STATE OF NEW HAMPSHIRE Department of Environrnenta• Services Air Resources Division 

Title V Operating Permit 

Permit No: TV-OP-016 15,Date2001Issued: April 7, 1999, Amended November 15, 1999, April 13, 2000, June 26, 2001, and November 

This certifies that: 

AES Eeotek Holdings LLC 

100 Pine Street, Suite 3300 

San Francisco, CA 94111 

HemphillhaS been grantedpower a&TitleLightV OperatingcompanyPermit for the following facility and location: 

54 Fisher Corner Road Springfield, NH 

AFS No. 3301900031 

This Title V Operating Permit is hereby issued under the terms and conditions specified in the Title V Operating Permit Application filed with the New Hampshire Department of Environmental Services Air 

Resources Division (DES) on April 10, 1996 and the supplemental information for the Title V application submitted on September 16, 19.96 and February 17, 1998 under the signature of the following responsible official certifiying to the best of their knowledge that the statements and information therein are true, accurate 

and complete. 

Responsible Official: 

Charles Theal 

Operations Manager (603) 763-4757 

Technical Contact: 

Anthony J. Colella 

ENSR Manager, Air Services (978) 595-3000 

This Permit is issued by the DES pursuant to its authority under New Hampshire RSA 125-C and in accordance 

with the provisions of Code of the Federal Regulations 40 Part 70. 

This Title V Operating Permit shall expire on April 30, 2004. 

SEE ATTACHED SHEETS FOR ADDITIONAL PERMIT CONDITIONS For the New Hampshire Department of Environmental Services, Air Resource Division 
Director, Air Resources Division 

TABLE OF CONTENTS 

I. Facility Description of Operations 4 

II. Permitted Activities 4 

III. Significant Activities Identification and Stack Criteria Tables 1 & 2 4-6 

IV. Insignificant Activities Identification 6 

V. Exempt Activities Identification 6 

Pollution Control Equipment Identification Table 3 7 VI. 

VII. Alternative Operating Scenarios 7 

VIII. Applicable Operational and Emission Limitations Table 4 8-11 

IX. Emission Reductions Trading Requirements 11 

Xo 

XI. 

Compliance Demonstration Requirements 

-Monitoring and Testing Requirements 

-Record Keeping and Reporting Requirements 

11-21 

Requirements Not Currently Applicable 

XII. Issuance of a Title V Operating Pe•it 22 

XIII. Title V Operating Pg•it Renewal Procedures 22 

XIV. Application Shield 22 

22 

XV. Permit Shield 

XVI. Reopening for Cause 

XVII, 

XVIII. 

Administrative Permit Amendments 

Operational Flexibility 

22-23 

24 

24 

24-25 

XIX. Minor Permit Amendments 25-26 

XX. Significant Permit Amendments 26 

XXI. Title V Operating Permit Suspension, Revocation or Nullification 26 

Inspection and Entry 26 
XXIII. 

XXIV. 

XXV. 

XXVI. 

XXVII. 

XXVIII. 

XXIX. 

XXX. 

Certifications 

Enforcement 

Emission Based Fee Requirements 

to Provide Information 

Property Rights 

Severability Clause 

Emergency Conditions 

Permit Malfunctions and Deviations 

27-28 

28 

28-29 

29 

29 

29 

29-30 

30 
Page 4 

Facility Specific Title V Operating Permit Conditions 

Facility Description of Operations: 

Hemphill Power and Light Company (Hemphill) Generating Station is located in Springfield, New 

Hampshire. The electric generating station is designed to consume wood fuel consisting of primarily whole 

tree chips, but may also include untreated wood waste from mill processing operations (mill residue) and 

bark to generate 16 MW (gross) of electrical power. Propane/natural gas is proposed to be used as an 

alternate fuel to fire an auxiliary bumer. Approximately half of the wood fuel used at Hemphill is chipped 

on site using a diesel-fired chipper. 

II. Permitted Activities: 

In accordance with all of the provisions of the New Hampshire Rules Governing the Control of Air Pollution 

(effective date 12/31/96) and as revised thereafter, the permittee is authorized to operate the devices and or 

processes identified in Sections III, IV, V and VI within the terms and conditions specified in this Permit. 

IlL Significant Activities Identification and Stack Criteria: 

Significant Activity Identification 

The activities identified in the following table (Table 1) are subject to and regulated by this Title V 

Operating Permit: 

Table 1- significant ACtivity Identifieati0n 

Emissi-- U- it Description of Emission I• nit 

(EU#) • 

EUI Boiler Babcock and Wilcox • 

with a 

Detroit Stoker Propane/natural gas 

Burner 

(Model DB-21 -SS-0 l-G) 

EU2-EG Cummins Emergency Diesel Generator 

Caterpillar 3412 Diesel Chipper Engine EU3 Chipper 

Exhaust Stack Identifi arian 

Stack #1 

EmissionsUnit Maxi um 

Design Capacity 

Maximum Firing Rate of 220 

mmBTU/hr with wood 

60 mmBTU/hr with 

propane/natural gas 

Stack #2 

Stack #3 

470 hp operating less than 500 

hours per year, max firing rote 

of 3.621 mmBTU/hr 

(25.5 gal/hr diesel) 

624 hp operating up to 8760 

hours per year, max firing rate 

of 4.445 mmBTUlhr 

(31.3 gal/hr diesel) 

Based on equipment design, the maximum operating rate of the EU1 Boiler shall be limited 

to a total of 220 million BTU per hour (mmBTU/hr) gross heat input. This is the equivalent 

of 152,000 pounds per hour (lbs/hr) of steam production as averaged over any consecutive 

30-day period at 900 degrees F and 885 PSIG assuming a boiler efficiency of 68% and boiler 

feedwater temperature of 443 degrees F. 

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Page 5 Si nificant Activities Identification and Stack Criteria continued 

2. Based on facility operations, fuel fed to the EU1 Boiler shall consist of following: any of the 

(approximately 

Whole tree wood chips, mill residue and bark at approximately 55% moisture 7.65 mmBTU/ton). 

Clean processed wood fuel (approximately 7.65 mmBTU/ton to 13.5 mmBTU/ton). 

moisture. 

Clean processed wood fuel and whole tree wood chips at approximately 55% 

Clean processed wood fuel and/or whole tree wood chips and specification used oil. 

Clean processed wood fuel and/or whole tree wood chips and propane/natural maximum 15 grains sulfur gas at per 100 cubic feet. 

P.ropane/natural 

15 grains sulfur 

gas proposed for startup and flame stabilization only at maximum per 100 cubic feet. 

Based on equipment design and 365 operating days consumption by the EU1 Boiler 

per year, the maximum wood shall be limited to 252,000 tons wet basis of wood fuel as 

consecutive 

specified in Section 

twelve 

III.2.a-fat approximately 55% moisture (7.65 mmBTU/ton) month period, during any 

4. 

of 

The 

the 

emission 

EU2-EG 

units 

shall 

EU2-EG 

be limited 

and EU3-Chipper shall be operated using diesel fuel. Operation to 500 hours per calendar Chipper shall be'limited year. The operation of the EU3- to 8,760 hours during not use more 274,200 gallons any consecutive 12-month period and shall of diesel fuel during any consecutive 12-month period. 

Stack Criteria 

without 

The following 

obstruction 

stacks 

(including 

for the above 

rain 

listed significant devices at this facility shall discharge vertically caps) and state-only air pollution dispersion modeling 

meet the folio.wing criteria in accordance with the requirements specified in Env-A 606. 

IClean processed wood fuel is considered to be fuel that exhibits fuel characteristics equivalent to 'lwhole tree wood chips" and "sawdust" with respect to the ultimate and proximate analysis of the fuel. 

Revised4113/00 
III. 

Page 6 

Significant Activities Identification andStack Criteria (continued): 

Stack#- MinimUm StackHeigh•,t) 

Stack #1- EU1-Boiler 212 6.5 

Stack #2-EU2-EG 21.5 0.406 

Stack #3-EU3-Chipper 24 0.666 

Preauthorized changes to the state-only requirements pertaining to stack parameters (set forth in this 

permit) shall be permitted only when an air quality impact analysis meeting the criteria of Part EnvA 606 is performed either by the facility or by the DES (if requested by the facility in writing) in 

accordance with the "NHARD Policy and Procedure for Air Quality Impact Modeling". All air 

modeling data shall be kept on file at the facility for review by the DES upon request. 

C. Modified Operations 

Hemphill is proposing to modify facility operations by installing a 60 mmBTU/hr propane/natural 

gas burner in conjunction with the existing wood-fired boiler. The proposed propane/natural gas 

burner is a Detroit Stoker Burner Model DB-21-SS-01-G. At this time, the proposed propane/natural 

gas burner is tentative and installation is not scheduled. Hemphill's current method of starting fires 

in the firebox consists of manually adding paper and woodchips and igniting them by hand. The 

proposed propane/natural gas burner, if installed, will be used to establish fire in the wood-fired 

boiler, for flame stabilization and to maintain minimum boiler operating level during maintenance 

and malfunction activities. The proposed propane/natural gas burner would also be used to control 

CO emissions should alternative fuels such as sawdust become more viable. Fire will be established 

by igniting wood chips that have been placed in the fire box with flames generated by the 

propane/natural gas burner. With the propane/natural gas burner, fires will be established in the fire 

box more efficiently with less smoke generated when compared to the current hand igniting method. 

Hemphill indicates that overall emissions will decrease during boiler startup when using the 

propane/natural gas burner. When the proposed propane/natural gas burner installation is scheduled, 

Hemphill shall request a permit modification prior to installing and operating the equipment. 

IV. Insignificant Activities Identification: 

Wo 

All activities at this facility that meet the criteria identified in the New Hampshire Rules Governing the 

Control of Air Pollution Part Env-A 609.03(g), shall be considered insignificant activities. Emissions from 

the insignificant activities shall be included in the total facility emissions for the emission-based fee 

calculation described in Section XXV of this Title V Operating Permit. 

Exempt Activities Identification: 

All activities identified in the New Hampshire Rules Governing the Control of Air Pollution Part Env-A 

609.03(c) shall be considered exempt activities and shall not be subject to or regulated by this Title V 

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VI. .,Pollution Control Equipment Identification: 

The devices and/or processes identified in Table 3 below are considered pollution control equipment for the identified emissions unit. 

Multiclone primary particulate control for the EU1 Boiler 

EUI 

Electrostatic Precipitator (ESP) secondary particulate control for the Boiler EU1 -Boiler 

Bo 

conditions 

All equipment, 

of this 

facilities 

permit shall 

and systems installed and used to achieve compliance with the terms and 

as efficiently as possible 

at all times be maintained in good working order and shall be operated 

pollutant emission limits. These 

so as to minimize air pollutant emissions and meet all applicable air controls shall be fully operational upon facility startup and shall not be bypassed during startup, operation or shutdown of the steam generating unit. 

manufacturer's 

The pollution 

Operation 

control equipment 

and Maintenance 

shall be maintained regularly, in accordance with the (O&M) manual and based on the schedules in Sections VIII.A. and as described X.A. 

VII. Alternative Operating Scenarios: 

Hemphill 

Hemphill 

proposed 

requested 

to 

the 

burn 

alternative operating scenario of burning used oil in their Title V application. as an auxiliary fuel. The specification 

up to 1,000 gallons of on-site generated specification used oil in the EU 1-Boiler used oil shall meet the criteria for specification used oil in Waste Management Rules Env-Wm as described 807.02 and shown in Table 4 in Section VIII. B. 9 of this permit. 

Based on proposed usage description, Hemphill shall not use more than 55 gallons of specification used oil 

gallons 

mixed with 

of specification 

approximately 

used 

20. tons 

oil during 

(full truck load) of sawdust. Hemphill shall not use more than 1,000 

specification used oil generated 

any consecutive 365-day period. Hemphill shall only burn 

the specification used oil in 

at the Hemphill thcilitv in the EU1-Boiler. Hemphill shall store and handle accordance with all applicable state and federal regulations. 

Hemphill shall monitor compliance with the used oil specifications by conducting at least certifying compliance with Env-Wm one fuel analysis 807.02 and the sulfur content of 0.4% by weight per calendar year. This data shall be retained at the •hcility in accordance with record keeping requirements described in Hemphill 

Section X.C. 

shall 

of 

comply 

this permit. 

with 

If 

applicable 

the facility-generated used oil is transferred off-site for recycling or disposal, DES rules regarding the storage/handling/transfer of used oil. 

h:•ermils•eurrent\till•v•amcndrnenls\tv•emph2.amd Revised4/] 3/00 
Page 8 

Applicable Operational and Emission Limitations: 

Hemphill is subject to the following operational and emission limitations as contained in this permit. 

A. Operational Limitations 

Based on equipment design, the maximum operating rate of the EU1-Boiler shall be limited to a total 

of 220 mmBTU/hr gross heat input with wood and 60 mmBTU/hr with propane/natural gas. This is 

equivalent to 152,000 lbs/hr of steam production as averaged over any consecutive 30-day period at 

900 degrees F and 885 PSIG assuming a boiler efficiency of 68% and boiler feedwater temperature 

of 443 degrees F. 

To operationally control CO emissions in accordance with Env-A 305, Hemphill shall comply with 

the following operational limitations. 

Hemphill shall control CO emissions by varying the total quantity of input combustion air and/or the 

local distribution of that air into the EU1 Boiler. The amount of combustion air required to 

optimize the EU1 Boiler efficiency and reduce CO emissions is dependent on the wood moisture 

content and the type of wood, among other factors. The steam generating unit shall be equipped 

with a fuel distribution, overfire air and undergrate air control systems for optimum NOx and CO 

emission control. 

B. State-Only Applicable Emission Lhrfitations 

In accordance with Env-A 1002.03, Hemphill shall take precautions to prevent, abate and 

control the emission of fugitive dust for those activities contained in Env-A 1002.02. Such 

precautions shall include wetting, covering, shielding or vacuuming. 

New or modified devices, new or modified area sources, and existing devices or area sources 

for which new applications for permits are filed that ha•e the potentialto emit, in any 

amount, substances that meet the criteria of Env-A 1301 shall be subject to Env-A 1300, 

until such time as the Env-A 1400 requirements supersede the Env-A 1300 requirements. 

Air quality impact analysis of devices and area sources emitting substances meeting the 

criteria of Env-A 1301 shall be performed in accordance with the "DES Policy and Procedure 

for Air Quality Impact Modeling" or other comparable dispersion modeling methods 

approved by EPA. 

In accordance with Env-A 1403.01, new or modified devices or processes installed after May 

8, 1998, shall be subject to the requirements of Env-A 1400. 

In accordance with 1403.02(a), all existing unmodified devices or processes which are in 

operation during the transition period ending three years from May 8, 1998 (May 8, 2001), 

h:•permils\current\titlev•amendments\tvhemplC2.amd 

Revised4113100 
VIII. 

Page 9 

shall comply with either Env-A 1300 or Env-A 1400. 

6. In accordance with Env-A 1403.02(b), all existing devices or processes in operation after the A licable 0 erational and Emission Limitations continued 

transition period ending three 

Env-A 1400. Env-A 1300 

years from May 8, 1998 (May 8, 2001), shall comply with will no longer be in effect. 

7. 

shall 

In accordance 

be retained 

with 

at 

Env-A 

the site, 

1404.01 (d), documentation for the demonstration of compliance and shall be made available to the DES for inspection. 

8. In accordance with Env-A 1405.02, the owner of an existing device or process requiring a permit modification under Env-A 1400 shall submit to the DES no later than to the end of the transition one year prior period (by May 8, 2000), an application for a modification to a Title V permit in accordance with Env-A 609.18, and dispersion model/ng. a request to the DES to perform air 

burned 

Pursuant.to 

at the 

Waste 

facility 

Management 

shall m•et 

Rules Env-Wm 807.02, specification used oil generated and the criteria for specification used oil as described below. 

A. The oil shall not be mixed with hazardous waste; and 

B. The oil shall 

exhibit 

meet all of the standards in the following table and shall not otherwise any of the hazardous waste characteristics specified in Env-Wm 403. 

Arsenic 

Cadmium 

Chromium 

Lead 

PCBs 

Total Halogens 

Flash Point 

5.0 ppm maximum 

2.0 ppm maximum 

10 ppm maximum 

100 ppm maximum 

Less than 2 pPm 

1,000 ppm maximum 

100 degrees F minimum 

gross 

The sulfur 

heat input 

content 

of used 

of the 

oil 

specification 

shall 

used oil shall be limited to 0.4% by weight and the be limited to 25 mmBTU/hr (approximately 180 gallons per hour) on an average annual basis. 

10• In accordance with Env-A 2003.04 (d), exceedances of the opacity standard shall not be 

APcnnits\curmnt•titlev•amenaments\tvhemph2,amd Revised4/I 3/00 
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Page 10 

considered violations of this part if the facility demonstrates to the division that such 

exceedances were the result of the adherence to good boileroperating practices which, in the 

long term, results in the most efficient or safe operation of the boiler. 

11. In accordance with Env-A 2003.04 (e)(2), opacity exceedances experienced during periods of 

cold startup of a boiler over a continuous period of time resulting in efficient heat-up and 

stabilization of its operation and the expeditious achievement of normal operation of the unit 

shall not be considered violations. 

1Z In accordance with Env-A 2003.04 (f), exceedances of the opacity standard shall not be 

considered violations of this part if the source demonstrates to the DES that such 

exceedances were the result of the occurrence of an unplanned incident in which the opacity 

exceedance was beyond the control of the operator and in response to such an incident, the 

operator took appropriate steps in conformance with good boiler operating practice to 

eliminate the excess opacity as quie.kly as possible. 

Federally Enforceable Emission Limitations 

In accordance with Env-A 1211.02(j)(1 and 2), EU2-EG shall be limited to less than 500 

hours of operation during any consecutive 12-month period and the combined theoretical 

potential emissions of NOx from all such generators are limited to less than 25 tons for any 

consecutive 12-month period. 

In accordance with Env-A 1211.04(d) and Env-A 1211.05(d)(5), the EU1 Boiler, firing 

wood fuel or capable of firing a combination of wood fuel and oil and equipped with a 

vibrating grate, shall comply with the oxides of nitrogen (NOx) Reasonably Available 

Control Technology (RACT) emission limit of 0.33 pounds per million BTU (lb/mmBTU), 

based on a 24-hour calendar day average. 

In accordance with Env-A 1211.07(c)(2)(b), the hourly average NOx emissions from the 

EU3-Chipper shall be limited at all times to no greater than 8.0 grams/bhp-hr or 11.0 lbs NO• 

per hour. The annual NOx emissions from the EU3-Chipper shall be limited to 48 tons per 

consecutive 12-month period. 

In accordance with Env-A 1604.01, the diesel fuelused in the EU2-EG and the EU3-Chipper 

shall not contain more than 0.4% sulfur by weight. Based on the capacity of the EU3- 

Chipper, the EU3-Chipper shall not use more than 274,000 gallons of diesel fuel in any 

consecutive 12-month period. 

In accordance with Env-A 2003.02, Hemphill shall not cause or allow average opacity from 

fuel burning devices installed after May 13, 1970 in excess of 20 percent for any continuous 

6-minute period in any 60-miuute period. The EU1-Boiler may apply one of the following 

exemptions in accordance with Env-A 2003.04(a): 

During periods of startup, shutdown and malfunction, avergge opacity shall be 

allowed to be in excess of 20 percent for one period of 6 continuous minutes in any 

h:•p ermils\cu nt\t illov•amCnd s\tvhemph2,amd 

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VIIL 

60 minute period; or 

Page 11 

b. During 

fires, average 

periods 

opacity 

of normal operation, soot blowing, grate cleaning, and cleaning of shall be allowed to be in 27 percent fbr excess of 20 percent but not more than one period of 6 continuous minutes in A licable O erational and Emission any 60 minute period. Limitations continued 

6. /n accordance with 40 CFR Part 522, the sulfur content of propane/natural exceed 5 grains of sulfur gas shall not per 100 cubic feet. 

7. 

regulation 

To avoid the 

40 CFR 

requirements 

52.21(b)(1)(i)(b), 

of the federal Prevention of Significant Deterioration (PSD) burning devices, including the combined NO• emission rate for the facility fuel 

57.0 pounds per hour (lbs/hr) 

the EU1-Boiler, EU2-EG and the EU3-Chipper shall be limited to average for this emission limit shall be demonstrated 

any consecutive 365-day period. Compliance with 

data, using the NOx CEM data and estimated emission 

combined 

To avoid the 

carbon 

requirements 

monoxide 

of the federal PSD regulation 40 CFR 52.21(b)(1)(i)(b), the 

including the EU1-Boiler, ((•O) emission rate for the facility fuel burning devices, 

average .for 

EU2-EG and the EU3-Chipper shall be limited to 57.0 lbs/hr any consecutive 365-day period. 

monoxid• 

In accordance 

(CO) 

with 

emission 

RSA 125-C:6, RSA 125-C: 11 and Env-A 606.04, the combined carbon 

EU2-EG and the EU3-Chipper 

rate for the facility fuel burning devices, including the EU1-Boiler, shall be limited to •.5 lbs/hr for each calendar day average as calculated 

permit. on the CEM system or using the calculation shown in Section X.B.6. of this 

10. 

11. 

In accordance with 40 CFR Part 60, Subpart Db, the PM emission shall be limited to 0.10 lb/rnmBTU rate for the EU1 Boiler heat input. 

Continuous Emission Monitoring (CEM) requirements permit. are described in Section X.B. of this 

IX. .Emission Reductions Trading Requirements 

The Permittee did 

the time of this permit 

not request emissions reductions trading in the facility ooeratin• preparation, DES did not included any permit terms-- authorizing- permit,• emissionsapplicati°n'tra,•;n• At 

this permit. All emissions reductions trading must be in 

EmissionsEnV'A 3000Reductions(the "EmissionS(or r•D•Reducti°ns Credits (or ERCs)aUth°rizedTradingunderprogram,,)the applicableor Env-A-3requirements100 (t he "Discrete°f either" 

•,s) Trading Program) and 42 U.S.C. §7401 et seq. (The "Act"), and must be provided for in this Permit." 

2 Env-A 402.03, effective on December 27, 1990, was adopted as part of the State Implementation Plan (SIP) on September 14, 1992 and is still considered federally enforceable until such time as the SIP is amended and approved by EPA. 

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Page 12 

Compliance Demonstration Requirements: 

The permittee is subject to the monitoring/testing, record keeping and reporting requirements as contained in 

the following permit sections. Refer to the standard operating practices and the manufacturer's O&M 

manual for additional information. The pollution control equipment and EU1 Boiler shall be monitored 

Compliance Demonstration Requirements (continued): 

and maintained in accordance with the appropriate manufacturers' O&M manuals. 

A. Monitoring/Testing Requirements for Total Suspended Particulate Controls 

(Regulatory cite Env-A 806.01 (a) and 40 CFR Part 70.6(a)(3)) 

1. PC 1 Multiclone Monitoring and Testing Requirements 

The PC1-Multiclone shall be operated in series with the PC2-ESP trait. 

Conduct monitoring of pressure differential across the PCI Multiclone unit once 

every shift. An acceptable pressure differential shall be in accordance with standard 

operating practices and manufacturer's recommended operating parameters and shall 

be maintained between 2" and 5" of water column. The PC1-Multiclone unit shall be 

operated under negative pressure. Pressure differential readings shall be recorded on 

standard forms and kept on file at the facility for review by the DES upon request. 

The standard forms shall include the acceptable operating parameters for quick 

reference by facility personnel. 

bo Facility personnel shall conduct a daily inspection for visible emissions of the PC 

Multiclone unit to observe leaks, lfa leak(s) is observed, facility personnel shall take 

immediate steps to repair the leak. Daily observations, maintenance and repairs 

performed to the unit shall be recorded in the log book. 

During down-time maintenance periods, facility personnel shall inspect inlet and 

outlet vanes and boots for any build up of caked dust. All caked dust shall be 

removed during each down-time maintenance period. 

Observations of operating parameters outside of the standard operating practices 

included in this permit shall be recorded, investigated and corrected immediately. If 

this results in a permit limit exceedance, Hemphill personnel shall contact DES 

within 8 hours in accordance with Section XXX of this permit. 

2. PC2 ESP Monitoring and Testing Requirements 

The PC2-ESP is used to control particulate matter emissions. 

Bi-Hourly Monitoring/Testing Requirements 

In accordance with Hemphill's O&M manual and standard operating practices for 

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this equipment, on a bi-hourly basis, facility personnel shall: 

i. 

shall 

Check the primary voltage reading on the PC2 ESP. The primary voltage be maintained between 25 and 250 volts. Voltage readings outside this range indicate a malfunction with the PC2- ESP and the operator shall the malfunction immediately. correct 

_Comolianee Demonstration Requirements (continued), 

ii. The facility operator shall respond to all equipment alarms immediately. 

m. Every 4 hours, monitoring data shall be recorded on standard forms and kept on file at the facility for review by the DES forms upon request. The standard 

by 

shall include the acceptable operating parameters for quick reference facility personnel. 

iv. 

practices 

Observations of operating parameters outside of the standard operating 

immediately. 

included in this permit shall be recorded, investigated and corrected If this results in 

shall a permit limit exceedance, Hemphill personnel contact DES within 8 hours in accordance with Section XXX of this permit, 

bo Daily Monitoring/Testing Requirements 

The PC2-ESP shall be inspected at least 

and ducts once each shift. The casing, piping shall be inspected for leaks, abnormal noise, hot spots and fires. Local instrumentation shall be monitored for normal values. The local control panel shall be monitored for 

alarms. proper indication of normal values and 

ii. 

practices 

Observations of operating parameters outside of the standard operating 

immediately. 

included in this permit shall be recorded, investigated and corrected Ifthis results in 

shall a permit limit exceedance, Hemphill personnel contact DES within 8 hours in accordance with Section XXX of this permit. 

3. Stack Testing Requirements 

At such times 

stack test for emissions 

as specified by the DES, Hemphill shall conduct USEPA method compliance at maximum production rate conditions, and/or at the DES, at request of the any other production rate at which maxmaum emissions might occur. 

If 

Sections 

requested, 

60.8(a), 

the emissions 

(b), 

stack test shall be conducted in accordance with 40 CFR Part 60, 

Minimum Requirements (d), (e) and (f), Appendix A and the DES' policy "Procedures and for Stack Tests". 

Compliance testing shall be planned and carried out in accordance with the following 

h:•pcnnils\currcnl\lillevxamendments•tvhemph2.amd Revised4/I 3/00 
Page 14 

schedule. At least30 days prior to the commencement of testing, Hemphill shall submit to 

the DES a pretest report presenting the following information: 

a. Calibration methods and sample data sheets; 

b. Description of the test methods to be used; 

Compliance Demonstration Requirements (continued): 

c. Pre-test preparation procedures; 

d. Sample collection and analysis methods; 

e. Process data to be collected; and 

f. Complete test program description. 

If requested by DES, at least 15 days prior to the test date, Hemphill, and any contractor that 

Hemphill retains for performance of the test, shall participate in a pretest conference with a 

DES representative. Emission testing shall be carried out under the observation of a DES 

representative. Within 60 days after completion of testing, Hemphill shall submit a test 

report to the DES. 

Any compliance stack test results determined •bllowing 40 CFR Part 60 paragraph 60.8, 

which show violations of the emission limitations shall be considered violations of this 

permit. 

5. Stack Inspections 

In accordance with 40 CFR 70.6(a)(3), Hemphill shall conduct annual visual inspections of 

each stack and fuel burning device. Annual inspections shall include a thorough inspection 

of the condition of each stack exterior and each fuel burning device. Every 5 years, 

Hemphill shall inspect the interior of each stack for evidence of corrosion, cracks or holes. 

Records of inspections and subsequent maintenance conducted as a result of the annual 

inspections shall be kept on file at the facility for review by the DES and/or EPA upon 

request. 

CEM Monitoring/Testing Requirements 

(Regulatory Cite Env-A 805.02 and 40 CFR Part 70.6(a)(3)) 

Hemphill shall install, maintain and operate the following CEM systems in the EU1-Boiler exhaust 

piping. 

1. Opacity CEM 

The opacity CEM system shall meet the requirements of 40 CFR Part 60, Appendix B, 

h:•pcrmits\current\titlevXamendmcnls\lvhemph2.amd 

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Page 15 

limits 

Performance 

established 

Specification 

in 

1 and Env-A 805. Determination of compliance with the opacity Section VIII.C. of this permit shall be made by the plant opacity CEM visible emission readings taken or 

Part 60, Appendix once per shift following the procedures specified in 40 CFR A, Method 9. Calculations shall be performed X.B.6. of this as specified in Section permit. 

.Compliance Demonstration Requirements (continued), 

2. NOx CEM 

Specification 

The NOx CEM shall meet the requirements of 40 CFR Part 60, Appendix B, Performance 

established in 

2 and Env-A 805. Determination of compliance with the NOx emission limits 

emission 

Section VIII.C. of this permit shall be made by the plant NOx CEM. The NOx rate shall be calculated daily as the calculated on the plant NOx CEM. Calculations 

average of the calendar day averages as shall be performed X.B.6. of this as specified in Section permit. 

3. CO CEM 

The CO CEM system shall 

Performance Specification meet the requirements of 40 CFR Part 60, Appendix B, 

emission limits established 

4 and Env-A 805. Determination of compliance with the CO 

CEM. The CO 

in Section VIII.C. of this permit shall be made by the plant CO emission rate shall be calculated daily as the inaVerageSsectionaSX.B.6.calculatedof this°npermit.the average of the calendar day plant CO CEM. Calculations shall be performed as specified 

4. Carbon Dioxide (CO2) CEM 

The CO2 CEM system shall 

Performance Specification 

meet the requirements of 40 CFR Part 60, Appendix B, 3 and Env-A 805. 

5. Volumetric Flow CEM 

CFR 

The stacl• 

Part 60, 

volumetric 

Appendix 

flow measuring device which shall meet all of the requirements of 40 

an automatic blow-back 

B, Performance Specification 6. The stack flow monitor shall have 

operation. The 

purge system installed and activated during all times of boiler 

CEM equipment 

stack 

for 

volumetric flow measuring device combined with the concentration CO and NOx shall be used to calculate comparison with the mass emission rates for 

volumetric flow monitor 

emission standard specified in permit condition VIII.C. The stack shall also meet the following requirements: 

All differential pressure flow monitors shall have an automatic blow-back system installed and in purge wet stack emissions shall have the capability for drainage of 

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the sensing lines. 

The stack flow monitoring system shall have the capability for manual transducer 

calibration and for a zero check. 

c. The stack flow monitoring system shall be capable of displaying the individual 

parameters used in the stack flow calculation. For example, a differential pressure 

monitoring system shall be able to display instantaneous values of differential 

pressure, stack temperature, and relevant constants used in the calculation which 

reflect the static pressure assumed, gas molecular weight assumed and the pitot tube 

Compliance Demonstration Requirements (continued): 

coefficient utilized. 

6. Calculations: 

a. CEM calendar day averages shall be calculated as follows: 

Calendar Day average (sum of all valid hourly averages for the calendar 

day)/(24 hours of CEM system downtime for the day); 

ii. Calendar day averages shall only be valid for days with 18 or more valid 

hours of CEM data; 

iii. A valid hour of CEM data shall be defined as a minimum of 42 minutes 

collection of CEM readings taken in a calendar hour; and 

iv. Hours of CEM system downtime shall be defined as the number of calendar 

hours when the CEM system has not collected data or is out-of-control for 

greater than 18 minutes for any reason (i.e. audits, CEM system calibration, 

CEM system failures, etc.) 

b. CEM consecutive 365-day averages shall be calculated as follows: 

Consecutive 365-day average (sum of all valid calendar day averages for 

the 365-day period)/(365 days of CEM system downtime); and 

ii. Days of CEM system downtime shall be defined as the number of calendar 

days when the CEM system has collected less than 18 valid hours of CEM 

data. 

Co Hours or days when the CEM system has been intentionally shutdown when the 

facility is not operating shall not be counted as CEM system downtime. 

Hemphill shall be subject to all of the CEM requirements of Env-A 805 which shall include 

but not be limited to: quarterly audit requirements, excess emission report requirements, 

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quality control written procedure requirements for keepingrequirements. gaseous CEM monitors and record The specific record keeping and reporting requirements in Section are described X.C. and X.D. of this permit. 

Hemphill shall continuously monitor and record data from the all periods of gaseous CEM system during operation, including periods ofstartup, shutdown, malfunctions conditions, or emergency 

shall be continuously 

except when the stack flow is less than 23,000 wet SCFM. The opacity CEM 

regardless monitoring and recording data during all periods of operation, of the stack flow rate. 

.Compliance 

9. 

Demonstration 

Excess emissions indicated by the CEM system shall be considered violations of the Requirements (continued): 

applicable emission limit for purposes of this permit, except where Hemphill demonstrate can adequately to the DES that the recorded exceedance resulted from a CEM malfunction. 

10. Hemphill shall install, maintain and operate a continuous steam flow monitoring/recording rate 

Calibration 

system which shall meet all applicable ASME specifications. of the steam flow transducer and inspection of the orifice plates shall least occur at once annually. If adequate straight length of piping is not available, then in lieu of measuring system that a meets ASME specifications, Hemphill monitoring may use a steam flow rate system that can be calibrated by instruments installed, maintained and calibrated per ASME specifications or by other metl•ods approved by the DES. 

C. Record Keeping Requirements 

required 

In accordance 

monitoring 

with 40 CFR Part 70.6(a)(3)(ii)(B), Hemphill shall retain records of all 

for 

data, record keeping and reporting requirements and support information a period of at least 5 

not be discarded, 

years from the date of the origination. These data and reports shall 

director in 

removed or destroyed thereafter without the express written approval of the accordance with Env-A 901.11. 

In accordance with 40 CFR 70.6(c)(5), Hemphill shall certification meet the requirements for compliance 

limitations, 

with terms and conditions contained in this permit, including emission standards, or work practices. Compliance certifications shall requirements meet the outlined in Section XXIII of this permit. 

Pursuant to Env-A 901.03, for each fuel burning device at the facility, the shall keep records owner or operator on fuel utilization in accordance with the following: 

a. 

include: 

Monthly records of all fuel utilization for each fuel burning device at the facility shall 

consumption of each fuel type per calendar month and a consecutive 12- month total; 

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ii. fuel type; 

iii. viscosity; 

iv. sulfur content as percent sulfur by weight of liquid fuel; and 

v. BTU content per gallon of fuel. 

b. Delivery tickets from each fuel oil supplier for each shipment of fuel oil received 

shall be kept on file in a form suitable for inspection and shall be made available to 

the DES and/or EPA upon request. Each delivery ticket shall indicate the name, 

address and telephone number of the fuel oil supplier, the quantity offuel oil 

Compliance Demonstration Requirements (continued): 

delivered, and the percent sulfur by weight of the fuel oil being delivered. If 

delivery tickets do not contain sulfur content of fuel being delivered, Hemphill shall 

perform 

testing in accordance with appropriate ASTM test methods to determine compliance 

with the sulfur content limitation provisions in Env-A 1604.01 (a) and 1604.01 (c)2 

for liquid fuels. 

c. Records shall be kept of hours of operation corresponding to the utilization and 

distribution of all fuels including alternative operating scenarios. 

4. NOx Record Keeping Requirements 

In accordance with Env-A 901.08, for each fuel btu'ning device, including boilers, turbines 

and internal combustion engines, the following information shall be recorded and 

maintained: 

Facility information, including: 

i. Source name; 

ii. Source identification; 

iii. Physical address; 

iv. Mailing address; 

v. Date of origination for reports; 

vi. Facility contact and title; 

vii. Facility telephone number; 

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Identification of each fuel burning device at the facility. 

Operating schedule information for each identified fuel burning device, including: 

i. days per calendar week during the normal operating schedule 

ii. Hours per day during the normal operating schedule and for a typical ozone season day, if different from the normal operating schedule 

111. Hours per year during the normal operating schedule. 

Type and amount of fuel or waste burned, for each fuel burning device, during 

Xo .Compliance Demonstration Requirements (continued•.. 

normal operating conditions and for a typical normal ozone season day 3, if different from operating conditions, on an hourly basis in mmBTU/hr. 

e. The following NOx emission data, including records of total annual emissions, in tons per year (tpy), and typical (lbs/day), shall ozone season day emissions, in pounds per day be maintained at the facility for a minimum of 4 years: 

i. Theoretical potential emissions for the calculation device; year for each fuel burning and 

D° 

ii. Actual NOx emissions for each fuel burning device. 

Reporting Requirements 

shall 

In accordance 

be reported 

with Env-A 901.09(b), NOx emission data for all facility fuel burning devices to the DES annually by April 15 of the following shall be collected year. The NOx emissions from the CEM data. 

Malfunction Reporting 

In accordance with Env-A 902.02 and 40 CFR Part 70.6(a)(3)(iii)(B), the shall notify the DES of owner or operator a malfunction 

8 hours of each or breakdown of air pollution control equipment within such occurrence, as described in Section XXX of this permit. 

Fuel Usage Reporting 

In accordance with Env-A 901.08(c), monthly fuel and sulfur content of liquid usage information, by device, fuel type, fuel shall be submitted in writing to the DES on a quarterly basis 

Typical ozone season day is defined any day between May and October, 

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within 30 days after the end of the quarter for which reporting is required. 

Excess Emission Reporting 

In accordance with Env-A 805, within 30 days following the close of each calendar quarter, 

Hemphill shall submit to the DES excess emission reports for the CEM systems and the EU1 

Boiler as approved by the DES containing information specified in Env-A 805 as well as 

the following information: 

ao Calendar daily averages of NOx and CO lb/hr and part per million (ppm) dry whether 

or not an excess emission has occurred; 

b. Calendar daily averages of percentage carbon dioxide (COz) on a wet basis; 

Compliance Demonstration Requirements (continued): 

c. Calendar daily averages of steam generation rate; 

d. Calendar daily averages of stack flow (dscfm); 

eo Average steam production rate for each consecutive 24-hour period where the 

production rate exceeds any of the limits set forth in Section VIII.C. of this permit; 

f. CEM system availability data; 

Estimated amount in tons (wet basis) of wood chips consumption per month and a 

consecutive twelve month total; 

Amount in gallons of fuel consumption per calendar month where the fuel usage cap 

set forth in Section VIII.C. 1 of this permit has been exceeded. 

All periods of gaseous and opacity exceedances including start time, end time and 

magnitude and the cause of the exceedance. 

5. CEM Audit Reporting 

Within 30 days following the close of each calendar quarter, Hemphill shall submit to the 

DES, a CEM audit report for all audits conducted as specified in Env-A 805.06 and Section 

X.B. of this permit. 

In accordance with 40 CFR 70.6(a)(3)(iii)(A), a summary report of monitoring and testing 

requirements shall be submitted every six months. Semi-annual reports shall be submitted no 

later than July 31 for the January through June report and no later than January 31 for the 

July through December report. All instances of deviations from permit requirements shall be 

clearly identified in such reports. All required reports shall be certified for accuracy by a 

responsible official consistent with 40 CFR 70.5(d). This certification and any other 

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included 

certification 

in Section 

required 

XXIII.B. 

under this part shall include the certification of accuracy statement of this permit. 

The report shall contain a summary of the following information: 

a. Monitoring and preventive maintenance results for PC1 through PC2. 

b. Preventive 

EU2-EG and 

maintenance 

EU3-Chipper. 

and inspection results for EU1-Boiler and related stacks, 

c. All instances of deviations from permit requirements shall be clearly identified. 

Annual 

Section 

reporting 

XXV of this 

and payment of emission based fees shall be conducted in accordance with Permit. 

An annual compliance certification 

submitted to DES as presented in Section XXIII of this Permit shall be and USEPA by April 15 following each reporting year. 

Pursuant 

contain certification 

to 40 CFR Part 70.6 (c)(l), all documents submitted to the DES and/or EPA shall by the responsible official of truth, accuracy, and completeness described in Section XXIII.B. of this as permit. 

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XI. Requirements Currently Not Applicable: 

The Permitee did not identify any requirements not currently applicable to the facility. 

General Title V Operating Permit Conditions 

XlI. Issuance of a Title V Operatine Permit: 

Ao This Permit is issued in accordance with the provisions of Part Env-A 609. In accordance with 40 

CFR 70.6(a)(2) this Permit shall expire on the date specified on the cover page of this Permit, which 

shall not be later than the date five (5) years after issuance of this Permit. 

Permit expiration terminates the Permittee's right to operate the Permittee's emission units, control 

equipment or associated equipment covered by this permit, unless a timely and complete renewal 

application is submitted at least 6 months before the expiration date. 

Bt Pursuant to Env-A 609.02(b), this Permit shall be a state permit to operate as defined in RSA 125- 

C:ll, III. 

XIII. Title V Operating Permit Renewal Procedures: 

Pursuant to Env-A 609.06(b), an application for renewal of this Permit shall be considered timely if it is 

submitted to the Director at least six months prior'to the designated expiration date of this Permit. 

XIV. Application Shield: 

Pursuant to Env-A 609.07, if an applicant submits a timely and complete application for the issuance or 

renewal of a Permit, the failure to have a Permit shall not be considered a violation of this part until the 

Director takes final action on the application. 

XV. Permit Shield: 

A. Pursuant to Env-A 609.08(a), a permit shield shall provide that: 

For any applicable requirement or any state requirement found in the New Hampshire Rules 

Governing the Control of Air Pollution specifically included in this Permit, compliance with 

the conditions of this Permit shall be deemed compliance with said applicable requirement or 

said state requirement as of the date of permit issuance; and 

For any potential applicable requirement or any potential state requirement found in the New 

Hampshire Rules Governing the Control of Air Pollution specifically identified in this TitleV 

Operating Permit Section XI as not applicable to the stationary source or area source, the 

Permittee need not comply with the specifically identified federal or state requirements. 

Uo The permit shield identified in Section XV.A. of this Permit shall apply only to those conditions 

incorporated into this Permit in accordance with the provisions of Env-A 609.08(b). It shall not 

hApermits\eurrent\litlov•amendmenls\tvhemph2.amd 

Revised4/I 3/00 
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apply to certain conditions following as specified in Env-A 609.08(c) that may be Incorporated into this Permit permit issuance by DES. 

Ifa Title V Operating Permit and amendments there to issued by the DES does not expressly include or exclude 

Control an applicable requirement or a state requirement found in the NH Rules Governing the of Air Pollution, that applicable requirement permit or state requirement shall not be covered by the 

that it applies 

shield and the Permit-tee shall comply with the provisions of said requirement to the extent to the Permittee. 

If the DES determines that this Title V Operating Permit was issuedbased upon inaccurate incomplete information provided or by the applicant or Permittee, Title any permit shield provisions in said V Operating Permit shall be void as to the portions of said Title V Operating Permit which affected, directly are or indirectly, by the inaccurate or incomplete information. 

Pursuant to Env-A 609.08(0, nothing contained in Section XV of this Permit shall alter ability or affect the of the DES to reopen this Permit for cause in accordance with Env-A 609. 8 or to exercise its summary abatement authority. 

Pursuant to Env-A 609.08(g), nothing contained in this section or in issued by the any title V operating permit DES shall alter or affect the following: 

The ability of the DES to order abatement requiring immediate compliance with applicable requirements upon finding that there is health, an imminent and substantial endangerment to public welfare, or the environment; 

The state of New Hampshire's ability to bring an enforcement action pursuant to RSA 125- C:15,II; 

The provisions of section 303 of the Act regarding emergency orders including the authority of the EPA Administrator under that section; 

The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance; 

The applicable requirements of the acid rain program, consistent with section 408(a) of the Act; 

The ability of the DES or the EPA Administrator to obtain information about a stationary source, area source, or device from the owner or operator pursuant to section 114 of the Act; or 

The ability of the DES or the EPA Administrator to enter, inspect, and/or monitor stationary a source, area source, or device. 

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XVI. Reopening for Cause: 

The Director shall reopen and revise a Title V Operating Permit for cause if any of the circumstances 

contained in Env-A 609.18(a) exist. In all proceedings to reopen and reissue a Title V Operating Permit, the 

Director shall follow the provisions specified in Env-A 609.18(b) through (g). 

XVII. Administrative Permit Amendments: 

Ao Pursuant to Env-A 612.01, the Permittee may implementthe changes addressed in the request for an 

administrative permit amendment as defined in Part Env-A 100 immediately upon submittal of the 

request. 

no Pursuant to Env-A 612.01, the Director shall take final action on a request for an administrative 

permit amendment in accordance with the provisions of Env-A 612.01 (b) and (c). 

XVIII. Operational Flexibility: 

Am Pursuant to Env-A 612.02(a), the Permittee subject to and operating under this Title V Operating 

Permit may make changes involving trading of emissions under this existing Title V Operating 

Permit at the permitted stationary source or area source without filing a Title V Operating Permit 

application for and obtaining an amended Title V Operating Permit, provided that all the conditions 

are met as specified in section XVIII. A. 1. through 7. of this permit and a notice is submitted to the 

DES and EPA describing the intended changes. At this point, DES has not included any permit terms 

authorizing emissions trading in this permit. 

1. The change is not a modification under any provision of title I of the Act; 

The changedoes not cause emissions to exceed the emissions allowable under the 

title V operating permit, whether expressed therein as a rate of emissions or in terms 

of total emissions; 

3. The owner or operator has obtained any temporary permit required by Env-A 600; 

The owner or operator has provided written notification to the director and 

administrator at least 15 days prior to the proposed change and such written 

notification includes: 

a. The date on which each proposed change will occur; 

b. A description of each such change; 

Co Any change in emissions that will result and how this change in emissions 

will comply with the terms and conditions of the permit; 

d. A written request that the operational fiexibility procedures be used; and 

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Revised4/13/00 
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XIX. 

e. The signature of the responsible official, consistent with Env-A 605.04(b); 

The Title V Operating Permit issued to the stationary source or area source already contains terms and conditions including all terms and conditions which determine compliance required under 40 CFR 70.6(a) and (c) and which allow for the trading of 

solely 

emissions increases and decreases at the permitted stationary source or area source for the purpose of complying with a federally-enforceable emissions cap that is established in the permit independent of otherwise applicable requirements; 

The owner or operator has included in the application for the Title V Operating Permit proposed replicable procedures and proposed permit terms which ensure that the emissions trades are quantifiable and federally enforceable for changes to the Title V Operating Permit which qualify under a federally- enforceable emissions that cap is established in the Title V Operating Permit independent of the otherwise applicable requirements; and 

7. The proposed change complies with Env-A 612.02 (e). 

Pursuant to Env-A 612.02(c), the Permittee subject to and operating under this Title V Operating Permit may mak• changes not addressed 

the permitted stationary or prohibited by this existing Title V Operating Permit at source or area source w•thout filing a Title V Operating Permit application, provided that all the conditions specified in Env-A 612.02(c)(1) through (6) are met and submitted a notice is to the DES and EPA describing the intended changes. 

Pursuant to Env-A 612.02(d), the Permittee, Operator, Director and Administrator shall attach each notice of an off-permit change completed in accordance with Section XVIII of this Title V Operating Permit to their copy of the current Title V Operating Pemait. 

Pursuant to Env-A 612.02(e), any change under Section XVII1 shall not exceed any emissions limitations established under the NH Rules Governing the Control of Air Pollution, or result in increase in emissions, an or result in new emissions, of any toxic air pollutant or hazardous air pollutant other than those listed in the existing Permit. 

Eo Pursuant to Env-A 612.02(f), the off-permit change shall not qualify for the permit shield under Env- A 609.08. 

.,Minor Permit Amendments. 

A. Pursuant to Env-A 612.04 prior to implementing submit a minor permit modification, the Permittee shall a written request to the Director in accordance with the requirements of Env-A 612.04(b). 

B. The Director shall take final action 

provisions on the minor permit amendment request in accordance with the of Env-A 612.04(c) through (g). 

C. Pursuant to Env-A 612.04(g), the permit shield specified in Env-A 609.08 shall not apply to minor 

Revised4113100 
Page 26 

permit amendments under Section XIX. of this Permit. 

Pursuant to Env-A 612.04(i), the Permittee shall be subject to the provisions of Part Env-A 614 and 

Part Env-A 615 if the change is made. prior to the filing with the Director a request for a minor 

permit amendment. 

XX. Significant Permit Amendments: 

At Pursuant to Env-A 612.05, a change at the facility shall qualify as a significant permit amendment if 

it meets the criteria specified in Env-A 612.05(a)(1) through (7). 

