Air Resources Date of IssuanceSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES Permit Conditions

and Emission

Limitations HINDLEY MFG. CO., INC. Approval No. 1760

mo Emission

Limitati6ns 1. Oil Firing

a, Nitrogen

Oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere

from the boiler shall not exceed 0.40 lb per million BTU heat input or 2.08 lbs/hr, whichever

is more stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere

from the boiler shall not exceed 0.070 lb per million BTU heat input or 0.37 lb/hr, whichever

is more stringent.

c. Sulfur Dioxide

(SO2)(i) All fuel burned in the boiler shall contain no more than 1.0 percent sulfur by weight. (ii) The emission

rate of sulfur dioxide discharged

to the atmosphere from the boiler shall not exceed 5.4 lbs/hr. d. Particulate

MatterThe emission

rate of particulate

matter discharged

to the atmosphere

from the boiler shall not exceed 0.041 lb per million BTU heat input or 0.213 lb/hr, whichever

is more stringent.

e. Total N6mnethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere from the boiler shall not exceed 0.025 lb per million BTU heat input or 0.131 lb/hr, whichever

is more stringent.
Page of 4Visible emissions

from the boiler exhaust flue shall not exceed 10% opacity(sixminute average).Operating Requirements 1. The maximum

firing rate of the boiler shall not exceed 36.0 gal/hr of No. 4 fuel oil. Continuous Monitors 1. Continuous

emission

monitoring

equipment

shall be installed,

operated

and maintained for opacity. Fuel oil flow to the boiler shall be continuously

measured

and recorded.
Fuel Oil TestingCompliance

with fuel oil sulfur limit may be determined

based on a certification from the fuel supplier. 2. Fuel supplier certification

shall include the following

information:

a. Thename

of the oil supplier; b. The sulfur and nitrogen

content of the oil;
Co The location of the oil when the sample was drawn for analysis

to determine the sulfur and nitrogen

content of the oil; specifically

including whether the oil was sampled

as delivered

to Hindley Mfg. Co., Inc. or whether the sample was drawn from oil in storage at the oil supplier's

or oil refiner's

facility or another location; d. The method used to determine

the sulfur and nitrogen

content of the oil. As an alternative

to fuelsupplier

certification,

the owner/operator

may elect to sample the fuel prior to combustion.

Sampling

and analysis shall be conducted

for the oil in the initial tank ofoil to be fired in the boiler and after each new shipment of oil is received.

Samples

shall be collected

from the fuel tank immediately

after the fuel tank is filled and before any oil is combusted. Each fuel supplier certification

or each fuel oil analysis must demonstrate

that the fuel oil for the boiler contains

1.0 percent sulfur by weight or less.

Page 2 of 4Record Keeping

and Reporting The owner/operator

shall notify the Office of Air Resources,

in writing, of the date of actual initial start-up of the boiler no later than fifteen days after such date. The owner/operator

shall, on a monthly basis, no later than 5 days after the first of the month, determine

the total quantity

of No. 4 fuel oil combusted

in the Cleaver Brooks boiler. The owner/operator

shall keep records of this determination

and provide such records to the Office of Air Resources

upon request. The owner/operator

shall notify the Office of Air Resources

in writing of any planned physical

or operational

change to any equipment

that would:

a. Change the representation

of the facility in the application. b° Alter the applicability

of any state or federal air pollution

rules or regulations.

c. Result in the violation

of any terms or conditions

of this permit. d. Qualify as a modification

under APC Regulation

No. 9. Such notification

shall include: Information describing

the nature of the change. Information describing

the effect of the change on the emission

of any air contaminant.

• The scheduled

completion

date of the planned

change. Any such change shall be consistent

with the appropriate

regulation

and have the prior approval

of the Director. The owner/operator

shall retain copies of all fuel supplier certifications

or fuel oil analyses for each calendar

quarter. These records shall be made accessible

for review by the Office of Air Resources

or EPA. This quarterly

record shall include a certified statement,

signed by the owner/operator,

that the records of fuel supplier certifications submitted

represent

all of the fuel combusted

during the quarter. The owner/operator

shall notify the Office of Air Resources

of any anticipated noncompliance with the terms of this permit or any other applicable

air pollution control rules and regulations.

Page

3 of 4The owner/operator

shall notify the Office of Air Resources,

in writing, of any noncompliance with the terms of this permit within 30 calendar

days of becoming aware of such occurrence

and supply the Director

with the following

information:

a. The name and location of the facility; b. The subject source(s)

that caused the noncompliance

with the permit term;

c. The time and date of first observation

of the incident of noncompliance; d. The cause and expected

duration

of the incident of noncompliance;

eo The estimated

rate of emissions

(expressed

in lbs/hr or lbs/day) during the incident and the operating

data and calculations

used in estimating

the emission rate.The proposed

corrective

actions and schedule

to correct the conditions causing the incidence

of noncompliance. All records required

in this permit shall be maintained

for a minimum

of five years after the date of each record and shall be made available

to representatives of the Office of Air Resources

upon request.
Fo Other Permit ConditionsTo the extent consistent

with the requirements

of this permit and applicable

federal and state laws, the facility shall be designed,

constructed

and operated

in accordance with the representation

of the facility in the permit application

dated 28 July 2003. Employees of the Office of Air Resources

and its authorized

representatives

shall be allowed to enter the facility at all times for the purpose of inspecting

any air pollution source, investigating

any condition

it believes may be causing air pollution or examining

any records required

to be maintained

by the Office of Air Resources. At all times, including

periods of startup, shutdown

and malfunction,

the owner/operator shall, to the extent practicable,

maintain

and operate this boiler in a manner consistent

with good air pollution

control practice

for minimizing emissions. Determination

of whether

acceptable

operating

and maintenance procedures are being used will be based on information

available

to the Office of Air Resources

which may include, but is not limited to, monitoring

results, opacity observations,

review of operating

and maintenance

procedures

and inspection of the source. 2003/Hindley-boiler.doc
Page 4 of 419 December

2003

Mr. Steven KruppaSafety EngineerMMF REALTY99 Main StreetP.O. Box 448Warren, RI 02885 Dear Mr. Kruppa:The Department

of Environmental

Management,

Office of Air Resources

has reviewed

and approved your application

for the installation

of fuel burning

equipment

at your facility, located at 99 Main Street, Warren, RI. Enclosed is a minor source permit issued pursuant

to our review of your application

(Approval No. 1778).If there are any questions

concerning

this permit, please contact me at 222-2808,

extension

7011. Sincerely,
Douglas L. McVay Associate Supervising

Engineer Office of Air ResourcesSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES MINOR SOURCE

PERMIT MMF Realty
APPROVAL NO. 1778
Pursuant to the provisions

of Air Pollution

Control Regulation

No. 9, this minor source permit is issued to: MMF Realty For the following: A Cleaver Brookx 6. 0 MMBtu/hr

boiler. Model No. CB 200 Thef•el burnin• equipment shall be/7red with either natural gas or No. 2_fuel oil containing

0.5 percent sulfur, bY weight, or less.

Located at: 99 Main Street, Warren

This permit shall be effective

from the date of its issuance

and shall remain in effect until revoked by or surrendered

to the Department.