Prior to implementing the significant permit amendment, the Permittee shall submit a written request 

to the Director which includes all the information as referenced in Env-A 612.05(b) and (c) and shall 

be issued an amended Title V Operating Permit from the DES. ThePermittee shall be subject to the 

provisions of Env-A 614 and Env-A 615 ifa request for a significant permit amendment is not filed 

with the Director and/or the change is made prior to the issuance of an amended Title V Operating 

Permit. 

The Director shall take final action on the significant permit amendment in accordance with the 

procedures specified in Env-A 612.05(d), (e) and (f). 

XXI. Title V Operating Permit Suspension, Revocation or Nullification: 

Pursuant to RSA 125-C: 13, the Director may suspend or revoke any fmal permit issued hereunder if, 

following a hearing, the Director determines that: 

the Permittee has committed a violation of any applicable statute or state requirement found 

in the New Hampshire Rules Governing the Control of Air Pollution, order or permit 

condition in force and applicable to it; or 

that the emissions from any device to which this Permit applies, alone or in conjunction with 

other sources of the same pollutants, presents an immediate danger to the public health. 

Bo The Director shall nullify any Permit, if following a hearing in accordance with RSA 541-A:30, II, a 

finding is made that the Permit was issued in whole or in part based .upon any information proven to 

be intentionally false or misleading. 

XXII. Inspection and Entry: 

Pursuant to Env-A 614.01, EPA and DES personnel shall be granted access to the facility covered by this 

Permit, in accordance with RSA 125-C:6,VII for the purposes of: inspecting the proposed or permitted site; 

investigating a complaint; and assuring compliance with any applicable requirement or state requirement 

found in the NH Rules Governing the Control of Air Pollution and/or conditions of any Permit issued 

pursuant to Chapter Env-A 600. 

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XXlII..Certifications: 

A. Compliance Certification Report 

In accordance with 40 CFR 70.6(c) the Responsible Official shall certify, for the previous calender year, that the facility is in compliance with the requirements of this permit. The report shall be submitted annually, no later than April 15th of the following the year. The report shall be submitted to DES and to the U.S. Environmental Protection Agency New England Region. The report shall be submitted in compliance with the submission requirements below. 

In accordance with 40 CFR 70.6(c)(5), the report shall describe: 

The terms and conditions of the Permit that are the basis of the certification; 

The current compliance status of the source with respect to the terms and conditions of this Permit, and whether the method was continuous or intermittent during the reporting period; 

The methods used for determining compliance, including a description of the monitoring, record keeping, and reporting requirements and test methods; and 

Any additional information required by the DES to determine the compliance status of the source. 

B. Certification of Accuracy Statement 

All documents submitted to the DES shall contain 

official a certification of accuracy statement by the responsible 

requirements 

of truth, accuracy, and completeness. Such certification shall be in accordance with the of 40 CFR 70.5(d) and contain the following language: 

"I am authorized to make this submission on behalf of the facility for which the submission is made. Based on information and belief formed after reasonable inquiry, I certify that the statements and information in the enclosed documents are to the best of my knowledge and belief true, accurate and complete. I am aware that there are significant penalties for submitting false statements and information or omitting required statements and information, including the possibility of free imprisonment." or 

All reports submitted to DES (except those submitted as emission based fees this as outlined in Section XXV of Permit) shall be submitted to the following address; 

New Hampshire Department of Environmental Services 

Air Resources Division 

6 Hazen Drive 

P.O. Box 95 

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Concord, NH 03302-0095 

ATTN: Compliance Bureau 

All reports submitted to EPA shall be submitted to the following address; 

Office of Environmental Stewardship 

Director Air Compliance Program 

United States Environmental Protection Agency 

1 Congress Street 

Suite 1100 (SEA) 

Boston, MA 02114-2023 

ATTN: Air Compliance Clerk 

XXIV. Enforcement: 

Any noncompliance with a permit condition constitutes a violation of RSA 125-C:15, and, as to the 

conditions in this permit which are federally enforceable, a violation of the Clean Air Act, 42 U.S.C. 

Section 7401 et seq., and is grounds for enforcement action, for permit termination or revocation, or for 

denial of an operating permit renewal application by the DES and/or EPA. Noncompliance may also be 

grounds for assessment of administrative, civil or criminal penalties in accordance with RSA 125-C: 15 

and/or the Clean Air Act. This Permit does not relieve the Permittee from the obligation to comply with any 

other provisions of RSA 125-C, the New Hampshire Rules Governing the Control of Air Pollution, or the 

Clean Air Act, or to obtain any other necessary authorizations from other governmental agencies, or to 

comply with all other applicable Federal, State, or Local rules and regulations, not addressed in this Permit. 

In accordance with 40 CFR 70.6 (a)(6)(ii) a Permittee shall not claim as a defense in an enforcement action 

that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance 

with the conditions of this Pernait. 

Emission-Based Fee Requirements: 

Ao The Permittee shall pay an emission-based fee annually for this facility as calculated each calendar 

year pursuant to Env-A 704.03. 

The Permittee shall determine the total actual annual emissions from the facility to be included in the 

emission-based multiplier specified in Env-A 704.03(a) for each calendar year in accordance with 

the methods specified in Env-A 620. 

C. The Permittee shall calculate the annual emission-based fee for each calendar year in accordance 

FEE E * DPT * CPIm * ISF 

with the procedures specified in Env-A 704.03 and the following equation: 

Where: 

FEE The annual emission-based fee for each calendar year as specified in Env-A 704. 

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E The emission-based multiplier is based on the calculation of total annual emissions as specified in Env-A 704.02 and the provisions specified in Env-A 704.03(a). DPT The dollar per ton fee the DES has specified in Env-A 704.03(b). CPIm= The Consumer Price Index Multiplier as calculated in Env-A 704.03(c). ISF The Inventory Stabilization Factor as specified in Env-A 704.03(d). 

The Permittee shall contact the DES each calendar year for the value of the Inventory Stabilization Factor. 

Et The Permittee shall contact the DES each calendar year for the value of the Consumer Price Index Multiplier. 

Fo The Permittee shall submit, to the DES, payment of the emission-based fee and a summary of the calculations referenced in Sections XXV.B. and C of this Permit for each calendar year by October 15 th of the following calendar year in accordance with Env-A 704.04. The emission-based fee and summary of the calculations shall be submitted to the following address: 

New Hampshire Department of Environmental Services 

Air Resources Division 

6 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

ATTN.: Emissions Inventory 

Go The DES shall notify the Permittee of any under payments or over payments of the annual emission- based fee in accordance with Env-A 704.05. 

XXVI. Duty To Provide Information 

In accordance with 40 CFR 70.6 (a)(6)(v), upon the DES's written request, the Permittee shall furnish, within a reasonable time, any information necessary for determining whether cause exists for modifying, revoking and reissuing, or terminating the Permit, or to determine compliance with the Permit. Upon request, the Permittee shall furnish to the DES copies of records that the Permittee is required to retain by this Permit. The Permittee may make a claim of confidentiality as to any information submitted this condition pursuant to in accordance with Part Env-A 103 at the time such information is submitted to DES. DES shall evaluate such requests in accordance with the provisions of Part Env-A 103. 

XXVII. • 

Pursuant to 40 CFR 70.6 (a)(6)(iv), this Permit does not convey any property rights of exclusive privilege. any sort, or any 

XXVIII. _Severabilitv Clause 

Pursuant to 40 CFR 70.6 (a)(5), the provisions of this Permit are severable, and if any provision of this Permit, or the application of any provision of this Permit to any circumstances is held invalid, the application of such provision to other circumstances, and the remainder of this Permit, shall not be affected thereby. 

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Emergency Conditions 

Pursuant to 40 CFR 70.6 (g), the Permittee shall be shielded from enforcement action brought for 

noncompliance with technology based 4 emission limitations specified in this Permit as a result of an 

emergency s. In order to use emergency as an affirmative defense to an action brought for noncompliance, 

the Permittee shall demonstrate the affirmative defense through properly signed, contemporaneous operating 

logs, or other relevant evidence that: 

A. An emergency occurred and that the Permittee can identify the cause(s) of the emergency; 

B. The permitted facility was at the time being properly operated; 

Co During the period of the emergency, the Permittee took all reasonable steps as expeditiously as 

possible, to minimize levels of emissions that exceeded the emissions standards, or other 

requirements in this Permit; and 

Do The Permittee submitted notice of the emergency to the DES within two (2) business days of the 

time when emission limitations were exceeded due to the emergency. This notice must contain a 

description of the emergency, any steps taken to mitigate emission, and corrective actions taken. 

Permit Deviation 

In accordance with 40 CFR 70.6(a)(3)(iii)(B), the Permittee shall report to the DES all instances of 

deviations from Permit requirements, by telephone or fax, within 8 hours of discovery of such deviation 

pursuant to Env-A 902.02. This report shall include the deviation itself, including those attributable to upset 

conditions as defined in the Permit, the probable cause of such deviations, and any corrective actions or 

preventative measures taken. Said Permit deviation shall also be submitted in writing to the DES within 

fifteen (15) days of documentation of the deviation by facility personnel. Deviations are instances where any 

Permit condition is violated and has not already been reported as an emergency pursuant to Section XXIX of 

this Permit. 

Reporting a Permit deviation is not an affirmative defense for action brought for noncompliance. 

Technology based emission limits are those established on the basis of emission reductions achievable with various 

control measures or process changes (e.g., a new source performance standard) rather thanthose established to attain 

health based air quality standards. 

An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of 

the source, including acts of God, which situation would require immediate corrective action to restore normal operation, 

and that causes the source to exceed a technology based limitation under the permit, due to unavoidable increases in 

emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by 

improperly designed equipment, lack of preventative maintenance, careless or improper operations, operator error or 

decision to keep operating despite knowledge of any of these things. 

h:kpermils\eurrent\tiflev•mendmenls\ivhernph2.amd 

Roviscd4/l 3/00 
STATE OF NEW HAMPSHIRE 

Department of Environmental Services 

Air Resources Division 

Title V Operating Permit 

Permit No: TV-OP-007 

Date 

November 

Issued: January 11, 1999, Amended November 15, 1999, April 12, 2000, June 26, 2001, & 15, 2001 

This certifies that: 

AES Ecotek Holdings LLC 

100 Pine Street, Suite 3300 

San Francisco, CA 94111 

has been granted a Title V Operating Permit for the following facility and location: Whitefield Power and Light Company Airport Road 

Whitefield, Nit 

Coos County 

AFS No. 3300700010 

Operating 

This Title V 

Permit 

Operating Permit is hereby issued under the terms and conditions specified in the Title V 

Resources 

Application filed with the New Hampshire Department of Environmental Services Air 

submitted 

Division (DES) on April 10, 1996 and the supplemental information for the Title V application 

certifying on September 23, 1996 and March 9, 1998 under the signature of the following responsible official to the best of their knowledge that the statements and information therein complete. are true, accurate and 

Responsible Official: 

Douglas York 

Operations Manager 

(603) 837-9328 

Technical Contact: 

Anthony J. Colella 

ENSR Manager, Air Services 

(978) 595-3000 

with 

This 

the 

Permit 

provisions 

is issued by the DES pursuant to its authority under New Hampshire RSA 125-C and in accordance of Code of the Federal Regulations 40 Part 70. 

This Title V Operating Permit shall expire on January 31, 2004. 

.SEE ATTACHED SHEETS FOR ADDITIONAL PERMIT CONDITIONS For the New Hampshire Department of Environmental Services, Air Resource Division 
Director, Air Resources Division 

TABLE OF CONTENTS 

I. 

II. 

III. 

IV. 

V. 

VI. 

VII. 

VIII. 

IX. 

XI. 

XIII. 

XIV. 

XV. 

XVI. 

XVlI. 

XVIII. 

XIX. 

XX. 

XXI. 

XXII. 

XXIII. 

:.•.'•,•':•.',-.• •':;.,.•'.• •-2-':'•: '•,'!:;:-.' ::•{ "'!-") •{:_ £•7'.- ,=•::'i',2..:,',.'::?v'<:'U•;./•'!•,•,[,i,•'.: :k 

Facili• Description of Operations 4 

Permitted Activities 

Significant Activities Identification and Stack Criteria Tables 1 & 2 

Insignificant Activities Identification 

Exempt Activities Identification 

Pollution Control Equipment Identification Table 3 

Alternative Operating Scenarios Table 4 

Applicable Operational and Emission Limitations 

Emission Reductions Trading Requirements 

Compliance Demonstration Requirements 

-Monitoring and Testing Requirements 

-Record Keeping and Reporting Requirements 

Requirements Not Currently Applicable 

Issuance of a Title V Operating Permit 

Title V Operating Permit Renewal Procedures 

Application Shield 

Permit Shield 

Reopening for Cause 

4 

4-6 

6 

6-7 

7-8 

8-11 

11 

11-20 

21 

21 

21 

21 

21-22 

23 

Administrative Permit Amendments 23 

Operational Flexibility 23-24 

Minor Permit Amendments 24-25 

Significant Permit Amendments 25 

Title V Operating Permit Suspension, Revocation or Nullifieation 25 

Inspection and Entry 25 

Certifications 26-27 
Page 3 

XXIV. 

XXV. 

XXVI. 

XXVII. 

Enforcement 

Emission Based Fee Requirements 

Duty to Provide Information 

Property Rights 

XXVIII,. • Clause 

XXX. 2 Permit Malfunctions and Deviations 

27 

27-28 

28 

28 
Page 4 

Facility Specific Title V Operating Permit Conditions 

I. Facility. Description of Operations: 

Whitefield Power and Light Company (Whitefield) is located on Ha•en Road in Whitefield, New 

Hampshire. The electric generating station is designed to consume wood fuel consisting of sawmill residue 

and/or whole tree chips to generate 16 MW (gross) of electrical power. Propane and/or natural gas is 

proposed to be used as an alternate fuel to fire an auxiliary burner. 

II. Permitted Activities: 

In accordance with all of the provisions of the New Hampshire Rules Governing the Control of Air Pollution 

(effective date 12/31/96) and as revised thereafter, the permittee is authorized to operate the devices and or 

processes identified in Sections III, IV, V and VI, within the terms and conditions specified in this Permit, 

III. Significant Activities Identification and Stack Criteria: 

A. Significant Activity Identification 

Yhe activities identified in the following table (Table 1) are subject to and regulated by this Title V 

Operating Permit: 

Table Significant Activity Identification 

Emissioh U: Description of Emission Unit Exhaust Stackldentifi ation Emissions Unit Maxi• um 

Number Design Capacity 

(EU#) 

EU1 -Boiler Babcock and Wilcox •/oodof'h--•d Boiler 

with 

Detroit Stoker Propane/Natural Gas 

Burner (Model DB-21-SS-0 l-G) 

CumminsEmergency Diesel Generator 

Stack #1 

EU2 EG Stack #2 

Maximum Firing Rate of 220 

mmBTU/hr with wood 

60 mmBTU/hr with propane 

470 hp operating less than 500 

hours per year, firing rate 

of 3.621 mmBTU/hr, 

25.5 gal/hr of diesel 

III. 

Based on equipment design, the maximum operating rate of the EU1 Boiler shall be limited 

to a total of 220 million BTU per hour (mmBTU/hr) gross heat input. This is the equivalent 

of 152,000 pounds per hour (lbs/hr) of steam production as averaged over any consecutive 

30-day period at 900 degrees F and 885 PSIG assuming a boiler efficiency of 68% and boiler 

feedwater temperature of 443 degrees F. 

Based on facility operations, fuel fed to the EU1 Boiler shall consist of any of the 

following: 

a. Whole tree wood chips at approximately 55% 

mmBTU/ton). 

Significant Activities Identification and Stack Criteria (continued): 

moisture (approximately 7.65 

h:pennits•eur•enl\litlevkamendrnnt\twvhite2.amd 

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bo Clean processed wood fuel (approximately 7.65 mmBTU/ton to 13.5 mmBTURon). 

Clean processed wood fuel and whole tree wood chips at approximately 55% moisture. 

Clean processed wood fuel and/or whole tree wood chips and specification used oil. 

Clean processed wood fuel and/or whole tree wood chips and propane or natural gas at maximum 15 grains sulfur per 100 cubic feet. 

Propane or natural gas proposed fbr startup and flame stabilization only at maximum 15 grains sulfur per 100 cubic feet. 

Based on equipment design and 365 operating days per year, the maximum wood consumption by the EU1 Boiler shall be limited to 252,000 tons wet basis of whole tree wood chips at approximately 55% moisture (7.65 mmBTU/ton) during any consecutive twelve month period. 

B. Stack Criteria 

The following stack for the above listed significant devices at this facility shall discharge vertically without obstruction (including rain caps) and meet the following criteria in accordance with the state-only air pollution dispersion modeling requirements specified in Env-A 606. 

Stack #1 EU1-Boiler 

Stack #2 EU2-EG 

145 

8.5 

Maxiinum Stack Diameter( 

6.5 

0.666 

Preauthorized changes to the state-only requirements pertaining to stack parameters (set forth in this permit) shall be permitted only when an air quality impact analysis meeting the criteria of Part Env-A 606 is performed either by the facility or by the DES (if requested by the facility in writing) in accordance with the "NHARD Policy and Procedure for Air Quality Impact Modeling". All air modeling data shall be kept on file at the facility for review by the DES upon request. 

1Clean processed wood fuel is considered to be fuel that exhibits fuel characteristics equivalent to "whole tree wood chips" and "sawdust" with respect to the ultimate and proximate analysis of the fuel. 

h:pctmlls•eurrent•titlovXamendrnntgtwvhile2.araO 

Revised4112100 
Page 6 

III. Significant Activities Identification and Stack Criteria (continued): 

C. Modified Operations 

Whitefield is proposing to modify facility operations by installing a 60 mmBTU/hr 

propane/natural gas burner in conjunction with the existing wood-fired boiler. The proposed 

propane/natural gas burner is a Detroit Stoker Burner Model DB-21-SS-01-G. At this time, the 

proposed propane/natural gas burner is tentative and installation is not scheduled. Whitefield's 

current method of starting fires in the firebox consists of manually adding paper and woodchips 

and igniting them by hand. The proposed propane/natural gas burner, if installed, will be used to 

establish fire in the wood-fired boiler, ibr flame stabilization and to maintain minimum boiler 

operating level during maintenance and malfunction activities. The proposed propane/natural 

gas burner would also be used to control CO emissions should alternative fuels such as sawdust 

become more viable. Fire will be established by igniting wood chips that have been placed in the 

fire box with flames generated by the propane/natural gas burner. With the propane/natural gas 

burner, fires will be established in the fire box more efficiently with less smoke generated when 

compared to the current hand igniting method. Whitefield indicates that overall emissions will 

decrease during boiler startup when using the propane/natural gas burner. 

IV. Insignificant Activities Identification: 

Wo 

VI. 

All activities at this facility that meet the criteria identified in the New Hampshire Rules Governing the 

Control of Air Pollution Part Env-A 609.03(g), shall be considered insignificant activities. Emissions 

from the insignificant activities shall be included in the total facility emissions for the emission-based 

fee calculation described in Section XXV of this Title V Operating Permit. 

Exempt Activities Identification: 

All activities identified in the New Hampshire Rules Governing the Control of Air Pollution Part Env-A 

609.03(c) shall be considered exempt activities and shall not be subject to. or regulated by this Title V 

Operating Permit. 

Pollution Control Equipment Identification: 

The devices and/or processes identified in Table 3 below are considered pollution control equipment for 

the identified eniissions unit. 

Pollution C ipt q 

PC1-Multiclone Multiclone primary particulate control for the EU1 Boil'er EU1-Boiler 

h:p rmits\eutreafl\t itlev•amend mnl\lvwhile2,amd 

Revised4/12/00 
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• able3 •:Pollutio trolEquipmehtI•et•ifi•afi •i •"•_•"• •. i"" :•-i• • :• 

PC2-ESP El•ctrosiatic P•ecipitat0r (ESP)- secondary particulatecontrol for the EU1-Boiler EU1 B°iler 

VI. Pollution Control Equipment Identification (continued): 

mo All equipment, facilities and systems installed and used to achieve compliance with the terms and conditions of this permit shall at all times be maintained in good working order and shall be operated as efficiently as possible so as to minimize air pollutant emissions and meet all applicable air pollutant emission limits. These controls shall be fully operational upon facility startup and shall not be bypassed during startup, operation or shutdown of the steam generating unit. 

The pollution control equipment shall be maintained regularly, in accordance with the manufacturer's Operation and Maintenance (O&M) manual and based on the schedules as described in Sections VIII.A. and X.A. 

VII. Alternative Operating Scenarios: 

Whitefield requested the alternative operating scenario of burning used oil in their Title V application. Whitefield proposed to bum up to 1,000 gallons of on-site generated specification used oil in the EU1- Boiler as an auxiliary fuel. The specification used oil shall meet the criteria for specification used oil described as in Waste Management Rules Env-Wm 807.02 and shown in Table 4 below: 

A. The oil shall not be mixed with hazardous waste; and 

The oil shall meet all of the standards in the following table and shall not otherwise exhibit any of the hazardous waste characteristics specified in Env-Wm 403. 

Arsenic 

Cadmium 

Chromium 

5.0 ppm maximum 

2.0 ppm maximum 

10 ppm maximum 

100 ppm maximum Lead 

PCBs Less than 2 ppm 

Total Halogens 1,000 ppm maximum 

Flash Point 100 degrees F minimum 

h:p ermils\eu•renl\iitlov•a nt\tvwhite2.amd Revised4/12/00 
Page 8 

The sulfur content of the specification used oil shall be limited to 0.4% by weight and the gross heat 

input of used oil shall be limited to 25 mmBTU/hr (approximately 180 gallons per hour) on an average 

annual basis. 

VII. Alternative Operating Scenarios (continued): 

VIII. 

Based on proposed usage description, Whitefield shall not use more than 55 gallons of specification 

used oil mixed with 25 tons (full truck load) of sawdust. Whitefield shall not use more than 1,000 

gallons of specification used oil during any consecutive 365-day period. Whitefield shall only burn 

specification used oil generated at the Whitefield facility in the EU1-Boiler. Whitefield shall store and 

handle the specification used oil in accordance with all applicable state and federal regulations. 

Whitefield shall monitor compliance with the used oil specifications by conducting at least one fuel 

analysis certifying compliance with Env-Wm 807.02 and the sulfur content of 0.4% by weight per 

calendar year. This data shall be retained at the facility in accordance with record keeping requirements 

described in Section X.C. of this permit. 

Applicable Operational and Emission Limitations: 

Whitefield is subject to the following operational and emission limitations as contained in this permit. 

A. Operational Limitations 

Based on equipment design, the maximum operating rate of the EU1-Boiler shall be limited to a 

total of 220 mmBTU/hr gross heat input with wood and 60 mmBTU/hr with propane. This is 

equivalent to 152,000 lbs/hr of steam production as averaged over any consecutive 30-day period 

at 900 degrees F and 885 PSIG assuming a boiler efficiency of 68% and boiler feedwater 

temperature of 443 degrees F. 

To operationally control CO emissions in accordance with Env-A 305, Whitefield shall comply 

with the following operational limitations. 

Whitefield shall control CO emissions by varying the total quantity of input combustion air 

and/or the local distribution of that air into the EU1 Boiler. The amount of combustion air 

required to optimize the EU1 Boiler efficiency and reduce CO emissions is dependent on the 

wood moisture content and the type of wood, among other factors. The steam generating unit 

shall be equipped with a fuel distribution, overfire air and undergrate air control systems for 

optimum NOx and CO emission control. 

B. State-Only Applicable Emission Limitations 

In accordance with Env-A 1002.03, Whitefield shall take precautions to prevent, abate 

and control the emission-of fugitive dust for those activities contained in Env-A 1002.02. 

Such precautions shall include wetting, covering, shielding or vacuuming. 

h:p ermits\eu•rcnt\litlev•amend mnt\t hile2.amd 

Revised4/I 2/00 
Page 9 

New or modified devices, new or modified area sources, and existing devices or area sources for which new applications for permits are filed that have the potential.to emit, in any amount, substances that meet the criteria of Env-A 1301 shall be subject to Env-A 1300, until such time as the Env-A 1400 requirements supersede the Env-A 1300 requirements. 

VIII. Applicable Operational and Emission Limitations (continued): 

Air quality impact analysis of devices and area sources emitting substances meeting the criteria of Env-A 1301 shall be performed in accordance with the "DES Policy and Procedure for Air Quality Impact Modeling" or other comparable dispersion modeling methods approved by EPA. 

In accordance with Env-A 1403.01, new or modified devices or processes installed after May 8, 1998, shall be subject to the requirements of Env-A 1400. 

In accordance with 1403.02(a), all existing unmodified devices or processes which are in operation during the transition period ending three years from May 8, 1998 (May 8, 2001), shall comply with either Env-A 1300 or Env-A 1400. 

In accordance with Env-A 1403.02(b), all existing devices or processes in operation after the transition period ending three years from May 8, 1998 (May 8, 2001), shall comply with Env-A 1400. Env-A 1300 will no longer be in effect. 

In accordance with Env-A 1404.01 (d), documentation for the demonstration of compliance shall be retained at the site, and shall be made available to the DES for inspection. 

In accordance with Env-A 1405.02, the owner of an existing device permit or process requiring a modification under Env-A 1400 shall submit to the DES no later than one year prior to the end of the transition period (by May 8, 2000), an application for a modification to a Title V permit in accordance with Env-A 609.18, and a request to the DES to perform air dispersion modeling. 

In accordance with Env-A 2003.04 (d), exceedances of the opacity standard shall not be considered violations of this part if the facility demonstrates to the division that such exceedances were the result of the adherence to good boiler operating practices which, in the long. term, results in the most efficient or safe operation of the boiler. 

10. In accordance with Env-A 2003.04 (e)(2), opacity exceedances experienced during periods of cold startup of a boiler over a continuous period of time resulting in efficient heat-up and stabilization of its operation and the expeditious achievement of normal operation of the unit shall not be considered violations. 

11. In accordance with Env-A 2003.04 (f), exceedances of the opacity standard shall not be 

:p ennlls•urrent•title v•amendmnt \lvwhilo2. Revised4/l 
Page 10 

considered violations of this part if the source demonstrates to the DES that such 

exceedances were the result of the occurrence of an unplanned incident in which the 

opacity exceedance was beyond the control of the operator and in response to such an 

incident, the operator took appropriate steps in conformance with good boiler operating 

practice to eliminate the excess opacity as quickly as possible. 

VIII. 

C. 

Applicable Operational and Emission Limitations (continued): 

Federally Enforceable Emission Limitations 

In accordance with Env-A 1211.020)(1 and 2), EU2-EG shall be limited to less than 500 

hours of operation during any consecutive 12-month period and the combined theoretical 

potential emissions of NOx from all such generators are limited to less than 25 tons for 

any consecutive 12-month period. 

In accordance with Env-A 1211.04(d) and Env-A 1211.05(d)(5), the EU1 Boiler, firing 

wood fuel or capable of firing a combination of wood fuel and oil and equipped with a 

vibrating grate, shall comply with the oxides of nitrogen (NOx) Reasonably Available 

Control Technology (RACT) emission limit of 0.33 pounds per million BTU 

(lb/mmBTU), based on a 24-hour calendar day average. 

In accordance with Env-A 1604.01(a), the su.lfur content of No. 2 oil, specification used 

oil and off-road diesel oil shall not exceed 0.40 percent sulfur by weight. 

In accordance with Env-A 1605.0,1, the sulfur content of propane/natural gas shall not 

exceed 15 grains of sulfur per 100 cubic feet. 

In accordance with Env-A 2003.02 and 40CFR Part 60, Subpart Db, Whitefield shall not 

cause or allow average opacity from fuel burning devices installed after May 13, 1970 in 

excess of 20 percent for any continuous 6-minute period in any 60-minute period. The 

EU 1-Boiler may apply one of the following exemptions in accordance with Env-A 

2003.04(a): 

During periods of startup, shutdown and malfunction, average opacity shall be 

allowed to be in excess of 20 percent for one period of 6 continuous minutes in 

any 60 minute period; or 

During periods of normal operation, soot blowing, grate cleaning, and cleaning of 

fires, average opacity shall be allowed to be in excess of 20 percent but not more 

than 27 percent for one period of 6 continuous minutes in any 60 minute period. 

To avoid the requirements of the federal Prevention of Significant Deterioration (PSD) 

regulation 40 CFR 52.21 (b)(1)(i)(b), the combined NOx emission rate for the facility fuel 

burning devices, including the EU1-Boiler and the EU2-EG shall be limited to 57.0 

h:pennils\current\tillev•amendmnt\t•vhite2.arad 

Revised4/12/00 
Page 11 

pounds per hour (lbs/hr) average for any consecutive 365-day period. Compliance with this emission limit shall be demonstrated using the NOx CEM data. 

To avoid the requirements of the federal PSD regulation 40 CFR 52.21(b)(1)(i)(b), the combined carbon monoxide (CO).. emission rate_for the facility fuel burning devices, including the EU1-Boiler and the EU2-EG shall be limited to 57.0 Ibs/hr average for any consecutive 365-day period. 

VIII. Al•licable Operational and Emission Limitations (continued): 

In accordance with RSA 125-C:6, RSA 125-C: 11 and Env-A 606.04, the combined carbon monoxide (C•O) emission rate for the facility fuel burning devices, including the EU1-Boiler and the EU2-EG shall be limited to 225 lbs/hr for each calendar day average as calculated on the CEM system or using the calculation shown in Section X.B.6. of this permit. 

In accordance with 40 CFR Part 60, Subpart Db, the PM emission rate for the EU1 Boiler shall be limited to 0.10 lb/mmBTU heat input. 

10. Continuous Emission Monitoring (CEM) requirements are described in Section X.]3. of this permit. 

IX. Emission Reductions Trading Requirements: 

Xo 

The Permittee did not request emissions reductions trading in the facility operating permit application. At the time of this permit preparation, DES did not included any permit terms authorizing emissions trading in this permit. All emissions reductions trading must be authorized under the. applicable requirements of either Env-A 3000 (the "Emissions Reductions Credits (or ERcs) Env-A-3100 (the Trading Program") or "Discrete Emissions Reductions (or DERs) Trading Program) and 42 U.S.C. §7401 et seq. (The "Act"), and must be provided for in this Permit." 

Compliance Demonstration Requirements. 

The permittee is subject to the monitoring/testing, record keeping and reporting requirements contained as in the following permit sections. Refer to the standard operating practices and the manufacturer's O&M manual for additional information. The pollution control equipment and EU1 Boiler shall be monitored and maintained in accordance with the appropriate manufacturers' O&M manuals. 

Monitoring/Testing Requirements for Total Suspended Particulate Controls (Regulatory cite- Env-A 806.01(a) and 40 CFR Part 70.6(a)(3)) 

1. PC 1 Multiclone Monitoring and Testing Requirements 

The PC1-Multiclone shall be operated in series with the PC2-ESP unit. 

h:permils\eurrent\litlev•amendrnnt\tvwhite2.amd 

Rcvised4/I 2/00 
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Xo 

a. Conduct monitoring of pressure differential across the PC1 Multiclone unit at 

least once each shift. An acceptable pressure differential shall be in accordance 

with standard operating practices and manufacturer's recommended operating 

parameters and shall be maintained between 2" and 5" of water column. The 

PC1-Multiclone unit shall be operated under negative pressure. Pressure 

differential readings shall be recorded on standard •orms and kept on file at the 

facility for review by the DES upon request. The standard forms shall include the 

acceptable operating parameters for quick reference by facility personnel. 

Compliance Demonstration Requirements (continued): 

Facility personnel shall conduct a daily inspection for visible emissions of the 

PC1 Multiclone unit to observe leaks. Ifa leak(s) is observed, facility personnel 

shall take immediate steps to repair the leak. Daily observations, maintenance 

and repairs performed to the unit shall be recorded in the log book. 

During down-time maintenance periods, facility personnel shall inspect inlet and 

outlet vanes and boots for any build up of caked dust. All caked dust shall be 

removed during each down-time maintenance period. 

Observations of operating parameters outside of the standard operating practices 

included in this permit shall be recorded, investigated and corrected immediately. 

If this results in a permit limit exceedance, Whitefield personnel shall contact 

DES within 8 hours in accordance with Section XXX of this permit. 

2. PC2 ESP Monitoring and-Testing Requirements 

The PC2-ESP is used to control particulate matter emissions. The PC2-ESP is digitally 

controlled to maintain 3-7% opacity. The computer automatically controls the voltage 

input of the PC2-ESP to maintain the opacity emissions in this range. 

a. Bi-Hourly Monitoring/Testing Requiremems 

In accordance with Whitefield's O&M manual and standard operating practices 

for this equipmem, on a bi-hourly basis, facility personnel shall: 

Check and record the primary voltage reading on the PC2 ESP. The 

primary voltage is controlled digitally and shall be maintained between 25 

and 250 volts. Voltage readings outside this range indicate a malfunction 

with the PC2- ESP and the computer control should notify the operator 

with an alarm. The PC2-ESP is digitally controlled to maintain opacity 

between 3% and 7%. The computer control notifies the operator if the 

opacity exceeds this range. 

li. The facility operator shall respond to all equipment alarms immediately. 

nnils\curr t\litlev•amendmnt\tvwhite2.a 

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Bi-hourly monitoring data shall be recorded daily on standard forms and kept on file at the facility for review by the DES upon request. The standard forms shall include the acceptable operating parameters for quick reference by facility persolmel. 

iv. Observations of operating parameters outside of the standard operating practices included in this permit shall be recorded, investigated and corrected immediately. If this results in a permit limit exceedance, Whitefield personnel shall contact DES within 8 hours in accordance with Section XXX of this permit. Comolianee Demonstration Requirements (eontinued}. 

b. Daily Monitoring/Testing Requirements 

The PC2-ESP shall be inspected at least once each shift. The casing, piping and ducts shall be inspected for leaks, abnormal noise, hot spots and fires. Local instrumentation shall be monitored for normal values. The local control panel shall be monitored for proper indication of normal values and alarms. 

ii. Observations of operating parameters outside of the standard operating practices included in this permit shall be recorded, investigated and corrected immediately. If this results in a permit limit exceedance, Whitefield personnel shall contact DES within 8 hours in accordance with Section XXX of this permit. 

Stack Testing Requirements 

At such times specified by the DES, Whitefield shall conduct USEPA method compliance stack tests for emissions at maximum production rate conditions, and/or at the request of the DES, at any other production rate at which maximum emissions might occur. 

If requested, the emissions stack test shall be conducted in accordance with 40 CFR Part 60, Sections 60.8(a), (b); (d), (e) and (f), Appendix A and the DES' policy "Procedures and Minimum Requirements for Stack Tests". 

Compliance testing shall be planned and carried out in accordance with the following schedule• At least 30 days prior to the commencement of testing, Whitefield shall submit to the DES a pretest report presenting the following information: 

Calibration methods and sample data sheets; 

Description of the test methods to be used; 

c. Pre-test preparation procedures; 

h:p ennils\eurrent\tillev•am endra nt\•vwhile2.ara Revised4/I 2/00 
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d. Sample collection and analysis methods; 

e. Process data to be collected; and 

f. Complete test program description. 

If requested by DES, at least 15 days prior to the test date, Whitefield, and any contractor 

that Whitefield retains for performance of the test, shall participate in a pretest 

conference with a DES representative. Emission testing shall be carried out under the 

observation of 

Compliance Demonstration Requirements (continued): 

a DES representative. Within 60 days after completion of testing, Whitefield shall submit 

a test report to the DES. 

Any compliance stack test results determined following 40 CFR Part 60 paragraph 60.8, 

which show violations of the emission limitations shall be considered violations of this 

permit. 

5. Stack Inspections 

In accordance with 40 CFR 70.6(a)(3), Whitefield shall conduct annual visual inspections 

of each stack and fuel burning device. Annual inspections shall include a thorough 

inspection of the condition of each stack exterior and each fuel burning device. Every 5 

years, Whitefield shall inspect the interior of each stack for evidence of corrosion, cracks 

or holes. Records of inspections and subsequent maintenance conducted as a result of the 

annual inspections shall be kept on file at the facility for review by the DES and/or EPA 

upon request. 

CEM Monitoring/Testing Requirements 

(Regulatory Cite Env-A 805.02 and 40 CFR Part 70.6(a)(3)) 

Whitefield shall install, maintain and operate the following CEM systems in the EU1-Boiler 

exhaust piping. 

1, Opacity CEM 

The opacity CEM system shall meet the requirements of 40 CFR Part 60, Appendix B, 

Performance Specification 1 and Env-A 805. Determination of compliance with the 

opacity limits established in Section VIII.C. of this permit shall be made by the plant 

opacity CEM or visible emission readings taken once per shift following the procedures 

specified in 40 CFR Part 60, Appendix A, Method 9. Calculations shall be performed as 

specified in Section X.B.6. of this permit. 

h:permits\eurrent\titlev•amendmnt\twvhite2.amd 
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NOx CEM 

The NOx CEM shall meet the requlrements of 40 CFR Part 60, Appendix B, Performance Specification 2 and Env-A 805. Determination of compliance with the NOx emission limits established in Section VIII.C. of this permit shall be made by the plant NOx CEM. The NO× emission rate shall be calculated daily as the average of the calendarday averages as calculated on the plant NOx CEM. Calculations shall be performed as specified in Section X.B,6. of this permit. 

Xo Compliance Demonstration Requirements (continued): 

3. CO CEM 

The CO CEM system shall meet the requirements of 40 CFR Part 60, Appendix B, Performance Specification 4 and Env-A 805. Determination of compliance with the CO emission limits established in Section VIII.C. of this permit shall be made by the plant CO CEM. The CO emission rate shall be calculated daily as the average of the calendar day averages as calculated on the plant CO CEM. Calculations shall be performed as specified in Section X.B.6. of this permit. 

4. Carbon Dioxide (CO2) CEM 

.The CO 2 CEM system shall meet the requirements of 40 CFR Part 60, Appendix B, Performance Specification 3 and Env-A 805. 

5. Volumetric Flow CEM 

The stack volumetric flow measuring device which shall meet all of the requirements of 40 CFR Part 60, Appendix B, Performance Specification 6. The stack flow monitor shall have an automatic blow-back purge system installed and activated during all times of boiler operation. The stack volumetric flow measuring device combined with the concentration CEM equipment for CO and NOx shall be used to calculate mass emission rates for comparison with the emission standard specified in permit condition VIII.C. The stack volumetric flow monitor shall also meet the following requirements: 

ao All differential pressure flow monitors shall have an automatic blow-back purge system installed and in wet stack emissions shall have the capability for drainage of the sensing lines. 

The stack flow monitoring system shall have the capability for manual transducer calibration and for a zero check. 

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The stack flow monitoring system shall be capable of displaying the individual 

parameters used in the stack flow calculation. For example, a differential pressure 

monitoring system shall be able to display instantaneous values of differential 

pressure, stack temperature, and relevant constants used in the calculation which 

reflect the static pressure assumed, gas molecular weight assumed and the pitot 

tube coefficient utilized. 

6. Calculations: 

a. CEM calendar day averages shall be calculated as follows: 

Calendar Day average (sum of all valid hourly averages for the calendar 

day)/(24 hours of CEM system downtime for the day); 

Compliance Demonstration Requirements (continued): 

ii. Calendar day averages shall only be valid for days with 18 or more valid 

hours of CEM data; 

iii. A valid hour of CEM data shall be defined as a minimum of 42 minutes 

collection of CEM readings taken in a calendar hour; and 

iv. Hours of CEM system downtime shall be defined as the number of 

calendar hours when the CEM system has not collected data or is out-ofcontrol for greater than 18 minutes for any reason (i.e. audits, CEM system 

calibration, CEM system failures, etc.) 

b. CEM consecutive 365-day averages shall be calculated as follows: 

Consecutive 365-day average (sum of all valid calendar day averages for 

the 365-day period)/(365 days of CEM system downtime); and 

ii. Days of CEM system downtime shall be defined as the number of calendar 

days when the CEM system has collected less than 18 valid hours of CEM 

data. 

Hours or days when the CEM system has been intentionally shutdown when the 

facility is not operating shall not be counted as CEM system downtime. 

Whitefield shall be subject to all of the CEM requirements of Env-A 805 which shall 

include but not be limited to: quarterly audit requirements, excess emission report 

requirements, quality control written procedure requirements for gaseous CEM monitors 

and record keeping requirements. The specific record keeping and reporting 

requirements are described in Section X.C. and X.D. of this permit. 

8. Whitefield shall continuously monitor and record data from the gaseous CEM system 

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Page 17 

during all periods of operation, including periods of startup, shutdown, malfunctions or emergency conditions, except when the stack flow is less than 23,000 wet SCFM. The opacity CEM shall be continuously monitoring and recording data during all periods of operation, regardless of the stack fiow rate. 

Excess emissions indicated by the CEM system shall be considered violations of the applicable emission limit for purposes of this permit, except where Whitefield can adequately demonstrate to the DES that the recorded exceedance resulted from a CEM malfunction. 

10. Whitefield shall install, maintain and operate a continuous steam flow rate monitoring/recording system which Shall meet all applicable ASME specifications. Calibration of the steam flow transducer and inspection of the orifice plates shall occur at least once annually. If adequate straight length of piping is not available, then in lieu of a measuring system that meets ASME specifications, Whitefield Compliance may use a steam flow rate Demonstration Requirements (continued): 

C. Record 

monitoring system that can be calibrated by instruments installed, maintained and calibrated per ASME specifications or by other methods approved by the DES. 

Keeping Requirements 

In accordance with 40 CFR Part 70.6(a)(3)(ii)(B), Whitefield shall retain records of all required monitoring data, record keeping and reporting requirements and support informati.on for a period of at least 5 years from the date of the origination. These data and reports shall not be discarded, removed or destroyed thereafter without the express written approval of the director in accordance with Env-A 901.11. 

In accordance with 40 CFR 70.6(c)(5), Whitefield shall meet the requirements for compliance certification with terms and conditions contained in this permit, including emission limitations, standards, or work practices. Compliance certifications shall meet the requirements outlined in Section XXIII of this permit. 

Pursuant to Env-A 901.03, for each fuel burning device at the facility, the owner or operator shall keep records on fuel utilization in accordance with the following: 

ao Monthly records of all fuel utilization for each fuel burning device at the facility shall include: 

consumption of each fuel type per calendar month and a consecutive 12- 

month total; 

ii. fuel type; 

iii. viscosity; 

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Xo 

iv. sulfur content as percent sulfur by weight of liquid fuel; and 

Page 18 

v. BTU content per gallon of fuel. 

Delivery tickets from each fuel oil supplier for each shipment of fuel oil received1 

shall be kept on file in a form suitable for inspection and shall be made available 

to the DES and/or EPA upon request. Each delivery ticket shall indicate the 

name, address and telephone number of the fuel oil supplier, the quantity of fuel 

oil delivered, and the percent sulfur by weight of the fuel oil being delivered. If 

delivery tickets do not contain sulfur content of fuel being delivered, Whitefield 

shall perform testing in accordance with appropriate ASTM test methods to 

determine compliance withthe sulfur content limitation provisions in Env-A 

1604.01(a) and 1604.01(c)2 for liquid fuels. 

c. Records shall be kept of hours of operation corresponding to the utilization and 

distribution of all fuels. 

Compliance Demonstration Requirements (continued): 

4. NOx Record Keeping Requirements 

In accordance with Env-A 901.08, for each fuel burning device, including boilers, 

turbines and internal combustion engines, the following information shall be recorded 

and maintained: 

a. Facility information, including: 

i. Source name; 

ii. Source identification; 

iii. Physical address; 

iv. Mailing address; 

v. Date of origination for reports; 

vi. Facility contact and title; 

vii. Facility telephone number; 

b. Identification of each fuel burning device at the facility. 

c. Operating schedule information for each identified fuel burning device, including: 

i. days per calendar week during the normal operating schedule 

Revised4/12/00 
ii. 

Page 19 

Hours per day during the normal operating schedule and for a typical ozone season day, if different from the normal operating schedule 

iii. Hours per year during the normal operating schedule. 

Type and amount of fuel or waste burned, for each fuel burning device, during normal operating conditions and for a typical ozone season day •, if different from normal operating conditions, on an hourly basis in mmBTU/hr. 

The following NOx emission data, including records of total annual emissions, in tons per year (tpy), and typical ozone season day emissions, in pounds per day (lbs/day), shall be maintained at the facility for a minimum of 4 years: 

XD Compliance Demonstration Requirements (continued), 

Theoretical potential emissions for the calculation year for each fuel burning device; and 

Do 

ii. Actual NOx emissions for each fuel burning device. 

Reporting Requirements 

In accordance with Env-A 901.09(b), NOx emission data for all facility fuel burning devices shall be reported to the DES annually by April 15 of the following year. The NOx emissions shall be collected from the CEM data. 

2. Malfunction Reporting 

In accordance with Env-A 902.02 and 40 CFR Part 70.6(a)(3)(iii)(B), the owner or operator shall notify the DES of a malfunction or breakdown of air pollution control equipment within 8 hours of each such occurrence, as described in Section XXX of this permit. 

3. Fuel Usage Reporting 

In accordance with Env-A 901.08(c), monthly fuel usage information, by device, fuel 

quarterly 

type, and sulfur content of liquid fuel shall be submitted in writing to the DES on a basis within 30 days after the end of the quarter for which reporting is required. 

Typical ozone season day is defined any day between May and October. 

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4. Excess Emission Reporting 

In accordance with Env-A 805, within 30 days following the close of each calendar 

quarter, Whitefield shall submit to the DES excess emission reports for the CEM systems 

and the EU1 Boiler as approved by the DES containing information specified in Env-A 

805 as well as the following information: 

ao Calendar daily averages of NOx and CO lb/hr and part per million (ppm) dry 

whether or not an excess emission has occurred; 

b, Calendar daily averages of percentage carbon dioxide (C02) on a wet basis; 

c. Calendar daily averages of steam generation rate; 

d. Calendar daily averages of stack flow (dscfm); 

eo Average steam production rate for each consecutive 24-hour period where the 

production rate exceeds any of the limits set forth in Section VIII.C. of this 

permit; 

f. CEM system availability data; 

Compliance Demonstration Requirements (continued): 

Estimated amount in tons (wet basis) of wood chips consumption per month and a 

consecutive twelve month total; 

h° Amount in gallons of fuel consumption per calend•ir month where the fuel usage 

cap set forth in Section VIII.C.1 of this permit has been exceeded. 

All periods of gaseous and opacity exceedances including start time, end time and 

magnitude and the cause of the exceedance. 

5. CEM Audit Reporting 

Within 30 days following the close of each calendar quarter, Whitefield shall submit to 

the DES, a CEM audit report for all audits conducted as specified in Env-A 805.06 and 

Section X.B. of this permit. 

In accordance with 40 CFR 70.6(a)(3)(iii)(A), a summary report of monitoring and 

testing requirements shall be submitted every six months. Semi-annual reports shall be 

submitted no later than July 31 for the January through June report and no later than 

January 31 for the July through December report. All instances of deviations from permit 

requirements shall be clearly identified in such reports. All required reports shall be 

certified for accuracy by a responsible official consistent with 40 CFR 70.5(d). This 

certification and any other certification required under this part shall include the 

certification of accuracy statement included in Section XXIII.B. of this permit. 

h:p ermils•euffent\tillev•mend t\tvwhite2.a md 

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The report shall contain a summary of the following information: 

a. Monitoring and preventive maintenance results for PC through PC2. 

bo Preventive maintenance and inspection results for EU1-Boiler and related stacks and EU2-EG. 

c. All instances of deviations from permit requirements shall be clearly identified. 

Annual r•porting and payment of emission based fees shall be conducted in accordance with Section XXV of this Permit. 

An annual compliance certification as presented in Section XXIII of this Permit shall be submitted to DES and USEPA by April 15 following each reporting year. 

Pursuant to 40 CFR Part 70.6 (c)(1), all documents submitted to the DES and/or EPA shall contain certification by the responsible official of truth, accuracy, and completeness as described in Section XXIII.B. of this permit. 

XI. Requirements Currently Not Applicable: 

Whitefield did not request that any non-applicable requirements be specifically listed in this permit. 

General Title V Operating Permit Conditions 

XII. Issuance of a Title V Operating Permit: 

Ao This Permit is issued in accordance with the provisions of Part Env-A 609. In accordance with 40 CFR 70.6(a)(2) this Permit shall expire on the date specified on the cover page of this Permit, which shall not be later than the date five (5) years after issuance of this Permit. 

no 

Permit expiration terminates the Permittee's right to operate the Permittee's emission units, control equipment or associated equipment covered by this permit, unless a timely and complete renewal application is submitted at least 6 months before the expiration date. 

Pursuant to Env-A 609.02(b), this Permit shall be a state permit to operate as defined in RSA 125-C:11, III. 

XIII. Title V Operating Permit Renewal Procedures: 

Pursuant to Env-A 609.06(b), an application for renewal of this Permit shall be considered timely if it is submitted to the Director at least six months prior to the designated expiration date of this Permit. 

h:permlls\eurrent\till0v•amendmnt\twvhito2.amd 

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XIV. 

Page 22 

Application Shield: 

Pursuant to Env-A 609.07, if an applicant submits a timely and complete application for the issuance or 

renewal of a Permit, the failure to have a Permit shall not be considered a violation of this part until the 

Director takes final action on the application. 

XV. Permit Shield: 

A. Pursuant to Env-A 609.08(a), a permit shield shall provide that: 

For any applicable requirement or any state requirement found in the New Hampshire 

Rules Governing the Control of Air Pollution specifically included in this Permit, 

compliance with the conditions of this Permit shall be deemed compliance with said 

applicable requirement or said state requirement as of the date of permit issuance; and 

For any potential applicable requirement or any potential state requirement found in the 

New Hampshire Rules Governing the Control of Air Pollution specifically identified in 

this TitleV Operating Permit Section XI as not applicable to the stationary source or area 

source, the Permittee need not comply with the specifically identified federal or state 

requirements. 

The permit shield identified in Section XV.A. of this Permit shall apply only to those conditions 

incorporated into this Permit in accordance with the provisions of Env-A 609.08(b). It shall not 

apply to certain conditions as specified in Env-A 609.08(c) that may be incorporated into this 

Permit following permit issuance by DES. 

If a Title V Operating Permit and amendments there to issued by the DES does not expressly 

include or exclude an applicable requirement or a state requirement found in the NH Rules 

Governing the Control of Air Pollution, that applicable requirement or state requirement shall 

not be covered by the permit shield and the Permittee shall comply with the provisions of said 

requirement to the extent that it applies to the Permittee. 

If the DES determines that this Title V Operating Permit was issued based upon inaccurate or 

incomplete information provided by the applicant or Permittee, any permit shield provisions in 

said Title V Operating Permit shall be void as to the portions of said Title V Operating Permit 

which are affected, directly or indirectly, by the inaccurate or incomplete information. 

Et Pursuant to Env-A 609.08(0, nothing contained in Section XV of this Permit shall alter or affect 

the ability of the DES to reopen this Permit for cause in accordance with Env-A 609.18 or to 

exercise its summary abatement authority: 

Pursuant to Env-A 609.08(g), nothing contained in this section or in any title V operating permit 

issued by the DES shall alter or affect the following: 

The ability of the DES to order abatement requiring immediate compliance with 

applicable requirements upon fmding that there is an imminent and substantial 

h:permils\currcnt\tiflev•amendmnt\tvwhite2.amd 

Revised4/12/00 
Page 23 

endangerment to public health, welfare, or the environment; 

The state of New Hampshire's ability to bring an enforcement action pursuant to RSA 

125-C: 15,II; 

The provisions of section 303 of the Act regarding emergency orders including the authority of the EPA Administrator under that section; 

The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance; 

The applicable requirements of the acid rain program, consistent with section 408(a) of the Act; 

The ability of the DES or the EPA Administrator to obtain information about a stationary source, area source, or device from the owner or operator pursuant to section 114 of the Act; or 

The ability of the DES or the EPA Administrator to enter, inspect, and/or monitor a stationary source, area source, or device. 

Revised4/12100 
Page 24 

XVI. Reopening for Cause: 

The Director shall reopen and revise a Title V Operating Permit for cause if any of the circumstances 

contained in Env-A 609.18(a) exist. In all proceedings to reopen and reissue a Title V Operating Permit, 

the Director shall follow the provisions specified in Env-A 609.18(b) through (g). 

XVII. Administrative Permit Amendments: 

Pursuant to Env-A 612.01, the Permittee may implement the changes addressed in the request for 

an administrative permit amendment as defined in Part Env-A 100 immediately upon submittal 

of the request. 

no Pursuant to Env-A 612.01, the Director shall take final action on a request for an administrative 

permit amendment in accordance with the provisions of Env-A 612.01 (b) and (c). 

XVIII. Operational Flexibili .ty: 

Ao Pursuant to Env-A 612.02(a), the Permittee subject to and operating under this Title V Operating 

Permit may make changes involving trading of emissions under this existing Title V Operating 

Permit at the permitted stationary source or area sottrce without filing a Title V Operating Permit 

application for and obtaining an amended Title V Operating Permit, provided that all the 

conditions are met as specified in section XVIII. A. 1. through 7 of this permit and a notice is 

submitted to the DES and EPA describing the intended changes. At this point, DES has not 

included any permit terms authorizing emissions trading in this permit. 

1. The change is not a modification under any provision of title I of the Act; 

The change does not cause emissions to exceed the emissiolas allowable under the 

title V operating permit, whether expressed therein as a rate of emissions or in 

terms of total emissions; 

3. The owner or operator has obtained any temporary permit required by Env-A 600; 

The owner or operator has provided written notification to the director and 

administrator at least 15 days prior to the proposed change and such written 

notification includes: 

a. The date on which each proposed change will occur; 

b. A description of each such change; 

Co Any change in emissions that will result and how this change in emissions 

will comply with the terms and conditions of the permit; 

d. A written request that the operational flexibility procedures be used; and 

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Revise, d4/I 2/00 
Page 25 

XIX. 

e. The signature of the responsible official, consistent with Env-A 605.04(b); 

The Title V Operating Permit issued to the stationary source or area source already contains terms and conditions including all terms and conditions which determine compliance required under 40 CFR 70.6(a) and (c) and which allow for the trading of emissions increases and decreases at the permitted stationary source or area source solely for the purpose of complying with a federally-enforceable emissions cap that is established in the permit independent of otherwise applicable requirements; 

The owner or operator has included in the application for the Title V Operating Permit proposed replicable procedures and proposed permit terms which ensure that the emissions trades are quantifiable and federally enforceable for changes to 

the Title V Operating Permit which qualify under a federally- enforceable 

emissions cap that is established in the Title V Operating Permit independent of the otherwise applicable requirements; and 

7. The proposed change complies with Env-A 612.02 (e). 

Pursuant to Env-A 612.02(C), the Permittee subject to and operating under this Title V Operating Permit may make changes not addressed or prohibited by this existing Title V Operating Permit at the permitted stationary source or area source without filing a Title V Operating Permit application, provided that all the conditions specified in Env-A 612.02(c)(1) through (6) are met and a notice is submitted to the DES and EPA describing the intended changes. 

Pursuant to Env-A 612.02(d), the Permittee, Operator, Director and Administrator shall attach each notice of an off-permit change completed in accordance with Section XVIII of this Title V Operating Permit to their copy of the current Title V Operating Permit. 

Do Pursuant to Env-A 612.02(e), any change under Section XVIII shall not exceed any emissions limitations established under the NH Rules Governing the Control of Air Pollution, or result in an increase in emissions, or result in new emissions, of any toxic air pollutant or hazardous air pollutant other than those listed in the existing Permit. 

Pursuant to Env-A 612.02(f), the off-permit change shall not qualify for the permit shield under Env-A 609.08. 

Minor Permit Amendments: 

At Pursuant to Env-A 612.04 prior to implementing a minor permit modification, the Permittee shall submit a written request to the Director in accordance with the requirements of Env-A 612.04(b). 

The Director shall take final action on the minor permit amendment request in accordance with the provisions of Env-A 612.04(c) through (g). 

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Revised4112/O0 
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Co Pursuant to Env-A 612.04(g), the permit shield specified in Env-A 609.08 shall not apply to 

minor permit amendments under Section XVII. of this Permit. 

Do Pursuant to Env-A 612.04(i), the Permittee shall be subject to the provisions of Part Env-A 614 

and Part Env-A 615 if the change is made prior to the filing with the Director a request for a 

minor permit amendment. 

XX. Significant Permit Amendments: 

Ao Pursuant to Env-A 612.05, a change at the facility shall qualify as a significant permit 

amendment if it meets the criteria specified in Env-A 612.05 (a)(1) through (7). 

Bo Prior to implementing the significant permit amendment, the Permittee shall submit a written 

request to the Director which includes all the information as referenced in Env-A 612.05(b) and 

(c) and shall be issued an amended Title V Operating Permit from the DES. The Permittee shall 

be subject to the provisions of Env-A 614 and Env-A 615 ifa request for a significant permit 

amendment is not filed with the Director and/or the change is made prior to the issuance of an 

amended Title V Operating Permit. 

Co The Director shall take final action on the significant permit amendment in accordance with the 

procedures specified in Env-A 612.05(d), (e) and (f). 

XXI. Title V Operating Permit Suspension• Revocation or Nullification: 

Ao Pursuant to RSA 125-C: 13, the Director may suspend or revoke any final permit issued 

hereunder if, following a hearing, the Director determines that: 

the Permittee has committed a violation of any applicable statute or state requirement 

found in the New Hampshire Rules Governing the Control of Air Pollution, order or 

permit condition in force and applicable to it; or 

that the emissions from any device to which this Permit applies; alone Or in conjunction 

with other sources of the same pollutants, presents an immediate danger to the public 

health. 

Bo The Director shall nullify any Permit, if following a hearing in accordance with RSA 541-A:30, 

II, a finding is made that the Permit was issued in whole or in part based upon any information 

proven to be intentionally false or misleading. 

XXII. Inspection and Entry: 

Pursuant to Env-A 614.01, EPA and DES personnel shall be granted access to the facility covered by 

this Permit, in accordance with RSA 125-C:6,VII for the purposes of: inspecting the proposed or 

permitted site; investigating a complaint; and assuring compliance with any applicable requirement or 

state requirement found in the NH Rules Governing the Control of Air Pollution and/or conditions of 

h:permils\eurrenl\titlov•amendmnt\tvwhile2.amd 

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any Permit issued pursuant to Chapter Env-A 600. 

Page 27 

XXIII. Certifications: 

A. Compliance Certification Report 

In accordance w•th 40 CFR 70.6(c) the Responsible Official shall certify, for the previous calender year, that the facility is in compliance with the requirements of this permit. The report shall be submitted annually, no later than April 15th of the following year. The report shall be 

submitted to the DES and to the U.S. Environmental Protection Agency New England Region. The report shall be submitted in compliance with the submission requirements below. 

In accordance with 40 CFR 70.6(c)(5), the report shall describe: 

1. The terms and conditions of the Permit that are the basis of the certification; 

The current compliance status of the source with respect to the terms and conditions of 

this Permit, and whether the method was continuous or intermittent during the reporting period; 

The methods used for determining compliance, including a description of the monitoring, record keeping, and reporting requirements and test methods; and 

Any additional information required by the DES to determine the compliance status of 

the source. 

B. Certification of Accuracy Statement 

All documents submitted to the DES shall contain a certification of accuracy statement by the responsible official of truth, accuracy, and completeness. Such certification shall be in accordance with the requirements of 40 CFR 70.5(d) and contain the following language: 

"I am authorized to make this submission on behalf of the facility for which the submission is made. Based on information and belief formed after reasonable inquiry, I certify that the 

statements and information in the enclosed documents are to the best of my knowledge and belief true, accurate and complete. I am aware that there are significant penalties for submitting false 

statements and information or omitting required statements and information, including the possibility of fine or imprisonment." 

All reports submitted to DES (except those submitted as emission based fees as outlined in Section 

XXV of this Permit) shall be submitted to the following address; 

New Hampshire Department of Environmental Services 

Air Resources Division 

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6 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

ATTN: Compliance Bureau 

All reports submitted to EPA shall be submitted to the following address; 

Office of Environmental Stewardship 

Director Air Compliance Program 

United States Environmental Protection Agency 

Congress Street 

Suite 1100 (SEA) 

Boston, MA 02114-2023 

ATTN: Air Compliance Clerk 

XXIV. Enforcement: 

Any noncompliance with a permit condition constitutes a violation of RSA 125-C:15, and, as to the 

conditions in this permit which are federally enforceable, a violation of the Clean Air Act, 42 

U.S.C. Section 7401 et seq., and is grounds for enforcement action, for permit termination or revocation, 

or for denial of an operating permit renewal application by the DES and/or EPA. Noncompliance may 

also be grounds for assessment of administrative, civil or criminal penalties in accordance with RSA 

125-C:15 and/or the Clean Air Act. This Permit does not relieve the Permittee from the obligation to 

comply with any other provisions of RSA 125-C, the New Hampshire Rules Governing the Control of 

Air Pollution, or the Clean Air Act, or to obtain any other necessary authorizations from other 

governmental agencies, or to comply with all other applicable Federal, State, or Local rules and 

regulations, not addressed in this Permit. 

In accordance with 40 CFR 70.6 (a)(6)(ii) a Permittee shall not claim as a defense in an enforcement 

action that it would have been necessary to halt or reduce the permitted activity in order to mdintain 

compliance with the conditions of this Permit. 

XXV. Emission-Based Fee Requirements: 

Ao 

no 

The Permit-tee shall pay an emission-based fee annually for this facility as calculated each 

calendar year pursuant to Env-A 704.03. 

The Permittee shall determine the total actual annual emissions from the facility to be included in 

the emission-based multiplier specified in Env-A 704.03(a) for each calendar year in accordance 

with the methods specified in Env-A 620. 

Co The Permittee shall calculate the annual emission-based fee for each calendar year in accordance 

with the procedures specified in Env-A 704.03 and the following equation: 

hrp rrent\liflevka rn©lld mr•l\lwvhit e2.auld 
Page 29 

FEE E * DPT * CPIm * ISF 

Where: 

FEE 

E= 

The annual emission-based fee for each calendar year as specified in Env-A 704. The emission-based multiplier is based on the calculation of total annual 

emissions as specified in Env-A 704.02 and the provisions specified in Env-A 704.03(a). 

DPT The dollar per ton fee the DES has specified in Env-A 704.03(b). CPIm= The Consumer Price Index Multiplier as calculated in Env-A 704.03(c). ISF The Inventory Stabilization Factor as specified in Env-A 704.03(d). 

The Permittee shall contact the DES each calendar year for the value of the Inventory Stabilization Factor. 

Eo The Permittee shall contact the DES each calendar year for.the value of the Consumer Price Index Multiplier. 

Fo The Permittee shall submit, to the DES, payment of the emission-based fee •md a summary of the calculations referenced in Sections XXV.B. and C of this Permit for each calendar year by October 15 th of the following calendar year in accordance with Env-A 704.04. The emission- based fee and summary of the calculations shall be submitted to the following address: 

New Hampshire Department of Environmental Services 

Air Resources Division 

6 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

ATTN.: Emissions Inventory 

The DES shall notify the Permittee of any under payments or over payments of the annual emission-based fee in accordance with Env-A 704.05. 

XXVI. Duty To Provide Information 

In accordance with 40 CFR 70.6 (a)(6)(v), upon the DES's written request, the Permittee shall furnish, within a reasonable time, any information necessary for determining whether cause exists for modifying, revoking and reissuing, or terminating the Permit, or to determine compliance with the Permit. Upon request, the Permittee shall furnish to the DES copies of records that the Permittee is required to retain by this Permit. The Permittee may make a claim of confidentiality as to any information submitted pursuant to this condition in accordance with Part Env•A 103 at the time such information is submitted to DES. DES shall evaluate such requests in accordance with the provisions of Part Env-A 103. 

XXVII. • 

Pursuant 

exclusive 

to 

privilege. 

40 CFR 70.6 (a)(6)(iv), this Permit does not convey any property rights of any sort, or any 

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Page 30 

XXVIII. Severability Clause 

Pursuant to 40 CFR 70.6 (a)(5), the provisions of this Permit are severable, and if any provision of this 

Permit, or the application of any provision of this Permit to any circumstances is held invalid, the 

application of such provision to other circumstances, and the remainder of this Permit, shall not be 

affected thereby. 

XXIX. Emergency Conditions 

Pursuant to 40 CFR 70.6 (g), the Permittee shall be shielded from enforcement action brought for 

noncompliance with technology based 3 emission limitations specified in this Permit as a result of an 

emergency4. In order to use emergency as an affirmative defense to an action brought for 

noncompliance, the Permittee shall demonstrate the affirmative defense through properly signed, 

contemporaneous operating logs, or other relevant evidence that: 

A. An emergency occurred and that the Permittee can identify the cause(s) of the emergency; 

B. The permitted facility was at the time being properly operated; 

Co During the period of the emergency, the Permittee took all reasonable steps as expeditiously as 

possible, to minimize levels of emissions that exceeded the emissions standards, or other 

requirements in this Permit; and 

Do The Permittee submitted notice of the emergency to the DES within two (2) business days of the 

time when emission limitations were exceeded due to the emergency. This notice must contain a 

description of the emergency, any steps taken to mitigate emission, and corrective actions taken. 

XXX. Permit Deviation 

In accordance with 40 CFR 70.6(a)(3)(iii)(B), the Permittee shall report to the DES all instances of 

deviations from Permit requirements, by telephone or fax, within 8 hours of discovery of such deviation 

pursuant to Env-A 902.02. This report shall include the deviation itself, including those attributable to 

upset conditions as defined in the Permit, the probable cause of such deviations, and any corrective 

actions or preventative measures taken. Said Permit deviation shall also be submitted in writing to the 

DES within fifteen (15) days of documentation of the deviation by facility personnel. Deviations are 

Technology based emission limits are those established on the basis of emission reductions achievable with various 

control measures or process changes (e.g., a new source performance standard) rather than those established to attain 

health based air quality standards. 

An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of 

the source, including acts of God, which situation would require immediate corrective action to restore normal operation, 

and that causes the source to exceed a technology based limitation under the permit, due to unavoidable increases in 

emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by 

Improperly designed equipment, lack of preventative maintenance, careless or improper operations, operator error or 

decision to keep operating despite knowledge of any of these things. 

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instances where any Permit condition is violated and has not already been reported as an emergency 

pursuant to Section XXIX of this Permit. 

Reporting a Permit deviation is not an affirmative defense for action brought for noncompliance. 

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STATE OF NEW HAMPSHIRE 

Department of Environmental Services 

Air Resources Division 

Title V Operating Permit 

Permit No: TV-OP-002 

Date Issued: July 23, 1998, Significant Modification July 6, 1999, Amended November 15, 1999 

This certifies that: 

Bio Energy Corporation 

1994 Maple Street 

West Hopkinton, NH 03229 

has been granted a Title V Operating Permit for the following facility and location: Bio Energy Corporation 

Route 127 

West Hopkinton, NH 

AFS No. 3301300101 

This Title V Operating Permit is hereby issued under the terms and conditions specified in the Title V Operating Permit Application filed with the New Hampshire Department of Environmental Services Air Resources Division (DES) on September 12, 1995 and the Addendum to Title V Permit Application filed with the DES on March 3, 1997 under the signature of the following responsible official certifying to the best of their knowledge that the statements and information therein are true, accurate and complete. 

Responsible Official: 

William Dell'Orfano 

President 

(603) 746-5833 

Technical Contact: 

Harry Smith 

Plant Manager 

(603) 746-5833 

This Permit is issued by the DES pursuant to its authority under New Hampshire RSA 125-C and in accordance with the provisions of Code of the Federal Regulations 40 Part 70. 

This Title V Operating Permit shall expire on July 31, 2003. 

SEE ATTACHED SHEETS FOR ADDITIONAL PERMIT CONDITION• 

For the New Hampshire Department of Environmental Services, Air Resource Division 

Director, Air Resources Division 
TABLE OF CONTENTS 

Page 2 

II. Permitted Activities 4 

III. Significant Activities Identification and Stack Criteria Tables 1 & 2 4-5 

IV. Insignificant Activities Identification 6 

V. Exempt Activities Identification 6 

VI. Pollution Control Equipment Identification Table 3 6 

VII. Alternative Operating Scenarios 7 

VIII. Applicable Operational and Emission Limitations 7-9 

IX. Emission Reductions Trading Requirements 10 

X. Compliance Demonstration Requirements .10-20 

-Monitoring and Testing Requirements 

-Record Keeping and Reporting Requirements 

XI. Requirements Not'Currently Applicable Table 4 20-22 

XII. 

XIII. 

XIV. 

 ̧XV. 

XVI. 

Issuance of a Title V Operating Permit 

Title V Operating Permit Renewal Procedures 

Application Shield 

Permit Shield 

Reopening for Cause 

Administrative Permit Amendments 

23 

23 

23 

23-24 

24-25 

Significant Permit Amendments 

XVII. 25 

XVIII. Operational Flexibility 25-26 

XIX. Minor Permit Amendments 26 

XX. 

Title V Operating Permit Suspension, Revocation or Nullification 

Inspection and Entry. 

XXI. 

XXII. 

XXIII. Certifications 

27 

27 

27 

27-29 
XXIV. 

XXV. 

XXVI. 

XXVII. 

XXVIII. 

XXIX. 

XXX. 

Enforcement 

Page 3 

29 

Emission Based Fee Requirements 29-30 

Duty to Provide Information 30 

Property Rights 

Severability Clause 

Emergency Conditions 

Permit Malfunctions and Deviations 

30 

30 

30-31 

31 
Facility Specific Title V Operating Permit Conditions 

I. 

II. 

III. 

Page 4 

Facility Description of Operations: 

Bio Energy Corporation (Bio Energy) Generating Station is located in West Hopkinton, New Hampshire. 

The electric generating station is designed to consume wood fuel consisting of cleaned processed wood fuel 

and/or whole tree wood chips to generate 12.65 MW (gross) of electrical power. No. 2 fuel oil is also used 

as fuel in combination with the wood fuel. 

Permitted Activities: 

In accordance with all of the provisions of the New Hampshire Rules Governing the Control of Air Pollution 

(effective date 12/31/96) and as revised thereafter, the permittee is authorized to operate the devices and or 

processes identified in Sections III, IV, V and VI within the terms and conditions specified in this Permit. 

Significant Activities Identification and Stack Criteria: 

A. Significant Acti-•ity Identification 

The activities identified in the following table (Table 1) are subject to and regulated by this Title V 

Operating Permit: 

EU1 Boiler Wood-fired Boiler Stack #1 

EU2 -Cooling Tower Circulation Water Cooling Tower Cooling Tower Drift Factor = 0.00005 gal drifl/gal circ 

Circulation Rate 10,600 gpm 

Maximum Firing Rate of 225 mmBTU/hr 

with wood 

Maximum Firing Rate of 80 mmBTU/hr 

with #2 oil 

III. 

Based on equipment design, the maximum operating rate of the Bio Energy EU1 Boiler shall 

be limited to a total of 225 million BTU'per hour (mmBTU/hr) gross heat input. This is the 

equivalent of 132,000 pounds per hour (lbs/lu') of steam production at 825 degrees F and 610 

PS!G as averaged over any consecutive 24-hour period. 

Based on facility operations, fuel fed to the EU1 Boiler shall consist of any Of the following: 

ao Whole tree wood chips at approximately 50% moisture (approximately 8,5 

mmBTU/ton). 

Whole tree wood chips at approximately 8.5 mmBTU/ton and #2 fuel oil at maximum 

0.4% sulfur by weight. 

Significant Activities Identification and Stack Criteria (continued): 

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Clean processed wood fuel (approximately 8.5 mmBTU/ton to 13.5 mmBTU/ton) and #2 fuel oil at maximum 0.4% sulfur by weight. 

do Clean processed wood fuel and whole tree wood chips at approximately 50% moisture. 

Clean processed wood fuel and whole tree wood chips at approximately 50% moisture and #2 fuel oil at maximum 0.4% sulfur by weight. 

f. No. 2 fuel oil at maximum 0.4% sulfur by weight. 

g. Clean processed wood fuel (approximately 8.5 mmBTU/ton to 13.5 mmBTU/ton). 

Based on equipment design, the maximum wood consumption by the EU1 Boiler shall be limited to 232,000 tons wet basis of whole tree wood chips at 50% moisture during any consecutive twelve month period. 

Based on equipment design, the maximum gross heat input rate of #2 fuel oil at maximum sulfur content of 0.4% by weight to the EU1 Boiler shall be limited to 80 mmBTU/hr. This is equivalent to 580 gallons per hour of #2 fuel oil. In accordance with Condition VIII.C. 10 of this permit, the maximum consumption of #2 fuel oil by the EU1 Boiler at maximum sulfur content of 0.4% by weight shall be limited to 1,302,800 gallons during any consecutive twelve month period. 

Stack Criteria 

The following stack for the above listed significant device at this facility shall discharge vertically without 

only 

obstruction (including rain caps) and meet the following criteria in accordance with the state- air pollution dispersion modeling requirements specified in Env-A 606. 

Stack #1 157.5 6.0 

Preauthorized changes to the state-only requirements pertaining to stack parameters (set forth in this permit) shall be permitted only when an air quality impact analysis meeting the criteria of Part Env-A 606 is performed either by the facility or by the DES (if requested by the facility in writing) in accordance with the "DES Policy and Procedure for Air Quality Impact Modeling", All air modeling data shall be kept on file at the facility for review by the DES upon request. 

IV. Insignificant Activities Identification. 

IClean 

wood chips" and 

processed 

"sawdust" 

wood fuel is considered to be fuel that exhibits fuel characteristics equivalent to "whole tree with respect to the ultimate and proximate analysis of the fuel. 

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VI. 

Page 6 

All activities at this facility that meet the criteria identified in the New Hampshire Rules Governing the 

Control of Air Pollution Part Env-A 609.03(g), shall be considered insignificant activities. Emissions 

from the insignificant activities shall be included in the total facility emissions for the emission-based fee 

calculation described in Section XXV of this Title V Operating Permit. 

Exempt Activities Identification: 

All activities identified in the New Hampshire Rules Governing the Control of Air Pollution Part Env-A 

609.03 (c) shall be considered exempt activities and shall not be subject to or regulated by this Title V 

Operating Permit. 

Pollution Control Equipment Identification: 

The devices and/or processes identified in Table 3 below are considered pollution control equipment for 

the identified emissions unit. 

PC 1-Multiclone Multiclone primary particulate control for the EU Boiler 

PC2-EFB Electrified Filter Bed secondary particulate control for'the EU1 Boiler 

PC3-Bag House Dry Dust Collector final particulate control for the EU1 Boiler 

PC4-CO Catalyst Ox),dizin•Catal),st CO control for the EU1 Boiler 

EU1-Boiler 

EU1-Boiler 

EU1-Boiler 

EU1-Boiler 

Co 

Based on the AP-42 uncontrolled particulate matter (PM) emissions of 8.8 lb/ton, the combined 

minimum efficiency of the PM control equipment (PC1 through.PC3) shall be at least 90.4% to 

meet the applicable permit limit for PM of 0.1 lb/mmBTU. 

All equipment, facilities and systems installed and used to achieve compliance with the terms and 

conditions of this permit shah at all times be maintained in good working order and shall be 

operated as efficiently as .possible so as to minimize air pollutant emissions and meet all applicable 

air pollutant emission limits. 

The pollution control equipment shall be maintained regularly, in accordance with the 

manufacturer's Operation and Maintenance (O&M) manual and based on the schedules as 

described in Sections VIII.A. and X.A. 

VII. Alternative Operating Scenarios: 

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Page 7 

Bio Energy did not include alternative operating scenarios in their Title V application. This permit will have to be amended if Bio Energy desires to include any alternative operating scenarios. 

Applicable Operational and Emission Limitations. 

Bio Energy is subject to the following operational and emission limitations as contained in this permit. 

A. Operational Limitations 

To maintain the efficiency of the CO catalyst and to operationally control CO emissions in accordance with DES State Permit to Operate, PO-B-1640 issued on December 20, 1994, Bio Energy shall comply with the following operational limitations. 

In addition to operation of the CO catalyst, Bio Energy shall control CO emissions by varying the total quantity of input combustion air and/or the local distribution of that air into the EU1 Boiler. The amount of combustion air required to optimize the EU1 Boiler efficiency and reduce CO emissions is dependent on the wood moisture content and the type of wood, among other factors. The combustion air shall be supplied and regulated by three fans (Forced Draft, Overfire and Induced Draft) and their associated dampers and controls to achieve optimum EU1 Boiler efficiency settings. 

The oxydizing catalyst shall be maintained by periodic steam sootblowing, based on the differential pressure across the layers of catalyst, Bio Energy shall perform sootblowing for the purpose of cleaning the oxydizing catalyst when the differential pressure across the catalyst exceeds 3 inches of water. 

In the event that the CO oxydizing catalyst modules become masked, a chemical cleaning, or equivalent, proce•lure shall be used to bring the modules back to life. The frequency of cleaning will vary based on the particular load and type of fuel burned. General module chemical cleaning or catalyst rotation shall be conducted at least once each year. Chemical cleaning shall be conducted in accordance with the manufacturer's specifications. Waste materials from the chemical cleaning shall be properly disposed in accordance with applicable DES rules and EPA regulations. 

State-Only Applicable Emission Limitations 

In accordance with Env-A 1002.03, Bio Energy shall take precautions to prevent, abate and control the emission of fugitive dust for those activities contained in Env-A 1002.02. Such precautions shall include wetting, covering, shielding or vacuuming. 

Devices installed and operational prior to May 9, 1998 that have the potential to emit, in any amount, substances that meet the criteria of Env-A 1301 shall be subject to Env-A 1300, until such time as the Env-A 1400 requirements supersede the Env-A 1300 requirements. 

VIII. Applicable Operational and Emission Limitations (_continued): 

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Air quality impact analysis of devices and area sources emitting substances meeting the 

criteria Of Env-A 1301 shall be performed in accordancewith the "DES Policy and 

Procedure for Air Quality Impact Modeling" or other comparable dispersion modeling 

methods approved by EPA. 

In accordance with Env-A 1403.01, new or modified devices or processes installed after 

May 8, 1998, shall be subject to the requirements of Env-A 1400. 

In accordance with 1403.02(a), all existing unmodified devices or processes which are in 

operation during the transition period ending three years from May 8, 1998 (May 8, 

2001), shall comply with either Env-A 1300 or Env-A 1400. 

In accordance with Env-A 1403.02(b), all existing devices or processes in operation after 

the transition period ending three years from May 8, 1998 (May 8, 2001), shall comply 

with Env-A 1400. Env-A 1300 will no longer be in effect. 

In accordance with Env-A 1404.01 (d), documentation for the demonstration of 

compliance shall be retained at the site, and shall be made available to the DES for 

inspection. 

In accordance with Env-A 1405.02, the owner of an existing device or process requiring a 

permit under Env-A 1400 shall submit to the DES no later than one year prior to the end 

of the transition period (by May 8, 2000), an application fora modification to a Title V 

permit in accordance with Env-A 609.18, and a request to the DES to perform air 

dispersion modeling. 

In accordance with Env-A 2003.04 (d), exceedances of the opacity standard shall not be 

considered violations of this part if the facility demonsmites to the division that such 

exceedances were the result of the adherence to good boiler operating practices which, in 

the long term, results in the most efficient or safe operation of the boiler. 

10. In accordance with Env-A 2003.04 (e)(2), opacity exceedances experienced during 

periods of cold startup of a boiler over a continuous period of time resulting in efficient 

heat-up and stabilization of its operation and the expeditious achievement of normal 

operation of the unit shall not be considered violations. 

C. Federally Enforceable Emission Limitations 

In accordance with Env-A 1211.04(d) and Env-A 1211.05(d)(5), the EU1 Boiler, firing 

wood fuel or capable of firing a combination of wood fuel and oil and equipped with a 

stationary grate, shall comply with the oxides of nitrogen (NOx) Reasonably Available 

Control Technology (RACT) emission limit of 0.25 pounds per million BTU 

(lb/mmBTU), based on a 24-hour calendar day average. 

2. In accordance with Env-A 1604.01(a), the sulfur content of No. 2 oil and off-road diesel 

Applicable Operational and Emission Limitations (continued): 

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oil shall not exceed 0.40 percent sulfur by weight. 

In accordance with Env-A 2003.02, Bio Energy shall not cause or allow average opacity from fuel burning devices installed after May 13, 1970 in excess of 20 percent for any continuous 6-minute period in any 60-minute period, except for one of the following exemptions, in accordance with Env-A 2003.04(a): 

During periods of startup, shutdown and malfunction, average opacity shall be allowed to be in excess of 20 percent for one period of 6 continuous minutes in 

any 60 minute period; or 

During periods of normal operation, soot blowing, grate cleaning, and cleaning of fires, average opacity shall be allowed to be in excess of 20 percent but not more than 27 percent for one period of 6 continuous minutes in any 60 minute period. 

To avoid the requirements of the federal Prevention of Significant Deterioration (PSD) regulation 40 CFR 52.21(b)(1)(i)(b), the NO emission rate for the EU1 Boiler shall be limited to 57.0 pounds per hour (lbs/hr) average for any consecutive 365-day period. Compliance with this emission limit shall be demonstrated using the annual NOx stack testing requirements described in Section X.B. of this permit. 

To avoid the requirements of the federal PSD regulation 40 CFR 52.21 (b)(1)(i)(b), the carbon mono•(CO) emission rate for the EU1 Boiler shall be limited to 57.0 tbs/hr for any consecutive 365-day period. Continuous Emission Monitoring (CEM) requirements are described in Section X.C. of this permit. 

In accordance with DES State Permit to Operate, PO-B-1640 issued on December 20, 1994, the carbon monoxide (CO) emission rate for the EU1 Boiler shall be limited to 225 lbs/hr for each calendar day average as calculated on the CEM system. 

In accordance with DES State Permit to Operate, PO-B-1640 issued on December 20, 1994, the PM emission rate for the EU1 Boiler shall be limited to 0.10 lb/mmBTU heat input as demonstrated by PM stack testing requirements as described in Section X.A.4. of this permit. 

To avoid the requirements of the federal Prevention of Significant Deterioration (PSD) regulation 40 CFR 52.21, the maximum consumption of#2 fuel oil by the EU1 Boiler at maximum sulfur content of 0.4% by weight shall be limited to 1,302,800 gallons during any consecutive twelve month period, (which is equivalent to 37.0 tons per year of SO2 based on EPA AP-42 Emissions Factors). 

IX. Emission Reductions Trading Requirements: 

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The Permittee did not request emissions reductions trading in the facility operating permit application. At 

the time of this permit preparation, DES did not included any permit terms authorizing emissions trading 

in this permit. All emissions reductions trading must be authorized under the applicable requirements of 

either Env-A 3000 (the "Emissions Reductions Credits (or ERCs) Trading Program") or Env-A-3100 

(the "Discrete Emissions Reductions (or DERs) Trading Program) and 42 U.S.C. §7401 et seq. (The 

"Act"), and must be provided for in this Permit." 

Compliance Demonstration Requirements: 

The permittee is subject to the monitoring/testing, record keeping and reporting requirements as 

contained in the following permit sections. Refer to the facility's standard operating practices and the 

manufacturer's O&M manual for additional information regarding operation and maintenance of the 

facility equipment. The pollution control equipment and EU1 Boiler shall be monitored and maintained 

in accordance with the appropriate manufacturers' O&M manuals. 

mo Monitoring/Testing Requirements for Total Suspended Particulate Controls 

(Regulatory cite Env-A 806.01 (a) and 40 CFR Part 70.6(a)(3)) 

1. PC 1 Multiclone Monitoring and Testing Requirements 

Conduct monitoring of pressure differential across the PC1 Multiclone unit every 

two hours. An acceptable pressure differential shall be in accordance with 

standard operating practices and manufacturer's recommended operating 

parameters and shall be maintained between 2" and 5" of water column. Pressure 

differential readings shall be recorded on standard forms and kept on file at the 

facility for review by the DES upon request. The standard forms shall include the 

acceptable operating parameters for quick reference by facility personnel. 

bo Facility personnel shall conduct a daily inspection for visible emissions of the PC 1 

Multiclone unit to Observe leaks using EPA Method 22, 40 CFR Part 60, 

Appendix A. If a leak(s) is observed, facility personnel shall take immediate steps 

to repair the leak. Daily observations, maintenance and repairs performed to the 

unit shall be recorded in the log book. The visible emissions observer shall meet 

the training requirements of EPA Method 22. 

Co During down-time maintenance periods, facility personnel shall inspect inlet and 

outlet vanes and boots for any build up of caked dust. All caked dust shall be 

removed during each down-time maintenance period. 

do Observations of operating parameters outside of the standard operating practices 

included in this permit shall be recorded, investigated and corrected immediately. 

If this results in a permit limit exceedance, Bio Energy personnel shall contact DES 

within 8 hours. 

X. Compliance Demonstration Requirements (continued): 

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PC2 EFB Monitoring and Testing Requirements 

In accordance with the manufacturer's O&M manual and standard operating practices for this equipment, on a bi-hourly basis, facility personnel shall: 

ao Monitor and record the pressure on the PC2 EFB differential pressure gauge. The pressure shall be maintained between 2" and 8" of water column. 

Monitor and record the voltage on the PC2 EFB voltmeters. The PC2 EFB voltage shall be maintained between 5 and 10 KV. 

Monitor and record the PC2 EFB current amperage on the PC2 EFB ammeters. The PC2 EFB current shall be maintained between 0.02 and 0.5 amps. 

Monitor and record the voltage on the ionizer voltmeters. The ionizer voltage shall be maintained between 10 and 25 KV. 

Monitor and record the ionizer amperage on the ammeters. The ionizer amperage shall be maintained between 0.2 and 3 milliamps. 

f. Bi-hourly monitoring data shall be recorded daily on standard forms and kept on file at the facility for review by the DES upon request. The standard forms shall include the acceptable operating parameters for quick reference by facility personnel. 

Observations of operating parameters outside of the standard operating practices included in this permit shall be recorded, investigated and corrected immediately. If this results in a permit limit exceedance, Bio Energy personnel shall contact DES within 8 hours. 

PC3 Baghouse Monitoring and Testing Requirements 

a. Bi-Hourly Monitoring/Testing Requirements 

In accordance with the manufacturer's O&M manual for the PC3- Baghouse, facility personnel shall monitor and record the pressure on the PC3-Baghouse differential pressure gauge on a bi-hourly basis. The differential pressure shall be maintained between 3" and 10" of water. 

ii. Bi-hourly monitoring data shall be recorded daily on standard forms and kept on file at the facility for review by the. DES upon request. The standard forms shall include the acceptable operating parameters for quick reference by facility personnel. 

X. Compliance Demonstration Requirements (continued). 

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Page 12 

b, Daily Monitoring/Testing Requirements 

Monitor and record the pressure on the PC3-Baghouse exhaust fan inlet 

pressure gauge, located on the baghouse discharge ductwork. The 

pressure shall be maintained between 10" to -20" of water. 

ii. Conduct visual inspections of the baghouse emissions in accordance with 

40 CFR Part 60 Appendix A Method 22. 

iii. Monitor and record that the rotary valve is operating freely with no rubbing 

or binding. 

iv. Monitor and record the pressure on the pulse air pressure gauge, located at 

the pulse air inlet manifold. The pressure shall be maintained between 70 

to 100 psi. 

Vo Daily monitoring data shall be recorded daily on standard forms and kept 

on file at the facility for review by the DES upon request, The standard 

forms shall include the acceptable operating parameters for quick reference 

by facility personnel. 

vi. Observations of operating parameters outside of the standard operating 

practices included in this permit shall be recorded, investigated and 

corrected immediately. If this results in a permit limit exceedance, Bio 

Energy personnel shall contact DES within 8 hours. 

4. Stack Testing Requirements for PM 

At such times as specified by the DES, Bio Energy shall conduct USEPA method 

compliance stack test for PM emissions at maximum production rate conditions, and/or at 

the request of the DES, at any other production rate at which maximum emissions might 

OCCur. 

If requested, the PM emissions stack test shall be conducted in accordance with the 

requirements described in Section X;B.2-6 of this permit. 

Monitoring/Testing Requirements for NO Emissions 

(Regulatory Cite Env-A 806.01(a) and 40 CFR Part 70.6(a)(3)) 

In the same calendar quarter each year, Bio Energy shall conduct a USEPA method 

compliance stack test for NO at maximum production rate conditions, and/or at the 

request of the DES, at any other production rate at which maximum emissions might 

occur. Results shall be reported in lbs/hr and lbs/mmBTU. If Bio Energy does not 

conduct annual NO stack tests or if NO emissions approach or exceed applicable permit 

Compliance Demonstration Requirements (continued): 

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limits, a NO CEM shall be installed at the facility to monitor NO emissions from the EU1 

Boiler. 

Testing shall be conducted and the results reported in accordance with 40 CFR Part 60, Sections 60.8(a), (b), (d), (e) and (f), Appendix A and the DES's policy "Procedures and 

Minimum Requirements for Stack Tests". Compliance testing for NO shall be conducted using EPA Method 7E or DES approved alternatives. 

Compliance testing shall be planned and carried out in accordance with the following schedule: 

At least 30 days prior to the commencement of testing, Bio Energy shall submit to the 

DES a pretest report presenting the following information: 

ao Calibration methods and sample data sheets; Description of the test methods to be used; 

Pre-test preparation procedures; Sample collection and analysis methods; 

Process data to be collected; and 

Complete test program description. 

At least 15 days prior to the test date, Bio Energy, and any contractor that Bio Energy retains for performance of the test, shall participate in a pretest conference with a DES representative. 

5. Emission testing shall be carried out under the observation of a DES representative. 

Within 30 days after completion of testing, Bio Energy shall submit a test report to the 

DES. 

Any compliance stack test results determined following 40 CFR 60 paragraph 60.8, which show violations of the emission limitations shall be considered violations of this permit. 

CEM Monitoring/Testing Requirements (Regulatory Cite Env-A 805.02 and 40 CFR Part 70.6(a)(3)) 

Bio Energy shall install, maintain and operate the following CEM systems in the EU1-Boiler exhaust piping. 

1. Opacity CEM 

The opacity CEM system shall meet the requirements of 40 CFR Part 60, Appendix B, Performance Specifications 1-4 and Env-A 805. Determination of compliance with the opacity limits established in Section VIII.C. of this permit shall be made by the plant 

Compliance Demonstration Requirements (continued)" 

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opacity CEM or, during periods of opacity CEM malfunction, visible emission readings 

taken once per shift following the procedures specified in 40 CFR Part 60, Appendix A, 

Method 9. Calculations shall be performed as specified in Section X.C.6. of this permit. 

2. CO CEM 

The CO CEM system shall meet the requirements of 40 CFR Part 60, Appendix B, 

Performance Specifications 1-4 and Env-A 805. Determination of compliance with the 

CO emission limits established in Section VIII.C. of this permit shall be made by the plant 

CO CEM. The CO emission rate shall be calculated daily as the average of the calendar 

day averages as calculated on the plant CO CEM. Calculations shall be performed as 

specified in Section X.C.6. of this permit. 

3. Oxygen (02) CEM 

The 0 2 CEM system shall meet the requirements of 40 CFR Part 60, Appendix B, 

Performance Specifications 1-4 and Env-A 805. 

4. NOx CEM 

In accordance with Env-A 805.02, ifBio Energy does not conduct annual NO stack tests, 

a NO CEM, that meets the requirements of Env-A 805, shall be installed at the facility to 

monitor NOx emissions from the EU1 Boiler. 

5. Volumetric Flow CEM 

The stack volumetric flow measuring device shall meet all of the requirements of 40 CFR 

Part 60, Appendix B, Performance Specification 6. The stack ftow monitor shall have an 

automatic bl0w-back, purge system installed and activated during all times of boiler 

operation: Data from the stack volumetric flow measuring device and the CO CEM shall 

be used to calculate mass emission rates for comparison with the emission standard 

specified in permit condition VIII.C. 

6. Calculations: 

a. CEM calendar day averages shall be calculated as follows: 

Calend,ar Day average (sum of all valid hour lb/hr averages for the 

calendar day)/(24 hours of CEM system downtime for the day); 

ii. A valid calendar day average shall be defined as a calendar day with 18 or 

more valid hours of CEM data; 

iii. A valid calendar hour of CEM data shall be defined as a minimum of 45 

minutes collection of CEM readings taken in a calendar hour; and 

Compliance Demonstration Requirements (continued): 

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Page 15 

iv. Hours of CEM system downtime shall be defined as the number of calendar hours when the CEM system has not collected data or is out-of-control for greater than 15 minutes for any reason (i.e. audits, CEM system calibration, CEM system failures, etc.) 

b. CEM consecutive 365-day averages shall be calculated as follows: 

Consecutive 365-day average (sum of all valid calendar day averages for the 365-day period)/(365 days of CEM system downtime); and 

ii. Days of CEM system downtime shall be defined as the number of calendar days when the CEM system has collected less than 18 valid hours of CEM 

data. 

Hours or days when the CEM system has been intentionally shutdown when the facility is not operating shall not be counted as CEM system downtime. 

Bio Energy shall be subject to all of the CEM requirements of Env-A 805 which shall include but not be limited to: quarterly audit requirements, excess emission report requirements, quality control written procedure requirements for gaseous CEM monitors and. record keeping requirements. The specific record keeping and reporting requirements are described in Section X.E. and X.F. of this permit. 

Bio Energy shall continuously monitor and record data from the gaseous CEM system during all periods of operation, including periods of startup, shutdown, malfunctions or emergency conditions, except when the stack flow is less than 13,080 dry SCFM (17,500 wet SCFM). The opacity CEM shall be continuously monitoring and recording data during all periods of operation, regardless of the stack flow rate. 

Excess emissions indicated by the CEM system shall be considered violations of the applicable emission limit for purposes of this permit, except where Bio Energy can adequately demonstrate to the DES that the recorded exceedance resulted from a CEM malfunction. 

Bio Energy shall install, maintain and operate a continuous steam flow rate monitoring/recording system which shall meet all applicable ASME specifications. Calibration of the steam flow transducer shall occur at least once annually. If adequate straight length of piping is not available, then in lieu 'of a measuring system that meets ASME specifications,, Bio Energy may use a steam flow rate monitoring System that can be calibrated by instruments installed, maintained and calibrated per ASME specifications or by other methods approved by the DES. 

X. Compliance Demonstration Requirements (continued). 

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Compliance Demonstration Requirements for the EU2 Cooling Tower State Enforceable Only 

In accordance with Env-A 1300 and Env-A 1400, prior to changing cooling water 

treatment chemicals, Bio Energy shall evaluate the impact of the proposed chemicals on 

the 24-hour and annual deminimus limits of the DES Air Toxics List. If the impact 

exceeds the deminimus 24-hour or annual levels, Bio Energy shall notify DES in writing of 

the proposed chemical changes. Written approval from DES shall be received prior to 

making the chemical change, if the deminimus levels are exceeded. If the impact does not 

exceed the deminimus levels, Bio Energy may make the chemical change and shall keep 

the records of the impact analysis in the facility files in accordance with the recordkeeping 

requirements of Section X.E. of this permit. 

The following equations shall be used to evaluate the impact of cooling water chemicals 

on the 24-hour and annual deminimus levels. This equation shall be used for each 

chemical used in the cooling water that is included on the DES Air Toxics List. Also, this 

equation shall be used to estimate particulate emissions from both chemical additives to 

the water and total dissolved solids contained in the water for emission-based fees as 

described in Section XXV. of this permit. 

24-hour Emissions (lb/hr) (DR)*(Hourly CR)*(8.34 lb/gal)*(C) 

Example Calculation: 24-hour emissions of total dissolved solids (lb/hr) 

(0.00005 gal/gal)*(636,000 gal/hr)*(8.34 lb/gal)*(1600 ppmw TDS) 

lxl0 6 

0.424 lb/hr TDS 

Annualized Emissions (lb/yr) (24-hour Emissions, lb/hr)*(Operating hours/year) 

Example Calculation: Annualized emissions of TDS (lb/yr) (0.424 lb/hr)*(8760 hrs/yr) 

3,717 lbs/yr TDS 

Where: DR drift rate for tower (based on manufacturer's data for facility tower), 

gal drift/gal circulation water (0.00005 gal/gal) 

Hourly CR water circulation rate, gal/hr 

C concentration of chemical of interest (or total dissolved solids 

concentration) in circulation water, ppmw (use maximum potential 

concentration for deminimus impact evaluation and average or actual 

data for emission-based fee calculations) 

X. Compliance Demonstration Requirements (continued): 

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Record Keeping Requirements 

In accordance with 40 CFR Part 70.6(a)(3)(ii)(B), Bio Energy shall retain records of all required monitoring data, record keeping and reporting requirements and support information for a period of at least 5 years from the date of the origination. Bio Energy shall maintain a written copy of the facility's Standard Operating Procedures and Operations and Maintenance Manual at the facility and shall provide a copy of these documents to DES upon request. These data and reports shall not be discarded, removed or destroyed thereafter without the express written approval of the director in accordance with Env-A 901.11. 