This permit does not relieve MMF Realty from compliance

with applicable

state and federal

air pollution

control

rules and regulations. The design, construction

and operation

of this equipment

shall be subject to the attached

permit conditions

and emission

limitations.
Stephen Majkut,

Chief Office of Air Resources Date of IssuanceSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES Permit Conditions

and Emission

Limitations MMF RealtyApproval No. 1778 Emission Limitations 1. Natural Gas Firing

a. Nitrogen

Oxides (as nitrogen

dioxide (NO2) The emission

rate of nitrogen

oxides discharged

to the atmosphere

from the boiler shall not exceed 0.12 lbs per million BTU heat input or 0.72 lb/hr, whichever

is more stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere

from the boiler shall not exceed 0.15 lbs per million BTU heat input or 0.9 lb/lfr, whichever

is more stringent.

c. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere from the boiler shall not exceed 0.016 lbs per million BTU heat input or 0.1 lb/hr, whichever

is more stringent. 2. Oil Firing

a. Nitrogen

Oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere

from the boiler shall not exceed 0.25 lbs per million BTU heat input or 1.5 lbs/hr whichever

is more stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere

from the boiler shall not exceed 0.07 lbs per million BTU heat input or 0.42 lbs/hr whichever

is more stringent.
Page of 5Bo c. Sulfur Dioxide

(SO2)(i) All fuel burned in the boiler shall contain no more than 0.5 percent sulfur by weight. (ii) The emission

rate of sulfur dioxide discharged

to the atmosphere from the boiler shall not exceed 3.02 lbs/hr. d. Particulate

MatterThe emission

rate of particulate

matter discharged

to the atmosphere

from the boiler shall not exceed 0.025 lbs per million BTU heat input or 0.15 lbs/hr whichever

is more stringent.

e. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere from the boiler shall not exceed 0.025 lbs per million BTU heat input or 0.15 lbs/hr, whichever

is more stringent. Visible emissions

from the boiler exhaust flue shall not exceed 10% opacity(sixminute average).Operating Requirements 1. The maximum

fn-ing rate of the boiler shall not exceed 43 gal/hr of No. 2 fuel oil or 6,000 ft3/hr of natural gas. Continuous Monitors 1. Continuous

emission

monitoring

equipment

shall be installed,

operated

and maintained for opacity when the boiler is operating

on fuel oil. 2. Fuel oil flow for the boiler shall be continuously

measured

and recorded. Fuel Oil Testing1. Compliance

with fuel oil sulfur limits may be determined

based on a certification from the fuel supplier. 2. Fuel supplier certification

shall include the following

information:

Page 2 of 5a. The name of the oil supplier; b. The sulfur and nitrogen

content of the oil; The location of the oil when the sample was drawn for analysis to determine the sulfur and nitrogen

content of the oil; specifically

including whether the oil was sampled

as delivered

to MMF Realty or whether

the sample was drawn from oil in storage at the oil supplier's

or oil refiner's facility or another location; d. The method used to determine

the sulfur and nitrogen

content of the oil. As an alternative

to fuel supplier certification,

the owner/operator

may elect to sample the fuel prior to combustion.

Sampling

and analysis shall be conducted

for the oil in the initial tank of oil to be fired in the boiler and after each new shipment of oil is received.

Samples

shall be collected

from the fuel tank immediately

after the fuel tank is filled and before any oil is combusted. Each fuel supplier certification

or each fuel oil analysis must demonstrate

that the oil for the Cleaver Brooks boiler contains

0.5 percent sulfur by weight or less.
E. Record Keeping

and Reporting The owner/operator

shall notify the Office of Air Resources,

in writing, within 30 days, of the date the Cleaver Brooks boiler first uses No. 2 fuel oil. The owner/operator

shall, on a monthly

basis, no later than 5 days after the fn'st of the month, determine

the total quantity

of No. 2 fuel oil and natural gas combusted in the Cleaver Brooks boiler. The owner/operator

shall keep records of this determination and provide such records to the Office of Air Resources

upon request The owner/operator

shall notify the Office of Air Resources

in writing of any planned physical

or operational

change to any equipment

that would:

a. Change the representation

of the facility in the application: Alter the applicability

of any state or federal air pollution

rules or regulations.

c. Result in the violation

of any terms or conditions

of this permit. d. Qualify as a modification

under APC Regulation

No. 9. Such notification

shall include:

Page 3 of 5• Information

describing

the nature of the change. Information describing

the effect of the change on the emission

of any air contaminant.

• The scheduled

completion

date of the planned

change. Any such change shall be consistent

with the appropriate

regulation

and have the prior approval

of the Director. The owner/operator

shall retain copies of all fuel supplier certifications

or fuel oil analyses for each calendar

quarter. These records shall be made accessible

for review by the Office of Air Resources

or EPA. This quarterly

record shall include a certified statement,

signed by the owner/operator,

that the records of fuel supplier certifications submitted

represent

all of the fuel combusted

during the quarter. The owner/operator

shall notify the Office of Air Resources

of any anticipated noncompliance with the terms of this permit or any other applicable

air pollution control rules and regulations. The owner/operator

shall notify ,the Office of Air Resources,

in writing, of any noncompliance with the terms of this permit within 30 calendar

days of becoming aware of such occurrence

and supply the Director

with the following

information:

a. The name and location of the facility; b. The subject source(s)

that caused the noncompliance

with the permit term;

c. The time and date of first observation

of the incident of noncompliance; d. The cause and expected

duration

of the incident of noncompliance; The estimated

rate of emissions

(expressed

in lbs/hr or lbs/day) during the incident and the operating

data and calculations

used in estimating

the emission rate. The proposed

corrective

actions and schedule

to correct the conditions

causing the incidence of noncompliance. All records required

in this permit shall be maintained

for a minimum

of five years after the date of each record and shall be made available

to representatives of the Office of Air Resources

upon request.

Page 4 of 5F. Other Permit ConditionsTo the extent consistent

with the requirements

of this permit and applicable

federal and state laws, the facility shall be designed,

constructed

and operated

in accordance with the representation

of the facility in the permit application

dated 14 October 2003.Employees of the Office of Air Resources

and its authorized

representatives

shall be allowed to enter the facility at all times for the purpose of inspecting

any air pollution source, investigation

any condition

it believes may be causing air pollution
or examining

any records required to be maintained

by the Office of Air Resources. At all times, including

periods of startup, shutdown

and malfunction,

the owner/operator shall, to the extent practicable,

maintain

and operate this boiler in a manner consistent

with good air pollution

control practice

for minimizing emissions. Determination

of whether

acceptable

operating

and maintenance procedures are being used will be based on information

available

to the Office of Air Resources

which may include, but is not limited to, monitoring

results, opacity observations,

review of operating

and maintenance

procedures

and inspection of the source.

MMF Realty (per).doc

Page 5 of 526 January 2004Mr. Jesse Simmons Facilities ManagerInduplate, Incorporated 1 Greystone

Drive North Providence,

RI 02911
Dear Mr. Simmons: The Department

of Environmental

Management,

Office of Air Resources

has reviewed and approved

your application

for the installation

of fuel burning equipment

at your facility located at Greystone

Drive, North Providence. Enclosed is a minor source permit issued pursuant

to our review of your application (Approval No. 1785). If there are any questions

concerning

this permit, please contact me at 222-2808,

extension 7011.Sincerely,Douglas L. McVayAssociate Supervising

Engineer Office of Air Resources

cc: North Providence

Building

OfficialSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES MINOR SOURCE

PERMIT IND UPLA TE, INCORPORA

TED APPROVAL NO. 1785
Pursuant to the provisions

of Air Pollution

Control Regulation

No. 9, this minor source permit is issued to:

Induplate,

Incorporated For the following:Installation of a Cleaver Brooks 250-HP firetube boiler, Model No. CB-200-250

(Approval No. 1785). The fuel burning equipment

shall be fired with either natural gas or No. 2fuel oil containing 0.3 percent sulfur, by weight, or less.

Located at: 1 Greystone

Drive, North Providence This permit shall be effective

from the date of its issuance

and shall remain in effect until revoked by or surrendered

to the Department.

This permit, does not relieve Induplate, Incorporated from compliance

with applicable

state and federal air pollution

control rules and regulations.

The design, construction

and operation

of this equipment

shall be subject to the attached

permit conditions

and emission

limitations. Stephen Majkut,

Chief Office of Air Resources Date of IssuanceSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES Permit Conditions

and Emission

Limitations INDUPLATE, INCORPORATED APPROVAL NO. 1785 Emission Limitations

The following

emission

limitations

are applicable

to the Cleaver Brooks 250-HP boiler, Model No. CB-200-250,

capable of burning No. 2 fuel oil or natural gas. The maximum

capacity of this boiler shall be 10.43 million BTUs per hour while burning No. 2 fuel oil and 10.46 million BTUs per hour while burning natural gas. 1. Oil Firing

a. Nitrogen

Oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere

from the boiler shall not exceed 0.25 lbs per million BTU heat input or 2.61 lbs/hr, whichever is more stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere

from the boiler shall not exceed 0.07 lbs per million BTU heat input or 0.73 lbs/hr, whichever is more stringent.

c. Sulfur Dioxide

(SO2)(1) All fuel burned in the boiler shall contain no more than 0.3 percent sulfur by weight.The emission

rate of sulfur dioxide discharged

to the atmosphere from the boiler shall not exceed 3.15 lbs/hr. d. Particulate

MatterThe emission

rate of particulate

matter discharged

to the atmosphere

from the boiler shall not exceed 0.025 lbs per million BTU heat input or 0.26 lbs/hr, whichever

is more stringent.

Page 1 of 5e. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere from the boiler shall not exceed 0.025 lbs per million BTU heat input or 0.26 lbs/hr, whichever

is more stringent. Natural Gas Firing

a. Nitrogen

oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere

from the boiler shall not exceed 0.12 lbs per million BTU heat input or 1.26 lbs/hr, whichever is more stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere

from the boiler shall not exceed 0.15 lbs per million BTU heat input or 1.57 lbs/hr, whichever is more stringent.

c. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere from the boiler shall not exceed 0.016 lbs per million BTU heat input or 0.17 lbs/hr, whichever

is more stringent. Visible emissions

from the boiler stack shall not exceed 10% opacity (6-minute average).
Bo Operating

RequirementsThe maximum

firing rate of the boiler shall not exceed 74.5 gal/hr of No. 2 fuel oil or 10,460 ft3/hr of natural gas. Continuous MonitorsContinuous emission

monitoring

equipment

shall be installed,

operated

and maintained for opacity when the boiler is operating

on fuel oil. 2. Fuel oil flow for the boiler shall be continuously

measured

and recorded.
Do Fuel Oil TestingCompliance

with the fuel oil sulfur limit may be determined

based on a certification from the fuel supplier.

Fuel supplier certifications

shall include the following information:

Page 2 of 5a. The name of the fuel supplier; b. The sulfur and nitrogen

content of the oil; The location of the fuel when the sample was drawn for analysis to determine the sulfur and nitrogen

content of the fuel, specifically including whether

the fuel was sampled

as delivered

to Induplate,

Inc., or whether the sample was drawn from fuel in storage at the fuel supplier's facility or another location; d. The method used to determine

the sulfur and nitrogen

content of the fuel. As an alternative

to fuel supplier certification,

the owner/operator

may elect to sample the fuel prior to combustion.

Sampling

and analysis

shall be conducted for the fuel in the initial tank of fuel to be fired in the boiler and after each new shipment of fuel is received.

Samples

shall be collected

from the fuel tank immediately after the fuel tank is filled and before any fuel is combusted. Each fuel supplier certification

or each fuel oil analysis must demonstrate

that the oil for the boiler contains

0.3 percent sulfur by weight or less. Record Keeping

and Reporting The owner/operator

shall, on a monthly

basis, no later than 5 days-after

the first of the month, determine

and record the total quantity

of No. 2 fuel oil and natural gas combusted

in the boiler. The owner/operator

shall keep records of this determination and provide such records to the Office of Air Resources

upon request. The owner/operator

shall maintain

copies of all fuel supplier certifications

or fuel analyses and these copies shall be made accessible

for review by the Office of Air Resources or its authorized

representative

and EPA. These records shall include a certified statement,

signed by the owner/operator

of the facility, that the records represent all of the fuel combusted

in the boiler. The owner/operator

shall notify the Office of Air Resources

in writing of any planned physical

or operational

change to any equipment

that would:

a. Change the representation

of the facility in the application. Alter the applicability

of any state or federal air pollution

rules or regulations.

c. Result in the violation

of any terms or conditions

of this permit. d. Qualify as a modification

under APC Regulation

No. 9. Page 3 of 5Such notification

shall include:

• Information

describing

the nature of the.change.

• Information

describing

the effect of the change on the emission

of any air contaminant.

• The scheduled

completion

date of the planned

change. Any such change shall be consistent

with the appropriate

regulation

and have the prior approval

of the Director. 4. The owner/operator

shall notify the Office of Air Resources

of any anticipated noncompliance with the terms of this permit or any other applicable

air pollution control rules and regulations. 5. The owner/operator

shall notify the Office of Air Resources,

in writing, of any noncompliance with the terms of this permit within 30 calendar

days of becoming
aware of such occurrence

and supply the Director

with the following

information:

a. The name and location of the facility; b. The subject source(s)

that caused the noncompliance

with the permit term;

c. The time and date of first observation

of the incident of noncompliance; d. The cause and expected

duration

of the incident of noncompliance;

e. The estimated

rate of emissions

(expressed

in lbs/hr or lbs/day) during the incident and the operating

data and calculations

used in estimating

the emission rate. f. The proposed

corrective

actions and schedule

to correct the conditions causing the incidence

of noncompliance. 6. All records required

as a condition

of this approval

must be made available

to the Office of Air Resources

or its representative

upon request.