In accordance with 40 CFR 70.6(c)(5), Bio Energy shall meet the requirements for compliance certification with terms and conditions contained in this permit, including emission limitations, standards, or work practices. Compliance certifications shall meet the requirements outlined in Section XXIII of this permit. 

Pursuant to Env-A 901.03, for each fuel burning device at the facility, the owner or operator shall keep records on fuel utilization in accordance with the following: 

Monthly records of liquid fuel utilization for each fuel burning device at the facility shall include: 

i. consumption; 

ii. fuel type; 

iii. viscosity; 

iv. sulfur content as percent sulfur by weight of fuel; and 

v. BTU content per gallon of fuel. 

Records shall be kept of hours of operation corresponding to the utilization and distribution of all fuels. 

In accordance with 40 CFR 60, Bio Energy shall retain records of Method 22 training for all personnel who conduct daily visible emissions monitoring as required in X.A. 1.b. of this permit. 

NO• Record Keeping Requirements 

In accordance with Env-A 901.08, for each fuel buming device, including boilers, turbines and internal combustion engines, the following information shall be recorded and maintained: 

Compliance Demonstration Requirements (continued): 

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Xo 

ao 

Page 18 

Facility information, including: 

i. Source name; 

ii. Source identification; 

iii. Physical address; 

iv. Mailing address; 

v. Date of origination for reports; 

vi. Facility contact and title; 

vii. Facility telephone number; 

b. Identification of each fuel burning device at the facility. 

c. Operating schedule information for each identified fuel burning device, including: 

i. days per calendar week during the normal operating schedule 

ii. Hours per day during the normal operating schedule and for a typical 

ozone season day, if different from the normal operating schedule 

iii. Hours per year during the normal operating schedule. 

d. Type and amount of fuel or waste burned, for each fuel burning device, during 

normal operating conditions and for a typical ozone season day, if different from 

normal operating conditions, on an hourly basis in mmBTU/hr. 

e. The following NOx emission data, including records of total annual emissions, in 

tons per year (tpy), and typical ozone season day emissions, in pounds per day 

(lbs/day), shall be maintained at the facility for a minimum of 5 years: 

i. Theoretical potential emissions for the calculation year for each fuel 

burning device; and 

ii. Actual NOx emissions for each fuel burning device. 

F. Reporting Requirements 

1. In accordance with Env-A 901.09(b), NOx emission data for all facility fuel burning 

devices shall be reported to the DES annually by April 15 of the following year. The NO 

emissions shall be estimated using fuel usage data and annual stack test data. 

Compliance Demonstration Requirements (continued): 

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Page 19 

In accordance with Env-A 902.02 and 40 CFR Part 70.6(a)(3)(iii)(B), the owner or operator shall notify the DES of a malfunction or breakdown of air pollution control equipment within 8 hours of each such occurrence, as described in Section XXX of this permit. 

Fuel Usage Reporting 

In accordance with Env-A 901.07(c), monthly fuel usage information, by device, fuel type, and sulfur content shall be submitted in writing to the DES on a quarterly basis within 30 days after the end of the quarter for which reporting is required. 

Excess Emission Reporting 

In accordance with Env-A 805, within 30 days following the close of each calendar quarter, Bio Energy shall submit to the DES excess emission reports for the EU1 Boiler as approved by the DES containing information specified in Env-A 805 as well as the following information: 

ao 

bo 

Co 

Calendar daily averages of CO lb/hr and part per million (ppm) whether or not an excess emission has occurred; 

Calendar daily averages of percentage oxygen (02); 

Calendar daily averages of steam generation rate; 

Calendar daily averages of stack flow; 

Average steam production rate for each consecutive 24-hour period where the production rate exceeds the limit set forth in Section VIII.A. of this permit; 

CEM system availability data; 

Amount in tons (wet basis) of wood chips consumption per month and a consecutive twelve month total; 

Amount in gallons of #2 fuel oil consumption per month and a consecutive twelve month total. 

All periods of gaseous and opacity exceedances including start time, end time and magnitude of exceedance. 

Xo Compliance Demonstration Requirements (continued): 

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5. CEM Audit Reporting 

Within 30 days following the close of each calendar quarter, Bio Energy shall submit to 

the DES, a CEM audit report for all audits conducted as specified in Env-A 805.06 and 

Section X.C. of this permit. 

In accordance with 40 CFR 70.6(a)(3)(iii)(A), a summary report of monitoring and testing 

requirements shall be submitted every six months. Semi-annual reports shall be submitted 

no later than July 31 for the January through June report and no later than January 31 for 

the July through December report. All instances of deviations from permit requirements 

shall be clearly identified in such reports. All required reports shall be certified for 

accuracy, by a responsible official consistent with 40 CFR 70.5(d). This certification and 

any other certification required under this part shall include the certification of accuracy 

statement included in Section XXIII.B. of this permit. 

The report shall contain a summary of the following information: 

a. Monitoring and preventive maintenance results for PC 1 through PC4. 

b. Preventive maintenance and inspection results for EU1-Boiler and related stacks. 

c. All instances of deviations from permit requirements shall be clearly identified. 

Annual reporting and payment of emission based fees shall be conducted in accordance 

with Section XXV of this Permit. 

An annual compliance certification as presented in Section XXIII of this Permit shall be 

submitted to DES and USEPA by April 15 following each reporting year. 

Pursuant to 40 CFR Part 70.6 (c)(1), all documents submitted to the DES and/or EPA 

shall contain certification by the responsible official of truth, accuracy, and completeness 

as described in Section XXIII.B. of this permit. 

Requirements Currently Not Applicable: 

Based on the information provided by Bio Energy in the Title V Permit application, the permittee is 

currently not subject to the requirements identified in the following Table 4 at the time of permit issuance: 

',AA Section 111, 42 U.S.C. 7411 Requirements establishing new Source performance standards. 

40 CFR 60 Not applicable to the Bio Energy Facility at this time. 

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CAA Section 123, 42 U.S.C. 7423 

40 CFR 61 

40 CFR 63 

40 CFR 68 

40 CFR 72, 73, 75, 76, 77 

40 CFR 82 

Part Env-A 400 

Env-A 610 

Env-A 611 

Env-A 613 

Env-A 621 

Env-A 703 

Env-A 805.06(b) 

Env-A 805.06(c) 

Env-A 901.06 

Requirement establishing Stack height standards and restrictions. 

Not applicable to the Bio Energy Facility at this time. 

National emission standards for hazardous air pollutants. Not 

applicable to the Bio Energy Facility at this time. 

National emission standards for hazardous air pollutants for source categories. (MACT Standards) 

Chemical Accident Prevention 

Permits, allowances, CEM, NO emission reductions and excess emissions for acid rain affected facilities. Not applicable to the 

Bio Energy Facility at this time. 

Protection of Stratospheric Ozone rules apply to anyone that produces, transforms, imports or exports controlled substances. 

Not applicable to the Bio Energy Facility at this time. 

Acid Deposition Control Program. Not applicable to Bio Energy 

at this time because sulfur dioxide (SO2) emissions are less than 

100 tpy. 

Provisions governing general permits issued by DES. Not 

applicable once Title V is issued, Title V permit will govern. 

General acid rain permitting requirements for sources subject to 

Title IV Clean Air Act. 

Additional permitting requirements for sources proposing use of 

the bubble concept. 

Research and Development Operations Bio Energy has not 

requested an exemption for a research and development operation. 

Testing and monitoring fees for temporary permit issued to 

sources not subject to the Title V operating permit program. 

Bio Energy does not have CEM systems other than SO2, NO 

TRS, O2 x, and carbon dioxide (CO2) 

Bio Energy does not have time-shared gaseous CEM systems 

Volatile Organic Compound (VOC) Record Keeping Requirements. Based on current actual VOC emissions being less than 10 tpy, Bio Energy is not subject to the VOC record keeping requirements at the time this permit was written. 

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Env-A 1001 

Env-All00 

Env-A1306 

Env-A 1800 

Env-A 1900 

Env-A 2100 

Env-A 2400 

Env-A 2500 

Env-A2700 

Env-A2800 

Env-A 3300 

Open Burning. Bio Energy does not conduct open buming 

activities. 

Prevention, Abatement and Control of Mobile Source Air 

Pollution. Not applicable to the Bio Energy facility at the time 

this permit was written. 

Requirements for Sources of Hazardous Air Pollutants Subject to 

Section 112 of the Clean Air Act. Bio Energy is not subject to 

this rule. 

Asbestos Management and Control. Bio Energy is not subject to 

this rule. 

Incinerators.. Bio Energy does not operate an incinerator. 

Process, Manufacturing and Service Industries. Bio Energy is 

not considered to be a process and manufacturing industry. 

Emission Standards for Foundries, Smelters and Investment 

Casting. Bio Energy is not subject to this rule. 

PM Emissions for Pulp and Paper Industry. Bio Energy is not 

subject to this rule. 

Emissions Standards for asphalt plants. Bio Energy is not 

subject to this rule. 

Emission Standards for Sand and Gravel and Cement and 

Concrete Industries. Bio Energy is not subject to this rule. 

Municipal Waste Combustion. Bio Energy is not subject to this 

rule. 

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General Title V Operating Permit Conditions 

X. Issuance of a Title V Operating Permit: 

At This Permit is issued in accordance with the provisions of Part Env-A 609. In accordance with 40 CFR 70.6(a)(2) this Permit shall expire on the date specified on the cover page of this Permit, which shall not be later than the date five (5) years after issuance of this Permit. 

Permit expiration terminates the Permittee's right to operate the Permittee's emission units, control equipment or associated equipment covered by this permit, unless a timely and complete renewal application is submitted at least 6 months before the expiration date. 

Pursuant to Env-A 609.02(b), this Permit shall be a state permit to operate as defined in RSA 125-C:11, III. 

XI. Title V Operating Permit Renewal Procedures" 

Pursuant to Env-A 609.06(b), an application for renewal of this Permit shall be considered timely if it is submitted to the Director at least six months prior to the designated expiration date of this Permit. 

XII. Application Shield: 

Pursuant to Env-A 609.07, if an applicant submits a timely and complete application for the issuance or renewal of a Permit, the failure to have a Permit shall not be considered a violation of this part until the Director takes final action on the application. 

XIII. Permit Sh_ield: 

A. Pursuant to Env-A 609.08(a), a permit shield shall provide that: 

For any applicable requirement or any state requirement found in the New Hampshire Rules Governing the Control of Air Pollution specifically included in this Permit, compliance with the conditions of this Permit shall be deemed compliance with said applicable requirement or said state requirement as of the date of permit issuance; and 

For any potential applicable requirement or any potential state requirement found in the 

New Hampshire Rules Governing the Control of Air Pollution specifically identified in this TitleV Operating Permit Section IX Table 8 as not applicable to the stationary source or 

area source, the Permittee need not comply with the specifically identified federal or state requirements. 

The permit shield identified in Section XIII.A. of this Permit shall apply only to those conditions incorporated into this Permit in accordance with the provisions of Env-A 609.08(b). It shall not apply to certain conditions as specified in Env-A 609.08(c) that may be incorporated into this Permit following permit issuance by DES. 

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XIV. 

Page 24 

Ct If a Title V Operating Permit and amendments there to issued by the DES does not expressly 

include or exclude an applicable requirement or a state requirement found in the NH Rules 

Governing the Control of Air Pollution, that applicable requirement or state requirement shall not 

be covered by the permit shield and the Permittee shall comply with the provisions of said 

requirement to the extent that it applies to the .Permittee. 

If the DES determines that this Title V Operating Permit was issued based upon inaccurate or 

incomplete information provided by the applicant or Permittee, any permit shield provisions in 

said Title V Operating Permit shall be void as to the portions of said Title V Operating Permit 

which are affected, directly or indirectly, by the inaccurate or incomplete information. 

Eo Pursuant to Env-A 609.08(0, nothing contained in Section XIII bfthis Permit shall alter or affect 

the ability of the DES to reopen this Permit for cause in accordance with Env-A 609.18 or to 

exercise its summary abatement authority. 

Fo Pursuant to Env-A 609.08(g), nothing contained in this section or in any title V operating permit 

issued by the DES shall alter or affect the following: 

The ability of the DES to order abatement requiring immediate compliance with applicable 

requirements upon finding that there is an imminent and substantial endangerment to 

public health, welfare, or the environment; 

The stateofNew Hampshire's ability to bring an enforcement action pursuant to RSA 

125-C: 15,II; 

The provisions of section 303 of the Act regarding emergency orders including the 

authority of the EPA Administrator under that section; 

The liability of an owner or operator of a source for any violation of applicable 

requirements prior to or at the time of permit issuance; 

The applicable requirements of the acid rain program, consistent with section 408(a) of the 

Act; 

The ability of the DES or the EPA Administrator to obtain information about a stationary 

source, area source, or device from the owner or operator pursuant to section 114 of the 

Act; or 

The ability of the DES or the EPA Administrator to enter, inspect, and/or monitor a 

stationary source, area source, or device. 

Reopening for Cause: 

The Director shall reopen and revise a Title V Operating Permit for cause if any of the circumstances 

contained in Env-A 609.18(a) exist. In all proceedings to reopen and reissue a Title V Operating Permit, 

the Director shall follow the provisions specified in Env-A 609.18(b) through (g). 

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XV. Administrative Permit Amendments: 

AJ Pursuant to Env-A 612.01, the Permittee may implement the changes addressed in the request for an administrative permit amendment as defined in Part Env-A 100 immediately upon submittal of 

the request. 

Pursuant to Env-A 612.01, the Director shall take final action on a request for an administrative permit amendment in accordance with the provisions of Env-A 612.01 (b) and (c). 

XVI. Operational Flexibility: 

AQ Pursuant to Env-A 612.02(a), the Permittee subject to and operating under this Title V Operating Permit may make changes involving trading of emissions under this existing Title V Operating Permit at the permitted stationary source or area source without filing a Title V Operating Permit application for and obtaining an amended Title V Operating Permit, provided that all the 

conditions are met as specified in section XVI. A. 1. through 7. of this permit and a notice is submitted to the DES and EPA describing the intended changes. At this point, DES has not 

included any permit terms authorizing emissions trading in this permit. 

1. The change is not a modification under any provision of title I of the Act; 

The change does not cause emissions to exceed the emissions allowable under the 

title V operating permit, whether expressed therein as a rate of emissions or in 

terms of total emissions; 

3. The owner or operator has obtained any temporary permit required by Env-A 600; 

The owner or operator has provided written notification to the director and 

administrator at least 15 days prior to the proposed change and such written 

notification includes: 

a. The date on which each proposed change will occur; 

b. A description of each such change; 

Any change in emissions that will result and how this change in emissions 

will comply with the terms and conditions of the permit; 

d. A written request that the operational flexibility procedures be used; and 

e. The signature of the responsible official, consistent with Env-A 605.04(b); 

The Title V Operating Permit issued to the stationary source or area source already contains terms arid conditions including all terms and conditions which 

determine compliance required under 40 CFR 70.6(a) and (c) and which allow for 

the trading of emissions increases and decreases at the permitted stationary source 

or area source solely for the purpose of complying with a federally-enforceable 

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XVII. 

Page 26 

emissions cap that is established in the permit independent of otherwise applicable 

requirements; 

The owner or operator has included in the application for the Title V Operating 

Permit proposed replicable procedures and proposed permit terms which ensure 

that the emissions trades are quantifiable and federally enforceable for changes to 

the Title V Operating Permit which qualify under a federally- enforceable 

emissions cap that is established in the Title V Operating Permit independent of the 

otherwise applicable requirements; and 

7. The proposed change complies with Env-A 612.02 (e). 

Bo Pursuant to Env-A 612.02(c), the Permittee subject to and operating under this Title V Operating 

Permit may make changes not addressed or prohibited by this existing Title V Operating Permitat 

the permitted stationary source or area source without filing a Title V Operating Permit 

application, provided that all the conditions specified in Env-A 612.02(c)(1) through (6) are met 

and a notice is submitted to the DES and EPA describing the intended changes. 

Ct Pursuant to Env-A 612.02(d), the Permittee, Operator, Director and Administrator shall attach 

each notice of an off-permit change completed in accordance with Section XVI of this Title V 

Operating Permit to their copy of the current Title V Operating Permit. 

Do Pursuant to Env-A 612.02(e), any change under Section XVI shall not exceed any emissions 

limitations established under the NH Rules Governing the Control of Air Pollution, or result in an 

increase in emissions, or result in new emissions, of any toxic air pollutant or hazardous air 

pollutant other than those listed in the existing Permit. 

Eo Pursuant to Env-A 612.02(0, the off-permit change shall not qualify for the permit shield under 

Env-A 609.08. 

Minor Permit Amendments: 

Ao Pursuant to EnwA 612.04 prior to implementing a minor permit modification, the Permittee shall 

submit a written request to the Director in accordance with the requirements of Env-A 612.04(b). 

The Director shall take final action on the minor permit amendment request in accordance with 

the provisions of Env-A 612.04(c) through (g). 

Co Pursuant to Env-A 612.04(g), the permit shield specified in Env-A 609.08 shall not apply to 

minor permit amendments under Section XVII. of this Permit. 

Do Pursuant to Env-A 612.04(i), the Permittee shall be subject to the provisions of Part Env-A 614 

and Part Env-A 615 if the change is made prior to the filing with the Director a request for a 

minor permit amendment. 

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XVIII. Significant Permit Amendments: 

Pursuam to Env-A 612.05, a change at the facility shall qualify as a significant permit amendment 

if it meets the criteria specified in Env-A 612.05(a)(1) through (7). 

Bt Prior to implementing the significant permit amendment, the Permittee shall submit a written request to the Dire6tor which includes all the information as referenced in Env-A 612.05(b) and (c) and shall be issued an amended Title V Operating Permit from the DES. The Permittee shall 

be subject to the provisions of Env-A 614 and Env-A 615 if a request for a significant permit amendment is not filed with the Director and/or the change is made prior to the issuance of an amended Title V Operating Permit. 

The Director shall take final action on the significant permit amendment in accordance with the procedures specified in Env-A 612.05(d), (e) and (f). 

XIX. Title V Operating Permit Suspension, Revocation or Nullification. 

Ao Pursuant to RSA 125-C: 13, the Director may suspend or revoke any final permit issued hereunder if, following a hearing, the Director determines that: 

the Permittee has committed a violation of any applicable statute or state requirement found in the New Hampshire Rules Governing the Control of Air Pollution, order or permit condition in force and applicable to it; or 

that the emissions from any device to which this Permit applies, alone or in conjunction with other sources of the same pollutants, presents an immediate danger to the public health. 

no The Director shall nullify any Permit, if following a hearing in accordance with RSA 541-A:30, II, a finding is made that the Permit was issued in whole or in part based upon any information 

proven to be intentionally false or misleading. 

XX. Inspection and Entry: 

Pursuant to Env-A 614.01, EPA and DES personnel shall be granted access to the facility covered by this Permit, in accordance with RSA 125-C:6,VII for the purposes of: inspecting the.proposed or permitted site; investigating a complaint; and assuring compliance with any applicable requirement or state requirement found in the NH Rules Governing the Control of Air Pollution and/or conditions of any Permit issued pursuant to Chapter Env-A 600. 

XXI. Certifications: 

At Compliance Certification Report 

In accordance with 40 CFR 70.6(c) the Responsible Official shall certify, for the previous calender 

year, that the facility is in compliance with the requirements of this permit. The report shall be 

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submitted annually, no later than April 15th of the following year. The report shall be submitted 

to the DES and to the U.S. Environmental Protection Agency New England Region. The report 

shall be submitted in compliance with the submission requirements below. 

In accordance with 40 CFR 70.6(c)(5), the report shall describe: 

1. The terms and conditions of the Permit that are the basis of the certification; 

The current compliance status of the source with respect to the terms and conditions of this 

Permit, and whether the method was continuous or intermittent during the reporting 

period; 

The methods used for determining compliance, including a description of the monitoring, 

record keeping, and reporting requirements and test methods; and 

Any additional information required by the DES to determine the compliance status of the 

source. 

B. Certification of Accuracy Statement 

All documents submitted to the DES shall contain a certification of accuracy statement by the responsible 

official of truth, accuracy, and completeness. Such certification shall be in accordance with the 

requirements of 40 CFR 70.5(d) and contain the following language: 

"I am authorized to make this submission on behalf of the facility for which the submission is 

made. Based on information and belief formed after reasonable inquiry, I certify that the 

statements and information in the enclosed documents are to the best of my knowledge and belief 

true, accurate and complete. I am aware that there are significant penalties for submitting false 

statements and information or omitting required statements and information, including the 

possibility of free or imprisonment." 

All reports submitted to DES (except those submitted as emission based fees as outlined in Section XXIII 

of this Permit) shall be submitted to the following address; 

New Hampshire Department of Environmental Services 

Air Resources Division 

6 Hazen Drive 

P.O. Box 0095 

Corrcord, NH 03302-0095 

ATTN: Compliance Bureau 

All reports submitted to EPA shall be submitted to the following address; 

Office of Environmental Stewardship 

Director Air Compliance Program 

United States Environmental Protection Agency 

Congress Street 

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Suite 1100 (SEA) 

Boston, MA 02114-2023 

ATTN: Air Compliance Clerk 

Enforcement: 

Any noncompliance with a permit condition constitutes a violation of RSA 125-C: 15, and, as to the 

conditions in this permit which are federally enforceable, a violation of the Clean Air Act, 42 U.S.C. 

Section 7401 et seq., and is grounds for enforcement action, for permit termination or revocation, or for 

denial of an operating permit renewal application by the DES and/or EPA. Noncompliance may also be 

grounds for assessment of administrative, civil or criminal penalties in accordance with RSA 125-C: 15 

and/or the Clean Air Act. This Permit does not relieve the Permittee from the obligation to comply with 

any other provisions of RSA 125-C, the New Hampshire Rules Governing the Control of Air Pollution, 

or the Clean Air Act, or to obtain any other necessary authorizations from other governmental agencies, 

or to comply with all other applicable Federal, State, or Local rules and regulations, not addressed in this 

Permit. 

In accordance with 40 CFR 70.6 (a)(6)(ii) a Permittee shall not claim as a defense in an enforcement 

action that it would have been necessary to halt or reduce the permitted activity in order to maintain 

compliance with the conditions of this Permit. 

Emission-Based Fee Requirements: 

Ao The Permittee shall pay an emission-based fee annually for this facility as calculated each calendar 

year pursuant to Env-A 704.03. 

BJ The Permittee shall determine the total actual annual emissions from the facility to.be included in 

the emission-based multiplier specified in Env-A 704.03(a) for each calendar year in accordance 

with the methods specifiedin Env-A 620. 

Co The Permittee shall calculate the annual emission-based fee for each calendar year in accordance 

with the procedures specified in Env-A 704.03 and the following equation: 

FEE E DPT * CPIm * ISF 

Where: 

FEE 

E= 

DPT 

CPIm= 

ISF 

The annual emissi0n-based fee for each calendar year as specified in Env-A 704. 

The emission-based multiplier is based on the calculation of total annual emissions 

as specified in Env-A 704.02 and the provisions specified in Env-A 704.03(a). 

The dollar per ton fee the DES has specified in Env-A 704.03(b). 

The. Consumer Price Index Multiplier as calculated in Env-A 704.03(c). 

The Inventory Stabilization Factor as specified in Env-A 704.03(d). 

OJ The Permittee shall contact the DES each calendar year for the value of the Inventory 

Stabilization Factor. 

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Eo The Permittee shall contact the DES each calendar year for the value of the Consumer Price Index 

Multiplier. 

The Permittee shall submit, to the DES, payment of the emission-based fee and a summary of.the 

calculations referenced in Sections XXIII.B. and C of this Permit for each calendar year by 

October 15 th of the following calendar year in accordance with Env-A 704.04. The emissionbased fee and summary of the calculations shall be submitted to the following address: 

New Hampshire Department of Environmental Services 

Air Resources Division 

6 Hazen Drive 

P.O. Box 0095 

Concord, NH 03302-0095 

ATTN.: Emissions Inventory 

Ge The DES shall notify the Permittee of any under payments or over payments of the annual 

emission-based fee in accordance with Env-A 704.05. 

XXIV. Duty To Provide Information 

In accordance with 40 CFR 70.6 (a)(6)(v), upon the DES's written request, the Permit-tee shall fumish, 

within a reasonable time, any information necessary for determining whether cause exists for modifying, 

revoking and reissuing, or terminating the Permit, or to determine compliance with the Permit. Upon 

request, the Permittee shall furnish to the DES copies of records that the Permittee is required to retain 

by this Permit. The Permittee may make a claim of confidentiality as to any information submitted 

pursuant to this condition in accordance with Part Env-A 103 at the time such information is submitted to 

DES DES shall evaluate such requests in accordance with the provisions of Part Env-A 103. 

XXV. Property Rights 

Pursuant to 40 CFR 70.6 (a)(6)(iv), this Permit does not convey any property rights of any sort, or any 

exclusive privilege. 

XXVI. Severability Clause 

Pursuant to 40 CFR 70.6 (a)(5), the provisions of this Permit are severable, and if any provision of this 

Permit, or the application of any provision of this Permit to any circumstances is held invalid, the 

application of such provision to other circumstances, and the remainder of this Permit, shall not be 

affected thereby. 

XXVII. Emergency Conditions 

Pursuant to 40 CFR 70.6 (g), the Permittee shall be shielded from enforcement action brought for 

h:\permits\current\tiflev\amendmnts\Vcbioen5.amd 

Revised I. 15/99 
Page 31 

noncompliance with technology based 2 emission limitations specified in this Permit as a result of an emergenc3?. In order to use emergency as an affirmative defense to an action brought for 

noncompliance, the Permittee shall demonstrate the affirmative defense through properly signed, contemporaneous operating logs, or other relevant evidence that: 

A. An emergency occurred and that the Permittee can identify the cause(s) of the emergency; 

B. The permitted facility was at the time being properly operated; 

During the period of the emergency, the Permittee took all reasonable steps as expeditiously as possible, to minimize levels of emissions that exceeded the emissions standards, or other 

requirements in this Permit; and 

DJ The Permittee submitted notice of the emergency to the DES within two (2) business days of the 

time when emission limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emission, and corrective actions taken. 

XXVIII. Permit Deviation 

In accordance with 40 CFR 70.6(a)(3)(iii)(B), the Permittee shall report to the DES all,instances of 

deviations from Permit requirements, by telephone or fax, within 8 hours of discovery of such deviation 

pursuant to Env-A 902.02. This report shall include the deviation itself, including those attributable to 

upset conditions as defined in the Permit, the probable cause of such deviations, and any corrective 

actions or preventative measures taken. Said Permit deviation shall also be submitted in writing to the 

DES within fifteen (15) days of documentation of the deviation by facility personnel. Deviations are instances where any Permit condition is violated and has not already been reported as an emergency 

pursuant to Section XXVII of this Permit. 

Reporting a Permit deviation is not an affirmative defense for action brought for noncompliance. 

Technology based emission limits are those established on the basis of emission reductions achievable with various control measures or processchanges (e.g., a new source performance standard) rather than those established to attain 

health based air quality standards. 

An "emergency" means any situation arising from sudden and reasonably mfforeseeable events beyond the control of 

the source, including acts of God, which situation would require immediate corrective action to restore normal operation, and that causes the source to exceed a technology based limitation under the permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operations, operator error or decision to keep operating despite knowledge of any of these things. 

h:\permit•\cu rrent\titlev\amendmnts\tvbioen5.amd Revised 1/15/99 

STATE OF NEW HAMPSHIRE 

Department of Environmental Services 

Air Resources Division 

Title V Operating Permit 

Permit No: TV-OP-004 (Amended) 

Date Issued: February 17, 1999 

This certifies that: 

APC Paper Co., Inc. 

130 Sullivan Street 

Claremont, NH 03743 

has been granted a Title V Operating Permit for the following facility and location: APC Paper Co., Inc. 

130 Sullivan Street 

Claremont, NH 03743 

AFS Point Source Number 3301900001 

This Title V Operating Permit is hereby issued under the terms and conditions specified in the Title V Operating Permit Application filed with the New Hampshire Department of Environmental Services on November 13, 1996 under the signature of the following responsible official certifying to the best of their knowledge that the statements and information therein are true, accurate and complete. 

Responsible Official: 

Paul Mallet 

V.P. Operations 

(603) 542-0411 

Technical Contact: 

Randy Carter 

Technical Director 

(802) 387-5571 or (603) 542-0411 

This Permit is issued by the New Hampshire Department of Environmental Services, Air Resources Division pursuant to its authority under New Hampshire RSA 125-C and in accordance with the provisions of Code of the Federal Regulations 40 Part 70. 

This Title V Operating Permit shall expire on October 31, 2003. 

SEE ATTACHED SHEETS FOR ADDITIONAL PERMIT CONDITIONS 

For the New Hampshire Department of Environmental Services, Air Resource Division 

Director, Air Resources Division 
TABLE OF CONTENTS 

Page 2 

I. Facili• Description of Operations 4 

II. Permitted Activities 4 

III. Significant Activities Identification Table 1. 4-5 

-Stack Criteria Table 2. 

IV. Insignificant Activities Identification 5 

V. Exempt Activities Identification 5 

VI. Pollution Control Equipment Identification 5 

VII. Alternative Operating Scenarios 5 

VIII. Applicable Requirements 6-15 

VIII. A. State-only Enforceable Operational and Emission Limitations - Table 3. 6-7 

VIII. B. Federally Enforceable Operational and Emission Limitations Table 4. 8-9 

VIII. C. Emission Reductions Trading Requirements 9 

VIII. D. Monitoring and Testing Requirements Table 5. 10 

VIII. E. Record keeping Requirements Table 6. 11-13 

VIII. F. Reporting Requirements Table 7. 14-15 

IX. Requirements Currently Not Applicable 15 

Issuance of a Title V Operming Pe•it 

XII. 

XIII. 

XIV. 

XVII. 

XVIII. 

Title V Operating Permit Renewal Procedures 

Application Shield 

Permit Shield 

Reopening for Cause 

Administrative Permit Amendments 

Operational Flexibility 

Minor Permit Amendments 

Significant Permit Amendments 

15-16 

16 

16 

16-17 

17 

17 

17-19 

19 

19 
XIX. 

XX. 

XXI. 

XXIL 

XXlll. 

XXIV. 

XXV. 

XXVI. 

XXVII. 

XXVIII. 

Page 3 

Title V Operating Permit Suspension, Revocation or Nullification 

Inspection and Entry 

Certifications 

Enforcement 

Emission-Based Fees 

Duty to Provide Information 

Property Rights 

Severability Clause 

Emergency Conditions 

Permit Deviations 

19-20 

20 

20-21 

21 

21-22 

22 

22 

22 

23 

23 
Page 4 

Facility Specific Title V Operating Permit Conditions 

I. Facility Description of Operations: 

APC Paper Co., Inc. ("APC") produces 30 to 50 lb. basis weight bag grade paper products derived from 

recycled paper (old corrugated containers and newsprint). Recycled paper products are repulped in a pulper 

and processed through various stock preparation equipment (refiners, screens, and cleaners) prior to delivery 

to the paper machine for final formation and drying of finished bag grade paper products. Steam for the 

pulping, papermaking, and building heat is provided by two boilers. 

II. Permitted Activities: 

In accordance with all of the applicable requirements identified in this permit, the permittee is authorized to 

operate the devices and or processes identified in Sections III, IV, and V within the terms and conditions 

specified in this Permit. 

III. Significant Activities Identification: 

Ao The activities identified in the following table (Table 1) are subject to and regulated by this Title V 

Operating Permit: 

EU1 

EU3 

Riley Stokes Boiler #1 

Riley Stokes Boiler#2 

Stack #1 (combined) 

Stack # (combined) 

PaperMaehine Wet End and Dryer Exhausts 

EU2 

33.0 mmBtu/hr gross heat input at a maximum of 8976 gallons 

per day total for the two boilers 

of • • Oil win a maximum 

sulfur content of 1.5% by 

weight, and rolling 12 

consecutive month fuel use limit 

of 2,727,275 gallons total for 

the two boilers 

33.0 mmBtu/hr gross heat input at a maximum of 8976 gallons 

per day total for the two boilers 

of #6 Ft•l •1 with a maximum 

sulfur content of 1.5% by 

weight, and rolling 12 

consecutive month fuel use limit 

of 2,727,275 gallons total for 

the two boilers 

50 tons per year actual volatile 

organic carbon (VOC) emissions 
Page 5 

Stack Criteria: 

Stack #1 (EU1 & EU2 combined) 

The following stacks for the above listed significant devices at this facility shall discharge vertically 

only 

without obstruction (including rain caps) and meet the following criteria in accordance with the state- modeling requirements specified in Env-A 1300 and Env-A 1400: 

125 4.5 

Preauthorized changes to the state-only requirements pertaining to stack parameters (set forth in this permit), shall be permitted only when an air quality impact analysis which meets the criteria of Env-A 606 is performed either by the facility or the DES (if requested by facility in writing) in accordance with the "DES Policy and Procedure for Air Quality Impact Modeling". All air modeling data shall be kept on file at the facility for review by the DES upon request. 

IV. Insignificant Activities IdentificationAll activities at this facility that meet the criteria identified in the New Hampshire Rules Governing the Control of Air Pollution Part Env-A 609.03(g), shall be considered insignificant activities. Emissions from the insignificant activities shall be included in the total facility emissions for the emission-based fee calculation described in Section XXIII of this Permit. 

V. Exempt Activities Identification: 

VI. 

All activities identified in the New Hampshire Rules Governing the Control of Air Pollution Env-A 609.03(c) shall be considered exempt activities and shall not be subject to or regulated by this Title V Operating Permit. 

Pollution Control Equipment IdentificationVII. 

The devices and/or processes identified in Table 1 do not operate with any pollution control equipment. 

Alternative Operating ScenariosNo alternative operating scenarios were identified for this Permit. 
VIII. 

Page 6 

Applicable Requirements: 

A. State-only Enforceable Operational and Emission Limitations: 

The Permittee shall be subject to the state-only operational and emission limitations identified in Table 

3 below. 

1. Env-A 404.01 EU1 & EU2 

2. Env-A 1305.01(a) Facility Wide 

3. Env-A 1305.02 Facility Wide 

4. Env-A 1403.01 Facility Wide 

5. Env-A 1403.02(a) Facility Wide 

6. Env-A 1403.02(b) Facility Wide 

Env-A 1404.01(d) Facility Wide 

8. Env-A 1405.02 Facility Wide 

9. Env-A 1405.03 Facility Wide 

Sulfur Dioxide emissions from each Class B major source, shall have an average 

emission rate of 1.6 pounds of sulfur dioxide per million Btu input, equivalent to 

No. 6 oil with 1.5 percent sulfur by weight.., 

New or modified devices, new or modified area sources, and existing devices or 

area sources for which new applications for permits are filed that have the potential 

to emit, in any amount, substances that meet the criteria of Env-A 1301 shall be 

subject to Env-A 1300, until such time as the Env-A 1400 requirements supersede 

the Env-A 1300 requirements. (As outlined below) 

Air quality impact analysis of devices and a•-ea sources emitting substances meeting 

the criteria of Env-A 1301 shall be performed in accordance with the "DES Policy 

and Procedure for Air Quality Impact Modeling" or other comparable dispersion 

modeling methods approved by EPA. 

In accordance with Env-A 1403.01, new or modified devices or processes installed 

after May 8, 1998, shall be subject to the requirements of Env-A 1400. 

In accordance with 1403.02(a), all existing unmodified devices or processes which 

are in operation during the transition period ending three years from May 8, 1998 

(May 8, 2001), shall comply with either Env-A 1300 or Env-A 1400. 

In accordance with Env-A 1403.02(b), all existing devices or processes in 

operation after the transition period ending three years from May 8, 1998 (May 8, 

2001), shall comply with Env-A 1400. Env-A 1300 will no longer be in effect. 

In accordance with Env-A 1404.01 (d), documentation for the demonstration of 

compliance shall be retained at the site, and shall be made available to the DES for 

inspection. 

In accordance with Env-A 1405.02 the owner 0fan existing device or process 

requiring a permit modification under chapter Env-A 1400 shall submit to the DES 

no later than one year prior to the end of the transition'period (May 8, 2000), an 

application for a modification to a title V permit in accordance with Env-A 609.18, 

and arequest to the DES to perform air dispersion modeling. 

In accordance with Env-A 1405.03 the owner of an existing device or process 

requiring a permit under Env-A 1300 shall submit to the DES no later than one 

year prior to the end of the transition period (May 8, 2000), a compliance plan 

identifying how the device or process will comply with chapter Env-A 1400 by the 

end of the transition period. The compliance plan shall contain the dates when the 

information required in Env-A 1405.02 will be filed with the DES. 

Facility Wide shall include all significant and insignificant activities at the facility. 
10. Env-A 1406.01 

Page 7 

Facility Wide In accordance with Env-A 1406.01 the owner of any device or process which emits a regulated toxic air pollutant shall determine compliance with the anabient air 

limits by using one of the methods provided in Env-A 1406.02, Env-A 1406.03, or Env-A 1406.04. Upon request, the owner of any device or process which emits a regulated toxic air pollutant shall provide documentation of compliance with the 

ambient air limits to. the DES. 
VIII. Bo 

Page 8 

Federally Enforceable Operational and Emission Limitations 

The Pcrmittce shall be subject to the federally enforceable operational and emission limitations 

identified in Table 4 below. 

RSA 125-C:6 

RSA 125-C:11 

Env-A 606.04 

Env-A 606 

Env-A 1204.02(c) & 

Env-A 1204.27(a) 

Env-A 2003.01& 

Env-A 2507.01 

Env-A 

2003.06(b)(2) & 

Env-A 2507.02 

EU1 & EU2 

Facility Wide 

Facility Wide 

EU1 & EU2 

EU1 & EU2 

The Riley ROH Boilers shall be limited to a combined daily total fuel limit of 8976 

gallons and a combined consecutive 12 month total of 2,727,275 gallons of No. 6 

oil with a maximum sulfur content of 1.5 percent by weight, in order to meet 

national ambient air quality standards for sulfur dioxide. 

Air pollution dispersion ,modeling impact analysis requirements in order to 

determine compliance with the state implementation plan, RSA 125-C, RSA 125-1, 

and any rules adopted, thereunder. 

Permittee shall keep fadility wide actual annual VOC emissions less than or equal 

to 50 tons. 

No owner or operator shall cause or allow average opacity from fuel burning 

devices installed on or prior to May 13, 1970 in excess of 40 percent for any 

continuous 6 minute period in any 60 minute period. 

No owner or operator shall cause or allow emissions of particulate matter from fuel 

burning devices installed on or prior to May 13, 1970 in excess of the rates setforth 

below: 

For devices with equal to or greater than 10 but less than 10,000, E shall 

be calculated by raising to the -0.166 power, and multiplying the result by 

0.880, expressed mathematically in the formula below: 

E 0.880 1-0'166 

where: 

"E" means the maximum allowable particulate matter emission rate in lb/mmBtu; 

'T' means the maximum gross heat input rate in mmBtu/hr; and 

E(EUl 0.49 lb/mmBtu 

E(EU2 0.49 lb/mmBtu 
Page 9 

Env-A 2507.03 EU3 For non-fuel burning devices utilized at paper manufacturing facilities installed prior to or on February 18, 1972, no person shall cause or allow emission standards 

to exceed those specified for "Existing Devices" in Env-A 2103, Table 2103-1, where the maximum allowable particulate matter emission rote shall be calculated by the equation which is applicable for the particular process weight, where: (A) "E" means the maximum allowable particulate matter emission rate in pounds per hour; and 

7. Env-A 2507.04 EU3 

(B) "P'.' means the process weight rate in tons per hour 

For an" Existing Dewce installed prior to February 18, 1972 with a process weight rate: 

(C) Up to 30 tons per hour, P shall be raised to the 0.67 power and multiply the 

result by 5.05, as in the formula below: 

E 5.05"P 0"67 

(D) In excess of 30 tons per hour, P shall be raised to the 0.11 power and multiply the result by 66.0, and then subtract 48, as in the formula below: 

E 66.0'P TM 48 

No person shall cause or allow average visible fugitive emissions or average visible stack emissions from any non-fuel burning device utilized at paper manufacturing facilities installed prior to or on February 18• 1972 to exceed an average of 20 percent opacity for any continuous 6-minute period in any 60 minute period. 

The facility is subject to the Purpose and General Duty clause of the 1990 Clean Air Act, Section 112(0(1 ). General Duty includes the following responsibilities: 

1. Identify potential hazards which may result from such releases using appropriate hazard assessment techniques; 2. Design and maintain a safe facility; 

3. Take steps necessary to prevent releases; and 

4. Minimize the consequences of accidental releases which do occur. 

8. 40 CFR 68 Facility Wide 

VIII. C. Emission Reductions Trading Requirements 

"The Permittee did not request emissions reductions trading in its operating permit application. At this point, DES has not included any permit terms authorizing emissions trading in this permit. All emission reductions trading, must be authorized under the applicable requirements of either Env-A 3000 (the "Em" •sstons Reducttons Credits (or ERCs) Trading Program") or Env-A 3100 (the "Discrete Emissions Reductions (or DERs) Trading Program") and 42 U.S.C. §7401 et seq. (The "Act"), and must be provided for in this Permit." 

VIII. D. Monitoring/Testin_• Requirements 
Page 10 

The Permittee is subject to the monitoring/testing requirements as contained in Table 5 below: 

EU1, Allows for Conduct an annual inspection of each stack and fuel Annually 

EU2, & adequate burning device. Records of inspections and subsequent 

EU3 dispersion of maintenance conducted as a result of the annual 

HAPs and inspections shall be kept on file at the Facility for 

other regulated review by the DES and/or EPA upon request. 

pollutants 

EU & NOx RACT Annually, before April st of each year, the permittee Annually, 

EU2 Testing shall perform an efficiency test using the test before April 

procedures specified in ASME/ANSI Boiler Test Code st 

4.1 and adjust the combustion process of the boiler in 

accordance with the procedures specified in chapter 5, 

Combustion Efficiency Tables, Taplin, Harry R., 

Fairmont Press, 1991. 

Facility Fuel Sulfur The operator shall conduct testing using the appropriate For each 

Wide Content ASTM method or retain certified delivery tickets which delivery 

Verification state the weight percent of sulfur for each delivery of 

fuel oil to determine compliance with the sulfur content 

limitation provisions in this permit for liquid fuels in 

order to meet the reporting requirements specified in 

Env-A 900. 

Facility Opacity 

Wide Measurement 

Opacity measurements shall be conducted following the 

procedures set forth in 40 CFR Part 60, AppendiX A, 

Method 9, VISUAL DETERMINATION OF TIlE 

OPACITY OF EMISSIONS FROM STATIONARY 

SOURCES. The opacity measurements shall be taken 

over 60 minutes durin• normal operation of the device. 

40 CFR 

70.6(a)(3) 

Federally 

Enforceable 

Env-A 

1211.05(b)(1) 

Federally 

Enforceable 

Env-A 809 

Federally 

Enforceable 

As needed Env-A 810.03 

Federally 

Enforceable 
VIII. 

Page 11 

Record keepin• Requirements 

The Permit-tee'is subject to the Record keeping requirements as contained in Table 6 below: 

The Perrnittee shall retain records of all required monitoring data, 

record keeping and reporting requirements and support infornaation 

for a period of at least 5 years from the date of the origination. 

The permittee Shall maintain records of monitoring and testing as specified in Table 5 of this permit for preventative maintenance and inspection results for stacks and fuel burning devices, sulfur 

content in fuel, and opacity readings. 

The permittee shall maintain records ofNOX RACT Testing Results for the boilers in a permanently bound logbook containing the following information: 

1. The date(s) on which 

a. TI•_• test was conducted; and 

b. The e,o•busfion process was last adjusted; 

2. The name(s), title and affiliation of the person(s) who: 

a. Conducted the efficiency test; and 

b. Made the adjustments; 

3. The NOX emission concentration, in ppmvd, corrected to 15% 

oxygen, after the adjustments are made; 

4. The CO emission concentration, in ppmvd, corrected to 15% 

oxygen, after the adjustments are made; and 

5. The opacity readings 

Daily records of combined fuel utilization, monthly records of 

combined fuel utilization, and twelve consecutive month rolling totals of combined fuel utilization shall be kept at the facility and 

contain the following information: 

(A) Consumption; 

(B) Fuel type; 

(C) Viscosity; 

(C) Sulfur content as percent sulfur by weight of 

fuel; 

(D) Btu content per gallon or cubic feet of fuel; and 

(E) Hours of operation of the Riley ROH Boilers. 

Daily, monthly, and annual records shall be kept regarding the total 

quantities of raw materials, including chemicals used and furnish to 

the pulpers, and tons of paper produced. The number of hours of 

operation for the paper machine shall also be recorded. 

Retain for a 

minim• of 5 

years 

Maintain on a 

continuous basis 

as specified in 

Table 5 of this 

permit 

Maintain on a 

continuous basig 

as specified in 

Table 5 of this 

permit 

Daily, monthly, 

& annual total of 

fuel consumption 

Daily, monthly, 

and annually 

Facility wide 

Facility wide 

40 CFR 

70.6(a)(3)(ii)(B) 

Federally 

Enforceable 

40 CFR 

70.6(a)(3)(iii) 

(A) 

Federally 

Enforceable 

EU1 & EU2 E•v-A 

1211.05(b)(2 ) & 

40 CFR 

70.6(a)(3)(iii) 

Federally 

Enforceable 

EU1 & EU2 Env-A 901.03 

and 40 CFR 70.6 

(a)(3)(i)(B) 

Federally 

Enforceable 

Facility 

Wide 

Env-A 901.04 

Federally 

Enforceable 
Page 12 

6. NOX Record keeping Requirements: Daily, weekly, 

For fuel burning devices and incinerators, including boilers, monthly, and 

turbines, and internal combustion engines, the following annually 

information shall, be recorded and maintained: 

(A) Facility information, including: 

1. Source name; 

2. Source identification; 

3. Physical address; 

4. Mailing address; and 

(B) Identification of fuel burning device or incinerator; 

(C) Operating schedule information for each fuel burning 

device or incinerator identified in (B), above, including; 

1. Days per calendar week during the normal 

operating schedule; 

2. Hours per day during the normal operating 

schedule and for a typical ozone season day, if 

different from the normal operating schedule; 

and 

3. Hours per year during the normal operating 

schedule; 

(D) Type, and amount of fuel or waste burned, for each 

fuel burning device or incinerator, during normal 

operating conditions and for a typical ozone season day, if 

different from normal operating conditions, on an hourly 

basis in million Btu's per hour or, for incinerators, in tons 

per hour; 

(E) The following NOX emission data, including records 

of total annual emissions, in tons per year, and typical 

ozone season day emissions, in pounds per day, shall be 

maintained at the facility: 

1. Theoretical potential emissions for the 

calculation year for each fuel burning device or 

incineration unit; and 

2. Actual NOX emissions for each fuel burning 

device or incineration unit. 

EU1 & EU2 Env-A 901.08 

Federally 

Enforceable 
VOC Record keeping Requirements: 

For all applicable facilities and devices, the following information 

shall be recorded and maintained at the facility: (A) Facility information, including: 

1. Source name; 

2. Source identification; 

3. Physical address; and 

4. Mailing address; 

(B) Identification of each VOC-emitting device or 

process, except: 

1. Processes or devices associated exclusively with non-core activities, as defined in Env-A 

1204.03; and 

2. Processes or devices emitting only exempt 

VOCs. 

(C) Operating schedule information for each VOC- emitting device or process identified in (B), above, including: 

1. Days of operation per calendar week during the normal operating schedule; 

2. HoUrs of operation per day during the normal 

operating schedule and for a typical high ozone 

season day, if different from the normal 

operating schedule; and 

3. Hours of operation per year under normal 

operating conditions; (D) The following VOC emission data: 

1. Annual theoretical potential emissions, as determined, in accordance with the applicable section(s) of Env-A 803, using the VOC content for the calculation year for each VOC-emitting device or process identified in (B), above, for: 

a. Each year, in tons per year; and 

b. A typical day during the high ozone 

season of each year, in pounds per day; 

2. Actual VOC emissions from each VOCemitting device or process identified in (B), 

above for: 

a. Each year, in tons per year; and 

b. A typical day during the high ozone 

season of each year, in pounds per day; 

3. Estimated emissions method code; and 

4. Applicable emission factors, if used to 

calculate emissions. 