These records must be maintainedfor a minimum

of five years after the date of each record. Other Permit Conditions 1. To the extent consistent

with the requirements

of this approval

and applicable Federal and State laws, the facility shall be designed,

constructed

and operated

in accordance with the representation

of the facility in the permit application.
Page 4 of 5Employees of the Office of Air Resources

and its authorized

representatives

shall be allowed to enter the facility at all times for the purpose of inspecting

any air pollution source, investigating

any condition

it believes

may be causing air pollution or examining

any records required

to be maintained

by the Office of Air Resources.At all times, including

periods of startup, shutdown

and malfunction,

the owner/operator shall, to the extent practicable,

maintain

and operate the facility in a manner consistent

with good air pollution

control practice for minimizing

emissions. Determination of whether acceptable

operating

and maintenance

procedures

are being used will be based on information

available

to the Office of Air Resources which may include, but is not limited to, monitoring

results, opacity obse•ations, review of operating

and maintenance

procedures

and inspection

of the source.

Induplate-app.doc

Page 5 of 58

January 2003

Mr. Peter M. CostaFinancial OfficerST. MARY ACADEMY

BAY VIEW 3070 Pawtucket

Avenue Riverside, RI 02915 Dear Mr. Costa:The Department

of Environmental

Management,

Office of Air Resources

has reviewed

and approved your application

for the installation

of fuel burning equipment

at your facility, located at 3070 Pawtucket

Avenue,

Riverside,

RI. Enclosed is a minor source permit issued pursuant

to our review of your application

(Approval Nos. 1736-1737).If there are any questions

concerning

this permit, please contact me at 222-2808,

extension

7011. Sincerely,
Douglas L. McVay Associate Supervising

Engineer Office of Air Resources

cc: East Providence

Building

OfficialSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES MINOR SOURCE

PERMIT ST. MARYACADEMY- BAY VIEW
APPROVAL NOs. 1736-1737
Pursuant to the provisions

of Air Pollution

Control Regulation

No. 9, this minor source permit is issued to: St. Mary Academy

Bay View For the following:Installation of two (2) Hurst 6.3 MMBtu/hr

boilers, Model No. S1-165. The fuel burning equipment

shall be .fired with No. 4fuel oil containing

O. 7percent sulfur by weiEht, or less,

Located at:

3070 Pawtucket

Avenue,

Riverside

This permit shall be effective

from the date of its issuance

and shall remain in effect until revoked by or surrendered

to the Department.

This permit does not relieve St. Mary Academy -Bay View from compliance

with applicable

state and federal air pollution

control rules and regulations.

The design, construction

and operation

of this equipment

shall be subject to the attached

permit conditions

and emission

limitations.
Stephen Majkut,

Chief Office of Air Resources Date of IssuanceSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES Permit Conditions

and Emission

Limitations St. Mary Academy

Bay View Approval Nos. 1736-1737 Emission Limitations

The following

emission

limitations

are applicable

to the two (2) 6.3 MMBTU/hr

Hurst boilers, Model No, S 1-165. 1. Oil Firing

a, Nitrogen

Oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere

from the boiler shall not exceed 0.42 lbs per million BTU heat input or 2.65 lbs/hr whichever

is more stringent, b. Carbon Monoxide

(CO) The. emission

rate of carbon monoxide

discharged

to the atmosphere

from the boiler shall not exceed 0.02 lbs per million BTU heat input or 0.04 lbs/hr whichever

is more stringent.

c, Sulfur Dioxide

(SO2)(i) All fuel burned in the boiler shall contain no more than 0.7 percent sulfur by weight. (ii) The emission

rate of sulfur dioxide discharged

to the atmosphere from the boiler shall not exceed 4.31 lbs/hr. d. Particulate

MatterThe emission

rate of particulate

matter discharged

to the atmosphere

from the boiler shall not exceed 0.1 lbs per million BTU heat input or 0.63 lbs/hr whichever

is more stringent.

Page of 4Co e. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere from the boiler shall not exceed 0.012 lbs per million BTU heat input or 0.05 lbs/hr, whichever

is more stringent. Visible emissions

from the boiler exhaust flue shall not exceed 10% opacity(sixminute average).Operating RequirementsThe maximum

fLring rate of the boiler(s)

shall not exceed 45.4 gal/hr of No. 4 fuel oil.Continuous MonitorsContinuous emission

monitoring

equipment

shall be installed,

operated

and maintained for opacity when the boiler is operating

on fuel oil. 2. Fuel oil flow for the boiler(s)

shall be continuously

measured

and recorded. Fuel Oil TestingCompliance

with fuel oil sulfur limits may be determined

based on a certification from the fuel supplier. 2. Fuel supplier certification

shall include the following

information:

a. The name of the oil supplier; b. The sulfur and nitrogen

content of the oil; The location of the oil when the sample was drawn for analysis to determine the sulfur and nitrogen

content of the oil; specifically

including whether the oil was sampled

as delivered

to St. Mary Academy/Bay

View or whether

the sample was drawn from oil in storage at the oil supplier's or oil refiner's

facility or another location; d. The. method used to determine

the sulfur and nitrogen

content of the oil. As an altemativeto

fuel supplier certification,

the owner/operator

may elect to sample the fuel prior to combustion.

Sampling

and analysis shall be conducted

for the oil in the initial tank ofoil to be fired in the boiler and after each new shipment of oil is received.

Samples

shall be collected

from the fuel tank immediately

after the fuel tank is filled and before any oil is combusted.
Page 2 of 4Each fuel supplier certification

or each fuel oil analysis must demonstrate

that the oil for the Hurst boiler(s)

contains

0.7 percent sulfur by weight or less.
E. Record Keeping

and Reporting The owner/operator

shall, on a monthly basis, no later than 5 days after the first of the month, determine

the total quantity

of No. 4 fuel oil combusted

in the Hurst boiler(s). The owner/operator

shall keep records of this determination

and provide such records to the Office of Air Resources

upon request. The owner/operator

shall notify the Office of Air Resources,

in writing, of the date of actual initial start-up of the boiler no later than fifteen days after such date. The owner/operator

shall notify the Office of Air Resources

in writing of any planned physical

or operational

change to any equipment

that would:

a. Change the representation

of the facility in the application. bo Alter the applicability

of any state or federal air pollution

rules or regulations.

c. Result in the violation

of any terms or conditions

of this permit. d. Qualify as a modification

under APC Regulation

No. 9. Such notification

shall include:

• Information

describing

the nature of the change. Information describing

the effect of the change on the emission

of any air contaminant.

• The scheduled

completion

date of the planned

change. Any such change shall be consistent

with the appropriate

regulation

and have the prior approval

of the Director. The owner/operator

shall retain copies of all fuel supplier certifications

or fuel oil analyses for each calendar

quarter. These records shall be made accessible

for review by the Office of Air Resources

or EPA. This quarterly

record shall include a certified statement,

signed by the owner/operator,

that the records of fuel supplier certifications submitted

represent

all of the fuel combusted

during the quarter.

Page 3 of 4The owner/operator

shall notify the Office of Air Resources

of any anticipated noncompliance with the terms of this permit or any other applicable

air pollution control rules and regulations. The owner/operator

shall notify the Office of Air Resources

of any noncompliance with the terms of this permit, in writing, within 5 days of the occurrence.All records required

in this permit shall be maintained

for a minimum

of five years after the date of each record and shall be made available

to representatives of the Office of Air Resources

upon request.
Other Permit ConditionsTo the extent consistent

with the requirements

of this permit and applicable

federal and state laws, the facility shall be designed,

constructed

and operated

in accordance with the representation

of the facility in the permit application

dated 15 October 2002.Employees of the Office of Air Resources

and its authorized

representatives

shall be allowed to enter the facility at all times for the purpose of inspecting

any air pollution source, investigation

any condition

it believes may be causing air pollution or examining

any records required to be maintained

by the Office of Air Resources. At all times, including

periods of startup, shutdown

and malfunction,

the owner/operator shall, to the extent practicable,

maintain

and operate this boiler in a manner consistent

with good air pollution

control practice

for minimizing emissions. Determination

of whether

acceptable

operating

and maintenance procedures .are being used will be based on information

available

to the Office of Air Resources

which may include, but is not limited to, monitoring

results, opacity observations,

review of operating

and maintenance

procedures

and inspection of the source.

Page 4 of 426 September

2002

Mr. John E. Hayes, HI Vice PresidentR1VERPOINT

LACE WORKS,

INC. 825 Main StreetWest Warwick,

RI 02893 Dear Mr. Hayes:The Department

of Environmental

Management,

Office of Air Resources

has reviewed

and approved your application

for the installation

of fuel burning

equipment

at your facility, located at 825 Main Street, West Warwick,

RI. Enclosed is a minor source permit issued pursuant

to our review of your application

(Approval No. 1711).If there are any questions

concerning

this permit, please contact me at 222-2808,

extension

7011. Sincerely,
Douglas L. McVayAssociate Supervising

Engineer Office of Air Resources

cc: West Warwick

Building

OfficialSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES MINOR SOURCE

PERMIT RIVERPOINT LA CE WORKS,

INC.
APPROVAL NO. 1711
Pursuant to the provisions

of Air Pollution

Control Regulation

No. 9, this minor source permit is issued to: Riverpoint

Lace Works, Inc. For the following: lnxtallation of a Cleaver Brookx 27.4 MMBtu/hr

boiler: Model No.CB 700. The fizel burning equipment shall be fired with either natural gas or No. 6fuel oil containing

O. 5 percent sulfur, he weight or less.

Located at: 825 Main Street, West Warwick

This permit shall be effective

from the date of its issuance

and shall remain in effect until revoked by or surrendered

to the Department.

This permit does not relieve Riverpoint

Lace Works, Inc. from compliance

with applicable

state and federal air pollution

control

rules and regulations.

The design, construction

and operation

of this equipment

shall be subject to the attached

permit conditions

and emission

limitations.
Stephen Majkut,

Chief Office of Air Resources Date of IssuanceSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES Permit Conditions

and Emission

Limitations Riverpoint Lace Works, Inc. Approval No. 1711 Emission Limitations 1. Natural Gas Firing

a. Nitrogen

Oxides (as nitrogen

dioxide (NO2) The emission

rate of nitrogen

oxides discharged

to the atmosphere

from the boiler shall not exceed 0.12 lbs per million BTU heat input or 3.29 lb/hr, whichever

is more stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere

from the boiler shall not exceed 0.15 lbs per million BTU heat input or 4.11 lb/hr, whichever

is more stringent.

c. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere from the boiler shall not exceed 0.016 lbs per million BTU heat input or 0.44 lb/hr, whichever

is more stringent. 2. Oil Firing

a. Nitrogen

Oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere

from the boiler shall not exceed 0.5 lbs per million BTU heat input or 13.7 lbs/hr whichever

is more stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere

from the boiler shall not exceed 0.075 lbs per million BTU heat input or 2.06 lbs/hr whichever

is more stringent.
Page of 5c. Sulfur Dioxide

(SO2)(i) All fuel burned in the boiler shall contain no more than 0.5 percent sulfur by weight. (ii) The emission

rate of sulfur dioxide discharged

to the atmosphere from the boiler shall not exceed 14.5 llbs/hr. d. Particulate

MatterThe emission

rate of particulate

matter discharged

to the atmosphere

from the boiler shall not exceed 0.1 lbs per million BTU heat input or 2.74 lbs/hr whichever

is more stringent.

e. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere from the boiler shall not exceed 0.035 lbs per million BTU heat input or 0.96 lbs/hr, whichever

is more stringent. Visible emissions

from the boiler exhaust flue shall not exceed 10% opacity(sixminute average).Operating RequirementsThe maximum

firing rate of the boiler shall not exceed 195.5 gal/hr of No. 6 fuel oil or 27,400 ft3/hr of natural gas. The owner/operator

shall limit the quantity of No. 6 fuel oil in this boiler to comply with the 1,250,000

gallons facility-wide

cap limit of residual fuel oil equivalents

or less for any consecutive

12-month

period contained

in Emission

Cap No. 01-47.
Co Continuous

MonitorsContinuous emission

monitoring

equipment

shall be installed,

operated

and maintained for opacity when the boiler is operating

on fuel oil. Natural gas and fuel oil flow for the boiler shall be continuously

measured

and recorded.

Page 2 of 5D. Fuel Oil TestingCompliance

with fuel oil sulfur limits may be determined

based on a certification from the fuel supplier. 2. Fuel supplier certification

shall include the following

information:

a. The name of the oil supplier; b. The sulfur and nitrogen

content of the oil;
Co The location of the oil when the sample was drawn for analysis

to determine the sulfur and nitrogen

content of the oil; specifically

including whether the oil was sampled

as delivered

to Riverpoint

Lace Works, Inc. or whether

the sample was drawn from oil in storage at the oil supplier's or oil refiner's

.facility or another location; d. The. method used to determine

the sulfur and nitrogen

content of the oil. As an alternative

to fuel supplier certification,

the owner/operator

may elect to sample the fuel prior to combustion.

Sampling

and analysis shall be conducted

for the oil in the initial tank of oil to be fired in the boiler and after each new shipment ofoil is received.

Samples

shall be collected

from the fuel tank immediately

after the fuel tank is filled and before any oil is combusted. Each fuel supplier certification

or each fuel oil analysis must demonstrate

that the oil for the Cleaver Brooks boiler contains

0.5 percent sulfur by weight or less.
E. Record Keeping

and Reporting The owner/operator

shall, on a monthly basis, no later than 5 days after the first of the month, determine

the total quantity

of No. 6 fuel oil combusted

in the Cleaver Brooks boiler. The owner/operator

shall.keep

records of this determination

and provide such records to the Office of Air Resources

upon request.

All fuel combusted in this boiler shall be included

in the determination

of fuel use for the entire facility under Condition

B.2 of Riverpoint

Lace Works, Inc. emission

cap (No. 01-47).The owner/operator

shall notify the Office of Air Resources,

in writing, of the date of actual initial start-up of the boiler no later than fifteen days after such date. The owner/operator

shall notify the Office of Air Resources

in writing of any planned physical

or operational

change to any equipment

that would:

a. Change the representation

of the facility in the application.
Page 3 of 5b. Alter the applicability

of any state or federal air pollution

rules or regulations.Result in the violation

of any terms or conditions

of this permit. d. Qualify as a modification

under APC Regulation

No. 9. Such notification

shall include:

• Information

describing

the nature of the change.