(E) The calculation Of emission estimates pursuant to (D), above, for a typical high ozone season day shall be based 

on the mean of the parameters relating to operating and 

process rate conditions during the high ozone season. 

Daily, weekly, 

monthly, and 

annually 

Facility 

Wide 

Page 13 

Env-A 

901.06(a), (b), 

(c), & (d) 

Federally 

Enforceable 

VIII. Fe Reporting Requirements 

The Permittee is subject to the reporting requirements as contained in Table 7 below: 
Page 14 

voc Reporting Requirements: 

All sources subject to the reporting requirements of this section shall 

submit the following information to the director in accordance with 

the schedule in Env-A 901.07(h): 

(A) Facility information, including: 

1. Source name; 

2. Source identification; 

3. Physical address; 

4. Mailing address; and 

(B) Identification of each device or process operating at 

the source identified in (A), above; 

(C) Operating schedule information for each device or 

process identified in (B), above, including such information 

for: 

1. A typical business day; and 

2. A typical high ozone season day, if different 

from a typical business day; 

(D) Total quantities of actual VOC and NOX emissions 

for the entire facility and for each device or process 

identified in (B), above, including: 

1. Annual VOC emissions, and 

2. Typical high ozone season day VOC 

emissions. 

NOX Reporting Requirements: 

For fuel buming devices and incinerators, including boilers, turbines 

and engines, as well as asphalt plant dryers and miscellaneous 

sources, the owner or operator shall submit to the director, annually 

(no later than April 15th of the following year), reports of the data 

required by Condition VIII.E, Table 6, Item 6., including total 

annual quantities of all NOX emissions. 

The permittee shall annually submit to the director, an annual fuel 

usage report indicating monthly fuel usage, annual fuel usage, an d 

corresponding fuel information as outlined in Condition VIII.E., 

Table 6, Item 4. 

The permittee shall annually submit to the director, an annual 

chemical usage report and annual production report. The annual 

production report will include tons of paper produced per month and 

total paper production for the year in tons. The chemical usage 

report will include monthly usage of all chemicals (pounds per 

month), the yearly usage of such chemicals (pounds per year), and 

the VOC content in weight percent for each of the chemicals. 

By April 15, 

1996 for 

calendar year 

1995; every 

third calendar 

year after 1995 

by April 15th of 

the following 

year. 

Annually (no 

later than April 

15th of the 

following year) 

Annually (no 

later than April 

15th of the 

following year) 

later than April 

15th of the 

following year) 

Facility Wide 

Regulatory, 

Env-A 

901.07(b) 

Federally 

Enforceable 

EU1 & EU2 Env-A 

901.09(b)(1) 

Federally 

Enforceable 

EU1 & EU2 40 CFR 70.6 

(a)(1) Federally 

Enforceable 

EU3 40 CFR 

70.6(a)(1) 

Federally 

Enforceable 
Page 15 

Prompt reporting of deviations from Permit requirements within 8 

hours of such an occurance by phone or fax in accordance with 

Section XXVIII. of this Permit. 

The Permittee shall submit to DES a summary report of monitoring and testing requirements every. 6 months. All instances of 

deviations from Permit requirements must clearly be identified in 

such reports. All required reports must be certified by a responsible official consistent with section 70.5(d). The report shall contain a 

summary of the following information: 

(A) 

(t•) 

(c) 

(D) 

Preventative maintenance and inspection results 

for stacks and fuel burning devices; 

A summary report of the NOX RACT Testing results required in the Applicable Record keeping section of this permit; 

Fuel sulfur content certifications; and 

Opacity readings. 

Any report submitted to the DES and/or EPA shall include the compliance certification statement as outlined in Section XXI.B. of 

this Permit and shall be signed by the responsible official. 

Annual reporting and payment of emission based fees shall be 

conducted in accordance with Section XXIII of this Permit. 

Annual compliance certification shall be submitted in accordance 

with Section XXI. of this Permit. 

Prompt 

reporting 

(ie; within 8 

hours of an 

occurrence). 

Every 6 months 

by January 31st 

and July 31st of 

each calendar 

year. 

Facility Wide 

Facility wide 

Env-A 902.02 

& 

40 CFR 

70.6(a)(3)(iii) 

Federally 

Enforceable 

40 CFR 

70.6(a)(3)(iii) 

(A) 

Federally 

Enforceable 

As specified Facility wide 

As specified in Facility wide 

Section XXIII. 

April 15th Facility wide 

40 CFR 

70.6(c)(1) 

Federally 

Enforceable 

Env-A 704.03 

40 CFR 

70.6(c)(1) 

Federally 

Enforceable 

IX. Requirements Currently Not Applicable. 

The Permittee did not identify any requirements which are not applicable to the facility. 

General Title V Operating Permit Conditions 

Xe Issuance of a Title V Operating Permit: 

Ao This Permit is issued in accordance with the provisions of Part Env-A 609. In accordance with 40 CFR 70.6(a)(2) this Permit shall expire on the date specified on the cover page of this Permit, which shall not be later than the date five (5) years after.issuance of this Permit. 

Permit expiration terminates the Permittee's right to operate the Permittee's emission units, control equipment or associated equipment covered by this Permit, unless a timely and complete renewal application is submitted at least 6 months beforethe expiration date. 
XI. 

XII. 

XIII. 

Page 16 

nm Pursuant to Env-A 609.02(b), this Permit shall be a state permit to operate as defined in RSA 125- 

C:ll, III. 

Title V Operating Permit Renewal Procedures: 

Pursuant to Env-A 609:06(b), an application for renewal of this Permit shall be considered timely if it is 

submitted to the Director at least six months prior to the designated expiration date of this Permit. 

Application Shield: 

Pursuant to Env-A 609.07, if an applicant submits a timely and complete application for the issuance or 

renewal of a Permit, the failure to have a Permit shall not be considered a violation of this part until the 

Director takes final action on the application. 

Permit Shield: 

A. Pursuant to Env-A 609.08(a), a permit shield shall provide that: 

For any applicable requirement or any state requirement found in the New Hampshire Rules 

Governing the Control of Air Pollution specifically included in this Permit, compliance with 

the conditions of this Permit shall be deemed compliance with said applicable requirement or 

said state requirement as of the date of permit issuance; and 

For any potentially applicable requirement or any potential state requirement found in the 

New Hampshire Rules Goveming the Control of Air Pollution specifically identified in 

Section IX of this Permit as not applicable to the stationary source or area source, the 

Permittee need not comply with the specifically identified federal or state requirements. 

The permit shield identified in Section XIII.A. of this Permit shall apply only to those conditions 

incorporated into this Permit in accordance with the provisions of Env-A 609.08(b). It shall not apply 

to certain conditions as specified in Env-A 609.08(c) that may be incorporated into this Permit 

following permit issuance by the DES. 

Co If a Title V Operating Permit and amendments there to issued by the DES does not expressly include 

or exclude an applicable requirement or a state requirement found in the NH Rules Governing the 

Control of Air Pollution, that applicable requirement or state requirement shall not be covered by the 

permit shield and the Permittee shall comply with the provisions of said requirement to the extent that 

it applies to the Permittee. 

If the DES determines that this Title V Operating Permit was issued based upon inaccurate or 

incomplete information provided by the applicant or Permittee, any permit shield provisions in said 

Title V Operating Permit shall be void as to the portions of said Title V Operating Permit which are 

affected, directly or indirectly, by the inaccurate or incomplete information. 

Pursuant to Env-A 609.08(0, nothing contained in Section XIII of this Permit shall alter or affect the 

ability of the DES to reopen this Permit for cause in accordance with Env-A 609.18 or to exercise 

its summary abatement authority. 
XV. 

XVI. 

Page 17 

Fg Pursuant to Env-A 609.08(g), nothing contained in Section XIII of this Permit or in any title V 

operating permit issued by the DES shall alter or affect the following: 

The ability of the DES to order abatement requiring immediate compliance with applicable requirements upon finding that there is an imminent and substantial endangerment to public 

health, welfare, or the environment; 

The state of New Hampshire's ability to bring an enforcement action pursuant to RSA 125- 

C: 15,1I; 

The provisions of section 303 of the Act regarding emergency orders including the authority 

of the EPA Administrator under that section; 

The liability, of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance; 

So The applicable requirements of the acid rain program, consistent with section 408(a) of the 

Act; 

6m The ability of the DES or the EPA Administrator to obtain information about a stationary 

source, area source, or device from the owner or operator pursuant to section 114 of the Act; 

or 

The ability of the DES or the EPA Administrator to enter, inspect, and/or monitor a 

stationary source, area source, or device. 

Reopening for Cause: 

The Director shall reopen and revise a Title V Operating Permit for cause if any of the circumstances 

contained in Env-A 609.18(a) exist. In all proceedings to reopen and reissue a Title V Operating Permit, the 

Director shall follow the provisions specified in Env-A 609.18(b) through (g). 

Administrative Permit Amendments: 

Pursuant to Env-A 612.01, the Permit-tee may implement the changes addressed in the request for an 

administrative permit amendment as def'med in Part Env-A 100 immediately upon submittal of the 

request. 

Bo Pursuant to Env-A 612.01, the Director shall take final action on a request for an administrative 

permit amendment.in accordance with the provisions of Env-A 612.01 (b) and (c). 

Operational Flexibility: 

Am Pursuant to Env-A 612.02(a), the Permittee subject to and operating under this Title V Operating 

Permit may make changes involving trading of emissions under this existing Title V Operating Permit 

at the permitted stationary source or area source without filing a Title V Operating Permit application 

for and obtaining an amended Title V Operating Permit, provided that all the conditions are met as 

specified in Section XVI. A. 1. through 7. of this permit and a notice is submitted to the DES and 
Bo 

Page 18 

EPA describing the intended changes. At this point, the DES has not included any permit terms 

authorizing emissions trading in this permit. 

1. The change is not a modification under any provision of title I 0f the Act; 

The change does not cause emissions to exceed the emissions allowable under the title 

V operating permit, whether expressed therein as a rate of emissions or in terms of 

total emissions; 

3. The owner or operator has obtained any temporary permit required by Env-A 600; 

The owner or operator has provided written notification to the director and 

administrator at least 15 days prior to the proposed change and such written 

notification includes: 

a. The date on which each proposed change will occur; 

b. A description of each such change; 

Any change in emissions that will result and how this change in emissions will 

comply with the terms and conditions of the permit; 

d. A written request that the operational flexibility procedures be used; and 

e. The signature of the responsible official, consistent with Env-A 605.04(b); 

The title V operating permit issued to the stationary source or area source already 

contains terms and conditions including all terms and conditions which determine 

compliance required under 40 CFR 70.6(a) and (c) and which allow for the trading 

of emissions increases and decreases at the permitted stationary source or area source 

solely for the purpose of complying with a federally-enforceable emissions cap that 

is established in the permit independent of otherwise applicable requirements; 

The owner or operator has included inthe application for the title V operating permit 

proposed replicable procedures and proposed permit terms which ensure that the 

emissions trades are quantifiable and federally enforceable for changes to the title V 

operating permit which qualify under a federally- enforceable emissions cap that is 

established in the title V operating permit independent of the otherwise applicable 

requirements; and 

7. The proposed change complies with Env-A 612.02 (e). 

Pursuant to Env-A 612.02(c), the Permittee subject to and operating under this Title V Operating 

Permit may make changes not addressed or prohibited by this existing Title V Operating Permit at 

the permitted stationary source or area source without filing a Title V Operating Permit application, 

provided that all the conditions specified in Env-A 612.02(c)(1) through (6) are met and a notice is 

submitted to the DES and EPA describing the intended changes. 
Page 19 

CJ Pursuant to Env-A 612.02(d), the Permittee, Operator, Director and Administrator shall attach each 

notice of an off-permit change completed in accordance with Section XVI of this Title V Operating Permit to their copy of the current Title V Operating Permit. 

Pursuant to Env-A 612.02(e), any change under Section XVI shall not exceed any emissions 

limitations established under the NH Rules Governing the Control of Air Pollution, or result in an increase in emissions, or result in new emissions, of any toxic air pollutant or hazardous air pollutant other than those listed in the existing Permit. 

Et Pursuant to Env-A 612.02(0, the off-permit change shall not qualify for the permit shield under EnvA 609.08. 

XVII. Minor Permit Amendments: 

Pursuant to Env-A 612.04 prior to implementing a minor permit modification, the Permittee shall 

submit a written request to the Director in accordance with the requirements of Env-A 612.04(b). 

The Director shall take final action on the minor permit amendment request in accordance with the provisions of Env-A 612.04(c) through (g). 

Pursuant to Env-A 612.04(h), the permit shield specified in Env-A 609.08 shall not apply to minor permit amendments under Section XVII. of this Permit. 

Do Pursuant to Env-A 612.04(i), the Permittee shall be subject to the provisions of Part Env-A 614 and 

Part Env-A 615 if the change is made prior to the filing with the Director a request for a minor permit amendment. 

XVIII. significant Permit Amendments: 

Ao Pursuant to Env-A 612.05, a change at the facility shall qualify as a significant permit amendment if 

it meets the criteria specified in Env-A 612.05(a)(1) through (7). 

Prior to implementing the significant permit amendment, the Permittee shall submit a written request 

to the Director and to the EPA which includes all the information as referenced in Env-A 612.05(b) and (c) and shall be issued an amended Title V Operating Permit from the DES. The Permittee shall 

be subject to the provisions of Env-A 614 and Env-A 615 if a request for a significant permit amendment is not .filed with the Director and/or the change is made prior to the issuance of an amended Title V Operating Permit. 

The Director shall take fmal action on the significant permit amendment in accordance with the procedures specified in Env-A 612.05(d), (e) and (f). 

XIX. Title V Operating Permit Suspension, Revocation or Nullification: 

Ao Pursuant to RSA 125-C: 13, the Director may suspend or revoke any final permit issued hereunder if, following a hearing, the Director determines that: 

1. The Permittee has committed a violation of any applicable statute or state requirement found 
XXj 

Page 20 

in the New Hampshire Rules Governing the Control of Air Pollution, order or permit 

condition in force and applicable to it; or 

That the emissions from any device to which this Permit applies, alone or in conjunction with 

other sources of the same pollutants, presents an immediate danger to the public health. 

Bt The Director shall nullify any Permit, if following a hearing in accordance with RSA 541-A:30, II, 

a finding is made that the Permit was issued in whole or in part based upon any information proven 

to be intentionally false or misleading. 

Inspection and Entry: 

Pursuant to Env-A 614.01, EPA and DES personnel shall be granted access to the facility covered by this 

Permit, in accordance with RSA 125-C:6,VII for the purposes of: inspecting the proposed or permitted site; 

investigating a complaint; and assuring compliance with any applicable requirement or state requirement 

found in the NH Rules Governing the Control of Air Pollution and/or conditions of any Permit issued 

pursuant to Chapter Env-A 600. 

Certifications: 

At 

Bt 

Compliance Certification Report 

In accordance with 40 CFR 70.6(c) the Responsible Official shall certify, annually from the date of 

issuance, that the facility is in compliance with the requirements of this permit. The report shall be 

submitted to the DES and to the Regional Administrator, U.S. Environmental Protection Agency 

New England Region. The report shall be submitted in compliance with the submission requirements 

below. 

In accordance with 40 CFR 70.6(c)(5), the report shall describe: 

1. The terms and conditions of the Permit that are the basis of the certification; 

The current compliance status of the source with respect to the terms and conditions of this 

Permit, and whether compliance was continuous or intermittent during the reporting period; 

The methods used for determining compliance, including a description of the monitoring, 

record keeping, and reporting requirements and test methods; and 

Any additional information required by the DES to determine the compliance status of the 

source. 

Mailing addresses for submittal of the Compliance Certification Report are as follows: 

New Hampshire Department of Environmental Services 

Air Resources Division 

64 North Main Street 

P.O. Box 2033 

Concord, NH 03302-2033 

ATTN: Compliance Bureau 

Certification of Accuracy Statement 

USEPA Region 

JFK Federal Building 

Boston, MA 02203 

ATTN: Air Compliance NH 
Page 21 

All documents submitted to the DES shall contain a certification of accuracy statement by the responsible official of troth, accuracy, and completeness. Such certification shall be in accordance with the requirements of 40 CFR 70.5(d) and contain the following language: 

"I am authorized to make this submission on behalf of the facility for which the submission is made. Based 

on information and belief formed after reasonable inquiry, I certify that the statements and information in the 

enclosed documents are to the best of my laaowledge and belief true, accurate and complete. I am aware that 

there are significant penalties for submitting false statements and information or omitting required statements 

and information, including the possibility of fine or imprisonment." 

XXII. Enforcement: 

Any noncompliance with a permit condition constitutes a violation of RSA 125-C:15, and, as to the 

conditions in this permit which are federally enforceable, a violation of the Clean Air Act, 42 U.S.C. section 

7401 et seq., and is grounds for enforcement action, for permit termination or revocation,, or for denial of 

an operating permit renewal application by the DES and/or EPA. Noncompliance may also be grounds for 

assessment of administrative, civil or criminal penalties in accordance with RSA 125-C: 15 and/or the Clean 

Air Act. This Permit does not relieve the Permittee from the obligation to comply with any other provisions of RSA 125-C, the New Hampshire Rules Governing the Control of Air Pollution, or the Clean Air Act, or 

to obtain any other necessary authorizations from other governmental agencies, or to comply with all other 

applicable Federal, State, or Local rules and regulations, not addressed in this Permit. 

In accordance with 40 CFR 70.6 (a)(6)(ii) a Permittee shall not claim as a defense in an enforcement action 

that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with 

the conditions of this Permit. 

XXIII. Emission-Based Fee Requirements: 

Ao The Permittee shall pay an emission-based fee annually for this facility as calculated each calendar 

year pursuant to Env-A 704.03. 

Bo The Permittee shall determine the total actual annual emissions from the facility to be included in the 

emission-based multiplier specified in Env-A 704.03(a) for each calendar year in accordance with the 

methods specified in Env-A 620. 

Co The Permittee shall calculate the annual emission-based fee for each calendar year in accordance with 

the procedures specified in Env-A 704.03 and the following equation: 

FEE E DPT CPIm * ISF 

Where: 

FEE 

E= 

DPT 

The annual emission-based fee for each calendar year as specified in Env-A 704. 

The emission-based multiplier is based on the calculation of total annual emissions as 

specified in Env-A 704.02 and the provisions specified in Env-A 704.03(a). 

The dollar per ton fee the DES has specified in Env-A 704.03(b). 
Page 22 

CPIm 

ISF 

The Consumer Price Index Multiplier as calculated in Env-A 704.03(c). 

The Inventory Stabilization Factor as specified in Env-A 704.03(d). 

The Permittee Shall contact the DES each calendar year for the value of the Inventory Stabilization 

Factor. 

The Permittee shall contact the DES each calendar year for the value of the Consumer Price Index 

Multiplier. 

Fe The Permittee shall submit, to the DES, payment of the emission-based fee and a summary of the 

calculations referenced in Sections XXIII.B. and C of this Permit for each calendar year by October 

15 th of the following calendar year in accordance with Env-A 704.04. The emission-based fee and 

summary of the calculations shall be submitted to the following address: 

New Hampshire Department of Environmental Services 

Air Resources Division 

64 North Main Street 

P.O. Box 2033 

Concord, NH 03302-2033 

ATTN: Emissions Inventory 

GQ The DES shall notify the Permittee of any under payments or over payments of the annual emissionbased fee in accordance with Env-A 704.05. 

XXIV. Duty To Provide Information 

In accordance with 40 CFR 70.6 (a)(6)(v), upon the DES's written request, the Permittee shall furnish, within 

a reasonable time, any information necessary for determining whether cause exists for modifying, revoking 

and reissuing, or terminating the Permit, or to determine compliance with the Permit. Upon request, the 

Permittee shall furnish to the DES copies of records that the Permittee is required to retain by this Permit. 

The Permittee may make a claim of confidentiality as to any information submitted pursuant to this condition 

in accordance with Part Env-A 103 at the time such information is submitted to the DES. The DES shall 

evaluate such requests in accordance with the provisions of Part Env-A 103. 

XXV. Property_ Rights 

Pursuant to 40 CFR 70.6 (a)(6)(iv), this Permit does not convey any property rights of any sort, or any 

exclusive privilege. 

XXVI. Severability Clause 

Pursuant to 40 CFR 70.6 (a)(5), the provisions of this Permit are severable, and if any provision of this 

Permit, or the application of any provision of this Permit to any circumstances is held invalid, the application 

of such provision to other circumstances, and the remainder of this Permit, shall not be affected thereby. 

XXVII. Emergency Conditions 
Page 23 

Pursuant to 40 CFR 70.6 (g), the Permittee shall be shielded from enforcement action brought for 

noncompliance with technology based 2 emission limitations specified in this Permit as a result of an 

emergency a. In order to use emergency as an affirmative defense to an action brought for noncompliance, 

the Permittee shall demonstrate the affirmative defense through properly signed, contemporaneous operating 

10gs, or other relevant evidence that: 

A. An emergency occurred and that the Permittee can identify the cause(s) of the emergency; 

B. The permitted facility was at the time being properly operated; 

Ct During the period of the emergency, the Permittee took all reasonable steps as expeditiously as 

possible, to minimize levels of emissions that exceeded the emissions standards, or other requirements 

in this Permit; and 

The Permittee submitted notice of the emergency to the DES within two (2) business days of the time 

when emission limitations were exceeded due to the emergency. This notice must contain a 

description of the emergency, any steps taken to mitigate emission, and corrective actions taken. 

XXVIII. Permit Deviation 

In accordance with 40 CFR 70.6(a)(3)(iii)(B), the Permittee shall report to the DES all instances of deviations 

from Permit requirements, by telephone (calling (603) 271-1088) or fax ((603) 271,1381 Attention: 

Compliance Bureau), within 8 hours of discovery of such deviation pursuant to Env-A 902.02. This report 

shall include the deviation itself, including those attributable to upset conditions as defined in the Permit, the 

probable cause of such deviations, and any corrective actions or preventative measures taken. Said Permit 

deviation shall also be submitted in writing to the DES, at the address listed in permit condition XXI.A. 

within fifteen (15) days of documentation of the deviation by facility personnel. Deviations are instances 

where any Permit condition is violated and has not already been reported as an emergency pursuant to 

Section XXVII of this Permit. 

Reporting a Permit deviation is not an affirmative defense for action brought for noncompliance. 

Technologybased emission limits are those established on the basis of emission reductions achievable with various 

control measures or process changes (e.g., a new source performance standard) rather than those established to attain 

health based air quality standards. 

An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of 

the source, including acts of God, which situation would require immediate corrective action to restore normal operation, 

and that causes the source to exceed a technology based limitation under the permit, due to unavoidable increases in 

emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by 

improperly designed equipment, lack of preventative maintenance, careless or improper operations, operator error or 

decision to keep operating despite knowledge of any of these things. 

h:\laughton\permits\apcpaper\tvamend.wpd 

Administrative Amendment 02-17-99 
Page 24 
STATE OF NEW HAMPSHIRE 

Department of Environmental Services 

Air Resources Division 

Title V Operating Permit 

Permit No: ]'V-OP-039 

Date Issued: November 8, 2001 

This certifies that: 

Monadnock Paper Mills, Inc. 

117 Antrim Road 

Bennington, NH 03442 

has been granted a Title V Operating Permit for the following facility and location: Monadnoek Paper Mills, Inc. 

117 Antrim Road 

Bennington, NH 03442 

AFS Point Source Number 3301100070 

This Title V Operating Permit is hereby issued pursuant to RSA 125-C and Part Env-A 609. This permit has been prepared based on information specified in the Title V Operating Permit Application filed with the New Hampshire Department of Environmental Services on July 1, 1996 and subsequent updates dated December 3 & 6, 1996 plus air emissions modeling dated July 7 & 9, 1997, and the Regulated Toxic Air Pollutants compliance Plan dated May 4, 2000 with associated modeling dated April 30, 2000, under the signature of the following responsible official certifying to the best of their knowledge that the statements and information therein are true, accurate and complete. 

Responsible Official: 

Paul M. Ciccone 

V.P. Manufacturing 

(603) 588-3311 

Technical Contact: 

Muriei Lajoie 

Environmental Manager 

(603) 588-3311 

Permit is issued by the New Hampshire Department of Environmental Services, Air Resources Division pursuant to its authority under New Hampshire RSA 125-C and in accordance with the prowsions of Code of the Federal Regulations 40 Part 70. 

This Title V Operating Permit shall expire on November 30, 2006. 

SEE ATTACHED SHEETS FOR ADDITIONAL PERMIT CONDITIONS 

For the New Hampshire Department of Environmental Services, Air Resource Division 

Director, Air Resources Division 
Page 2 

TABLE OF CONTENTS 

I. Facility Description of Operations 4 

II. 4 

4-6 

IV. 

VIII. 

VIII. A. 

VIII. B. 

VIII. C. 

VIII. D. 

VIII. E. 

VIII. F. 

VIII. Q. 

IX. 

Permitted Activities 

Significant Activities Identification Table 1. 

-Stack Criteria Table 2. 

Insignificant Activities Identification 

Exempt Activities Identification 

Pollution Control Equipment Identification 

Alternative Operating Scenarios 

V. 6 

VI. 6 

VII. 6 

Applicable Requirements 7-24 

State-only Enforceable Operational and Emission Limitations Table 3. 

Federally Enforceable Operational and Emission Limitations Table 4. 

Emission Reductions Trading Requirements 

Monitoring and Testing Requirements Table 5. 

Record keeping Requirements Table 6. 

Reporting Requirements Table 7. 

Compliance Plan 

Requirements Currently Not Applicable 

Issuance of a Title V Operating Permit 

Title V Operating Permit Renewal Procedures 

XII. 

XIV. 

Application Shield 

Permit Shield 

Reopening for Cause 

Administrative Permit Amendments 

Operational Flexibility 

XV. 

XVI. 

7-9 

10-12 

13 

13-16 

17-21 

22-24 

25 

25-26 

27 

27 

27 

27-28 

28 

28-29 

29-30 
Page 3 

XVII. Minor Permit Amendments 

XVl•I. Significant Permit Amendments 30-31 

Title V Operating Permit Suspension, Revocation or Nullification 31 

XX. Inspection and .Entry 

XXI; 

XXII. 

XXI/I. 

XXIV. 

Certifications 

Enforcement 

Emission-Based Fees 

Duty to Provide Information 

31 

31-32 

32 

32-33 

33 

XXV. Property Rights 34 

XXVI. Severability Clause 34 

XXVII. Emergency Conditions 34 

XXVIII. Permit Deviations 34-35 

Appendix A List of Emergency Generators 36-37 
Page 4 

Facility Specific Title V Operating Permit Conditions 

I. Facility Description of Operations: 

Monadnock Paper Mills, Inc. ("MPM") is a non-integrated paper mill producing a variety of paper grades 

from purchased pulp. Products include wallpaper, abrasive paper backings, medical packaging paper, 

graphic arts papers, and book covers for elementary and high school text books. The mill is composed of 

the following: two paper machines with stock preparation equipment, on-machine coating application, 

steam-heated dryers, and other support equipment; two 30,000 pounds steam.per hour boilers; .a 1.8 

mmBtu/hour emergency generator; and an existing off-machine coater. Depending upon grade of paper 

produced, coatings can be applied at the size press on either of the two paper machines, just prior to the last 

dryer section or on the existing off-machine coater. 

II. Permitted Activities: 

In accordance with all of the applicable requirements identified in this permit, the permittee is authorized 

to operate the devices and or processes identified in Sections III, IV, and V within the terms and conditions 

specified in this Permit. 

IlL Significant Activities Identification: 

Ao The activities identified in the following table (Table 1) are subject to and regulated by this Title V 

Operating Permit: 

Babcock & Wilcox • #1 

(Built in 1960) No. 112 (combined stack for 

EU1 and EU2) 

EU1 

,?.!•!•Em•sslons•ffntt;Max!mum "., 

30,000 pounds per hour 

steam production at 250 psig 

and 406 degrees F; fuel 

input to the boiler being 

eilh•lqo. 6 fttet oil or blend 

of No. 6 fuel oil with onsite generated onspecification (on-spec) or 

off-specification (off-spec) 

used oil in accordance with 

Conditions VIII.B. 1., 2., 3., 

& 4., with a maximum 

sulfur content of 1.5% by 

weight; and a rolling 12 

consecutive month fuel use 

limit of 3,942,000 gallons 

for EU1 and EU2 combined. 
Page 5 

EU2 

EU31 

EU4 

EU5 

EU6 

Babcock & WilOl• #2' 

(Built in 1960) 

No. Paper Machine 

No. 2 Paper Machine 

Coater #1 

All MPM Emergency Generators 

(See Appendix A for a listing of all 

Emergency Generators located at the 

Monadnock Paper Mill facility 

No. 112 (combined stack for 

EUI and EU2) 

30,000 pounds per hour 

steam production at 250 ps•l 

and 406 degrees F; fuel 

input to the boiler being eitMl'lg• 6 fuel oil or bMnd 

of No. 6 fuel oil with onsite generated on-spec or 

off-spec used oil in 

accordance with Conditions 

VIII.B. 1., 2., 3., & 4., with a 

maximum sulfur content of 

1.5% by weight, and a 

rolling 12 consecutive 

month fuel use limit of 

3,942,000 gallons for EU1 

and EU2 combined. 

No's. 41, 43, 83, 84, 85, 86, 91, 

93 

No's.40, 42, 33, 34, 35, 37, 92 

No. 46 

Stacks vary 

Coatings to be in.compliance 

with VOC RACT limitation of 

2.9 lbs VOC per gallon, as 

applied, excluding water and 

exempt compounds 

Coatings to be in compliance 

with VOC RACT limitation of 

2.9 lbs VOC per gallon, as 

applied, excluding water and 

exempt compounds 

8.4 mmBtu/hr propane fired 

dryer; Coatings to be in 

compliance with VOC RACT 

limitation of 2.9 lbs VOC per 

gallon, as applied, excluding water and exempt compounds 

Less than 500 hours of 

operation during any 

consecutive 12-month period 

for any individual unit and the 

combined theoretical potential 

emissions ofNOX fi'om all 

such generators ale limited to 

less than 25 tons for any 

consecUtive 12-month period 

Stacks 83, 84, 85, 86, 91, & 93 in the No. Paper Machine Area are small unquantifiable sources whose fugitive emissions are accounted for in Stacks No. 

41 and 43. 

Stacks 33, 34, 35, 37, & 92 in the No. 2 Paper Machine Area are small unquantifiable sources whose fugitive emissions are accounted for in Stacks No. 

40 and 42. 
Page 6 

Stack Criteria: 

go The following stacks for the above listed significant devices at this facility shall discharge vertically 

without obstruction (no rain caps) and meet the following criteria in accordance with the state-only 

modeling requirements specified in Env-A 1300 and Env-A 1400: 

No. 112 EUI & EU2 (Boilers) 121.0 6.0 

No. 41 EU3 (No. Machine 60.0 5.125 

No. 43 EU3 (No. Machine)' 60.0 5.i25 

No. 40 EU4 (No. 2 Machine) 60.0 5.125 

No. 42 EU4 (No. 2 Machine) 60.0 5.125 

No. 46 EU5 (#1 Coater) 61.0 2.33 

No. 98 EU6 (Emerg. Generator) 15.0 0.5 

Preauthorized changes to the state-only requirement s pertaining to stack parameters (set forth in this permit), 

shall be permitted only when an air quality impact analysis which meets the criteria of Env,A 606 is 

performed either by the facility or the New Hampshire Department of Environmental Services, Air 

Resources Division (DES) [if requested by the facility in writing] in accordance ,with the "DES Policy and 

Procedure for Air Quality Impact Modeling". All air modeling data shall be kept on file at the facility for 

review by the DES upon request, 

IV. Insignificant Activities Identification: 

Wo 

VI. 

All activities at this facility that meet the criteria identified in the New Hampshire Rules Governing the 

Control of Air Pollution Part Env-A 609.03(g), shall be considered insignificant activities. Emissions from 

the insignificant activities shall be included in the total facility emissions for the emission-based fee 

calculation described in Section XXIII of this Permit. 

Exempt Activities Identification: 

All activities identified in the New Hampshire Rules Goveming the Control of Air Pollution Env-A 

609.03(c) shall be considered exempt activities and shall not be subject to or regulated by this Title V 

Operating Permit. 

Pollution Control Equipment Identification: 

The devices and/or processes identified in Table do not operate with any pollution control equipment. 

VII. Alternative Operating Scenarios: 

No alternative operating scenarios were identified for this Permit. 
Page 7 

VIII. Applicable Requirements: 

A. State-only Enforceable Operational and Emission Limitations: 

The Permittee shall be subject to the state-only operational and emission limitations identified in Table 3 below. 

It;m ,: •lat0ryC,t • •sPsli•2bul:i --:: ,/ Applieab!eReq•l•em•nt .,:: ,: :•: 

1. Env-A 404.01 EU1 & EU2 Sulfur Dioxide emissions from each Class B major source, shall have an average 

emission rate of 1.6 pounds of sulfur dioxide per million Btu input, equivalent to no. 6 oil with 1.5 percent sulfur by weight. MPM shall be required to use No. 6 

oil with a maximum of 1.5 percent sulfur by weight. 

Env-A 1305.01(a) Facility Wide 

3. Env-A 1305.02 Facility Wide 

4. Env-A 1403.01 

5. Env-A 1403.02(a) 

6. Env-A 1403.02(b) 

7. Env-A 1404.01(d) 

Env-A 1405.02 

New or modified devices, new or modified area sources, and existing devices or 

area sources for which new applications for permits are filed that have the potential to emit, in any amount, substances that meet the criteria of Env-A 1301 

shall be subject to Env-A 1300, until such time as the Env-A 1400 requirements supersede the Env-A 1300 requirements. (As outlined below) 

Air quality impact analysis of devices and area sources emitting substances meeting the criteria of Env-A 1301 shall be performed in accordance with the 

"DES Policy and Procedure for Air Quality Impact Modeling" or other comparable dispersion modeling methods approved by EPA. 

9. Env-A 1405.03 

Facility Wide In accordance with Env-A 1403.01, new ormodified devices or processes 

installed after May 8, 1998, shall be subject to the requirements of Env-A 1400. 

Facility Wide In accordance with 1403.02(a), all existing unmodified devices or processes 

which are in operation during the transition period ending three years from May 8, 1998 (May 8, 2001), shall comply with either Env-A 1300 or Env-A 1400. 

Facility Wide In accordance with Env-A 1403.02(b), all existing devices or processes in operation after the transition period ending three years from May 8, 1998 (May 8, 2001), shall comply with Env-A 1400. Env-A 1300 will no longer be in effect. 

Facility Wid•e In accordance with Env-A 1404.01 (d), documentation for the demonstration of compliance shall be retained at the site, and shall be made available to the DES 

for inspection. 

Facility Wide In accordance with Env-A 1405.02 the owner of an existing device or process requiring a permit modification under chapter Env-A 1400 shall submit to the 

DES no later than one year prior to the end of the transition period (May 8, 2000), an application for a modification to a title V permit in accordance with Env-A 609.18, and a request to the DES to perform air dispersion modeling. 

Facility Wide In accordance with Env-A 1405.03 the owner of an existing device or process requiring a permit under Env-A 1300 shall submit to the DES no later than one 

year prior to the end of the transition period (May 8, 2000), a compliance plan identifying how the device or process will comply with chapter Env-A 1400 by the endof the transition period. The compliance plan shall contain the dates when the information required in Env-A 1405.02 will be filed with the DES. 

Facility Wide shall include all significant and insignificant activities at the facility. 
Page 8 

1o. Env-A 1406.01 Facility Wide In accordance with Env-A 1406.01 the owner of any device or process which 

emits a regulated toxic air pollutant shall determine compliance with the ambient 

air limits by using one of the methods provided in Env-A 1406.02, Env-A 

1406.03, or Env-A 1406.04. Upon request, the owner of any device or process 

which emits a regulated toxic air pollutant shall provide documentation of 

compliance with the ambient air limits to the DES. 

In order to ensure compliance with Env-A 1400,relativ.e to formaldehyde, MPM 

will do the following: 

A. Each week, MPM will project forward a 4-week paper machine schedule 

(if order backlog exists) to determine combined formaldehyde impacts 

from the facility's paper machines and coater; 

B• MPM will develop emissions estimates based on previous runs of each 

formaldehyde-containing grade for each machine. These emissions 

estimates shall be used in conjunction with the modeling submitted to 

DES on May 4, 2000 to determine the impact, An micrograms per cubic 

meter, at the property line. If more recent approved modeling becomes 

available during the term of this permit, MPM shall use those values to 

determine the impact. This value will be compared to the Ambient Air 

Limit (AAL) for formaldehyde listed in the Table in Env-A 1450.01.; 

C. The formaldehyde emission rates at the wet end of the paper machines 

will be calculated using the NCASI value of 0.65% of the dry resin 

applied.4; 

D. The formaldehyde emission rates at the dry end (size press) of the paper 

machines will be based on Acetyl Acetone emissions testing conducted 

in August 1993 for the grade 2109-076, and prorated to other grades 

based on application rate of resin, machine speed, deckle and other 

production related conditions as may be appropriate.; 

E. Each formaldehyde emission rate default value will be verified and 

updated semi-annually, if necessary, using the methods above, beginning 

with the 6-month period ending June 30, 2001, if the grade is. 

manufacttwed during that period. The subsequent 6-month's emission 

rate default value will be based on the revised information.; 

F. The emission rates and associated impacts presented in the spreadsheet 

of the August 1, 2000 correspondence from MPM, based on values 

submitted in MPM's May 4, 2000 compliance schedule, will be used to 

predict compliance until the first verification cycle.; and 

G. MPM will make a good faith effort to coordinate the paper machine and 

coater operating schedules in order to maintain compliance with the 

AAL Limits for formaldehyde contained in the Table in Env-A 1450.01. 

* If compliance can be demonstrated through stack testing data and 

ambient air dispersion modeling analyses that the facility is in 

compliance with AALs for formaldehyde at maximum worst case 

scenario conditions for the paper machines and coaters combined, then 

Conditions A. through G., mentioned above, will no longer be 

applicable. 

Unpublished National Council of the Pulp and Paper Industry for Air and Stream Improvement 

(NCASI) Study, A Procedure for the Calculation of Emission Inventories or Measurement of 

Formaldehyde Emissions from Paper Machine Dryers When Manufacturing Wet Strength Papers 

with Formaldehyde Based Resins, dated June 1992. 
I0. Env-A 1406.01 

(Continued) 

Page 9 

Facili• Wide To demons•ate compliance with EnV-A 1400 for other chemical compounds, MPM will do the following: 

H. •ual review of all existing Regulated Toxic Air Pollu•nts (RTAPs) in use and emi•ed. 

I. Review of all new RTAPs p•or to their use to ensure A•s are not exceeded. 

J. Use of deminimus calculations, adjusted in-s•ck concen•ations, DES 

approved modeling or the following fo•ula to ensure RT• A•s are not exceeded: 

•ere: 

AAL •rar) •bient Air Limit in u•m3 

MI •r•) Modeled Maximum Impact in u•m3/Ib•r 

ER Ac•al Allowable Emission Rate of the RT• in Ib/• 
VIII. mo 

Page. 10 

Federally Enforceable Operational and Emission Limitations 

The Permittee shall be subject to the federally enforceable operational and emission limitations 

identified in Table 4 below. 

40 CFR 525 

40 CFR 

70.6(a)(3)(i)(B) 

Env-Wm 807.03(b) 

40 CFR 70.6(c)(1) 

Env-A 1204.10(c) 

Env-A 

1211.02(j)(1)&(2) 

EU6 

EU1 & EU2 

EU1 & EU2 

EU1 &EU2 

EU3, EU4, & 

EU5 

EU6 

The sulfur content of No. 2 fuel oil shall not exceed 0.4 percent sulfur by weight. 

The combustion of used oil at the facility shall be subject to the following 

contaminant concentration requirements as verified through analysis: 

On-spec used oil Off-spec used oil 

Constituent/Property Allowable Level 

Sulfur (% by weight) 

Arsenic 

Cadmium 

Chromium 

Lead 

Total Halogens 

PCBs 

Flash Point 

.Allowable Level 

No more than 1.5% S 

5.0 ppm maximum 

2.0 ppm maximum 

10.0 ppm maximum 

100.0 ppm maximum 

1000.0 ppm maximum 

Less than 2.0 ppm 

Not Applicable 

No more than 1.5% S 

18.0 ppm maximum 

10.0 ppm maximum 

35.0 ppm maximum 

660 ppm maximum 

Not Applicable 

'Less than 50.0 ppm 

100 deg F minimum 

MPM shall cpmply with all the requirements listed in 40 CFR 761.20(e)(3) to 

burn, under normal operating temperatures, quantifiable levels (2 to less than 50.0 

ppm) of PCBs contained in the on site generated used oil. 

The used oil generated on site shall be analyzed for the properties listed in 

condition VIII.B.2. before blending occurs. The New Hampshire Department of 

Environmental Services, Waste Management Division and U.S. Environmental 

Protection Agency must be notified and their approval obtained for used oil 

recycling. Monadnock Paper Mills, Inc. shall comply with all the requirements 

under Env-Wm Chapter 800 Requirements For Recycling of Hazardous Wastes, 

Those processes applying a coating to any woven or non-woven, fibrous or nonfibrous substrate, including paper, fabric, glass matting, plastic film, ribbon, and 

magnetic tapes shall be limited at all times to an emission rate of 0.35 kg/1 (2.9 lb 

VOC/gallon) of coating, as applied, excluding water and exempt compounds. 

The emergency generator shall be limited to less than 500 hours of 0peration 

during any consecutive 12 month period and the combined theoretical potential 

emissions of NOx from all such generators are limited to less than 25 tons for any 

consecutive 12 month period of time. 

Env-A 402.02(a), effective on December 27, 1990, was adopted as part of the State Implementation 

Plan (SIP) on September 14, 1992 and is still considered federally enforceable until such time as the 

SIP is amended and approved by the EPA. 

Ambient air dispersion modeling conducted on the boilers for burning off-spec used oil at a 450 

gallon per day limit showed that the lead content of any off-spec used oil must be less than or equal to 660 ppm, which is lower than the off-spec oil limit of 1000 ppm lead contained in Env-Wm 

807.03. 
I0. 

11. 

12. 

RSA 125-C:6, 

RSA 125-C:11, and 

Env-A 606.04 

Env-A 2003.01 and 

Env-A 2507.02 

Env-A 2003.02 and 

Env-A 2508.02 

Env-A 2003.06 and 

Env-A 2507.01 

Env-A 2003.07 

Env-A 2003.08 and 

Env-A 2508.01 

Page 11 

EU1 & EU2 The boilers shall be limited to a consecutive 12 month combined total of 3,942,000 gallons of No. 6 oil with a maximum sulfur content of 1.5 percent by weight, in order to meet national ambient air quality standards for sulfur dioxide (annual standard). In addition, the boilers shall be limited to burning less than or equal to 450 gallons per day of on-site generated on-spec or off-spec used oil. Lead concentration in off-spec used oil must be less than 660 ppm, which is lower than the limit of 1000 ppm lead contained in Env-Wm 807.03. 

EU1 & EU2 No owner or operator shall cause or allow average opacity from fuel burning devices installed on or prior to May 13, 1970 in excess of 40 percent for any continuous 6 minute period in any 60 minute period, 

EU5 & EU6 No owner or operator shall cause or allow average opacity from fuel burning devices installed after May 13, 1970 in excess of 20 percent for any continuous 6 minute period in any 60 minute period. 

EU1 & EU2 

EU6 

EU5 

No owner or operator shall cause or allow emissions of particulate matter from fuel burning devices installed on or prior to May 13, 1970 in excess of the rates set forth below, where: 

(A) "E" means the maximum allowable particulate matter emission rate in lb/106 BTU; 

(B) 'T' means the maximum gross heat input rate in 10 BTU/hr; (C) For devices with less than 10, E shall be equal to 0.60; (D) For devices with equal to or greater than 10 but less than 10,000, E 

shall be calculated by raising to the -0.166 power, and multiplying the 

result by 0.880, expressed mathematically in the formula below: 

E 0.880 "°'166 

(E) E (EU1 & EU2) 0.48 lb/106 BTU 

Compliance can be verified by using fuel usage rate fired and Use of AP-42 emission factors. 

No owner or operator shall cause or allow emissions of particulate matter from fuel burning devices installed after May 13, 1970 but before January 1, 1985 in excess of the rates set forth below, where: 

(A) "E" means the maximum allowable particulate matter emission rate in lb/10 BTU; 

(B) "I" means the maximum gross heat inpu• rate in 10 BTU/hr; (C) For devices with less than 10, E shall be equal to 0.60; (D) E (EU6) 0.6 lb/106 BTU 

Compliance can be verified by using fuel usage rate fired and use of AP-42 emission factors. 

No owner or operator shall cause or allow emissions of particulate matter from fuel burning devices installed on or after January 1, 1985, in excess of the rates set forth below, where: 

(A) "E" means the maximum allowable particulate matter emission rate in lb/10 BTU; 

(B) "I" means the maximum gross hea• input rate in 10 BTU/hr; (C) For devices with less than 100, E shall be equal to 0.30; (D) E (EU5) 0.30 lb/106 BTU 

Compliance can be verified by using fuel usage rate fired and use of AP-42 emission factors. 
Page 12 

13. 40 CFR 68 

14. 40 CFR 70.6(a)(1) 

Facility Wide 

Facility Wide 

The facility is subject to the Purpose and General Duty clause of the 1990 Clean 

Air Act, Section 112(r)(1), which states: 

"Identify hazards which may result from such releases using appropriate hazard 

assessment techniques; to design and maintain a safe facility taking such steps as 

are necessary to prevent releases; and to minimize the consequences of accidental 

releases which do occur.,, 

The facility is limited to less than 10 tons per year of any individual federal 

hazardous air pollutant (HAP)emissions and less than 25 tons per year emissions 

for all HAPs combined. IfMPM exceeds these emissions limitations it may be 

subject to National Emission Standards for Hazardous Air Pollutants (NESHAP) 

contained in 40 CFR 63. 
Page 13 

VIII. C. Emission Reductions Trading Requirements 

"The Permittee did not request emissions reductions trading.in its operating permit application. At this point, DES has not included any permit terms authorizing emissions trading in this permit. All emission reductions trading, must be authorized under the applicable requirements of either Env-A 3000 (the "Emissions Reductions Credits (or ERCs) Trading Program") or Env-A 3100 (the "Discrete Emissions Reductions (or DERs) Trading Program") and 42 U.S.C. §7401 et seq. (The "Act"), and must be provided for in this Permit." 

VIII. D. Monitorina/Testing Requirements 

The Permittee is subject to the monitoring/testing requirements as contained in Table 5 below: 

EU1, Allows for 

EU2, adequate 

EU3, dispersion of 

EU4, HAPs and 

EU5, EU6 other regulated 

pollutants 

EU1 & NOX RACT 

EU2 Compliance 

EU 1, Fuel Sulfur 

EU2, Content 

EU5, & Verification 

EU6 

EU1 & Opacity 

EU2 Measurement 

Conduct an annual inspection of each stack .and fuel burning device. Inspections shall include 

documenting any leaks, holes, rusting and/or disrepair of stacks. Inspections of fuel burning equipment shall 

follow either manufacturers recommended checks or insurance carrier and National Fire Protection 

Association Guidelines. Records of inspections and subsequent maintenance conducted as a result of the 

annual inspections shall be kept on file at the facility for review by the DES and/or EPA upon request. 

Annually, before April 1st of each year, the permittee 

shall perform an efficiency test using the test procedures specified in ASME/ANSI Boiler Test Code 

4.1 and adjust the combustion process of the boiler in 

accordance with the procedures specified in Chapter 5, 

Combustion Efficiency Tables, Taplin, Harry R., 

Fairmont Press, 1991. 

The operator shall conduct testing using the 

appropriate ASTM method or retain certified delivery tickets which state the weight percent of sulfur for 

each delivery of fuel oil to determine compliance with 

the sulfur content limitation provisions in this permit 

for liquid fuels in order to meet the reporting 

requirements specified in Env-A 900. If the fuel 

supplier blends quantities of differing sulfur content fuel oil, the delivery ticket will state proportions of 

each fuel oil and the associated sulfur content so the 

sulfur content by weight for the delivery can readily be 

determined. 

Opacity measurements shall be conducted following the procedures set forth in 40 CFR Part 60, Appendix A, Method 9, VISUAL DETERMINATION OF THE 

oPACITY OF EMISSIONS FROM STATIONARY 

SOURCES. The opacity measurements shall be taken during the annual boiler efficiency testing. 

Annually 40 CFR 

70.6(a)(3) 

Federally 

Enforceable 

Annually, Env-A 

before April 1211.05(b)(l) 

1st Federally 

Enforceable 

For each 

delivery 

During annual 

efficiency test 

Env-A 809 

State-only 

Enforceable & 

40 CFR 

70.6(a)(3) 

Federally 

Enforceable 

Env-A 810.03 

Federally 

Enforceable 
Page 14 

EU1 & 

EU2 

On-site Used 

Oil Analysis 

A representative sample of on-site generated used oil 

shall be analyzed prior to transferring and blending 

each batch (450 gallons maximum) with No. 6 fuel oil. 

The on-site generated used oil must be below the 

following maximum allowable concentrations in order 

to be blended with No. 6 fuel oil and burned in the 

boilers: 

Maximum Allowable Concentrations in Used Oil: 

Constituent On-soec Off-s.p_•. 

SulfUr(% by wt) 1.5% 1.5% 

Arsenic 5,0 ppm 18.0 ppm 

Cadmium 2.0 ppm 10.0 ppm 

Chromium 10.0 ppm 35.0 ppm 

Lead 100 ppm 660 ppm 

Total Halogens 1000 ppm Not applic. 

PCB's 2.0 ppm 50.0 ppm 

Flash Point Not applic. 100 deg F 

Prior to 

burning a 450 

gallon batch of 

on-site 

generated used 

oil with No. 6 

fuel oil 

40 CFR 

70.6(a)(1) 

Federally 

Enforceable 
EU3, 

EU4, & 

EU5 

Testing of 

Coatings for 

VOC RACT 

Compliance 

All coating formulations used on the size presses of 

the paper machines No. and No. 2 and on the paper coater at the MPM facility shall be either tested using Methods below or the facility will retain sufficient 

records for prima facie evidence in support of demonstrating compliance with the limit of 2.9 pounds 

VOC per gallon of coating, as applied, excluding water and exempt compounds.: 

(A) Method 24, 40 CFR Part 60, Appendix A at l-hour bake time, or an alternative test method approved by the director in 

accordance with Env-A 807.01; or 

(B) Method 24A, 40 CFR Part 60, Appendix A, or an alternative test method approved by the 

director in accordance with Env-A 807.01. 

For multi component coatings, the following procedures shall be used in addition to prima facie evidence, Method 24 of 40 CFR 60, Appendix A, or an alternative test method approved by the Director in 

accordance with Env-A 807.01 (Regulatory Cite EnvA 803.03(d)): 

1. Separate samples of each component 

shall be obtained; 

2. The components shall be mixed in a 

container in the same proportions as 

those in the coating, as applied; 

3. The container in which mixing takes 

place shall be closed between 

additions and during mixing; 

4. About 100ml of coating shall be 

prepared in a container just large enough to hold the mixture prior to withdrawing a sample; and 

5. A sample shall be withdrawn from 

the mixed coating and then 

transferred to a dish which shall be 

weighed and then allowed to stand 

for at least one hour, but not more 

than 24 hours prior to being oven 

dried at 110 degrees C for one hour. 

Upon request by DES or EPA, MPM may be required to take samples of as applied coatings and have testing conducted using one of the Methods above or alternative approved by the Director for demonstration 

of compliance with the 2.9 lb VOC/gal limit. 

One time for 

existing and 

new coating 

formulations 

and when an 

existing 

coating is 

reformulated 

or there is a 

change in 

supplier of a 

component 

containing 

VOCs. 

Page 15 

Env-A 803.03 

Federally 

Enforceable 
Page 16 

7. EU3, State Air Monadnock Papers (MPM) is required to demonstrate Performed Env-A 1406 

EU4, & Toxics compliance with the Ambient Air Limits (AAL) listed once, prior to RSA 125- 

EU5 Compliance in the New Hampshire Code of Administrative Rules, March 1,2001 C:6,XI 

Demonstration Chapter Env-A 1400, Regulated Toxic Air Pollutants State-only 

for both normal and maximum worst case operating Enforceable 

scenarios through air dispersion modeling impact 

analyses or a•aother method specified in Env-A 

1406.01. MPM must conduct stack testing by March 

1, 2001 for formaldehyde from the paper machines and 

coater. MPM must use one of the following three test 

methods listed below or an alternative method 

approved by the Director. All such testing must be 

performed by a third party familiar with the referenced 

test methods or approved alternative test methods. 

NCASI Method CI/S6/Pulp-94.02 

NCASI Method CI/WP-98.01 

EPA Methods TO-5 and TO-11 (DPNH sample 

collection/HPLC analysis) 

Testing must be planned and carried out in accordance 

with the following schedule: 

1. At least 30 days prior to the testing, MPM must 

submit to the Division a pretest report containing the 

following: 

a. Calibration methods and sample d•ta 

sheets; 

b. Description of test methods to be used; 

c. Pre-test preparation procedures; 

d. Sample analysis/collection methods; 

e. Where samples are to be collected; 

f. Process data to be collected; and 

g. Complete test program description. 

2. At least 15 days prior to the test date, MPM and the 

contractor it retains for performance of the testing, 

must participate in a pretest conference with a 

Division representative. 

3. Emission Testing must be carried out under the 

observation of a Division representative. 

4. Within 30 days of test completion, MPM must 

submit a test report to the Division. 
VIII. 

Page 17 

Record keeping Requirements 

The Permittee is subject to the Record keeping requirements as contained in Table 6 below: 

The Permittee shall retain records of all required monitoring data, 

record keeping and reporting requirements and support 

information for a period of at least 5 years from the date of the origination. 

The permittee shall maintain records of monitoring and testing as specified in Table 5 of this permit, which includes the following items: 

(A) Preventative maintenance and inspection results for 

stacks and fuel burning devices; (B) Fuel sulfur content verification; (C) On-site generated used oil analyses; (D) Opacity data; 

(E) Boiler NOX PACT tuneup results; and 

(F) Coatings VOC content (proof of compliance With the 2.9 

Ib VOC/gal limit, i.e. Method 24, Method 24A, other 

Director approved test method results, or all supporting information for prima faci• evidence). 

Monthly or period records Of fuel utilization shall be kept at the facility and contain the following information: 

(A) Consumption; 

(B) Fuel type; 

(C) Sulfur content as percent sulfur by weight of 

fuel; 

(D) Btu content per gallon or cubic feet of fuel; and 

(E) Hours of operation of the boilers, coaters, and 

diesel emergency generator. 

Retain for a Facility 40 CFR 

minimum of 5 wide 70.6(a)(3)(ii)(B) 

years .Federally 

Enforceable 

Maintain on a Facility 40 CFR 

continuous basis wide 70.6(a)(3)(iii) as specified in (A) 

Table 5 of this Federally permit Enforceable 

Monthly & EUI, EU2, Env-A 903.03 

consecutive 12 EU5, & State-Only 

month rolling EU6 Enforceable & 

total or period(s) Env-A 901.03 

& consecutive 13 Federally period rolling Enforceable 

total of fuel (See footnote) consumption 

Monthly records of on-site generated used oil used as fuel for the Monthly & EU1 & EU2 Env-A 901.03 boilers and results of used oil chemical analysis as required by consecutive 12 Federally permit Section VIII.D.5. month rolling Enforceable 

total of used oil 

consumption 

On April 23, 1999, DES promulgated new Env-A 900 regulations in an attempt to streamline the 

record keeping and reporting requirement sections of the New Hampshire Code of Administrative 

Rules. Until such time that the new Env-A 900 regulations are approved and adopted into the State Implementation Plan (SIP) by EPA, all Title V Permits will be incorporating the old Env-A 900 regulations (which became effective on November 11, 1992), unless the new Env-A 900 regulations are more stringent. The record keeping and reporting requirements contained in this permit are those requirements which the facility shall be required to comply with. These record keeping and reporting requirements shall fall under the Permit Shield provisions as contained in Section XIII of 

this permit. 
Page 18 

Period records shall be kept regarding the beginning inventory, 

quantity purchased, quantity consumed, and ending inventory of 

raw materials used, including chemicals and coating components 

used. Period records shall be kept of tons of paper produced on 

the paper machines, pounds or tons of paper coated for the coater, 

and hours of operation for this equipment. 

For each 28-day 

period and 

annually 

Facility 

Wide 

Env-A 903.02 

State-Only 

Enforceable & 

Env-A 901.04 

Federally 

Enforceable 

(See footnote) 

On September 2, 1999• DES granted MPM permission to use a 13-period, 28-day accounting period 

for a calendar year as •he period of record for the two paper machines and the paper coater rather 

than the standard monthly period referred to in Env-A 901.04 and Env-A 901.06. 
VOC Record keeping Requirements: 

For all applicable facilities and devices, the following information 

shall be recorded and maintained at the facility: (A) Facility information, including: 

1. Source name; 2. Source identification; 

3. Physical address; and 

4. Mailing address; 

(B) Identification of each VOC-emitting device or 

process, except: 

1. Processes or devices associated exclusively 

with non-core activities, as defined in Env-A 

1204.03; and 

2. Processes or devices emitting only exempt 

VOCs. 

(C) Operating schedule infol•ation for each VOCemitting device or process identified in (B), above, including: 

a. Days of operation per calendar week during 

the normal operating schedule; 

b. Hours of operation per day during the normal 

operating schedule and for a typical high ozone 

season day, if different from the normal 

operating schedule; and 

c. Hours of operation per year under normal 

operating conditions; 

(D) The following VOC emission data: 

1. Annual theoretical potential emissions, as determined in accordance with the applicable section(s) of Env-A 803, using the VOC content for the calculation year for each VOC-emitting 

device or process identified in (B), above, tbr: 

a. Each year, in tons per year; and 

b. A typical day during the high ozone 

season of each year, in pounds per day; 

2. Actual VOC emissions from each VOCemitting device or process identified in (B), 

above for: 

a. Each year, in tons per year; and. 

b. A typical day during the high ozone 

season of each year, in pounds per day; 

3. Estimated emissions method code; and 

4. Applicable emission factors, if used to 

calculate emissions. 

(E) The calculation of emission estimates pursuant to (D), above, for a typical high ozone season day shall be 

based on the mean of the parameters relating to operating and process rate conditions during the high ozone 

season. 

Daily and 

annually Facility 

Wide 

Page 19 

Env-A 

901.06(a), (b), 

(c), & (d) 

Federally 

Enforceable 
Page 20 

voc Record keeping requirements for surface coating and 

printing operations: 

For all surface coating and printing operations, the following 

information shall be recorded and maintained: 

(A) Coating formulation and analytical data, as follows: 

(1) Supplier; 

(2) Name and color; 

(3) Type; 

(4) Identification number; 

(5) Density described as lbs/gal; 

(6) Total volatiles content described as weight 

percent; 

(7) Water content described as weight percent; 

(8) Exempt solvent content described as weight 

percent; 

(9) VOC content described as weight; 

(10) Solids content described as volume percent; 

(11) Diluent solvent name and identification number 

used with each coating; 

(12) Diluent solvent density described as lbs/gal; 

(13) Diluent VOC content described as weight 

percent; 

(14) Diluent exempt solvent content described as 

weight percent; 

(15) Volume of diluent VOC described as gal; and 

(16) Diluent/solvent ratio described as gal diluent 

solvent/gal coating. 

(B) For the paper machines, record the following 

information: 

(1) Tons of paper produced for each grade of paper 

on a period basis (period basis as defined in 

Footnote 5 of this permit); 

(2) Total quantities of each coating component 

used on a period basis; 

(3) Total VOC's emitted, on a yearly basis; and 

(4) Individual and total annual HAP emissions. 

(C) For the coater, record the following information: 

(1) Pounds of paper produced for each grade on a 

period basis; 

(2) Total quantities of each coating used on a 

period basis; 

(3) Total VOC's emitted, on a yearly basis; and 

(4) Individual and total annual HAP emissions. 

For each 28-day 

period and 

annually 

EU3, EU4, 

& EU5 

Env-A 

90k06(a), (b), 

(c), & (d) 

Federally 

Enforceable 
Page 21 

NOx Record keeping Requirements: 

For fuel burning devices and incinerators, including boilers, turbines, and internal combustion engines• the following information shall be recorded and maintained: 

(A) Facility information, including: 

1. Source name; 2. Source identification; 

3. Physical address; and 

4. Mailing address. 

(B) Identification of fuel burning device or incinerator; (C) Operating schedule information for each fuel buming device or incinerator identified in (B), above, including; 

1. Days per calendar •veek during the normal 

operating schedule; 

2. Hours per day during the normal operating schedule and for a typical ozone season day, if 

different from the normal operating schedule; 

and 

3. Hours per year during the normal operating schedule; 

(D) Type, and amount of fuel or waste burned, for each 

fuel burning device or incinerator, during normal 

operating conditions and for a typical ozone season day, if different from normal operating conditions, on an hourly basis in million Btu's per hour or, for 

incinerators, in tons per hour; 

(E) The following NOx emission data, including records 

of total annual emissions, in tons per year, and typical ozone season day emissioris, in pounds per day, shall be 

maintained at the facility: 

1. Theoretical potential emissions for the 

calculation year foreach fuel burning device or 

incineration unit; and 2. 

Actual NOx emissions for each fuel burning device or incineration unit. 

The permittee shall maintain records ofNOx RACT Testing Results for the boilers in a permanently bound log book containing the following information: 

1. The date(s) on which: 

a. The efficiency test was conducted; and 

b. The combustion process was last adjusted; 

2. The name(s), title and affiliation of the person(s) who: 

a. Conducted the efficiency test; and 

b. Made the adjustments; 

3. The NOx emission concentration, in ppmvd, corrected to 15% 

oxygen, after the adjustments are mhde; 

4. The.CO emission concentration, in ppmvd, corrected to 15% 

oxygen, after the adjustments are made; and 

5. The opacit,/readings 

Daily and 

annually 

Maintain on a 

continuous basis 

as specified in 

Table 5 of this 

permit 

Facility Env-A 901.08 

Wide Federally 

Enforceable 

EU1 & EU2 Env-A 

1211.05(b)(2) & 

40 CFR 

70.6(a)(3)(iii) 

(A) Federally 

Enforceable. 
VIII. Renorting Requirements 9 

The Permittee is subject to the reporting requirements as contained in Table 7 below: 

Page 22 

voc Reporting Requirements: 

All sources subject to the reporting requirements of this section 

shall submit the following information to the director in 

accordance with the schedule in Env-A 901.07(h): 

(A) Facility information, including: 

1. Source name; 

2. Source identification; 

3. Physical address; 

4. Mailing address; and 

(B) Identification of each device or process operating at 

the source identified in (A), above; 

(C) Operating schedule information for each device or 

process identified in (B), above, including such 

information for: 

1. A typical business day; and 

2. A typical high ozone season day, if different 

from a typical business day; and 

(D) Total quantities of actual VOC and NOx emissions 

for the entire facility and for each device or process 

identified in (B), above, including: 

1. Annual VOC emissions, and 

2. Typical high ozone season day VOC 

emissions. 

NOx Reporting Requirements: 

For fuel burning devices and incinerators, including boilers, 

turbines and engines, as well as asphalt plant dryers and 

miscellaneous sources, the owner or operator shall submit to the 

director, annually (no later than April 15th of the following year), 

reports of the data required by Condition VIII.E., Table 6, Item 7., 

including total annual quantities of all NO• emissions. 

Annually (no FaciliW Wide Env-A 

later than April 901.07(b) 

15th of the Federally 

following year) Enforceable 

to DES 

Annually (no 

later than April 

15th of the 

following year). to DES 

Facility Wide Env-A 901.09 

Federally 

Enforceable 

On April 23, 1999, DES promulgated new Env-A 900 regulations in an attempt to streamline the 

record keeping and reporting requirement sections of the New Hampshire Code of Administrative 

Rules. Until such time that the new Env-A 900 regulations are approved and adopted into the State 

Implementation Plan (SIP) by EPA, all Title V Permits will be incorporating the old Env-A 900 

regulations (which became effective on November 11, 1992), unless the new Env-A 900 regulations 

are more stringent. The record keeping and reporting requirements contained in this permit are 

those requirements which the facility shall be required to comply with. These record keeping and 

reporting requirements shall fall under the Permit Shield provisions as contained in Section XIII of 

this permit. 
Page 23 

(c) 

(D) 

The permittee shall submit to the DES an annual emissions report by April 15th for the previous calendar year. The annual emissions 

report will include the following information: 

(A) The actual emissions of the stationary source, area source, or device and the methods used in calculating such 

emissions in accordance with Env-A 704.02; (B) For process operations, all information in accordance with 

Env-A 903.02; 

For Combustion devices, all information in accordance 

with Env-A 903.03; and 

The actual annual emissions speciated by individual regulated air pollutants, including a breakdown of VOC 

emissions by compound. 

Prompt reporting of deviations from Permit requirements within 24 

hours of such an occurance by phone or fax in accordance with 

Section XXVIII. of this Permit. 

The permit•ee shall submit to the director an annual fuel usage 

report indicating monthly or period fuel usage and consecutive 

twelve month or 13 period fuel usage totals at the end of each 

calendar month or period for that calendar year. 

The permittee shall submit to the Director an annual chemical 

usage report and production report containing the following information: 

For the paper machines 

(A) Tons of paper produced for each grade of paper on a period basis; 

(B) Hours of operation per period; (C) Hours of operation per year; 

(D) Total quantities of coating components used on a period basis; 

(E) Total quantities of coating components used on an annual 

basis; 

(F) Total VOCs emitted on an annual basis; and 

(G) Individual and total annual HAP emissions. 

For the coater 

(A) Pounds or tons of paper produced for each grade of paper on a period basis; 

(B) Hours of operation per period; (C) Hours of operation per year; 

(D) Total quantities of each coating used on a period basis; (E) Total quantities of each coating used on an annual basis; (F) Total VOCs emitted on an annual basis; and 

(G) Individual and total annual HAP emissions. 

Annually (no 

later than April 

15th of the 

following year) to DES 

Facility Wide Env-A 907.01 

State-only 

Enforceable 

Prompt Facility wide 

reporting 

(ie; within 24 

hours of an 

occurrence) to 

DES 

Annually (•o Facility Wide 

later than April 

15th of the 

following year) to DES 

Annually (no Facility Wide 

later than April 

15th of the 

following year) to DES 

40 CFR 

70.6(a)(3)(iii) 

(•) 

Federally 

Enforceable 

40 CFR 70.6 

(a)(1) 

Federally 

Enforceable 

40 CFR 

70.6(a)(1) 

Federally 

Enforceable 
Page 24 

The Permittee shall submit to the DES a summary report of 

monitoring and testing requirements every 6 months. All 

instances of deviations from Permit requirements must clearly be 

identified in such reports. All required reports must be certified by 

a responsible official consistent with section 70.5(d). The report 

shall contain a summary of the following information: 

(A) Preventative maintenance and inspection results 

for stacks and fuel burning devices; 

(B) A summary report of the boiler tuneups required 

in the Applicable Monitoring/Testing section of 

this permit; 

(C) Fuel sulfur content for each delivery of No. 6 

fuel oil received; 

(D) Opacity measurements; and 

(E) Analyses for each batch of on-site generated used 

oil which was blended with No. 6 fuel oil for 

buming in the boilers. 

(F) Any permit deviation subject to Section XXVIII. 

Upon request by DES or EPA, MPM may be required to submit all 

support documentation for compliance with VOC RACT limits for 

coatings used on the paper machine size presses or the paper 

coater. 

Any report submitted to the DES and/or EPA shall include the 

compliance certification statement as outlined in Section XXI.B. of 

this Permit and shall be signed by the responsible official. 

Annual reporting and payment of emission based fees shall be 

conducted in accordance with Section XXIII of this Permit. 

Annual compliance certification shall be submitted in accordance 

with Section XXI. of this Permit. 

Every 6 months 

by July 31 st and 

January 31 st of 

each calendar 

year to DES 

and EPA 

Facility wide 

Facility wide 

40 CFR 

70.6(a)(3)(iii) 

(A) 

Federally 

Enforceable 

As specified 

As specified in 

Section XXIII. 

To DES 

Facility wide 

April 15th to 

DES and EPA 

Facility wide 

40 CFR 

70.6(c)(1) 

Federally 

40 CFR 

70.6(c)(1) 

Federally 

Enforceable 

Env-A 704.03 

Federally 

Enforceable 

Enforceable 
VIII. 

IX. 

Page 25 

G. Compliance Plan 

In addition to the above state and federally enforceable requirements, Monadnock Papers shall adhere to 

the schedule put forth in the Compliance Plan received May 8, 2000 listed below pursuant to Env-A 1709.01(h) for Emission Units EU3, EU4, &EU5 (Paper Machines #1 & #2 and the Coater #1). Monadnock Papers shall submit progress reports to DES upon completion of the major milestones as detailed in the Compliance Plan schedule listed below. If milestone dates will not be met or are not met, Monadnock Papers shall submit to DES in writing, the reasons and a good faith estimate of completion. 

Description of Action Required Completion Date 

Provide DES with an update on formaldehyde emissions reductions February 1, 2001 

Conduct stack testing for formaldehyde emissions as described in 

Table 5, Item 7. 

March 1, 2001 

Model emissions of formaldehyde to determine compliance with EnvA 1400 and determine any necessary process restrictions in hours of operation or limits on simultaneous production of formaldehyde grades of paper on the Paper Machines #1 & #2, and Coater #1. 

April 1, 2001 

Adjust hours of operation, if necessary. May 8, 2001 

Requirements Currently Not Applicabler 

The Permittee identified the following requirements listed in Table 8 below, which are not applicable to the facility at the time of permit issuance. 

CAA Section 111, 42 U.S.C. 7411 

CAA Section 112(g), 42 U.S.C. 7412 

CAA Section 123, 42 U.S.C. 7423 

40 CFR 82 

Table 8 Requirements Currently Not Applicable 

Statutes and Regulations Requirement & Reason 

New Source Performance Standards. MPM does not have any new equipment subject to these standards. 

Requirement to establish case-by-case MACT standards for 

construction of new sources and modifications of existing sources which are major sources of HAPs for which there is not 

an applicable emission limitation established by the EPA 

administrator. MPM is currently not a major source of HAPs, nor has it constructed a new source or made modifications at the facility which would require a case-by-ease MACT standard to be developed.. 

Requirement for establishing Good Engineering Practice stack 

height. MPM used actual stack heights in ambient air dispersion modeling analyses to show compliance with applicable requirements in its Title V Operating Permit. 

Stratospheric Ozone Protection. MPM does not have any freon containing air conditioning units greater than 50 pounds in 

capacity. 
Page 26 

Table 8 Requirements Currently Not Applicable 

40 CFR 63 

Env-A 608 

Env-A 610 

Env-A 611 

Env-A 613 

Env-A 2106 

Env-A 1204.09 and 1204.11 through 1204.26 

Env-A 1211.03 & 1211.04, Env-A 1211.06 through 1211.10, & 

Env-A 1211.12 through 1211.14 

National Emissions Standards for Hazardous Air Pollutants. 

MPM is not a major source (greater than 10 tons per year of an 

individual HAP or greater than 25 tons per year of any 

combination of HAPs) of HAPs and at the time of permit 

issuance, no standards have been promulgated which are 

applicable to the facility. However, EPA is in process of 

developing a MACT for paper and web coating at this time, 

which may or may not be applicable to MPM. 

State Permits to Operate. Once the facility is issued a final Title 

V Operating Permit, previously issued State Permits to Operate 

for the Boilers & 2 and the Emergency Generator will be null 

and void. The Title V Permit will govern. 

General State Permits and General Permits Under Title V. Not 

applicable to MPM in that it is a major source and all affected 

units are covered in its Title V Operating Permit. 

General Acid Rain Permitting Requirements. MPM is not a 

source subject to Title IV of the Clean Air Act and hence this 

section is not applicable. 

Additional Division Review of Permit Applications Under the 

Bubble Concept. MPM did notrequest for an alternative 

emission control combining stacks at the facility. 

Emissions standards for acid mists from process, manufacturing, 

or service based industries. There are no acid mists resulting 

from process operations at MPM. 

VOC RACT requirements for specific source categories other 

than coating of paper, unless MPM makes a modification or 

addition in the future which includes a new source category for 

which there is an applicable requirement in Env-A 1204. 

NOx RACT requirements for control of NOx emissions from 

source categories stipulated here, other than industrial boilers 

and emergency generators. 
Page 27 

General Title V Operating Permit Conditions 

X. Issuance of a Title V Operating Permit: 

Ao This Permit is issued in accordance with the provisions of Part Env-A 609. In accordance with 

RSA 125-C: 11, I-a and consistent with 40 CFR 70.6(a)(2) this Permit shall expire on the date specified on the cover page of this Permit, which shall not be later than the date five (5) years 

after issuance of this Permit. 

Permit expiration terminates the Permittee's right to operate the Permittee's emission units, control equipment or associated equipment covered by this Permit, unless a timely and complete renewal application is submitted at least 6 months before the expiration date. 

no Pursuant to Env-A 609.02(b), this Permit shall be a state permit to operate as defined in RSA 

125-C:1 l, III. 

XI. Title V Operating Permit Renewal Procedures; 

Pursuant to Env-A 609.06(b), an application for renewal of this Permit shall be considered timely if it is submitted to the Director at least six months prior to the designated expiration date of this Permit. 

XlI. Application Shield: 

Pursuant to Env-A 609.07, if an applicant submits a timely and complete application fbr the issuance or renewal of a Title V Permit, the failure to have a Title V Permit shall not be considered a violation of 

Part Env-A 609 until the Director takes final action on the application. 

XlII. Permit Shield: 

A. Pursuant to Env,A 609.08(a), a permit shield shall provide that: 

For any applicable requirement or any state requirement found in the New Hampshire Rules Governing the Control of Air Pollution specifically included in this Permit, compliance with the conditions of this Permit shall be deemed compliance with said applicable requirement or said state requirement as of the date of permit issuance; and 

no 

For any potentially applicable requirement or any potential state requirement found in the 

New Hampshire Rules Governing the Control of Air Pollution specifically identified in 

Section IX of this Permit as not applicable to the stationary source or area source, the 

Permittee need not comply with the specifically identified federal or state requirements. 

The permit shield identified in Section XIII.A. of this Permit shall apply only to those conditions incorporated into this Permit in accordance with the provisions of Env-A 609.08(b). It shall not apply to certain conditions as specified in Env-A 609.08(c) that may be incorporated into this 

Permit following permit issuance by the DES. 

Co If a Title V Operating Permit and amendments there to issued by the DES does not expressly include or exclude an applicable reqmrement or a state requirement found in the NH Rules 
Page 28 

Governing the Control of Air Pollution, that applicable requirement or state requirement shall 

not be covered by the permit shield and the Permittee shall comply with the provisions of said 

requirement to the extent that it applies to the Permittee. 

Do If the DES determines that this Title V Operating Permit was issued based upon inaccurate or 

incomplete information provided by the applicant or Permittee, any permit shield provisions in 

said Title V Operating Permit shall be void as to the portions of said Title V Operating Permit 

which are affected, directly or indirectly, by the inaccurate or incomplete information. 

EQ Pursuant to Env-A 609.08(0, nothing contained in Section XIII of this Permit shall alter or affect 

the ability of the DES to reopen this Permit for cause in accordance with Env-A 609.18 or to 

exercise its summary abatement authority. 

FQ Pursuant to Env-A 609.08(g), nothing contained in Section XIII of this Permit or in any title V 

operating permit issued by the DES shall alter or affect the following: 

The ability of the DES to order abatement requiring immediate compliance with 

applicable requirements upon finding that there is an imminent arid substantial 

endangerment to public health, welfare, or the environment; 

The state of New Hampshire's ability to bring an enforcement action pursuant to RSA 

125-C: 15,II; 

The provisions of section 303 of the Act regarding emergency orders including the 

authority of the EPA Administrator under that section; 

The liability of an owner or operator of a source for any violation of applicable 

requirements prior to or at the time of permit issuance; 

The applicable requirements of the acid rain program, consistent with section 408(a) of 

the Act; 

The ability of the DES or the EPA Administrator to obtain information about a stationary 

source, area source, or device from the owner or operator pursuant to section 114 of the 

Act; or 

The ability of the DES or the EPA Administrator to enter, inspect, and/or monitor a 

stationary source, area source, or device. 

XIV. Reopening for Cause: 

The Director shall reopen and revise a Title V Operating Permit for cause if any of the circumstances 

contained in Env-A 609.18(a) exist. In all proceedings to reopen and reissue a Title V Operating 

Permit, the Director shall follow the provisions specified in Env-A 609.18(b) through (g). 

XV. Administrative Permit Amendments: 

A. Pursuant to Env-A 612.01, the Permittee may implement the changes addressed in the request for 
XVI. 

an administrative permit amendment as defined in Part Env-A 100 

of the request. 

Page 29 

immediately upon submittal 

go Pursuant to Env-A 612.01, the Director shall take fmal action on a request for an administrative permit amendment in accordance with the provisions of Env-A 612.01 (b) and (c). 

Operational Flexibility: 

Ao Pursuant to Env-A 612.02(a), the Permittee subject to and operating under this Title V Operating Permit may make changes involving trading of emissions under this existing Title V Operating Permit at the permitted stationary source or area source without filing a Title V Operating Permit application for and obtaining an amended Title V Operating Permit, provided that all the 

conditions are met as specified in Section XV1, A. 1. through 7. of this permit and a notice is 

submitted to the DES and EPA describing the intended changes. At this point, the DES has not 

included any permit terms authorizing emissions trading in this permit. 

1. The change is not a modification under any provision of title I of the Act; 

The change does not cause emissions to exceed the emissions allowable under the 

title V operating permit, whether expressed therein as a rate 

of emissions or in terms of total emissions; 

3. The owner or operator has obtained any temporary permit required by Env-A 600; 

The owner or operator has provided written notification to the director and 

administrator at least 15 days prior to the proposed change and such written 

notification includes: 

a. The date on which each proposed change will occur; 

b. A description of each such change; 

Co Any change in emissions that will result and how this change in emissions 

will comply with the terms and conditions of the permit; 

d, A written request that the operational flexibility procedures be used; and 

e. The signature of the responsible official, consistent with Env-A 605.04(b); 

The title V operating permit issued to the stationary source or area source already contains terms and conditions including all terms and conditions which determine compliance required under 40 CFR 70.6(a) and (c) and which allow for the trading Of emissions increases and decreases at the permitted stationary source or 

area source solely for the purpose of complying with a federally-enforceable emissions cap that is established in the permit independent, of otherwise applicable requirements; 

6. The owner or operator has included in the application for the title V operating 
Page 30 

permit proposed replicable procedures and proposed permit terms which ensure 

that the emissions trades are quantifiable and federally enforceable for changes to 

the title V operating permit which qualify under a federally- enforceable 

emissions cap that is established in the title V operating permit independent of the 

otherwise applicable requirements; and 

7. The proposed change complies with Env-A 612.02 (e). 

Pursuant to Env-A 612.02(c), the Permittee subject to and operating under this Title V Operating 

Permit may make changes not addressed or prohibited by this existing Title V Operating Permit 

at the permitted stationary source or area source without filing a Title V Operating Permit 

application, provided that all the conditions specified in Env-A 612.02(c)(1) through (6) are met 

and a notice is submitted to the DES and EPA describing the intended changes. 

Co Pursuant to Env-A 612.02(d), the Permittee, Operator, Director and Administrator shall attach 

each notice of an off-permit change completed in accordance with Section XVI of this Title V 

Operating Permit to their copy of the current Title V Operating Permit. 

Pursuant to Env-A 612.02(e), any change under Section XVI shall not exceed any emissions 

limitations established under the NH Rules Governing the Control of Air Pollution, or result in 

an increase in emissions, or result in new emissions, of any toxic air pollutant or hazardous air 

pollutant other than those listed in the existing Permit. 

Et Pursuant to Env-A 612.02(0, the off-permit change shall not qualify for the permit shield under 

Env-A 609.08. 

XVII. Minor Permit Amendments: 

Pursuant to Env-A 612.04 prior to implementing a minor permit modification, the Permittee shall 

submit a written request to the Director in accordance with the requirements of Env-A 

612.04(b). 

The Director shall take final action on the minor permit amendment request in accordance with 

the provisions of Env-A 612.04(c) through (g). 

Pursuant to Env-A 612.04(h), the permit shield specified in Env-A 609.08 shall not apply to 

minor permit amendments under Section XVII. of this Permit. 

Do Pursuant to Env-A 612.04(i), the Permittee shall be subject to the provisions of Part Env-A 614 

and Part Env-A 615 if the change is made prior to the filing with the Director a request for a 

minor permit amendment. 

XVIII. Significant Permit Amendments: 

Ao Pursuant to Env-A 612.05, a change at the facility shall qualify as a significant permit 

amendment if it meets the criteria specified in Env-A 612.05(a)(1) through (7). 

B. Prior to implementing the significant permit amendment, the Permittee shall submit a written 
Co 

Page 31 

request to the Director and to the EPA which includes all the information as referenced in Env-A 

612.05(b) and (c) and shall be issued an amended Title V Operating Permit from the DES. The 

Permittee shall be subject to the provisions of Env-A 614 and Env-A 615 if a request for a significant permit amendment is not filed with the Director and/or the change is made prior to 

the issuance of an amended Title V Operating Permit. 

The Director shall take final action on the significant permit amendment in accordance with the 

procedures specified in Env-A 612.05(d), (e) and (f). 

Title V Operating Permit Suspension• Revocation or Nullification" 

A° Pursuant to RSA 125-C: 13, the Director may suspend or revoke any final permit issued 

hereunder if, following a hearing, the Director determines that: 

The Permittee has committed a violation of any applicable statute or state requirement 

found in the New Hampshire Rules Governing the Control of Air Pollution, order or permit condition in force and applicable to it; or 

That the emissions from any device to which this Permit applies, alone or in conjunction with other sources of the same pollutants, presents an immediate danger to the public 

health. 

The Director shall nullify any Permit, if following a hearing in accordance with RSA 541-A:30, II, a finding is made that the Permit was issued in whole or in part based upon any information 

proven to be intentionally false or misleading. 

XX. Inspection and Entry: 

Pursuant to Env-A 614.01, EPA and DES personnel shall be granted access to the facility covered by this Permit, in accordance with RSA 125-C:6,VII for the purposes of: inspecting the proposed or permitted site; investigating a complaint; and assuring compliance with any applicable requirement or 

state requirement found in the NH Rules Governing'the Control of Air Pollution and/or conditions of 

any Permit issued pursuant to Chapter Env-A 600. 

Certifications: 

A° Compliance Certification Report 

In accordance with 40 CFR 70.6(c) the Responsible Official shall certify, annually from the date 

of issuance (during the first year it will be from date of permit issuance until December 31 st, for 

the remainder of the permit term it will be for each calendar year), that the facility is in compliance with the requirements of this permit. The report shall be submitted to the DES and to 

the Regional Administrator, U.S. Environmental Protection Agency New England Region. The 

report shall be submitted in compliance with the submission requirements below. 

In accordance with 40 CFR 70.6(c)(5), the report shall describe: 

1. The terms and conditions of the Permit that are the basis of the certification; 
Page 32 

The current compliance status of the source with respect to the terms and conditions of 

this Permit, and whether compliance was continuous or intermittent during the reporting 

period; 

The methods used for determining compliance, including a description of the monitoring, 

record keeping, and reporting requirements and test methods; and 

Any additional information required by the DES to determine the compliance status of the 

source. 

B. Certification of Accuracy Statement 

All documents submitted to the DES shall contain a certification of accuracy statement by the 

responsible official of truth, accuracy, and completeness. Such certification shall be in accordance with 

the requirements of 40 CFR 70.5(d) and contain the following language: 

"I am authorized to make this submission on behalf of the facility fbr which the Submission is made. 

Based on information and belief formed after reasonable inquiry, I certify that the statements and 

information in the enclosed documents are to the best of my knowledge and belief true, accurate and 

complete. I am aware that there are significant penalties for submitting false statements and information 

or omitting required Statements and information, including the possibility of fine or imprisonment." 

XXII. Enforcement: 

Any noncompliance with a permit condition constitutes a violation of RSA 125-C: 15, and, as to the 

conditions in this permit which are federally enforceable, a violation of the Clean Air Act, 42 U.S.C. 

section. 7401 et seq., and is grounds for enforcement action, for permit termination or revocation, or for 

denial of an operating permit renewal application by the DES and/or EPA. Noncompliance may also be 

grounds for assessment of administrative, civil or criminal penalties in accordance with RSA 125-C: 15 

and/or the Clean Air Act. This Permit does nor relieve the Permittee from the obligation to comply with 

any other provisions of RSA 125-C, the New Hampshire Rules Governing the Control of Air Pollution, 

or the Clean Air Act, or to obtain any other necessary authorizations from other governmental agencies, 

or to comply with all other applicable Federal, State, or Local rules and regulations, not addressed in 

this Permit. 

In accordance with 40 CFR 70.6 (a)(6)(ii) a Permittee shall not claim as a defense in an enforcement 

action that it would have been necessary to halt or reduce the permitted activity in order to maintain 

compliance with the conditions of this Permit. 

XXlII. Emission-Based Fee Requirements: 

The Permittee shall pay an emission-based fee annually for this facility as calculated each 

calendar year pursuant to Env-A 704.03. 

The Permittee shall determine the total actual annual emissions •om the facility to be included 

in the emission-based multiplier specified in Env-A 704.03(a) for each calendar year in 

accordance with the methods specified in Env-A 620. 
Co 

Page 33 

The Permittee shall calculate the annual emission-based fee for each calendar year in accordance 

with the procedures specified in Env-A 704.03 and the following equation: 

FEE E * DPT CPIm ISF 

Where: 

FEE 

E= 

DPT 

CPIm= 

ISF 

The annual emission-based fee for each calendar year as specified in Env-A 704. 

The emission-based multiplier is based on the calculation of total annual 

emissions as specified in Env-A 704.02 and the provisions specified in Env-A 

704.03(a). 

The dollar per ton fee the DES has specified in Env-A 704.03(b). 

The Consumer Price Index Multiplier as calculated in Env-A 704.03(c). 

The Inventory Stabilization Factor as specified in Env-A 704.03(d). 

Do The Permittee shall contact the DES each calendar year for the value of the Inventory 

Stabilization Factor. 

Eo The Permittee shall contact the DES each calendar year for the value of the Consumer Price 

Index Multiplier. 

The Permittee shall submit, to the DES, payment of the emission-based fee by October 15th of 

the following calendar year and a summary of the calculations referenced in Section XXIII.B. of 

this permit by April 15th of the following calendar year for each calendar year in accordance 

with Env-A 704.04. The emission-based fee shall be made payable to: Treasurer-State of NH 

and shall be submitted with the summary of the calculations to the following address: 

New Hampshire Department of Environmental Services 

Air Resources Division 

6 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

ATTN: Emissions Inventory 

Go The DES shall notify the Permittee of any under payments or over payments of the annual 

emission-based fee in accordance with Env-A 704.05. 

XXIV. Duty To Provide Information 

In accordance with 40 CFR 70.6 (a)(6)(v), upon the DES's written request, the Permittee shall furnish, 

within a reasonable time, any information necessary for determining whether cause exists for modifying, revoking and reissuing, or terminating the Permit, or to determine compliance with the Permit. Upon 

request, the Permittee shall furnish to the DES copies of records that the Permittee is required to retain by this Permit. The Permittee may make a claim of confidentiality as to any information submitted 

pursuant to this condition in accordance with Part Env-A 103 at the time such information is submitted 

to the DES. The DES shall evaluate such requests in accordance with the provisions of Part Env-A 103. 
Page 34 

XXV. Property Rights 

Pursuant to 40 CFR 70.6 (a)(6)(iv), this Permit does not convey any property rights of any sort, or any 

exclusive privilege. 

XXVI. Severability Clause 

Pursuant to 40 CFR 70.6 (a)(5), the provisions of this Permit are severable, and if any provision of this 

Permit, or the application of any provision of this Permit to any circumstances is held invalid, the 

application of such provision to other circumstances, and the remainder of this Permit, shall not be 

affected thereby. 

XXVII. Emergency Conditions 

Pursuant to 40 CFR 70.6 (g), the Permittee shall be shielded from enforcement action brought for 

noncompliance with technology based 1° emission limitations specified in this Permit as a result of an 

emergency 11. In order to use emergency as an affirmative defense to an action brought for 

noncompliance, the Permittee shall demonstrate the affirmative defense through properly signed, 

contemporaneous operating logs, or other relevant evidence that: 

A. An emergency occurred and that the Permittee can identify the cause(s) of the emergency; 

B. The permitted facility was at the time being properly operated; 

Ca During the period of the emergency, the Permittee took all reasonable steps as expeditiously as 

possible, to minimize levels of emissions that exceeded the emissions standards, or other 

requirements in this Permit; and 

The Permittee submitted notice of the emergency to the DES within two (2) business days of the 

time when emission limitations were exceeded due to the emergency. This notice must contain a 

description of the emergency, any steps taken to mitigate emission, and corrective actions taken. 

XXVIII. Permit Deviation 

In accordance with 40 CFR 70.6(a)(3)(iii)(B), the Permittee shall report to the DES all instances of 

deviations from Permit requirements, by telephone or fax, within 24 hours of discovery of such 

Technology based emission limits are those established on the basis of emission reductions achievable with various 

control measures or process changes (e.g., a new source performance standard) rather than those established to attain 

health based air quality standards. 

An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control 

of the source, including acts of God, which situation would reqmre immediate corrective action to restore normal 

operation, and that causes the source to exceed a technology based limitation under the permit, due to unavoidable 

increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused 

by improperly desighed equipment, lack of preventative maintenance, careless or improper operations, operator error or 

decision to keep operating despite knowledge of any of thesethings. 
Page 35 

deviation. This report shall include the deviation itself, including those attributable to upset conditions 

as defined in the Permit, the probable cause of such deviations, and any corrective actions or 

preventative measures taken. Said Permit deviation shall also be submitted in writing to the DES in the 

next semi-annual report which is due on July 31st or January 31st for the previous 6-month period. 

Deviations are instances where any Permit condition is violated and has not already been reported as an 

emergency pursuant to Section XXVII of this Permit. 

Reporting a Permit deviation is not an affirmative defense for action brought for noncompliance. 

h:•laughton\permitskmonadpap\tvfinal.wpd 

Final Permit Issued November 8, 2001 
Page 36 

Appendix A 
Page 37 

List of All Emergency Generators Located at Monadnock Paper Mill 

Location Number of Units Rated Generator Power Type of Fuel 

Output (kW) 

Building 5 1 (1.8 mmBm/hr gross 175 No. 2 fuel oil 

heat input rate) 
Addendum List of Insignificant Activities at Monadnock Paper Mill 

Page 38 

Insignificant Activities (Emissions to be included in annual fee payment) 

Source ID 

2a, b, c,d 

Process/Equipment Use 

Fuel Oil Storage Tanks Displacement Vent 

Description 

Working and breathing losses 

while material in tank and 

during filling 

Paper Machine Room 

39 Paper Machine Room Comfort Exhaust Fan Minor dust source 

52 Comfort Exhaust Fan Minor dust source 

Fire Pump Engine 

Hot Air Furnace 

Hot Melt Adhesive Wrap 

105 

108 

113 

Exhaust 

Power Vent/Exhaust 

Comfort Exhaust Fan 

Formaldehyde and other 

chemicals added at the paper 

machines 

116 Wastewater Treatment Plant 

Lagoons 

Emissions from fuel bumed 

Emissions from fuel burned 

Volatilization of petroleum 

wax 

VOC emissions 
STATE OF NEW HAMPSHIRE 

Department of Environmental Services 

Air Resources Division 

Title V Operating Permit 

Permit No:TV-OP-010 

Date Issued: June 3, 1999 

This certifies that: 

University of New Hampshire 

Main Street 

Durham, NH 03824-3522 

has been granted a Title V Operating Permit for the following facility and location: University of New Hampshire 

Main Street 

Durham, NH 03824-3522 

AFS Point Source Number 3301700009 

This Title V Operating Permit is hereby issued under the terms and conditions specified in the Title V Operating Permit Application filed with the New Hampshire Department of Environmental Services on June 20, 1996 under the signature of the following responsible official certifying to the best of their knowledge that the statements and information therein are true, accurate and complete. 

Responsible Official: 

Bradford Perry 

Vice Chancellor, Financial Affairs 

(603)-862-2650 

Technical Contact: 

Brad Larrabee 

Utilities Engineer 

(603)-862-2650 

This Permit is issued by the New Hampshire Department of Environmental Services, Air Resources Division pursuant to its authority under New Hampshire RSA 125-C and in accordance with the provisions of Code of the Federal Regulations 40 Part 70. 

This Title V Operating Permit shall expire on June 30, 2004 

SEE ATTACHED SHEETS FOR ADDITIONAL PERMIT CONDITIONS 

For the New Hampshire Department of Environmental Services, Air Resource Division 

Director, Air Resources Division 
TABLE OF CONTENTS 

Page 2 

II. 

III. 

Facility Description of Operations 

Permitted Activities 

Significant Activities Identification Table 1. 

Stack Criteria Table 2. 

IV. Insignificant Activities Identification 6 

V. Exempt Activities Identification 6 

VI. Pollution Control Equipment Identification 6 

VII. Alternative Operating Scenarios 6 

VIII. 

VIII A. 

VIII B. 

VIII C. 

VIII D. 

Applicable Requirements 

State-only Enforceable Operational and Emission Limitations Table 3. 

Federally Enforceable Operational and Emission Limitations Table 4. 

Emission Reductions Trading Requirements 

Monitoring and Testing Requirements Table 5. 

XI. Title V Operating Permit Renewal Procedures 

XII, Application Shield 

XIII, Permit Shield 

4-6 

7-8 

8-10 

10 

11-12 

VIII E. Recordkeeping Requirements Table 6. 13-15 

VIII F. Reporting Requirements Table 7. 15-16 

IX. Requirements Not Currently Applicable 17 

Issuance of a Title V Operating Pe•it 

Reopening for Cause 

Administrative Permit Amendments 

Operational Flexibility 

XIV. 

XV. 

XVI. 

XVII. Minor Permit Amendments 

17 

17 

17 

17-18 

18 

19 

19-20 

20 
Page 3 

XVIII. 

IXX. 

XX. 

XXI. 

XXII. 

XXIII. 

XXIV. 

XXV 

XXVI 

XXVII 

XXVIII 

21 

Inspection and Entry 21 

Certifications 

Enforcement 

Emission-Based Fees 

Duty to Provide Information 

Property Rights 

Severability Clause 

Emergency Conditions 

Permit Deviations 

21-22. 

22 

23-24 

24 

24 

24 

24-25 

25 
Facility Specific Title V Operating Permit Conditions 

I. 

II. 

III. 

Page 4 

Facility_ Description of Operations: 

The University of New Hampshire, Durham Campus ("UNH") is an educational institution located in 

Durham, NH. The predominant source of air pollutant emissions at UNH is their central heating plant, a 

boiler located at the New England Center, and emergency generators located throughout the facility. 

Permitted Activities: 

In accordance with all of the applicable requirements identified in this permit, the permittee is authorized to 

operate the devices and or processes identified in Sections III, IV, V and VI within the terms and conditions 

specified in this Permit. 

Significant Activities Identification: 

Ao The activities identified in the following table (Table 1) are subject to and regulated by this Title V 

Operating Permit: 

•Em•ss•on :/•Des gr•ption •0•!• 

EU Boiler # 1, 

Babcock and 

Wilcox Boiler 

(heming plan 0 

EU2 

EU3 

EU4 

EU5 

Boiler #2, 

Babcock and 

Wilcox Boiler 

(heating plant) 

Boiler 

#3,Babcock and 

Wilcox Boiler 

(heating piano 

Boiler #4, Riley 

Boiler (heating 

plant) 

Boiler #5, 

Cleaver Brooks 

(heating plant) 

EU6 

Cleaver Brooks 

(NE Center) 

;•,MdXl•m'•ss:•at!•!d•t]•! li',••e!i•i•'!'.a•cl•i•ge :•!•.itat|•,•i;;•;:•!l•l• •u•t :sta• I¢' !:!:::•:•i 1:•!ii!•1 

47.3 •r Stack #1 

47.3 mmBtu/hr 

Operation of Emission Units through 4 

Stack #1 

47.3 mmBtu/hr 

47.3 mmBtu/hr 

shall be limited to 3,326,400 gallons per 

year (aggregate) of#6 fuel oil containing 

no more than 1.5% sulfur content by 

16.7 m•rd3tu/hr 

weight or natural gas. 