• Information

describing

the effect of the change on the emission

of any air contaminant.

• The scheduled

completion

date of the planned

change. Any such change shall be consistent

with the appropriate

regulation

and have the prior approval

of the Director. The owner/operator

shall retain copies of all fuel supplier certifications

or fuel oil analyses for each calendar

quarter. These records shall be made accessible

for review by the Office of Air Resources

or EPA. This quarterly

record shall include a certified statement,

signed by the owner/operator,

that the records of fuel supplier certifications submitted

represent

all of the fuel combusted

during the quarter. The owner/operator

shall notify the Office of Air Resources

of any anticipated noncompliance with the terms of this permit or any other applicable

air pollution control rules and regulations, The owner/operator

shall notify the Office of Air Resources

of any noncompliance with the terms of this permit, in writing, within 5 days of the occurrence..All records required

in this permit shall be maintained

for a minimum

of five years after the date of each record and shall be made available

to representatives of the Office of Air Resources

upon request.
Other Permit ConditionsTo the extent consistent

with the requirements

of this permit and applicable

federal and state laws, the facility shall be designed,

constructed

and operated

in accordance with the representation

of the facility in the permit application

dated 23 April 2002.

Page 4 of 5Employees of the Office of Air Resources

and its authorized

representatives

shall be allowed to enter the facility at all times for the purpose of inspecting

any air pollution source, investigating

any condition

it believes may be causing air pollution
or examining

any •records required to be maintained

by the Office of Air Resources. The boiler is subject to the requirements

of the Federal New Source Performance Standards 40 CFR 60, Subparts

A (General

Provisions),

and Dc (SmallIndustrialCommercial-Institutional Steam Generating

Units). At all times, including

periods of startup, shutdown

and malfunction,

the owner/operator shall, to the extent practicable,

maintain

and operate this boiler in a manner consistent

with good air pollution

control practice

for minimizing emissions. Determination

of whether

acceptable

operating

and maintenance procedures are being used will be based on information

available

to the Office of Air Resources

which may include, but is not limited to, monitoring

results, opacity observations,

review of operating

and maintenance

procedures

and inspection of the source.

Page 5 of 59 March 2004Ms. Gale A. GennaroDirector, Office of Environmental

Health and Safety Providence College Department

of Physical

Plant Huxley AvenueProvidence, RI 02918 Dear Ms. Germaro:The Department

of Environmental

,Management,

Office of Air Resources,

has reviewed

and approved your application

for the installation

of fuel burning equipment

at your facility on Huxley Avenue,

Providence. Enclosed is a minor source permit issued pursuant

to our review of your application (Approval Nos. 1789-1791). In your application,

you also requested

that your emissions

cap be revised to reflect these changes to your facility. After receipt of the notification

required

in Condition

E.2 for the last of the three boilers, we will prepare a draft emissions

cap and provide you a copy for your review and comment

prior to publishing

public notice. Please be advised that until your emissions

cap is revised to be consistent

with this minor source permit, the limitations in that emissions

cap apply. Modifications

of an emissions

cap are subject to public comment.If there are any questions

concerning

this permit, please contact me at 222-2808,

extension 7011.Sincerely,
Douglas L. McVay Associate Supervising

Engineer Office of Air Resources

cc: Providence

Building

OfficialSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES MINOR SOURCE

PERMIT PR 0 VIDENCE

COLLEGE
APPROVAL NOs. 1789 1791.
Pursuant to the provisions

of Air Pollution

Control Regulation

No. 9, this minor source permit is issued to:

Providence

College For the following:Installation of three new Cleaver Brooks Model No. CB-LE 400-227-150

firetube

boilers (Approval Nos. 1789-1791).

The new boilers shall replace existing boilers BOO1 and BOO2. Each new boiler shall utilize a low-NOx

burner and flue gas recirculation.

All fuel burning equipment

is to be fired with either natural gas or No. 6fuel oil containing

1.0% sulfur, by weight orTess. Located at: Huxley Avenue, Providence

This permit shah be effective

from the date of its issuance

and shall remain in effect until revoked

by or surrendered

to the Department.

This permit does not relieve Providence College from compliance

with applicable

state and federal air pollution control rules and regulations.

The design,

construction

and operation

of this equipment shall be subject to the attached

permit conditions

and emission

limitations. Stephen Majkut,

Chief Office of Air Resources Date of issuanceSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES Permit Conditions

and Emission

Limitations PROVIDENCE COLLEGE APPROVAL NOS. 1789-1791
Ao Emission

Limitations

The following

emission

limitations

are applicable

to three (3) 9.5 MMBTU/hr

Cleaver Brooks boilers, Model No. CB-LE 400-227-150, equipped with low-NOx

burners and flue gas recirculation,

capable of burning No. 6 fuel oil or natural gas: 1, Natural Gas Firing

a. Nitrogen

oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere from each boiler shall not exceed 0.036 lbs per million BTU heat input or 0.34 lbs/hr, whichever

is more stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere from each boiler shall not exceed 0.11 lbs per million BTU heat input or 0.35 lbs/hr, whichever

is more stringent.

c. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere

from each boiler shall not exceed 0.016 lbs per million BTU heat input or 0.15 lbs/hr, whichever

is more stringent. 2. Oil Firing

a. Nitrogen

Oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere from each boiler shall not exceed 0.505 lbs per million BTU heat input or 4.79 lbs/hr, whichever

is more stringent.

Page of 6Co

eo Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere from each boiler shall not exceed 0.08 lbs per million BTU heat input or 0.71 lbs/hr, whichever

is more stringent. Sulfur Dioxide

(SO2)(1) All fuel bumed in the boilers shall contain no more than 1 percent sulfur by weight. (2) The emission

rate of sulfur dioxide discharged

to the atmosphere from each boiler shall not exceed 9.79 lbs/hr. Particulate MatterThe emission

rate of particulate

matter discharged

to the atmosphere from each boiler shall not exceed 0.081 lbs per million BTU heat input or 0.75 lbs/hr, whichever

is more stringent. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere

from each boiler shall not exceed 0.035 lbs per million BTU heat input or 0.33 lbs/hr, whichever

is more stringent. Operating RequirementsThe maximum

firing rate of each boiler shall not exceed 63.3 gal/hr of No.6 fuel oil or 9,350 ft3/hr of natural gas, based on a higher heating value (HHV) of 1,016 BTU/ft 3. The owner/operator

shall limit the combined

quantity

of No. 6 fuel oil and natural gas combusted

in the three (3) boilers to comply with the 1,250,000 gallon facility-wide

cap limit of No. 6 fuel oil equivalents

or less for any consecutive

12 month periOd contained

in the facility's Emission Cap.The flue gas recirculation

system for each boiler shall be in full operation whenever each boiler is in operation

and firing natural gas. Visible emissions

from the boiler stack shall not exceed 10% opacity (6- minute average).

Page 2 of 6Continuous MonitorsContinuous emission

monitoring

equipment

shall be installed,

operated and maintained

for opacity when any boiler is operating

on fuel oil. Natural gas and fuel oil flows for each boiler shall be continuously measured and recorded.
Do Fuel Oil TestingCompliance

with fuel oil sulfur limits may be determined

based on a certification from the fuel supplier. 2. Fuel supplier certification

shall include the following

information:

a. The name of the oil supplier; The sulfur and nitrogen

content of the fuel oil from which the shipment came or of the shipment

itself; .The location of the oil when the sample was drawn for analysis to determine the nitrogen

and sulfur content of the oil, specifically including whether the oil was sampled as delivered

to Providence College or whether the sample was drawn from oil in storage at the oil suppliers/refiners

facility or another location; do The method used to determine

the sulfurand

nitrogen

content of the 0il.As an alternative

to fuel supplier certification,

the owner/operator

may elect to sample the fuel prior to combustion.

Sampling

and analysis

shall be conducted

for the oil in the initial tank of oil to be fired in the boilers and after each new shipment

ofoil is received.

Samples

shall be collected from the fuel tank immediately

after the fuel tank is filled and before any oil is combusted.Each fuel supplier certification

or each fuel oil analysis must demonstrate that the oil for the boilers contains

percent sulfur by weight or less.

Page 3 of 6E. Record Keeping

and Reporting The owner/operator

shall, on a monthly

basis, no later than 5 days after the first of the month, determine

the fuel use in the three (3) new boilers for the previous

12 months.

The owner/operator

shall keep records of this determination and provide such records to the Office of Air Resources upon request.

All fuel combusted

in these boilers shall be included

in the determination of fuel use for the entire facility under Condition

C. 1 of Providence College's

emission

cap. The owner/operator

shall notify the Office of Air Resources

in writing of the date of actual initial start-up of each boiler no later than fifteen days after such date.The owner/operator

shall notify the Office of Air Resources

in writing of any physical

or operational

change to any equipment

that would:

a. Change the representation

of the facility in the application. bo Alter the applicability

of any state of federal air pollution

rules or regulations.

c. Result in the violation

of any terms or conditions

of this permit. d. Qualify as a modification

under APC Regulation

No. 9. Such notification

shall include:

• Information

describing

the nature of the change. Information describing

the effect of the change on the emission

of any air contaminant.

• The scheduled

completion

date of the planned change. Any such change shall be consistent

with the appropriate

regulation

and have the prior approval

of the Director. The owner/operator

shall maintain

copies of all fuel supplier certifications or fuel analyses

and these copies shall be made accessible

for review by the Office of Air Resources

or its authorized

representative

and EPA. These records shall include a certified

statement,

signed by the owner/operator of the facility, that the records represent

all of the fuel combusted in the boilers.

Page 4 of 6The owner/operator

shall notify the Office of Air Resources

of any anticipated noncompliance

with the terms of this permit or any other applicable air pollution

control rules and regulations. The owner/operator

shall notify the Office of Air Resources,

in writing, of any noncompliance

with the terms of this permit within 30 calendar

days of becoming

aware of such occurrence

and supply the Director

with the following information:

a. The name and location of the facility; The subject source(s)

that caused the noncompliance

with the permit term;
Co The time and date of first observation

of the incident of noncompliance; d. The cause and expected

duration

of the incident of noncompliance;

eo The estimated

rate of emissions

(expressed

in lbs/hr or lbs/day) during the incident and the operating

data and calculations

used in estimating the emission

rate; f. The proposed

corrective

actions and schedule

to correct the conditions causing the incidence

of noncompliance. All records required

as a condition

of this approval

must be made available to the Office of Air Resources

or its representative

upon request. These records must be maintained

for a minimum

of five years after the date of each record.
Fo Other Permit ConditionsTo the extent consistent

with the requirements

of this approval

and applicable federal and state laws, the facility shall be designed, constructed and operated

in accordance

with the representation

of the facility in the permit application

prepared

by Quonset

Environmental Associates dated November

2003. Employees of the Office of Air Resources

and its authorized representatives shall be allowed to enter the facility at all times for the purpose of inspecting

any air pollution

source, investigating

any condition it believes

may be causing air pollution

or examining

any records required to be maintained

by the Office of Air Resources.

Page 5 of 6At all times, including

periods of startup, shutdown

and malfunction,

the owner/0perator shall, to the extent practicable,

maintain

and operate the facility in a manner consistent

with good air pollution

control practice

for minimizing emissions.

Determination

of whether

acceptable

operating

and maintenance procedures

are being used will be based on information available to the Office of Air Resources

which may include, but is not limited to, monitoring

results, opacity observations,

review of operating and maintenance

procedures

and inspection

of the source. The existing boilers, B001 (25,79 MMBTU/hr)

and B002 (39.0 MMBTU/hr), shall be removed

from service or rendered

inoperable

on or before the startup of the last of the three new boilers (Approval

Nos. 1789- 1791). 2004/pc-boilers.doc

Page 6 of 626 July 2006

Mr. Dave ParrilloPlant ManagerBtmge Oils, Inc.38 Colfax StreetPawtucket, RI 02860 Dear Mr. Parrillo:The Department

of Environmental

Management,

Office of Air Resources,

has reviewed

and approved your application

forthe installation

of fuel burning equipment

at your facility located at 38 Colfax Street, Pawtucket. Enclosed is a minor source permit issued pursuant

to our review of your application (Approval No. 1897). If there are any questions

concerning

this permit, please contact me at 222-2808,

extension 7011.Sincerely,
Douglas L. McVay Associate Supervising

Engineer Office of Air Resources

CC: Pawtucket

Building

Official John Gibbons

Btmge OilsSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES MINOR SOURCE

PERMIT BUNGE OILS, INC.
APPROVAL NO. 1897
Pursuant to the provisions

of Air Pollution

Control Regulation

No. 9, this minor source permit is issued to:

Bunge Oils, Inc. For the following:Installation of a Clayton 27.9 MMBtu/hr

boiler, Model No. SEOG704-2-FGR.

The fi•el burning equipment

shall be fired with natural gas or No. 2fuel oil containing

0.3 percent sulfur, by weight, or less.

Located at: 38 Colfax Street, Pawtucket

This permit shall be effective

from the date of its issuance

and shah remain in effect until revoked

by or surrendered

to the Department.

This permit does not relieve Bunge Oils, Inc. from compliance

with applicable

state and federal air pollution

control rules and regulations,

The design, construction

and operation

of this equipment

shah be subject to the attached

permitconditions

and emission

limitations.
Stephen Majkut,

Chief Office of Air Resources Date of issuanceSTATE OF RHODE

ISLAND

AND PROVIDENCE

PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES Permit Conditions

and Emission

Limitations Bunge Oils, Inc. APPROVAL NO. 1897 Emission Limitations 1. Natural Gas Firing

a. Nitrogen

Oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere from the boiler shall not exceed 0.036 lb per million BTU heat input or 1.00 lb/hr, whichever

is more stringent. b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere from the boiler shall not exceed 0.074 lb per million BTU heat input or 2.06 lbs/in', whichever

is more stringent.

c. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere

from the boiler shall not exceed 0.0054 lb per million BTU heat input or 0.15 lb/hr, whichever

is more stringent. 2. Fuel Oil Firing

a. Nitrogen

Oxides (as nitrogen

dioxide (NO2)) The emission

rate of nitrogen

oxides discharged

to the atmosphere from the boiler shall not exceed 0.14 lb per million BTU heat input or 3.82 lbs/hr, whichever

is more stringent.