Stack #1 

Stack #1 

12.55 mmBtu/hr #2 fuel oil at no more than 0.4 • sulfur 

content by weight, liquid propane or 

natural gas. 

Stack #3 

Operation of Emission Unit 5 shall be Stack #2 

limited to 299,712 gallons per year of#6 

fuel oil containing no more than 1;5% 

sulfur content by weight or natural gas. 
Page 5 

EU7 

EU8 

EU9 

EUi0 

EU11 

EU12 

EU13 

HeatingPlant 

Emergency 

Generator 

Caterpillar 

Morse Hall 

Emergency 

Generator 

Caterpillar 

N.E. Center 

Emergency 

Generator 

Caterpillar 

Water 

Treatment Plant 

Emergency 

Generator 

Kohler 

Gables 

Emergency 

Generator 

Caterpillar 

New Ice Arena 

Emergency 

Generator 

Caterpillar 

Biosciences 

Emergency 

Generator 

Caterpillar 

Stack Criteria: 

202 HP 

353 HP 

377 HP 

335 HP 

377 HP 

377 HP 

890 HP 

Diesel oil at no more than 0.4% sulfur 

content by weight, propane, Or natural gas. 

Diesel oil at no more than 0.4% sulfur 

content by weight, propane, or natural gas. 

Diesel oil at no more than 0.4% sulfur 

content by weight, propane, or natural gas. 

Diesel oil at no more than 0.4% sulfur 

content by weight, propane, or natural gas. 

Diesel oil at no more than 0.4% sulfur 

content by weight, propane, or natural gas. 

Diesel oil at no more than 0.4% sulfur 

content by weight, propane, or natural gas. 

Diesel oil at no more than 0.4% sulfur 

content by weight, propane, or natural gas. 

Stack #4 

Stack #5 

Stack #6 

Stack #7 

Stack #8 

Stack #9 

Stack #10 

Be The following stacks for the above listed significant devices at this facility shall discharge vertically without obstruction (including rain caps) and meet the following criteria in accordance with the state- only modeling requirements specified in Env-A 1300 and Env-A 1400: 

Stuck#1 EUI 

EU2 205 8.5 

EU3 

EU4 

Stack #2 EU5 

Stack #3 EU6 35 

3 
IV. 

VI. 

VII. 

Page 6 

Stack #4 EU7 

EU8 

45 

Stack #5 75 

Stack #6 EU9 50 

Stack #7 EU 10 30 

Stack #8 EU11 !2 

Stack #9 

Stack #10 

EU12 12 

EU13 75 

0.5 

0.5 

0.5 

0.5 

0.5 

0.75 

Preauthorized changes to the state-only requirements pertaining to stack parameters (set forth in this permit), 

shall be permitted only when an air quality impact analysis which meets the criteria of Env-A 606 is 

performed either by the facility or the DES (if requested by facility in writing) in accordance with the "DES 

Policy and Procedure for Air Quality Impact Modeling". All air modeling data shall be kept on file at the 

facility for review by the DES upon request. 

Insignificant Activities Identification: 

All activities at this facility that meet the criteria identified in the New Hampshire Rules Governing the 

Control of Air Pollution Part Env-A 609.03(g), shall be considered insignificant activities. Emissions from 

the insignificant activities shall be included in the total facility emissions for the emission-based fee calculation 

described in Section XXIII of this Permit. 

Exempt Activities Identification: 

All activities identified in the New Hampshire Rules Governing the Control of Air Pollution Env-A 609.03(c) 

shall be considered exempt activities and shall not be subject to or regulated by this Title V Operating Permit, 

Emissions fi:om exempt activities shall not be included in the total facility emissions for the emission based 

fee calculation described in Section XXIII. of this Permit. 

Pollution Control Equipment Identification: 

Pollution control equipment is not used for any of the devices identified in this Permit. 

Alternative Operating Scenarios: 

No alternative operating scenarios were identified for this Permit. 
Page 7 

VIII. Applicable Requirements: 

VIII. A. State-only Enforceable Operational and Emission Limitations: 

The Permittee shall be subject to the state-only operational and emission limitations identified in Table 3 below. 

item 

1. Env-A 1305.01(a) Facili• Wide New or modified devices, new or modified area sources, and existing devices or 

area sources for which new applications for pewits •e filed that have thepotential to emit, in any amount, substances that meet the criteria of Env-A1301 shall be 

Facility Wide 2. Env-A 1305.02 

3. Env-A 1403.01 Facility Wide 

4. Env-A 1403.02(a) Facility Wide 

5. Env-A 1403.02(b) Facility Wide 

6. Env-A 1404.01(d) Facility Wide 

7. Env-A 1405.02 Facility Wide 

8. Env-A 1405.03 Facility Wide 

subject to Env-A 1300, until such time as the Env-A 1400 requirements supersede the Env-A 1300 requirements. (As outlined below) 

Air quality impact analysis of devices and area sources emitting substances meeting the criteria of Env-A 1301 shall be performed in accordance with the 

"DES Policy and Procedure for Air Quality Impact Modeling" or other comparable dispersion modeling methods approved by EPA. 

In accordance with Env-A 1403.01, new or modified devices or processes 

installed after May 8, 1998, shall be subject to the requirements of•Env-A 1400. 

In accordance with 1403.02(a), all existing unmodified devices or processes 

which are in operation during the transition period ending three years from May 8, 1998 (May 8, 2001), shall comply with either Env-Al300 or Env-A 1400. 

In accordance with Env-A 1403.02(b), all existing devices or processes in operation after the transition period ending three years from May 8, 1998 (May 8, 2001), shall comply with Env-A 1400. Env-A 1300 will no longer be in effect. 

In accordance with Env-A 1404.01(d), documentation for the demonstration of compliance shall be retained at the site, and shall be made available to the DES 

for inspection. 

In accordance with Env-A 1405.02 the owner of an existing device or process requiring a permit under chapter Env-A 1400 shall submit to the DES no later 

than one year prior to the end of the transition period (May 8, 2000), an application for a modification to a title V permit in accordance with Env-A 

609.18, and a request to the DES to perform air dispersion modeling. 

In accordance with Env-A 1405.03 the owner of an existing device or process requiring a permit under Env-A 1300 shall submit to the DES no later than one 

year prior to the end of the transition period (May 8, 2000), a compliance plan identifying how the device• or process will comply with chapter Env-A 1400 by the 

end of the transition period. The compliance plan shall contain the dates when the 

information required in Env-A 1405.02 will be filed with the DES. 
Page 8 

Env-A 1406.01 Facility Wide In accordance with Env-A 1406.01 the owner 0fany device or process which emits 

a regulated toxic air pollutant shall determine compliance with the ambient air 

limits by using one of the methods provided in Env-A 1406.02, Env-A 1406.03, or 

Env-A 1406.04. Upon request, the owner of any device or process which emits a 

regulated toxic air pollutant shall provide documentation of compliance with the 

ambient air limits to the DES. 

VIII. B. Federally Enforceable Operational and Emission Limitations 

The Permittee shall be subject to the operational and emission limitations identified in Table 4 below. 

1. Env-A 1604.01(a) Facility Wide The sulfur content of No. 2 oil and off road diesel oil shall not exceed 0.40 

percent sulfur by weight. 

2. Env-A 

1604.01(c)(2) 

3. 40 CFR Part 521 

Env-A 2003.01 

5. Env-A 2003.02 

Facility Wide 

(Except for EUs 

1-6 which shall 

not exceed 1.5%) 

Facility .Wide 

6. Env-A 2003.06 

EU1, EU2, EU3, 

EU4, and EU6 

EU5 

EU1, EU2, EU3, 

EU4, and EU6 

The sulfur content of No. 5 oil, No. 6 oil, shall not exceed 2.0 percent sulfur by 

weight. 

Gaseous fuel shall contain no more than 5 grains of sulfur per 100 cubic feet of 

gas, calculated as hydrogen sulfide at standard temperature and pressure. 

Visible Emission Standard for fuel buming devices installed prior to May 13,1970. 

No owner or operator shall cause or allow average opacity from fuel burning 

devices installed on or prior to May 13, 1970 in excess of 40 percent for any 

continuous 6 minute period in any 60 minute period. 

Visible Emission Standard for fuel burning devices installed after May 13,1970. No 

owner or operator shall cause or allow average opacity from fuel burning devices 

installed after May 13, 1970 in excess of 20 percent for any continuous 6 minute 

period in a 60 minute period. 

No owner or operator shall cause or allow emissions of particulate matter from fuel 

burning devices installed on or prior to May 13, 1970 in excess of the rates set forth 

below, where: 

For devices with ( maximum gross heat input rate in 106 BTU/hr) equal to or 

greater than 10 but less than 10,000, E the maximum allowable particulate matter 

emission rate in lb/106 BTU) shall be calculated by raising to the -0.166 power, 

and multiplying the result by 0.880, expressed mathematically in the formula below: 

E =0.880 1 °a66 

Env-A 402.03, effective December 27, 1990 was adopted as part of the State 

Implementation Plan (SIP) on September 14, 1992 and is considered federally enforceable until 

such time as the SIP is amended and approved by EPA. 
Page 9 

7. Env-A EU5, EU7, EU8, For devices installed after January 1, 1985 with I (maximum gross heat input rate in 2003.08(c)(1) EU9, EU10, 106 BTU/hr) less than 100, E (the maximum allowable particulate matter EU11, EU12 & emission rate in ih/10 BTU) shall be equal to or less than 0.30. 

EU13 

8. Env-A EU7, EU8, EU9 All emergency generators at a stationary source which operate less than 500 hours 1211.020)(1 EU10, EU11, with aggregate emissions of NOx from all such generators less than 25 tons EU12 & EU13 during any consecutive 12 month period shall be exempt from the requirements of 

Env-A 1211.020). EU7- EU13 shall be limited to 500 hours of operation each 

per year. 

9. Eng-A 1211.05(b) Facility Wide Emission Standards for Industrial Boilers. The Permittee shall maintain Reasonably Available Control Technology (RACT) for NOx emissions', as specified in. Secion VIII.D, Table 5, Item 4 of this Permit; Monitoring and Testing Requirements, 

10. 40 CFR 68 Facility Wide The Permittee's propane and anhydrous ammonia storage capacities exceed the 

threshold quantities specified in 40 CFR 68, therefore the facility shall be subject to the requirements of the Accidental Release Program. 

40 CFR 52.21 •EU5 In order to avoid the Prevention of Significant Deterioration (PSD) applicability PSD Avoidance thresholds, Emission Unit 5 shall be limited to 299,712 gallons per year of#6 

fuel oil containing no more than 1.5% sulfur content by weight or natural gas. This is equivalent to: 

35.29 tpy SO2 (PSD applicability threshold ± 40 tpy) 8.24 tpy NOx (PSD applicability threshold 40 tpy) 

0.75 tpy CO (PSD applicability threshold 100 tpy) 2.55 tpy TSP (PSD applicability threshold 25 tpy) 2.19 tpy PM: 10 (PSD applicability threshold 15 tpy) 

Env-A 609.04 EU1, EU2, EU3, Operation of Emission Units 1 through 4 shall be limited to 3,326,400 gallons & EU4 per year (aggregate) of#6 fuel oil containing no more than 1.5% sulfur content by weight or natural gas 

RSA 125-C:6, Facility Wide National Ambient Air Quality Standards (NAAQS). The facility shall comply with RSA 125-C' 11 the national ambient air quality standards and the applicable requirements of and RSA 125-C:6, RSA 125-C:11 and Env-A 606.04. Env-A 606.04. 

11. 

12. 

13. 

14. Env-A 404.01 EU1, EU2, EU3, 

EU4, EU5 & 

EU6 

Pursuant to RSA 125-D:3,I(e) annual sulfur dioxide emissions from each Class B major source except as provided by Env-A 405.02, shall have an average calender 

year emission rate not to exceed 1.6 pounds of sulfur dioxide per million BTU input, equivalent to no. 6 oil with 1.5 percent sulfur by weight, which is 75 

percent of the baseline average emission rate for Class B major sources. Recordkeeping and tracking of individual fuel deliveries shall be conducted in 

accordance with Section VIII. E. of this Permit. 

VIII. C. Emission Reductions Trading Requirements: 

Pursuant to ERC Certificate No. 97NUNH02C and in accordance with Env-A 3004, the facility has been granted 33 Emissions Reductions Credits (ERCs) for the shutdown of Consumat Incinerators 1, 2, & 3. The 33 ERCs shall be valid provided that the credited reductions remain real, quantifiable, surplus, enforceable, and permanent and provided that the Permittee complies with all the legally enforceable conditions specified below: 
Page 10 

UNH shall be subject to the New Hampshire Rules Governing the Control of Air Pollution, including but not 

limited to Chapter Env-A 3000, and the approved NOx ERCs Creation Protocol. 

UNH shall not operate Consumate Incinerators 1, 2, 3. 

UNH shall not sell, transfer, trade, or use these ERCs prior to obtaining written consent from DES, in 

accordance with Env-A 3006.11. 

These ERCs, generated from shutdown of the above devices, shall only be used by UNH, and UNH may not 

sell, transfer, or trade these ERCs. 

Furthermore, ERC Certificate No. 97NUNH01C for the gas conversion 0f Boilers 1 5 shall herein be 

revoked. However, UNH shall be authorized under the applicable requirements of Env-A-3100 (the Discrete 

Emissions Reductions (DERs) Trading Program) to trade seven (7) 1997 ozone season and 13 non-ozone 

season uncertified DERs. Additional DERs may be traded upon submittal of Notices of Generation of DERs 

for periods after 1997. Upon submittal, said Notices shall be available to the public under RSA 91-A. 
VIII. 

Page 11 

Monitoring, and Testing Requirements 

The Permittee is subject to the monitoring and testing requirements as contained in Table 5, below: 

Facility 

Stacks 

andEUs 

1-13 

All 

devices 

using 

liquid 

fuels 

All 

devices 

using 

gaseous 

fuels 

Allows for 

adequate 

dispersion 

of HAPs 

and other 

regulated 

pollutants 

Sulfur 

content in 

liquid fuels 

Sulfur 

content in 

gaseous 

fuels 

Conduct an annual inspection of each stack and emission unit. 

Records of inspections and subsequent maintenance 

conducted as a result of the annual inspections shall be kept on file at the Facility for review by the DES and/or EPA upon 

request. 

The operator shall conduct testing in accordance with 

appropriate ASTM test methods to determine compliance with the sulfur content limitation provisions in Env-A 

1604.01(a) and 1604.01(c)2 for liquid fuels in order to meet 

the reporting requirements as specified in Section VIII F. 

Table 7, Item 4 Of this Permit. Delivery tickets which certify percent sulfur by weight of the fuel oil being delivered may 

be used as an alternative to determine compliance with the 

sulfur content limitation provisions in Env-A 1604.01(a) and 

1604.01 (c)2 for liquid fuels. 

The operator shall conduct testing to determine compliance with the sulfur content limitation provisions in Env-A 402.03 

for gaseous fuels. 

Annually 

For each 

delivery of fuel 

oil to the 

facility 

Env-A 

806.01(4) 

and 

40 CFR 

70.6(a)(3) 

Federally 

Enforceable 

Env-A 809.01 

Upon written 

request by 

EPA or DES 

Env-A 809.02 
Page 12 

EUs I-6 Boiler 

efficiency 

Owners or operators of industrial boilers with heat input rates 

of at least 5,000,000 Btu per hour but less than 50,000,000 

Btu per hour shall: 

(1) Annually, before April 1st of each year: 

a. Perform an ef•t•t using•the lest 

procedures specified in ASME/ANSI Boiler Test 

Code 4.1; and 

b. Adjust the conl•.process of the boiler in 

accordance with the procedures specified in chapter 

5, Combustion Efficiency Tables, Taplin, Harry R., 

Fairmont Press, 1991; and 

(2) Maintain, in a permanently bound log book the following 

information: 

a. The date(s) on which: 

1. The efficiency test was conducted; and 

2. The combustion process was last 

adjusted; 

b. The name(s), title and affiliation of the person(s) 

who: 

1. Conducted the efficiency test; and 

2. Made the adjustments; 

c. The NOx emission concentration, in ppmvd, 

corrected to 15% oxygen, after the adjustments are 

made; 

d. The CO emission concentration, •n ppmvd, 

corrected to 15% oxygen, after the adjustments are 

'made; 

e. The opacity readings; and 

f. Any other information required by Env-A 901.06 

and Env-A 901.07. 

Annually Env-A 1211.03 

Federally 

Enforceable 
Page 13 

VIII. Record keeping Requirements: 

The Permittee shall be subject to the record keeping requirements identified in Table 6 below. 

The Permittee shall retain records of all required monitoring data, recordkeeping and reporting requirements and support information 

for a period of at least 5 years from the date of the origination. 

Retain for a Facili• 40 CFR 

•nimum of 5 Wide 70.6(a)(3)(ii)(B) 

ye•s Federally 

Enforceable 

The Perrnittee shall maintain records of monitoring requirements.as Maintain on a specified inTable 5 of this Permit including: continuous basis 

as specified in (A) Preventative maintenance and inspection results Table 5 of this 

for stacks and emission Units. Permit (B) Sumrnary of testing and/or delivery ticket 

certifications for sulfur content limitation 

provisions. 

Summary of test results performed on each boiler 

(EU1-EU6). 

(c) 

Monthly and 12 month rolling.totals of liquid fuel utilization shall be kept at the facility and contain the following information: 

Monthly and 12 

month rolling 

total of liquid 

fuel consumption (A) Consumption 

(B) Fuel type; 

(C) Sulfur content as percent sulfur by weight of fuel; (D) Btu content per gallon or cubic feet of fuel; (E) Hours of operation of each boiler and generator; 

and 

(F) Viscosity. 

Facility 

Wide 

40 CFR 

70.6(a)(3)(iii) 

(A) 

Federally 

Enforceable 

EU1 through 

EU13 

Env-A 901.03 

Federally 

Enforceable 
Page 14 

4. NOx Record keeping Requirements: Maintain on a Facility Env-A 901.08 

For fuel burning devices, including boilers, and internal combustion continuous basis Wide Federally 

engines, the following information shall be recorded and maintained: Enforceable 

(A) Facility information, including: 

1. Source name; 

2. Source identification; 

3. Physical address; 

4. Mailing address; and 

5. A copy of the certificate of accuracy, 

required to be maintained pursuant to EnvA 901.04(c). 

(B) Identification of fuel burning device; 

(C) Operating schedule information for each fuel burning 

device identified in (B), above, including; 

1. Days per calendar week during the normal 

operating schedule; 

2. Hours per day during the normal operating 

schedule and for a typical ozone season 

day, if different from the normal operating 

schedule; and 

3. Hours per year during the normal 

operating schedule; 

(D) Type, and amount of fuel burned, for.each fuel burning 

device 2, during normal operating conditions and for a 

typical ozone season day, if different from normal operating 

conditions, on an hourly basis in million Btu's per hour 

and; 

(E) The following NOx emission data, including recoi'ds of 

total annual emissions, in tons per year, and typical ozone 

season day emissions, in pounds per day: 

1. Theoretical potential emissions for the 

calculation year for each fuel burning 

device; and 

2. 

Act 

ual 

NO 

X 

emi 

ssi 

ons 

for 

eac 

h 

fuel 

bur 

2 For boilers with fuel usages not metered seperately, this may be calculated using steam 

generation circular charts recording steam production on a continuous basis for each boiler and 

hours of operation for each boiler. These charts and records shall be maintained on a continuous 

basis for inspection by DES or EPA. 
Page 15 

Delivery tickets from eachfuel oil supplier for each shipment of fuel 

oil received shall be kept on file in a form suitable for inspection and 

shall be made available to theDES and/or EPA upon request. Each delivery ticket shall indicate the name, address and telephone number of the fuel oil supplier the quantity of fuel oil delivered, and 

the percent sulfur by weight of the fuel oil being delivered. If delivery tickets do not contain sulfur content of fuel being delivered, the Permittee shall perform testing in accordance with appropriate ASTM test methods to determine compliance with the sulfur content 

limitation provisions in Env-A 1604.01(a) and 1604.01(c)2for liquid fuels. 

Billing tickets from the Natural Gas supplier for each month shall be kept on file in a form suitable for inspection and shall be made 

available to the DES and/or EPA upon request. Each billing ticket 

shall indicate the name, address and telephone number of the 

Natural Gas supplier and the quantity of Natural Gas used. 

Annual records of actual emissions for each significant and msignificant activity for determination of emission based fees. 

Maintain on a Facility 

continuous basis Wide 

Maintain on a Facility 

continuous basis Wide 

40 CFR 

70.6(a)(3) 

Federally 

Enforceable 

40 CFR 

70.6(a)(3) 

Federally 

Enforceable 

Maintain at Facility Env-A 901.04 

facility at all Wide Federally 

times. Enforceable 

Vlll. Reporting Requirements: 

The Permittee shall be subject to the reporting requirements identified in Table 7 below. 

The Permittee shall submit a summary report of monitoring data as specified in Table 5 of this permit including: 

(A) Preventative maintenance and inspection results 

for stacks and emission units. 

(B) Summary of testing and/or delivery ticket 

certifications for sulfur content limitation 

provisions. 

(C) Summary ofNOx RACT maintenance and test 

results performed on EUs 1-6. 

Prompt reporting of deviations from Permit requirements shall be 

conducted in accordance with Section XXVIII of this Permit. 

Every 6 months Facility Wide 40 CFR 

(By January 70.6(a)(3)(iii) 31 st and July (A) 

31 st) Federally 

Enforceable 

Prompt Facility Wide Env-A 902.02 

reporting & 

(ie; within 8 40 CFR 

hours of an 70.6(a)(3)(iii) occurrence). (B) 

Federally 

Enforceable 
Pag• 16 

NOx Reporting Requirements: 

For fuel burning devices, including boilers, and engines, as well as 

miscellaneous sources, the owner or operator shall submit to the 

director, annually (no later than April 15th of the following year), 

reports of the data required by Condition VIII.E., Table 6, Item 4, 

including total annual quantities of all NOx emissions. 

The permittee shall submit quarterly fuel usage reports indicating 

monthly and consecutive 12 month rolling totals of fuel utilization 

for each boiler and emergency generator, and corresponding fuel 

information as outlined in Condition VIII.E., Table 6, Item 3. Fuel 

usages for boilers designated as EU 1-4 may be reported 

cumulatively. 

Any report submitted to the DES and/or EPA shall include the 

certification of accuracy statement as outlined in Section XXI.B. of 

this Permit and shall be signed by the responsible official. 

Annual reporting and payment of emission based fees for pollutants, 

including, but not limited to SO2; NOx, CO, TSP, VOC and HAPs 

shall be conducted in accordance with Section XXIII of this Permit 

Annual compliance certification shall be submitted in accordance 

Section XXI of this Permit. 

Annually (no 

later than April 

15th of the 

following year) 

Quarterly, due 

30 days from 

the end of the 

calender quarter 

As specified 

Annually (no 

later than April 

15th of the 

following year) 

Annually (no 

later than April 

15th of the 

following ),ear) 

Facility Wide 

EU1 through 

EU13 

Facility Wide 

Facility Wide 

Facility Wide 

Env-A 901.09 

Federally 

Enforceable 

40 CFR 70.6 

(a)(1) Federally 

Enforceable 

40 CFR 

70.6(c)(1) 

Federally 

Enforceable 

Env-A 704.03 

Federally 

Enforceable 

40 CFR 

70.6(c)(1) 

Federally 

Enforceable 
Page 17 

IX. Requirements Currently. Not ApplicableThe Permitee did not identify any requirements not currently applicable to the facility. 

General Title V Operating Permit Conditions 

X. Issuance of a Title V Operating Permit" 

At This Permit is issued in accordance with the provisions of Part Env-A 609. In accordance with 40 

CFR 70.6(a)(2) this Permit shall expire on the date specified on the cover page of this Permit, which 

shall not be later than the date five (5) years after issuance of this Permit. 

Permit expiration terminates the Permittee's right to operate the Permittee's emission units, control equipment or associated equipment covered by this permit, unless a timely and complete renewal application is submitted at least 6 months before the expiration date. 

Pursuant to Env-A 609.02(b), this Permit shall be a state permit to operate as defined in RSA 125- 

C: 1 l, III. 

XI. Title V Operating Permit Renewal Procedures: 

Pursuant to Env-A 609.06(b), an application for renewal of this Permit shall be considered timely if it is submitted to the Director at least six months prior to the designated expiration date of this Permit. 

XII. Application Shield: 

Pursuant to Env-A 609.07, if an applicant submits a timely and complete application for the issuance or renewal of a Permit, the failure to have a Permit shall not be considered a violation of this part until the 

Director takes final action on the application. 

XIII. Permit Shield: 

A. Pursuant to Env-A 609.08(a), a permit shield shall provide that: 

For any applicable requirement or any state requirement found in the New Hampshire Rules Governing the Control of Air Pollution specifically included in this Permit, compliance with 

the conditions of this Permit shall be deemed c•)mpliance with said applicable requirement or said state requirement as of the date of permit issuance; and 

For any potential applicable requirement or any potential state requirement found in the New Hampshire Rules Governing the Control of Air Pollution specifically identified in this TitleV Operating Permit Section IX Table 8 as. not applicable to the stationary source or area source, 

the Permittee need not comply with the specifically identified federal or state requirements. 

Bo The permit shield identified in Section XIII.A. of this Permit shall apply only to those conditions incorporated into this Permit in accordance with the provisions of Env-A 609.08(b). It shall not apply to certain conditions as specified in Env-A 609.08(c) that may be incorporated into this Permit 
XIV. 

Page 18 

following permit issuance by DES. 

Co If a Title V Operating Permit and amendments there to issued by the DES does not expressly include 

or exclude an applicable requirement or a state requirement found in the NH Rules Governing the 

Control of Air Pollution, that applicable requirement or state requirement shall not be covered bythe 

permit shield and the Permittee shall comply with the provisions of said requirement to the extent that 

it applies to the Permittee. 

Do If the DES determines that this Title V Operating Permit was issued based upon inaccurate or 

incomplete information provided by the applicant or Permittee, any permit shield provisions in said 

Title V Operating Permit shall be void as to the portions of said Title.V Operating Permit which are 

affected, directly or indirectly, by the inaccurate or incomplete information. 

Eo Pursuant to Env-A 609.08(0, nothing contained in Section XIII of this Pennit shall alter or affect the 

ability of the DES to reopen this Permit for cause in accordance with Env-A 609.18 or to exercise 

its summary abatement authority. 

Fo Pursuant to Env-A 609.08(g), nothing contained in this section or in any title V operating permit 

issued by the DES shall alter or affect the following: 

The ability of the DES to order abatement requiring immediate compliance with applicable 

requirements upon finding that there is an imminent and substantial endangerment to public 

health, welfare, or the environment; 

The state of New Hampshire's ability to bring an enforcement action pursuant to RSA 125- 

C: 15,11; 

The provisions of section 303 of the Act regarding emergency orders including the authority 

of the EPA Administrator under that section; 

The liability of an owner or operator of a source for any violation of applicable requirements 

prior to or at the time of permit issuance; 

The applicable requirements of the acid rain program, consistent with section 408(a) of the 

Act; 

The ability of the DES or the EPA Administrator to obtain information about a stationary 

source, area source, or device from the owner or operator pursuant to section 114 of the Act; 

or 

The ability of the DES or the EPA Administrator to. enter, inspect, and/or monitor a 

stationary source, area source, or device. 

Reopening for Cause: 

The Director shall reopen and revise a Title V Operating Permit for cause if any of the circumstances 

contained in Env-A 609.18(a) exist. In all proceedings to reopen and reissue a Title V Operating Permit, the 

Director shall follow the provisions specified in Env-A 609.18(b) through (g). 
XV. 

XVI. 

Page 19 

Administrative Permit Amendments: 

Pursuant to Env-A 612.01, the Permittee may implement the changes addressed in the request for an administrative permit amendment as defined in Part Env-A 100 immediately upon submittal of the request. 

BQ Pursuant to Env-A 612.01, the Director shall take final action on a request for an administrative permit amendment in accordance with the provisions of Env-A 612.01 (b) and (c). 

Operational Flexibility: 

Ao Pursuant to Env-A 612.02(a), the Permittee subject to and operating under this Title V Operating Permit may make changes involving trading of emissions under this existing Title V Operating Permit 

at the permitted stationary source or area source without filing a Title V Operating Permit application for and obtaining an amended Title V Operating Permit, provided that all the conditions are met as specified in section XVI. A. 1. through 7. of thispermit and a notice is submitted to the DES and 

EPA describing the intended changes. At this point, DES has not included any permit terms authorizing emissions trading in this permit. 

1. The change is not a modification under any provision of title I of the Act; 

The change does not cause emissions to exceed the emissions allowable under the title 

V operating permit, whether expressed therein as a rate of emissions or in terms of 

total emissions; 

3. The owner or operator has obtained any temporary permit required by Env-A 600; 

The owner or operator has provided written notification to 

administrator at least 15 days prior to the proposed change notification includes: 

the director and 

and such written 

a. The date on which each proposed change will occur; 

b. A description of each such change; 

Any change in emissions that will result and how this change in emissions will comply with the terms and conditions of the permit; 

d. A written request that the operational flexibility procedures be used; and 

e. The signature of the responsible official, consistent with Env-A 605.04(b); 

The Title V Operating Permit issued to the stationary source or area source already contains terms and conditions including all terms and conditions which determine compliance required under 40 CFR 70.6(a) and (c) and which allow for the trading of emissions increases and decreases at the permitted stationary source or area source solely for the purpose of complying with a federally-enforceable emissions cap that 

is established in the permit independent of otherwise applicable requirements; 
Page 20 

6. The owner or operator has included in the application for the Title V Operating Permit 

proposed replicable procedures and proposed permit terms which ensure that the emissions 

trades are quantifiable and federally enforceable for changes to the Title V Operating Permit 

which qualify under a federally- enforceable emissions cap that is established in the Title V 

Operating Permit independent of the otherwise applicable requirements; and 

7. The proposed change complies with Env-A 612.02 (e). 

BQ Pursuant to Env-A 612.02(c), the Permittee subject to and operating under this Title V Operating 

Permit may make changes not addressed or prohibited by this existing Title V Operating Permit at 

the permitted stationary source or area source without filing a Title V Operating Permit application, 

provided that all the conditions specified in Env-A 612.02(c)(1) through (6) are met and a notice is 

submitted to the DES and EPA describing the intended changes. 

Co Pursuant to Env-A 612.02(d), the Permittee, Operator, Director and Administrator shall attach each 

notice of an off-permit change completed in accordance with Section XVI of this Title V Operating 

Permit to their copy of the current Title V Operating Permit. 

Do Pursuant to Env-A 612.02(e), any change under Section XVI shall not exceed any emissions 

limitations established under the NH Rules Governing the Control of Air Pollution, or result in an 

increase in emissions, or result in new emissions, of any toxic air pollutant or hazardous air pollutant 

other than those listed in the existing Permit. 

Eo Pursuant to Env-A 612.02(f), the off-permit change shall not qualify for the permit shield under EnvA 609.08. 

XVII. Minor Permit Amendments: 

Pursuant to Env-A 612.04 prior to implementing a minor permit modification, the Permit-tee shall 

submit a written request to the Director in accordance with the requirements of Env-A 612.04(b). 

Bo The Director shall take final action on the minor permit amendment request in accordance with the 

provisions of Env-A 612.04(c) through (g). 

Co Pursuant to Env-A 612.04(g), the permit shield specified in Env-A 609.08 shall not apply to minor 

permit amendments under Section XVII. of this Permit. 

Pursuant to Env-A 612.04(i), the Permittee shall be subject to the provisions of Part Env-A 614 and 

Part Env-A 615 if the change is made prior to the filing with the Director a request for a minor permit 

amendment. 

XVIII. Significant Permit Amendments: 

At Pursuant to Env-A 612.05, a change at the facility shall qualify as a significant permit amendment if 

it meets the criteria specified in Env-A 612.05(a)(1) through (7). 

Bo Prior to implementing the significant permit amendment, the Permittee shall submit a written request 

to the Director which includes all the information as referenced in Env-A 612.05(b) and (c) and shall 
Co 

Page 21 

be issued an amended Title V Operating Permit from the DES. The Permittee shall be subject to the provisions of Env-A 614 and Env-A 615 if a request for a significant permit amendment is not filed 

with the Director and/or the change is made prior to the issuance of an amended Title V Operating Permit. 

The Director shall take final action on the significant permit amendment in accordance with the procedures specified in Env-A 612.05(d), (e) and (f). 

Title V Operating Permit Suspension, Revocation or Nullification. 

Pursuant to RSA 1.25-C: 13, the Director may suspend or revoke any final permit issued hereunder if, following a hearing, the Director determines that: 

the Permittee has committed a violation of any applicable statute or state requirement found 

in the New Hampshire Rules Governing the Control of Air Pollution, order or permit condition in force and applicable to it; or 

that the emissions from any device to which this Permit applies, alone or in conjunction with 

other sources of the same pollutants, presents an immediate danger to the public health. 

no The Director shall nullify any Permit, if following a hearing in accordance with RSA 541-A:30, II, a finding is made that the Permit was issued in whole or in part based upon any information proven 

to be intentionally false or misleading. 

XX. Inspection and Entry: 

Pursuant to Env-A 614.01, EPA and DES personnel shall be granted access to the facility covered by this Permit, in accordance with RSA 125-C:6,VII for the purposes of: inspecting the proposed or permitted site; investigating a complaint; and assuring compliance with any applicable requirement or state requirement found in the NH Rules Governing the Control of Air Pollution and/or conditions of any Permit issued pursuant to Chapter EnV-A 600. 

Certifications: 

Ao Compliance Certification Report 

In accordance with40 CFR 70.6(c) the Responsible Official shall certify, for the previous calender 

year, that the facility is in compliance with the requirements of this permit. The report shall be submitted annually, no later than April 15th of the following year. The re'port shall be submitted to 

the DES and to the U.S. Environmental Protection Agency New England Region. The report shall 

be submitted in compliance with the submission requirements below. 

In accordance with 40 CFR 70.6(c)(5), the report shall describe: 

1. The terms and conditions of the Permit that are the basis of the certification; 

The current compliance status of the source With respect to the terms and conditions of this Permit, and whether the method was continuous or intermittent during the reporting period; 
Page 22 

The methods used for determining compliance, including a description of the monitoring, 

record keeping, and reporting requirements and test methods; and 

Any additional information required by the DES to determine the compliance status of the 

source. 

B. Certification of Accuracy Statement 

All documents submitted to the DES shall contain a certification of accuracy statement by the responsible 

official of truth, accuracy, and completeness. Such certification shall be in accordance with the requirements 

of 40 CFR 70.5(d) and contain the following language: 

"I am authorized to make this submission on behalf of the facility for which the submission is made. Based 

on information and belief formed after reasonable inquiry, I certify that the statements and information in the 

enclosed documents are to the best of my knowledge and belief true, accurate and complete. I am aware that 

there are significant penalties for submitting false statements and information or omitting required statements 

and information, including the possibility of f'me or imprisonment." 

All reports submitted to DES (except those submitted as emission based fees as outlined in Section XXIII 

of this Permit) shall be submitted to the following address; 

New Hampshire Department of Environmental Services 

Air ReSources Division 

64 North Main Street 

P.O. Box 2033 

Concord, NH 03302-2033 

ATTN: Mary Ruel, Compliance Bureau 

All reports submitted to EPA shall be submitted to the following address; 

Office of Environmental Stewardship 

Director Air Compliance Program 

United States Environmental Protection Agency 

1 Congress Street 

Suite 1100 (SEA) 

Boston, MA 02114-2023 

ATTN: Air Compliance Clerk 

Enforcement: 

Any noncompliance with a permit condition constitutes a violation of RSA 125-C:15, and, as to the 

conditions in this permit which are federally enforceable, a violation of the Clean Air Act, 42 U.S.C. Section 

7401 et seq., and is grounds for enforcement action, for permit termination or revocation, or for denial of 

an operating permit renewal application by the DES and/or EPA. Noncompliance may also be grounds for 

assessment of administrative; civil or criminal penalties in accordance with RSA 125-C: 15 and/or the Clean 

Air Act. This Permit does not relieve the Permittee from the obligation to comply with any other provisions 

of RSA 125-C, the New Hampshire Rules Governing the Control of Air Pollution, or the Clean Air Act, or 

to obtain any other necessary authorizations from other governmental agencies, or to comply with all other 

applicable Federal, State, or Local rules and regulations, not addressed in this Permit. 
Page 23 

In accordance with 40 CFR 70.6 (a)(6)(ii) a Permittee shall not claim as a defense in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this Permit. 

XXIII. Emission-Based Fee Requirements: 

Ao The Permittee shall pay an emission-based fee annually for this facility as calculated each calendar 

year pursuant to Env-A 704.03. 

B• The Pemaittee shall determine the total actual annual emissions from the facility to be included in the emission-based multiplier specified in Env-A 704.03(a) for each calendar year in accordance with the methods specified in Env-A 620. 

Co The Permittee shall calculate the annual emission-based fee for each calendar year in accordance with the procedures specified in Env-A 704.03 and the following equation: 

FEE E * DPT * CPIm * ISF 

Do 

EQ 

Ft 

Go 

Where: 

FEE 

E= 

DPT 

CPIm= 

ISF 

The annual emission-based fee for each calendar year asspecified in Env-A 704. 

The emission-based multiplier is based on the calculation Of total annual emissions as specified in Env-A 704.02 and the provisions specified in Env-A 704.03(a). The dollar per ton fee the DES has specified in Env-A 704.03(b). The Consumer Price Index Multiplier as calculated in Env-A 704.03(c). The Inventory Stabilization Factor as specified in Env-A 704.03(d). 

The Permittee shall contact the DES each calendar year for the value of the Inventory Stabilization Factor. 

The Permittee shall contact theDES each calendar year for the value of the Consumer Price Index Multiplier. 

The Permittee shall submit, to the DES, payment of the emission-based fee and a summary of the calculations referenced in Sections XXIII.B. and C of this Permit for each calendar year by October 15 th of the following calendar year in accordance with Env-A 704.04. The emission=based fee and summary of the calculations shall be submitted to the following address: 

New Hampshire Department of Environmental Services 

Air Resources Division 

64 North Main Street 

P.O. Box 2033 

Concord, NH 03302-2033 

ATTN.: Emissions Inventory 

The DES shall notify the Permittee of any under payments or over payments of the annual emission- based fee in accordance with Env-A 704.05. 
Page 24 

XXIV. Duty To Provide Information 

In accordance with 40 CFR 70.6 (a)(6)(v), upon the DES's written request, the Permittee shall furnish, within 

a reasonable time, any information necessary for determining whether cause exists for modifying, revoking 

and reissuing, or terminating the Permit, or to determine compliance with the Permit..Upon request, the 

Permittee shall furnish to the DES copies of records that the Permittee is required to retain by this Permit. 

The Permittee may make a claim of confidentiality as to any information submitted pursuant to this condition 

in accordance with Part Env-A 103 at the time such information is submitted to DES. DES shall evaluate 

such requests in accordance with the provisions of Part Env-A 103. 

XXV. Property Rights 

Pursuant to 40 CFR 70.6 (a)(6)(iv), this Permit does not convey any property rights of any sort, or any 

exclusive privilege. 

XXVI. Severabilitv Clause 

Pursuant to 40 CFR 70.6 (a)(5), the provisions of this Permit are severable, and if any provision of this 

Permit, or the application of any provision of this Permit to any circumstances is held invalid, the application 

of such provision to other circumstances, and the remainder of this Permit, shall not be affected thereby. 

XXVII. Emergency Conditions 

Pursuant to 40 CFR 70.6 (g), the Permittee shall be shielded from enforcement action brought for 

noncompliance with technology based 3 emission limitations specified in this Permit as a result of an 

emergency 4. In order to use emergency as an affirmative defense to an action brought for noncompliance, 

the Permittee shall demonstrate the affirmative defense through properly signed, contemporaneous operating 

logs, or other relevant evidence that: 

A. An emergency occurred and that the Permittee can identify the cause(s) of the emergency; 

B. The permitted facility was at the time being properly operated; 

Co During the period of the emergency, the Permittee took all reasonable steps as expeditiously as 

possible, to minimize levels of emissions that exceeded the emissions standards, or other requirements 

in this Permit; and 

Technology based emission limits are those established on the basis of emission reductions achievable with various 

control measures or process changes (e.g., a new source performance standard) rather than those established to attain 

health based air quality standards. 

An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of 

the source, including acts of God, which situation would require immediate corrective action to restore normal operation, 

and that causes the source to exceed a technology based limitation under the permit, due to unavoidable increases in 

emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by 

improperly designed equipment, lack of preventative maintenance, careless or improper operations, operator error or 

decision to keep operating despite knowledge 0f any of these things. 
Page 25 

The Permittee submitted notice of the emergency to the DES within two (2) business days of the time 

when emission limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emission, and corrective actions taken. 

XXVIII. Permit Deviation 

In accordance with 40 CFR 70.6(a)(3)(iii)(B), the Permittee shall report to the DES all instances of deviations 

from Permit requirements, by telephone or fax, within 8 hours of discovery of such deviation pursuant to 

Env-A 902.02. This report shall include the deviation itself, including those attributable to upset conditions as defined in the Permit, the probable cause of such deviations, and any corrective actions or preventative measures taken. Said Permit deviation shall also be submitted in writing to the DES within fifteen (15) days of documentation of the deviation by facility personnel. Deviations are instances where any Permit condition 

is violated and has not already been reported as an emergency pursuant to Section XXVII of this Permit. 

Reporting a Permit deviation is not an affirmative defense for action brought for noncompliance. 

h:\osullivn\tvunhfnl 

STATE OF NEW HAMPSHIRE 

Department of Environmental Services 

Air Resources Division 

Title V Operating Permit 

Permit No: TV-OP-018 

Date Issued: September 15, 1999; Minor Permit Modification issued on April 9, 2001 

This certifies that: 

Tractebel Power, Inc. 

24 Bridge Street 

Concord, NH 03301 

has been granted a Title V Operating Permit for the following facility and location: 

Pinetree Power Tamworth 

Route 41 

West Ossipee, Nil 03890-0233 

Carroll County 

AFS No, 3300300019 

This Title V Operating Permit is hereby issued under the terms and conditions specified in the Title V Operating Permit Application filed with the New Hampshire Department of Environmental Services Air Resources Division (DES) on June 27, 1996 and the supplemental information for the Title V application submitted on September 23, 1996 and March 9, 1998 under the signature of the following responsible official certifying to the best of their knowledge that the statements and information-therein are true, accurate, and complete. 

Responsible Official: 

Russell F. Dowd 

Plant Superintendent 

(603) 323-8187 (Ext. 303) 

Technical Contact: 

Russell F. Dowd 

Plant Superintendent 

(603) 323.8187 (Ext. 303) 

This Permit is issued by the DES pursuant to its authority under New Hampshire RSA 125-C and in accordance with the provisions of Code of the Federal Regulations 40 Part 70. 

This Title V Operating Permit shall expire on September 30, 2004. 

SEE ATTACHED SHEETS FOR ADDITIONAL PERMIT CONDITIONS 

For the New Hampshire Department of Environmental Services, Air Resource Division 

Director, Air Resources Division 
TABLE OF CONTENTS 

Page 2 

I. Facili• Description of Operations 4 

H. Periled Activities 4 

•. Significant Activities Identification and Stack Criteria Tables 1 & 2 4-5 

IV. 5-6 

V. 6 

VI. 6 

VII. 6 

VIII. 6-10 

IX. 10 

X. 10-20 

XI. 20 

Insignificant Activities Identification 

Exempt Activities Identification 

Pollution Control Equipment Identification Table 3 

Alternative Operating Scenarios 

Applicable Operational and Emission Limitations 

Emission Reductions Trading Requirements 

Compliance Demonstration Requirements 

-Monitoring and Testing Requirements 

-Recordkeeping and Reporting Requirements 

Requirements Not Currently Applicable. 

XII. 

XIII. 

XIV. 

XV. 

XVIII. 

XIX. 

XX. 

XXI. 

XXII. 

XXIlI. 

Issuance of a Title V Operating Permit 

Title V Operating Permit Renewal Procedures 

Application .Shield 

Permit Shield 

Reopening for Cause 

Administrative Permit Amendments 

Operational Flexibility 

Minor Permit Amendments 

Significant Permit Amendments 

Title V Operating Permit Suspension, Revocation, or Nullification 

Inspection and Entry 

21 

21 

21 

21-22 

22 

22-23 

23 -24 

24 

24 

25 

25 

Certifications 25-26 
Page 3 

Enforcement 26 

XXV. Emission Based Fee Requirements 

XXVI. Duty to Provide Information 

XXVII. 

XXVIII. 

Property Rights 

Severability Clause 

Emergency Conditions 

Permit Malfunctions and Deviations 

26-27 

27 

27 

28 

28 

28-29 
Page 4 

Facility Specific Title V Operating Permit Conditions 

I. Facility Description of Operations: 

The Pinetree Tamworth wood-fired electric power generating plant ("Pinetree Tamworth") began operation 

in December of 1987 using a 25 megawatt ("MW") turbine to produce electricity. The turbine generator is 

driven by steam produced in a 404.13 million British thermal unit per hour (mmBTU/hr) waterwall boiler. 

At the maximum firing rate (404.13 mmBTU/hr), the boiler produces approximately 220,000 lb/hr of steam 

.at 700 psig and 900°F. The boiler is fired using approximately 47.5 tons/hour of wood chips with an average 

heating value of 4,250 BTU/lb, assuming approximately 50% moisture. The facility also operates a 745 

horsepower ("hp") emergency generator, which fires diesel fuel at a maximum rate of 39.9 gallons per hour. 

This generator is fired only in the event of a Public Service Company of New Hampshire ("PSNH") 

blackout, and for maintenance purposes. 

The Pinetree Tamworth facility received a United States Environmental Protection Agency ("EPA") 

Prevention of Significant Air Quality Deterioration ("PSD") permit (Permit No. 040-149NH06) on 

November 15, 1990. The PSD permit limits are incorporated in this Title V Operating Permit. 

II. Permitted Activities: 

In accordance with all of the provisions of the New Hampshire Rules Goveming the Control of Air Pollution 

(effective date 12/31/96) and as revised thereafter, Pinetree Tamworth is authorized to operate the devices 

and or processes identified in Sections III., IV., V., and VI. within the terms and conditions specified in this 

Permit. 

III. Significant Activities Identification and Stack Criteria: 

A. Significant Activity Identification 

The activities identified in the following table (Table 1) are subject to and regulated by this Title V 

Operating Permit: 

EU1 Boiler 

EU2-EG 

EU3 Cooling 

Tower 

Zum Two Drum Waterwall Wood-fireat 

Boiler 

Caterpillar Emergency Diesel 

Generator, Model #3412 

Circulation Water Cooling Tower 

Stack #1 

Stack #2 

Cooling Tower 

Maximum Firing Rate of 

404.13 mmBTU/hr derived 

from whole tree wood chips 

745 hp operating less than 500 

hours per year, max firing rate 

of 4.9 mmBTU/hr, 

39.9 gal/hr of diesel; sulfur 

content limit of 0.4 

Drift Factor 0.0002 gal 

drifl/gal circ 

Circulation Rate 26,000 •pm 
Page 5 

III. Significant Activities Identification and Stack Criteria (continued): 

Based on equipment design, the maximum operating rate of the EU1 Boiler shall be limited 

to a total of 404.13 mmBTU/hr gross heat input. 

In accordance with Pinetree Tamworth's federal PSD permit (No. 040-149NH06), Pinetree Tamworth shall burn in the EU1 Boiler only wood chips uncontaminated by glues, preservatives, oils, or similar foreign substances in the boiler. Pinetree shall notify the EPA 

and the DES and obtain written EPA and DES approval of all proposed sources of wood fuel other than wood chips, and of the nature of said fuels, prior to the securing of any purchase/utilization agreements for said fuels. 

Based on equipment design and 365 operating .days per year, the maximum wood consumption by the EU1 Boiler shall be limited to 416,494 tons wet basis of whole tree wood chips at approximately 50% moisture (4,250 BTU/lb) during any consecutive twelve month period. This is equivalent to 220,000 lbs/hr of steam production as averaged over any 

consecutive 24-hour period at 900 degrees F and 700 PSIG, assuming a boiler efficiency of 

71.47% and boiler feedwater temperature of 405 degrees F. 

B. Stack Criteria 

The following stacks for the above listed significant devices at Pinetree Tamworth shall discharge vertically without obstruction (including rain caps) and meet the following criteria in accordance with the state-only air pollution dispersion modeling requirements specified in Env-A 606. 