Page of 6b. Carbon Monoxide

(CO) The emission

rate of carbon monoxide

discharged

to the atmosphere from the boiler shall not exceed 0.078 lb per million BTU heat input or 2.13 lbs/hr, whichever

is more stringent.

c. Sulfur Dioxide

(SO2)(1) All fuel burned in the boiler Shall contain no more than 0.3 percent sulfur by weight. (2) The emission

rate of sulfur dioxide discharged

to the atmosphere from the boiler shall not exceed 8.20 lbs/hr. d. Particulate

MatterThe emission

rate of particulate

matter discharged

to the atmosphere from the boiler shall not exceed 0.023 lb per million BTU heat input or 0.64 lb/hr, whichever

is more stringent.

e. Total Nonmethane

Hydrocarbons

(NMHC) The emission

rate of total nonmethane

hydrocarbons

discharged

to the atmosphere

from the boiler shall not exceed 0.0015 lb per million BTU heat input or 0.04 lb/hr, whichever

is more stringent. Visible emissions

from the boiler exhaust flue shall not exceed 10% opacity (6-minute

average). Operating RequirementsThe maximum

firing rate of the boiler shall not exceed 193.8 gal/hr of No.2 fuel oil or 27,896 ft3/hr of natural gas. The flue gas recirculation

system for the boiler shall be in full operation whenever the boiler is in operation. The owner/operator

shall conduct a complete

annual inspection

of the flue gas recirculation

system and its components.

The owner/operator

shall check for proper operation

and compare

all internal and external control and driTe linkage settings with those established

by Clayton Industries. The owner/operator

shall note and correct any deviations

prior to operating the boiler after each such annual inspection.

Page 2 of 6Co Continuous

Monitors 1. Continuous

emission

monitoring

equipment

shall be installed,

operated and maintained

for opacity when the boiler is operating

on fuel oil. 2. Natural gas and fuel oil flow for the boiler shall be continuously

measured and recorded.
Do Fuel Oil TestingCompliance

with fuel oil sulfur limits maybe determined

based on a certification from the fuel supplier. 2. Fuel supplier certification

shall include the following

information:

a. The name of the oil supplier; b° The sulfur content of the fuel oil from which the shipment

came or of the shipment

itself; The location of the oil when the sample was drawn for analysis to determine the sulfur content of the oil, specifically

including

whether the oil was sampled as delivered

to Bunge Oils, Inc. or whether the sample was drawn from oil in storage at the oil suppliers/refiners facility or another location; d. The method used to determine

the sulfur content of the oil. As an alternative

to fuel supplier certification,

the owner/operator

may elect to sample the fuel prior to combustion:

Sampling

.and analysis

shall be conducted

for the oil in the initial tank of oil to be fired in the boiler and after each new shipment

of oil is received.

Samples

shall be collected from the fuel tank immediately

after the fuel tank is filled and before any oil is combusted.Each fuel supplier certification

or each fuel oil analysis must demonstrate that the oil for the boiler contains

0.3 percent sulfur by weight or less.
E° Record Keeping

and Reporting 1. The owner/0perator

shall, on a monthly

basis, no later than 5 days after the first 0fthe month, determine

the total quantity

of No. 2 fuel oil and natural gas combusted

in the boiler. The owner/operator

shall keep records of this

Page 3 of 6determination and provide such records to the Office of Air Resources upon request.The owner/operator

shall notify the Office of Air Resources

in writing of the date of actual initial start-up of the boiler no later than fifteen days after such date.The owner/operator

shall notify the Office of Air Resources

in writing of any physical

or operational

change to any equipment

that would:

a. Change the representation

of the facility in the application. Alter the applicability

of any state of federal air pollution

rules or regulations.

c. Result in the violation.of

any terms or conditions

of this permit. d. Qualify as a modification

under APC Regulation

No. 9. Such notification

shall include:

• Information

describing

the nature of the change. Information describing

the effect of the change on the emission

of any air contaminant.

• The scheduled

completion

date of the planned change. Any such change shall be consistem

with the appropriate

regulation

and have the prior approval

of the Director. The owner/operator

shall maintain

copies of all fuel supplier certifications or fuel analyses

and these copies shall be made accessible

for review by the Office of Air Resources

or its authorized

representative

and EPA. These records shall include a certified

statement,

signed by the owner/operator of the facility, that the records represent

all of the fuel combusted in the boiler. The owner/operator

shall maintain

records of the annual visual inspection of the flue gas recirculation

system and its components. The owner/operator

shall notify the Office of Air Resources

of any anticipated noncompliance

with the terms of this permit or any other applicable air pollution

control rules and regulations.

Page 4 of 6The owner/operator

shall notify the Office of Air Resources,

in writing, of any noncompliance

with the terms of this permit within 30 calendar

days of becoming

aware of such occurrence

and supply the Director

with the following information:

a. The name and location of the facility; bo The subject source(s)

that caused the noncompliance

with the permit term;
Co The time and date of first observation

of the incident of noncompliance; d. The cause and expected

duration

of the incident of noncompliance;

eo The estimated

rate of emissions

(expressed

in lbs/hr or lbs/day) during the incident and the operating

data and calculations

used in estimating the emission

rate; The proposed

corrective

actions and schedule

to correct the conditions causing the incidence

of noncompliance. All records required

in this permit shall be maintained

for a minimum

of five years after the date of eachrecord

and shall be made available

to representatives of the Office of Air Resources

upon request.
Other Permit ConditionsTo the •xtent consistent

with the requirements

of this approval

and applicable federal and state laws, the facility shall be designed, constructed and operated

in accordance

with the representation

of the facility in the permit application. Employees of the Office of Air Resources

and its authorized representatives shall be allowed to enter the facility at all times for the purpose Of inspecting

any air pollution

source, investigating

any condition it believes

may be causing air pollution

or examining

any records required to be maintained

by the Office of Air Resources. At all times, including

periods of startup, shutdown

and malfunction,

the owner/operator shall, to the extent practicable,

maintain

and operate the facility in a manner consistent

with good air pollution

control practice

for minimizing emissions.

Determination

of whether

acceptable

operating

and maintenance procedures

are being used will be based on information available to the Office of Air Resources

which may include, but is not Page 5 of 6limited to, monitoring

results, opacity observations,

review of operating and maintenance

procedures

and inspection

of the source. The boiler is subject to the requirements

of the Federal New Source Performance Standards

§ 40 CFR 60, Subparts

A (General

Provisions)

and Dc (Small Industrial-Commercial-Institutional Steam Generating

Units). Compliance with all applicable

provisions

of these regulations

is required. Approval No. 1805, issued on 21 June 2004, shall remain in effect and allows the owner/operator

to install and operate a temporary

boiler in the event that the permanent

boiler (Approval

No. 1897) is out of service. The temporary boiler shall meet the requirements

of the minor source permit (Approval No. 1805). 2006/BungeNA

06.doc

Page 6 of 6