IV. 

Stack #1 EU1-Boiler 197.5 8.5 

Stack #2 EU2-EG 10.0 0.67 

Preauthorized changes to the state-only requirements pertaining to stack parameters (set forth in this permit) shall be permitted only when an air quality impact analysis meeting the criteria of Part Env-A 606 is performed either by Pinetree Tamworth or by the DES (if requested by Pinetree Tamworth in writing) in accordance with the "NHARD Policy and Procedure for Air Quality Impact Modeling". All air modeling data generated by the facility shall be kept on file at Pinetree Tamworth for review by the DES upon request. 

Insignificant Activities Identification. 

All activities at Pinetree Tamworth that meet the criteria identified in the New Hampshire Rules Governing the Control of Air Pollution Part Env-A 609.03(g), shall be considered insignificant activities. Emissions from the insignificant activities shall be included in the total Pinetree Tamworth emissions for the emission- based fee calculation described in Section XXV. of this Title V Operating Permit. 
VI. 

Page 6 

Insignificant activities at the facility include two liquid propane heaters and a maintenance shop degreasing 

unit. 

Exempt Activities Identification: 

All activities identified in the New Hampshire Rules Governing the Control of Air Pollution Part Env-A 

609.03(c) shall be considered exempt activities and shall not be subject to or regulated by this Title V 

Operating Permit. These activities include an emergency diesel fire pump rated at 187 hp. 

Pollution Control Equipment Identification: 

The devices and/or processes identified in Table 3 below are considered pollution control equipment for the 

identified emissions unit. 

-- Table3 PollutionControl Equi Identification 

PC1-Multiclone Multiclone primary particulate control for the EU1 Boiler EU1-Boiler 

PC2-ESP Electrostatic Precipitator (ESP) secondary particulate control for the EU1-Boiler 

EU1 Boiler 

VII. 

VIII. 

Ao All equipment, facilities, and systems installed and used to achieve compliance with the terms and 

conditions of this permit shall at all times be maintained in good working order and shall be operated 

as efficiently as possible so as to minimize air pollutant emissions and meet all applicable air 

pollutant emission limits. These controls shall be fully operational upon Pinetree Tamworth startup 

and shall not be bypassed during startup, operation, or shutdown of the steam generating unit, except 

when the stack flow is less than 39,762DSCFM, as specified in Section X.C. 10 of this permit. 

The pollution control equipment shall be maintained regularly, in accordance with the 

manufacturer's Operation and Maintenance ("O&M") manual and based on the schedules as 

described in Sections VIII.A. and X.A. 

Alternative Operating Scenarios: 

Pinetree Tamworth did not request any alternative operating scenarios in the Title V permit application. 

Applicable Operational and Emission Limitations: 

Pinetree Tamworth is subject to the following operational and emission limitations as contained in this 

permit. 
mo 

Page 7 

Operational Limitations 

Based on equipment design, the maximum operating rate of the EU1-Boiler shall be limited 

to a total of 404.13 mmBTU/hr gross heat input with wood. This is equivalent to 220,000 lbs/hr of steam production as averaged over any consecutive 24-hour period at 900 degrees F and 700 PSIG, assuming a boiler efficiency of 71.47% and boiler feedwater temperature of 405 degrees F. 

To operationally control CO emissions in accordance with Env-A 305, Pinetree Tamworth 

shall comply with the following operational limitations. 

Pinetree Tamworth shall control CO emissions by varying the total quantity of input combustion air and/or the local distribution of that air into the EU1 Boiler. The amount of combustion air required to optimize the EU1 Boiler efficiency and reduce CO emissions is dependent on the wood moisture 

content and the type of wood, among other factors. The steam generating unit shall be equipped with fuel distribution, overfire air, and undergrate air control systems for optimum NOx and CO emission 

control. 

State-Only Applicable Emission Limitations 

The facility shall comply with the national ambient air quality standards and the applicable requirements of RSA 125-C:6, RSA 125-C: 11, and Env-A 606.04. These sections include, but are not limited to, descriptions of the powers and duties of the commissioner, and requirements for adherence to permit application procedures and air pollutant dispersion modeling impact analyses 

In accordance with Env-A 1002.03, Pinetree Tamworth shall take precautions to prevent, abate, and control the emission of fugitive dust for those activities described in Env-A 

1002.02. Such precautions shall include wetting, covering, shielding, or vacuuming. 

In accordance with Env-A 1305.01(a), new or modified devices, new or modified area 

sources, and existing devices or area sources for which new applications for permits are filed 

that have the potential to emit, in any amount, substances that meet the criteria of Env-A 

1301 shall be subject to Env-A 1300, until such time as the Env-A 1400requirements supersede the Env-A 1300 requirements. 

In accordance with Env-A 1305.02, air quality impact analysis of devices and area sources emitting substances meeting the criteria of Env-A 1301 shall be performed in accordance 

with the "DES Policy and Procedure for Air Quality Impact Modeling" or other comparable dispersion modeling methods approved by EPA. 

In accordance with Env-A 1403.01, new or modified devices or processes installed after May 8, 1998 shall be subject to the requirements of Env-A 1400. 

In accordance with 1403.02(a), all existing unmodified devices or processes which are in operation during the transition period ending three years from May 8, 1998 (May 8, 2001) shall comply with either EnwA 1300 or Env-A 1400. 

7. In accordance with Env-A 1403.02(b), all existing devices or processes in operation after the 
Page 8 

transition period ending three years from May 8, 1998 (May 8, 2001) shall comply with EnvA 1400. Env-A 1300 will no longer be in effect. 

In accordance with Env-A 1404.01(d), documentation for the demonstration of compliance 

shall be retained at the site, and shall be made available to the DES for inspection. 

In accordance withEnv-A 1405.02, the owner of an existing device or process requiring a 

permit modification under Env-A 1400 shall submit to the DES no later than one year prior 

to the end of the transition period (by May 8, 2000) an application for a modification to a 

Title V permit in accordance with Env-A 609.18, and a request to the DES to perform air 

dispersion modeling. 

10. In accordance with Env-A 1405.03, the owner of an existing device or process requiring a 

permit under Env-A 1300 shall submit to the DES no later than One year prior to the end of 

the transition period (May 8, 2000) a compliance plan identifying how the device or process 

will comply with chapter Env-A 1400 by the end of the transition period. The compliance 

plan shall contain the dates when the information required in Env-A 1405.02 will be filed 

with the DES. 

11. In accordance with Env-A 1406.01, the owner of any device or process which emits a 

regulated toxic air pollutant shall determine compliance with the ambient air limits by using 

one of the methods provided in Env-A 1406.02, Env-A 1406.03, or Env-A 1406.04. Upon 

request, the owner of any device.or process which emits a regulated toxic air pollutant shall 

provide documentation of compliance with the ambient air limits to the DES. 

Federally Enforceable Emission Limitations 

In accordance with Pinetree Tamworth's federal PSD permit (No. 040-149NH06), annual 

SO2 emissions from the facility shall not exceed 40 tons in any consecutive 12-month period. 

In accordance with Env-A 1211.02(j)(1 and 2), EU2-EG shall be limited to less than 500 

hours of operation during any consecutive 12-month period, and the theoretical potential 

emissions of NO from this generator are limited to less than 25 tons for any consecutive 12- 

month period. 

In the event that EU2-EG exceeds 500 hours of operation and 25 tons of NOx emissions in 

any consecutive 12-month period, it shall become subject to the requirements of Env-A 

1211.11. 

In accordance with 40 CFR Part 52 and Env-A 1604.01(a), the sulfur content of diesel fuel 

burned at this facility shall not exceed 0.40 percent sulfur by weight. 

Env-A 402.02(a), effective on December 27, 1990, was adopted as part of the State Implementation Plan 

(SIP) on September 14, 1992 and is still considered federally enforceable until such time as the SIP is amended and 

approved by the EPA. 
Page 9 

In accordance with 40 CFR Part 52 2, the sulfur content of gaseous fuels burned at this facility shall not exceed 5 grains per 100 cubic feet of gas, calculated as hydrogen sulfide at 

standard temperature and pressure. 

In accordance with Env-A 2003.08, emissions of particulate matter from EU2-EG shall not 

exceed 0.30 lb/mmBtu. 

In accordance with Pinetree Tamworth's federal PSD permit (No. 040-149NH06), startup and shutdown periods for the EU1-Boiler are defined as follows: 

Startup periods are those periods of time from the initiation of wood firing until the 

unit reaches steady-state operation (85% to 100% load conditions). This period shall 

not exceed 8 hours (480 minutes) for a cold startup, nor 4 hours (240 minutes) for a hot startup. A cold startup shall be defined as startup when the EU1-Boiler has been 

down for more than 24 hours. 

Shutdown periods shall not exceed 4 hours (240 minutes) from the moment the wood fuel supply to the EU1- Boiler is eliminated. 

Co The number of hours that the EU1-Boiler can operate in a startup or shutdown mode shall not exceed 15% of the total operating hours of the plant. 

In accordance with Pinetree Tamworth's federal PSD Permit No. 040-149NH06, Pinetree Tamworth is subject to the following opacity limits: 

a. Startup/Shutdown Conditions 

Pinetree shall not cause or allow visible emissions from the EU1-Boiler to exceed 20 percent (6-minute average), except for one 6-minute average per hour of not more than 27 percent opacity. 

b. Steady State Operating Conditions 

Pinetree shall not cause or allow visible emissions from EU1 to exceed 15 percent (6-minute average), except for one 6-minute average per hour of not more than 27 percent opacity. 

Pinetree shall not cause or allow visible emissions from EU2 to exceed 20%, in accordance with Env-A 2003.02. 

Opacity shall be determined in accordance with procedures set forth in 40 CFR Part 60, Appendix A, Method 9 during opacity Continuous Emissions Monitoring System (CEMS) down times. 

2 Env-A 402.03, effective on December 27, 1990, was adopted as part of the State Implementation Plan (SIP) on September 14, 1992 and is still considered federally enforceable until such time as the SIP is amended and approved by the EPA. 
IX. 

Xo 

Page 10 

9. In accordance with the requirements of Pinetree Tamworth's federal PSD permit,(No. 040- 

149NH06), the NO emission rate from the EU1- Boiler. shall be limited to 107.10 pounds 

of NOx per hour (lbs/hr) and 0.265 lbs NOx/mmBTU, as averaged over any consecutive 24- 

hour period. Compliance with this emission limit shall be demonstrated using the NO 

CEMS data. 

10. In accordance with the requirements of Pinetree Tamworth's federal PSD permit (No. 040- 

149NH06), during steady state operating conditions, the carbon monoxide ("CO") emission 

rate for Pinetree Tamworth's boiler EU1 shall be limited to 0.5 lb/mmBTU heat input and 

202.10 lbs/hr as averaged over any consecutive 24-hour period; Compliance with this 

emission limit shall be demonstrated using the CO CEMS data. CEMS requirements are 

described in Section X.B. of this permit. 

11. In accordance with Pinetree Tamworth's federal PSD permit (No. 040-149NH06), the PM 

emission rate for the EU1 Boiler shall be limited to 0.025 lb/mmBTU heat input and 10.10 

lb/hr at all times. 

12. In accordance with Pinetree Tamworth's federal PSD permit (No. 040-149NH06), the 

volatile organic compound ("VOC") emission rate for the EU1 Boiler shall be limited to 

0.096 lb/mmBTU heat input and 38.80 lb/hr at all times. 

13. In accordance with Pinetree Tamworth'S federal PSD permit. (No. 040-149NH06), Pinetree 

shall not allow fugitive emissions from the facility to exceed 5% opacity at any time. 

Pinetree shall continuously clean and maintain the facility to minimize fugitive particulate 

matter emissions. The fugitive emission control plan prepared and submitted to the EPA 

following issuance of the facility PSD permit shall be reviewed on an annual basis and 

updated as needed to accurately reflect facility conditions. 

Emission Reductions Trading Requirements: 

Pinetree Tamworth did not request emissions reductions trading in the Pinetree Tamworth operating permit 

application. At the time of this permit preparation, the DES did not include any permit terms authorizing 

emissions trading in this permit. All emissions reductions trading must be authorized under the applicable 

requirements of either Env-A 3000 (the "Emissions Reductions Credits (or ERCs) Trading Program") or 

Env-A-3100 (the "Discrete Emissions Reductions (or DERs) Trading Program") and 42 U.S.C. §7401 et 

seq. (The."Act"), and must be provided for in this Permit. 

Compliance Demonstration Requirements: 

Pinetree Tamworth is subject to the monitoring/testing, record keeping, and reporting requirements as 

follows. The pollution control equipment and EU1 Boiler shall be monitored and maintained in accordance 

with the appropriate manufacturers' O&M manuals. 

A. The facility shall refer to the standard operating practices and the manufacturer's O&M manual for 

This device is subject to both the PSD limit of 0.265 lb NOx/mmBtu, and to the NOx RACT limit of 

0.33 Ib NOx/mmBtu (Env-A 1211.04(d) and Env-A 1211.05(d)(5)), although the PSD limit shall take priorit.y 

as the most stringent federally enforceable limit. 
any additional information. 

Page 11 

Bo Monitoring/Testing Requirements for Total Suspended Particulate Controls (Regulatory cite Env-A 806.01(a) (rule effective 6/30/95) and 40 CFR Part 70.6(a)(3)) 

1. PC 1 Multiclone Monitoring and Testing Requirements 

The PC 1-Multiclone shall be operated in series with the PC2-ESP unit (i.e., emissions from 

the Multiclone shall be vented to the ESP). 

ao Conduct monitoring of pressure differential across the PC Multiclone unit every 

two hours. An acceptable pressure differential shall be in accordance with standard operating practices and manufacturer's recommended operating parameters and shall 

be maintained between 2 inches and 8 inches of water column. Pressure differential readings shall be recorded on standard forms and kept on file at Pinetree Tamworth 

for review by the DES upon request. The standard forms shall include the acceptable operating parameters for quick reference by Pinetree Tamworth personnel. 

bo Pinetree Tamworth personnel shall conduct a daily inspection for visible emissions 

of the PC 1 Multiclone unit to observe leaks using EPA Method 22, found in 40 

CFR Part 60, Appendix A. If a leak(s) is observed, Pinetree Tamworth personnel shall take immediate steps to repair the leak. Daily observations, maintenance, and repairs performed to the unit shall be recorded in the log book. 

Co During down-time maintenance periods, Pinetree Tamworth personnel shall inspect inlet and outlet vanes and boots for any build up of caked dust. All caked dust shall 

be removed during each down-time maintenance period. Maintenance and repair activities shall be recorded in .the log book. 

do Observations of operating parameters outside of the standard operating practices included in this permit shall be recorded, investigated, and corrected immediately. If this results in an exceedance of the requirements found in Section VIII. of this permit, Pinetree Tamworth personnel shall contact the DES within 8 hours in 

accordance with Section XXX. of this permit. 

2. PC2 ESP Monitoring and Testing Requirements 

The PC2-ESP is used to control particulate matter emissions from the EU1 Boiler. 

a. Bi-Hourly Monitoring/Testing Requirements: 

In accordance with Pinetree Tamworth's O&M manual and standard operating practices for this equipment, on a bi-hourly basis, Pinetree Tamworth personnel shall: 

Check and record the secondary voltage and pressure drop readings on the 

PC2 ESP. The secondary voltage shall be maintained between 3 and 60 kv 

and the pressure drop across the PC2-ESP shall be maintained between 0-2 

inches of water column. Voltage or pressure drop readings outside these 

ranges indicate a malfunction with the PC2- ESP, and the operator shall 
P•el2 

correct the malfunction immediately. 

ii. The Pinetree Tamworth operator shall respond to all equipment alarms 

immediately. 

iii. Bi-hourly monitoring data shall be recorded daily on standard forms and kept 

on file at Pinetree Tamworth for review by the DES upon request. The 

standard forms shall include the acceptable operating parameters for quick 

reference by Pinetree Tamworth personnel. 

iv. Observations of operating parameters outside of the standard operating 

practices included in this permit shall be recorded, investigated, and corrected 

immediately. If this results in an exceedance of the requirements found in 

Section VIII. of this permit, Pinetree Tamworth personnel shall contact the 

DES within 8 hours in accordance with Section XXX. of this permit. 

b. Daily Monitoring/Testing Requirements 

The PC2-ESP shall be inspected at least once each shil% The casing, piping, 

and ducts shall be inspected for leaks, abnormal noise,•hot spots, and fires. 

Local instrumentation shall be monitored for normal values. The local 

control panel shall be monitored for proper indication of normal values and 

alarms. 

ii. Observations of operating parameters outside of the standard operating 

practices included in this permit shall be recorded, investigated, and corrected 

immediately. If this results in a permit limit exceedance, Pinetree Tamworth 

personnel shall contact the DES within 8 hours in accordance with Section 

XXX. of this permit. 

Stack Testing Requirements 

At such times specified by the DES, Pinetree Tamworth shall conduct USEPA method 

compliance stack tests for emissions at maximum production rate conditions and/or, at the 

request of the DES, at any other production rate at which maximum emissions might occur. 

If a stack test is requested, the emissions stack test shall be conducted in accordance with 40 

CFR Part 60, Section 60.8, Appendix A, and the DES' policy "Procedures and Minimum 

Requirements for Stack Tests". 

Compliance testing shall be planned and carried out in accordance with the following 

schedule. At least 30 days prior to the commencement of testing, Pinetree Tamworth shall 

submit to the DES a pre-test report presenting the following information: 

a. Calibration methods and sample data sheets; 

b. Description of the test methods to be used; 
Co 

Page 13 

c. Pre-test preparation procedures; 

d. Sample collection and analysis methods; 

e. Process data to be collected; and 

f. Complete test program description. 

If requested by the DES, at least 15 days prior to the test date, Pinetree Tamworth, and any 

contractor that Pinetree Tamworth retains for performance of the test, shall participate in a pre-test conference with a DES representative. Emission testing shall be carried out under the observation of a DES representative. Within 60 days after completion of testing, Pinetree Tamworth shall submit a test report to the DES. 

Any emission rates determined following specified compliance stack testing which show violations of the emission limitations shall be considered violations of this permit. 

5. Stack Inspections 

In accordance with 40 CFR 70.6(a)(3), Pinetree Tamworth shall conduct annual visual inspections of each stack and fuel burning device. Annual inspections shall include a thorough inspection of the condition of each stack exterior and each fuel burning device. Every 5 years, Pinetree Tamworth shall inspect the interior of each stack for evidence of corrosion, cracks, or holes. Records of inspections and subsequent maintenance conducted as a result of the annual inspections shall be kept on file at Pinetree Tamworth for review by the DES and/or the EPA upon request. 

CEMS Monitoring/Testing Requirements (Regulatory Cite Env-A 805.02 (rule effective and 40 CFR Part 70.6(a)(3)) 

Pinetree Tamworth shall install, maintain, and operate the following CEMS systems in the EU1- Boiler exhaust piping, unless otherwise noted. 

1. Opacity CEMS 

The opacity CEMS system shall be installed on the ESP outlet. This system shall meet the requirements of 40 CFR Part 60, Appendix B, Performance Specification 1, and Env-A 805 (rule effective 1/15/92). Determination of compliance with the opacity limits established in Section VIII.C. of this permit shall be made by the plant opacity CEMS or, during any CEMS downtime, by visible emission readings taken once per shift following the-procedures specified in 40 CFR Part 60, Appendix A, Method 9. Calculations shall be performed as specified in Section X.C.8. of this permit. 

2. NO CEMS 

The NO CEMS shall meet the requirements of 40 CFR Part 60, Appendix B, Performance Specification 2, and Env-A 805 (rule effective 11/15/92). Determination of compliance with the NOx emission limits established in Section VIII.C. of this permit shall be made by the plant NOx CEMS. The NQ, emission rate shall be calculated daily as the average of the 
Page 14 

calendar day averages as calculated on the plant NO CEMS. Calculations shall be 

performed as specified in Section X.C.8. of this permit. 

CO CEMS 

The CO CEM system shall meet the requirements of 40 CFR Part 60, Appendix B, 

Performance Specification 4, and Env-A 805 (rule effective 11/15/92). Determination of 

compliance with the CO emission limits established in Section VIII.C. of this permit shall 

be made by the plant CO CEMS. The CO emission rate shall be calculated daily as the 

average of the calendar day averages as calculated on the plant CO CEMS. Calculations 

shall be performed as specified in Section X.C.8. of this permit. 

Oxygen ("02") CEMS 

The 02 CEM system shall meet the requirements of 40 CFR Part 60, Appendix B, 

Performance Specification 3, and Env-A 805 (rule effective 11/15/92). 

Volumetric Flow CEMS 

The stack volumetric flow measuring device shall meet all of the requirements of 40 CFR 

Part 60, Appendix B, Performance Specification 6. The stack flow monitor shall have an 

automatic blow-back purge system installed and activated during all times of boiler 

operation..The stack volumetric flow measuring device combined with the concentration 

CEMS equipment for CO and NOx shall be used to calculate mass emission rates for 

comparison with the emission standard specified in permit condition VIII.C. The stack 

volumetric flow monitor shall also meet the following requirements: 

ao All differential pressure flow monitors shall have an automatic blow-back purge 

system installed and in wet stack emissions shall have the capability for drainage of 

the sensing lines. 

The stack flow monitoring system shall have the capability for on-line manual 

transducer calibration and for a zero check. 

Co The stack flow monitoring system shall be capable of displaying the individual 

parameters used in the stack flow calculation. For example, a differential pressure 

monitoring system shall be able to display instantaneous values of differential 

pressure, stack temperature, and relevant constants used in the calculation which 

reflect the static pressure assumed, gas molecular weight assumed, and the pitot tube 

coefficient utilized. 

Steam Flow CEMS 

Pinetree Tamworth shall install, maintain, and operate a continuous steam flow rate 

monitoring/recording system on the boiler output steam pipe which shall meet all 

applicable ASME speci..fications. Calibration of the steam flow transducer shall occur at 

least once annually in accordance with manufacturer's specifications. Pinetree 

Tamworth may use a steam flow rate monitoring system that can be calibrated by 
Page 15 

instruments installed, maintained, and calibrated per ASME specifications or by other 

methods approved by the DES. 

To meet the requirements of Section VIII.C.7.(c), the facility shall record the number of hours that the facility is operated in startup or shutdown modes, the total number of hours in operation, and the total number of hours that the facility is down for maintenance and repairs. This information shall be used to demonstrate that the number of hours that the EU1-Boiler operates in a startup or shutdown mode does not exceed 15% of the total operating hours of the plant. 

Calculations: 

a. CEMS calendar day averages shall be calculated as follows: 

Calendar Day average (sum of all valid hourly averages for the calendar day)/(24 hours of CEM system downtime for the day); 

ii. Calendar day averages shall only be valid for days with 18 or more valid 

hours of CEMS data; 

iii. A valid hour of CEMS data shall be defined as a minimum of 45 minutes 

collection of CEMS readings taken in a calendar hour; and 

iv. Hours of CEM system downtime shall be defined as the number of calendar 

hours when the CEM system has not collected data or is out-of-control for 

greater than 15 minutes for any reason (i.e., audits, CEM system calibration, CEM system failures, etc.). "Out of control" periods are defined in 40 CFR 

60, Appendix F. 

b. CEMS consecutive 365-day averages shall be calculated as follows: 

Consecutive 365-day average (sum of all valid calendar day averages for 

the 365-day period)/(365 days of CEM system downtime); and 

ii. Days of CEM system downtime shall be defined as the number of calendar days when the CEM system has collected less than 18 valid hours of CEMS 

data. 

Co Hours or days when the CEM system has been intentionally shutdown when Pinetree Tamworth is not operating shall not be counted as CEM system downtime. The facility shall document all plant operating hours during which any required CEMS 

is not operational. 

Pinetree Tamworth shall be subject to all of the CEMS requirements of Env-A 805 (rule effective 11/15/92) which shall include, but not be limited to: quarterly audit requirements, excess emission report requirements, quality control written procedure requirements for 

gaseous CEMS monitors, and record keeping requirements. The specific record keeping and reporting requirements are described in Sections X.E. and X.F. of this permit. 
Do 

Page 16 

10. Pinetree Tamworth shall continuously monitor and record data from the gaseous, volumetric 

flow, and steam flow CEM systems during all periods of operation, including periods of 

startup, shutdown, malfunctions, or emergency conditions, except when the stack flow is less 

than 39, 762 DSCFM. The opacity CEMS shall be continuously monitoring and recording 

data during all periods of operation, regardless of the stack flow rate. 

11. Excess emissions indicated by the CEM system shall be considered violations of the 

applicable emission limit for purposes of this permit, except where Pinetree Tamworth can 

adequately demonstrate to the DES that the recorded exceedance resulted from a CEMS 

malfunction. 

Compliance Demonstration Requirements for the EU3 Cooling Tower State Enforceable Only 

In accordance with Env-A 1400, prior to changing cooling water treatment chemicals, 

Pinetree Tamworth shall evaluate the impact of the proposed chemicals on the 24-hour and 

annual de minimus limits of the DES Air Toxics List. If the impact exceeds the de minimus 

24-hour or annual levels, Pinetree Tamworth shall notify the DES in writing of the proposed 

chemical changes, and shall either perform modeling or request the DES to perform 

modeling of the proposed substance. Written approval from the DES shall be received prior 

to making the chemical change, if the de minimus levels are exceeded. If the impact does 

not exceed the de minimus levels, Pinetree Tamworth may make the chemical change and 

shall keep the records of the impact analysis in the Pinetree Tamworth files in accordance 

with the record keeping requirements of Section X.D. of this permit. 

The following equations shall be used to evaluate the impact of cooling water chemicals on 

the 24-hour and annual de minimus levels. These equations shall be used for each chemical 

used in the cooling water that is included on the DES Air Toxics List. Also, these equations 

shall be used to estimate particulate emissions from both chemical additives to the water and 

total dissolved solids contained in the water for emission-based fees as described in Section 

XXV. of this permit. 

24-hour Emissions (lb/hr) (DR)*(Hourly CR)*(8.34 lb/gal)*(C) 

Example Calculation: 24-hour emissions of total dissolved solids (lb/hr) 

(0.0002 gal/gal)*(1,560,,000 gal/hr)*(8.34 lb/gal)*(1200 ppmw TDS) 

lxl06 

3.1225 lb/hr TDS 

Annualized Emissions (lb/yr) (24-hour Emissions, lb/hr)*(Operating hours/year) 

Example Calculation: Annualized emissions of TDS (lb/yr) (3.1225 lb/hr)*(8760 hrs/yr) 

(2000 lb/ton) 

13.68 tons/yr TDS 

Where: DR drift rate for cooling tower (based on manufacturer's data for Pinetree 

Tamworth cooling tower), 

gal drift/gal circulation water (0.0002 gal/gal) 
Page 17 

Hourly CR water circulation rate, gal/hr 

C concentration of chemical of interest (or total dissolved solids 

concentration) in circulation water, ppmw (use maximum potential 

concentration for de minimus impact evaluation and average or actual 

data for emission-based fee calculations). 

Record keeping Requirements 

In accordance with 40 CFR Part 70.6(a)(3)(ii)(B), Pinetree Tamworth shall retain records of 

all required monitoring data, record keeping and reporting requirements, and support information for a period of at least 5 years from the date of the origination. These data and 

reports shall not be discarded, removed, or destroyed thereafter without the express written approval of the director in accordance with Env-A 901.11 (rule effective 11/16/89). 

In accordance with 40 CFR 70.6(c)(5), Pinetree Tamworth shall meet the requirements for compliance certification with terms and conditions contained in this permit, including emission limitations, standards, or work practices. Compliance certifications shall meet the requirements outlined in Section XXIII. of this permit. 

Pursuant to Env-A 901.03 (rule effective 11/16/89), for each fuel burning device at Pinetree Tamworth, the owner or operator shall keep records on fuel utilization in accordance with 

the following: 

ao Monthly records of all fuel utilization for each fuel burning device at Pinetree 

Tamworth shall include: 

Consumption of each fuel type per calendar month and a consecutive 12- 

month total; 

ii. Fuel type; 

iii. Viscosity; 

iv. Sulfur content as percent sulfur by weight of fuel; and 

v. BTU content per gallon of fuel. 

bo Delivery tickets from each fuel oil supplier for each shipment of fuel oil and/or diesel 

fuel received shall be kept on file in a form suitable for inspection and shall be made 

available to the DES and/or the EPA upon request. Each delivery ticket shall indicate 

the name, address, and telephone number of the fuel supplier; the quantity of fuel delivered, and the percent sulfur by weight of the fuel being delivered. If delivery tickets do not contain sulfur content of fuel being delivered, Pinetree Tamworth shall perform testing in accordance with appropriate ASTM test methods to determine compliance with the sulfur content limitation provisions in Env-A 1604.01(a) for liquid fuels. 

c. As specified in Env-A 809.02 (rule effective 5/29/97), the operator shall (upon 
Page 18 

written request by the DES) conduct testing in accordance with appropriate ASTM 

test methods to determine compliance with the sulfur content limitation provisions 

in Env-A 1605.01 tbr gaseous fuels. If requested, such information shall be 

submitted to DES. 

d. Records shall be kept of hours of operation corresponding to the utilization and 

distribution of all fuels. 

NOx Record keeping Requirements 

In accordance with Env-A 901.08 (rule effective 11/16/89), for each fuel burning device, 

including boilers, turbines, and internal combustion engines, the following information shall 

be recorded and maintained: 

a. Pinetree Tamworth information, including: 

i. Source name; 

ii. Source identification; 

iii. Physical address; 

iv. Mailing address; 

v. Date of origination for reports; 

vi. Pinetree Tamworth contact and title; 

vii. Pinetree Tamworth telephone number; 

b. Identification of each fuel burning device at PinetreeTamworth. 

c. Operating schedule information for each identified fuel burning device, including: 

i. Days per calendar week during the normal operating schedule; 

ii. Hours per day during the normal operating schedule and for a typical ozone 

season day, if different from the normal operating schedule; and 

iii. Hours per year during the normal operating schedule. 

d. Type and amount of fuel burned, for each fuel burning device, during normal 

operating conditions and for a typical ozone season day 4, if different from normal 

operating conditions, on an hourly basis in mmBTU/hr. 

e. The following NO emission data, including records of total annual emissions, in tons 

4 q?ypical ozone season day is defined as any day between April and October 31. 
Fo 

Page 19 

per year (tpy), and typical ozone season day emissions, in pounds per day (lbs/day), shall be maintained at Pinetree TamwOrth for a minimum of 4 years: 

Theoretical potential emissions for the calculation year for each fuel burning device; and 

ii. Actual NO emissions for each fuel burning device• 

Reporting Requirements 

In accordance with Env-A 901.09(b) (rule effective 11/16/89), NO emission data for all 

Pinetree Tamworth fuel burning devices shall be reported to the DES annually by April 15 

of the following year. The NO emissions for the EU1-Boiler shall be collected from the applicable CEMS data. The NOx emissions for EU2-EG shall be based on NOx record keeping requirements and calculations using EPA-published emission factors. 

Malfunction Reporting 

In accordance with Env-A 902.02 (rule effective 11/16/89) and 40 CFR Part 70.6(a)(3)(iii)(B), the owner or operator shall notify the DES of a malfunction or breakdown 

of air pollution control equipment within 8 hours of each such occurrence, as described in 

Section XXX. of this permit. 

Fuel Usage Reporting 

In accordance with Env-A 901.03 (rule effective 11/16/89), monthly fuel usage information, by device, fuel type, and sulfur content shall be submitted in writing to the DES on a quarterly basis within 30 days after the end of the quarter for which reporting is required. 

Excess Emission Reporting 

In accordance with Env-A 805 (rule effective 11/15/92), within 30 days following the close of each calendar quarter, Pinetree Tamworth shall submit to the DES excess emission reports for the EU1 Boiler containing information specified in Env-A 805 (rule effective 11/15/92)• as well as the following information: 

Calendar daily averages of NO and CO lb/hr and part per million (ppm) dry, whether or not an excess emission has occurred; 

b. Calendar daily averages of percentage oxygen (02) on a dry basis; 

c. Calendar daily averages of steam generation rate; 

d. Calendar daily averages of stack flow (dscfm); 

Average steam production rate for each consecutive 24-hour period where the production rate exceeds any of the limits set forth in Section VIII.A. of this permit; 

f. CEM system availability data; 
XI. 

Page 20 

Estimated amount in tons (wet basis) of wood chip consumption per month and a 

consecutive twelve month total; 

h° Amount in gallons of fuel consumption per calendar month where the fuel usage cap 

set forth in Section VIII.A. of this permit has been exceeded; and 

All periods of gaseous, opacity, and steam flow rate exceedances including start time, 

end time, and magnitude and cause of the exceedance. This shall include 

exceedances of the consecutive 24-hour average limits for NOx and CO, as measured 

by the CEM systems. 

5. CEMS Audit Reporting 

Within 30 days following the close of each calendar quarter, Pinetree Tamworth shall submit 

to the DES a CEMS audit report for all audits conducted as specified in Env-A 805.06 (rule 

effective 11/15/92) and Section X.C. of this permit. 

In accordance with 40 CFR 70.6(a)(3)(iii)(A), a summary report of monitoring and testing 

requirements shall be submitted every six months. Semi-annual reports shall be submitted 

no later than July 31 for the January through June report and no later than January 31 for the 

July through December report. All instances of deviations from permit requirements shall 

be clearly identified in such reports. All required reports shall be certified for accuracy by a 

responsible official consistent with 40 CFR 70.5(d). Thus, all required reports shall include 

the certification of accuracy statement included in Section XXIII.B. of this permit. 

The report shall contain a summary of the following information: 

a. Monitoring and preventive maintenance results for control devices PC1 and PC2. 

bo Preventive maintenance and inspection results for. EU1-Boiler, EU2-EG, and related 

stacks. 

c. All instances of deviations from permit requirements shall be clearly identified. 

Calculation and payment of emission based fees shall be conducted in accordance with 

Section XXV. of this Permit. 

An annual compliance certification as presented in Section XXIII. of this Permit shall be 

submitted to the DES and the USEPA by April 15 following each reporting year. 

Pursuant to 40 CFR Part 70.6 (c)(1), all documents submitted to the DES and/or the EPA 

shall contain certification by the responsible official of truth, accuracy, and completeness as 

described in Section XXIII.B. of this permit. 

Requirements Currently Not Applicable: 

Pinetree Tamworth did not request that any non-applicable requirements be specifically listed in this permit. 
Page 21 

General Title V Operating Permit Conditions 

XII. Issuance of a Title V Operating Permit: 

This Permit is issued in accordance with the provisions of Part Env-A 609. ha accordance with 40 

CFR 70.6(a)(2) this Permit shall expire on the date specified on the cover page of this Permit, which 

shall not be later than the date five (5) years after issuance of this Permit. 

Permit expiration terminates the Permittee's right to operate the Permittee's emission units, control equipment or associated equipment covered by this permit, unless a timely and complete renewal application is submitted at least 6 months before the expiration date. 

Bo Pursuant to Env-A 609.02(b), this Permit shall be a state permit to operate as defined in RSA 125- 

C:I 1, III. 

XIII. Title V Operating Permit Renewal Procedures: 

Pursuant to Env-A 609.06(b),. an application for renewal of this Permit shall be considered timely if it is submitted to the Director at least six months prior to the designated expiration date of this Permit. 

XIV. Application Shield: 

Pursuant to Env-A 609.07, if an applicant submits a timely and complete application for the issuance or renewal of a Permit, the failure to have a Permit shall not be considered a violation of this part until the Director takes final action on the application. 

XV. Permit Shield: 

A. Pursuant to Env-A 609.08(a), a permit shield shall provide that: 

For any applicable requirement or any state requirement found in the New Hampshire Rules Governing the Control of Air Pollution specifically included in this Permit, compliance with 

the conditions of this Permit shall be deemed in compliance with said applicable requirement or said state requirement as of the date of permit issuance; and 

For any potential applicable requirement or any potential state requirement found in the New Hampshire Rules Governing the Control of Air Pollution specifically identified in this Title 

V Operating Permit as not applicable to the stationary source or area source, the Permittee 

need not comply with the specifically identified federal or state requirements. 

The permit shield identified in Section XV.A. of this Permit shall apply only to those conditions incorporated into this Permit in accordance with the provisions of Env-A 609.08(b). It shall not apply to certain conditions as specified in Env-A 609.08(c) that may be incorporated into this Permit following permit issuance by the DES. 

Co If a Title V Operating Permit and amendments thereto issued by the DES does not expressly include or exclude an applicable requirement or a state requirement found in the New Hampshire Rules Governing the Control of Air Pollution, that applicable requirement or state requirement shall not 

be covered by the permit shield and the Permittee shall comply with the provisions of said 
XVI. 

XVII. 

Page 22 

requirement to the extent that it applies to the Permit-tee. 

If the DES determines that this Title V Operating Permit was issued based upon inaccurate or 

incomplete information provided by the applicant or Permittee, any permit shield provisions_in said 

Title V Operating Permit shall be void as to the portions of said Title V Operating Permit which are 

affected, directly or indirectly, by the inaccurate or incomplete information. 

Pursuant to Env-A 609.08(0, nothing contained in Section XVL of this Permit shall alter or affect 

the ability of the DES to reopen this Permit for cause in accordance with Env-A 609.18, or to 

exercise its summary abatement authority. 

Pursuant to Env-A 609.08(g), nothing contained in this section or in any Title V operating permit 

issued by the DES shall alter or affect the following: 

The ability of the DES to order abatement requiring immediate compliance with applicable 

requirements upon finding that there is an itmninent and substantial endangerment to public 

health, welfare, or the environment; 

The State of New Hampshire's ability to bring an enforcement action pursuant to RSA 125- 

C:15, II; 

The l•rovisions of Section 303 of the Act regarding emergency orders including the authority 

of the EPA Administrator under that section; 

The liability of an owner or operator of a source for any violation of applicable requirements 

prior to or at the time of permit issuance; 

The applicable requirements of theacid rain program, consistent with Section 408(a) of the 

Act; 

The ability of the DES or the EPA Administrator to obtain information about a stationary 

source, area source, or device from the owner or operator pursuant to Section 114 of the Act; 

or 

The ability of the DES or the EPA Administrator to enter, inspect, and/or monitor a 

stationary source, area source, or device. 

Reopening for Cause: 

The Director shall reopen and revise a Title V Operating Permit for cause if any of the circumstances 

contained in Env-A 609.18(a) exist. In all proceedings to reopen and reissue a Title V Operating Permit, 

the Director shall follow the provisions specified in Env-A 609.18(b) through (g). 

Administrative Permit Amendments: 

Pursuant to Env-A 612.01, the Permittee may implement the changes addressed in the request for 

an administrative permit amendment as defined in Part Env-A 100 immediately upon submittal of 

the request. 
Page 23 

Bo Pursuant to Env-A 612.01, the Director shall take final action on a request for an administrative permit amendment in accordance with the provisions of Env-A 612.01 (b) and (c). 

XVIII. Operational Flexibility: 

mo Pursuant to Env-A 612.02(a), the Permittee subject to and operating under this Title V Operating Permit may make changes involving trading of emissions under this existing Title V Operating Permit at the permitted stationary source or area source without filing a Title V Operating Permit application for and obtaining an amended Title V Operating Permit, provided that all the conditions are met as specified in Section XVIII.A. 1. through 7. of this permit and a notice is submitted to the DES and the EPA describing the intended changes. The DES has not included any permit terms authorizing emissions trading in this permit. 

1. The change is not a modification under any provision of Title I of the Act; 

The change does not cause emissions to exceed the emissions allowable under the Title V operating permit, whether expressed therein as a rate of emissions or in terms of total 

emissions; 

3. The owner or operator has obtained any temporary permit required by Env-A 600; 

The owner or operator has provided written notification to the director and administrator at 

least 15 .days prior to the proposed change and such written notification includes: 

a. The date on which each proposed change will occur; 

b. A description of each such change; 

Any change in emissions that will result and how this change in emissions will comply with the terms and conditions of the permit; 

d. A written request that the operational flexibility procedures be used; and 

e. The signature of the responsible official, consistent with Env-A 605.04(b); 

The Title V operating permit issued to the stationary source or area source already contains 

terms and conditions including all terms and conditions which determine compliance required under 40 CFR 70.6(a) and (c) and which allow for the trading of emissions increases and decreases at the permitted stationary source or area source solely for the purpose of complying with a federally-enforceable emissions cap that is established in the permit independent of otherwise applicable requirements; 

The owner or operator has included in the application for the Title V operating permit proposed replicable procedures and proposed permit terms which ensure that the emissions trades are quantifiable and federally enforceable for changes to the Title V operating permit which qualify under a federally-enforceable emissions cap that is established in the Title V operating permit independent of the otherwise applicable requirements; and 

7. The proposed change complies with Env-A 612.02(e). 
Page 24 

Bo Pursuant to Env-A 612.02(c), the Permittee subject to and operating under this Title V Operating 

Permit may make changes not addressed or prohibited by this existing Title V Operating Permit at 

the permitted stationary source or area source without filing a Title V Operating Permit application, 

provided that all the conditions specified in Env-A 612.02(c)(1) through (6) are met and a notice is 

submitted to the DES and the EPA describing the intended changes. 

Pursuant to Env-A 612.02(d), the Permittee, Operator, Director, and Administrator shall attach each 

notice of an off-permit change completed in accordance with Section XVIII.B. of this Title V 

Operating Permit to their copy of the current Title V Operating Permit. 

Pursuant to Env-A 612.02(e), any change under Section XVIII. shall not exceed any emissions 

limitations established trader the New Hampshire Rules Governing the Control of Air Pollution, or 

result in an increase in emissions, or result in new emissions, of any toxic air pollutant or hazardous 

air pollutant other than those listed in the existing Permit. 

Pursuant to Env-A 612.02(f), the off-permit change shall not qualify for the permit shield under EnvA 609.08. 

Minor Permit Amendments: 

Ao Pursuant to Env-A 612.04 prior to implementing a minor permit modification, the Permittee shall 

submit a written request to the Director in accordance with the requirements of Env-A 612.04(b). 

The Director shall take final action on the minor permit amendment request in accordance with the 

provisions of Env-A 612.04(c) through (g). 

Pursuant to Env-A 612.04(g), the permit shield specified in Env-A 609.08 shall not apply to minor 

permit amendments under Section XIX. of this Permit. 

Do Pursuant to Env-A 612.04(i), the Permittee shall be subject to the provisions of Part Env-A 614 and 

Part Env-A 615 if the change is made prior to the filing with the Director a request for a minor 

permit amendment. 

XX. Significant Permit Amendments: 

Pursuant to Env-A 612.05, a change at the facility shall qualify as a significant permit amendment 

if it meets the criteria specified in Env-A 612.05(a)( 1 ) through (7). 

Prior to implementing the significant permit amendment, the Permittee shall submit a written request 

to the Director and to the EPA which includes all the information as referenced in Env-A 612.05(b) 

and (c), and shall be issued an amended Title V Operating Permit from the DES. The Permittee shall 

be subject to the provisions of Env-A 614 and Env-A 615 if a request for a significant permit 

amendment is not filed with the Director and/or the change is made prior to the issuance of an 

amended Title V Operating Permit. 

The Director shall take final action on the significant permit amendment in accordance with the 

procedures specified in Env-A 612.05(d), (e), and (f). 
Page 25 

Title V Operating Permit Suspension, Revocation• or NullificationAo Pursuant to RSA 125-C: 13, the Director may suspend or revoke any final permit issued hereunder if, following a hearing, the Director determines that: 

The Permittee has committed a violation of any applicable statute or state requirement found 

in the New Hampshire Rules Governing the Control of Air Pollution, order, or permit condition in force and applicable to it; or 

That the emissions from any device to which this Permit applies, alone or in conjunction with 

other sources of the same pollutants, present an immediate danger to the public health. 

The Director shall nullify any Permit, if following a hearing in accordance with RSA 541-A :30, II, a f'mding is made that the Permit was issued in whole or in part based upon any information proven 

to be intentionally false or misleading. 

Inspection and Entry: 

Pursuant to Env-A 614.01, EPA and DES personnel shall be granted access to the facility covered by this Permit, in accordance with RSA 125-C:6, VII for the purposes of: inspecting the proposed or permitted site; investigating a complaint; and assuring compliance with any applicable requirement or state requirement found in the New Hampshire Rules Governing the Control of Air Pollution and/or conditions of any Permit issued pursuant to Chapter Env-A 600. 

XXIII. Certifications: 

A° Compliance Certification Report 

In accordance with 40 CFR 70.6(c) the Responsible Official shall certify,, annually from the date of issuance, that the facility is in compliance with the requirements of this permit. The report shall be 

submitted to the DES and to the Regional Administrator, U.S. Environmental Protection Agency New England Region. The report shall be submitted in compliance with the submission requirements below. 

In accordance with 40 CFR 70.6(c)(5)(B), the report shall describe: 

1. The terms and conditions of the Permit that are the basis of the certification; 

The current compliance status of the source with respect to the terms and conditions of this Permit, and whether the method was continuous or intermittent during the reporting period; 

The methods used for determining compliance, including a description of the monitoring, record keeping and reporting requirements, and test methods; and 

Any additional information required by the DES to determine the compliance status of the source. 

B. Certification of Accuracy Statement 
Page 26 

All documents submitted to the DES shall contain a certification of accuracy statement by the 

responsible official of truth, accuracy, and completeness. Such certification shall be in accordance 

with the requirements of 40 CFR 70.5(d) and contain the following language: 

"I am authorized to make this submission on behalf of the facility for which the submission 

is made. Based on information and belief formed after reasonable inquiry, I certify that the 

statements and information in the enclosed documents are to the best of my knowledge and 

belief true, accurate, and complete. I .am aware that there are significant penalties for 

submitting false statements and information or omitting required statements and information, 

including the possibility of fine or imprisonment." 

All reports submitted to the DES (except those submitted as emission based fees as outlined in 

Section XXV. of this permit) shall be submitted to the following address: 

New Hampshire Department of Environmental Services 

Air Resources Division 

64 North Main Street 

P.O. Box 2033 

Concord, NH 03302-2033 

Attn: Compliance Bureau 

XXIV. Enforcement: 

Any noncompliance with a permit condition constitutes a violation of RSA 125-C:15, and, as to the 

conditions in this permit which are federally enforceable, a violation of the Clean Air Act, 42 U.S.C. Section 

7401 et seq., and is grounds for enforcement action, for permit termination or revocation, or for denial of 

an operating permit renewal application by the DES and/or EPA. Noncompliance may also be grounds for 

assessment of administrative, civil, or criminal penalties in accordance with RSA 125-C: 15 and/or the Clean 

Air Act. This Permit does not relieve the Permittee from the obligation to comply with any other provisions 

of RSA 125-C, the New Hampshire Rules Governing the Control of Air Pollution, or the Clean Air Act, or 

to obtain any other necessary authorizations from other governmental agencies, or to comply with all other 

applicable Federal, State, or Local rules and regulations not addressed in this Permit. 

In accordance with 40 CFR 70.6 (a)(6)(ii) a Permittee shall not claim as a defense in an enforcement action 

that it would have been necessary to halt or reduce the permitted activity in order to maintain compliaiace 

with the conditions of this Permit. 

XXV. Emission-Based Fee Requirements: 

The Permittee shall pay an emission-based fee annually for this facility as calculated each calendar 

year pursuant to Env-A 704.03. 

The Permittee shall determine the total actual annual emissions from the facility to be included in 

the emission-based multiplier specified in Env-A 704.03(a) for each calendar year in accordance 

with the methods specified in EnwA 620. 

The Permittee shall calculate the annual emission-based fee for each calendar year in accordance 

with the procedures specified in Env-A 704.03 and the following equation: 
Where: 

FEE E * DPT * CPIm * ISF 

Page 27 

Do 

FEE The annual emission-based fee for each calendar year as specified in Env-A 704. 

DPT 

CPIm 

ISF 

The emission-based multiplier is based on the calculation of total annual emissions 

as specified in Env-A 704.02 and the provisions specified in Env-A 704.03(a). 

The dollar per ton fee the DES has specified in Env-A 704.03(b). 

The Consumer Price Index Multiplier as calculated in Env-A 704.03(c). 

The Inventory Stabilization Factor as specified in Env=A 704.03(d). 

The Permittee shall contact the DES each calendar year for the value of the Inventory Stabilization 

Factor. 

Eo The Permittee shall contact the DES each calendar year for the value of the Consumer Price Index 

Multiplier. 

The Permittee shall submit, to the DES, payment of the emission-based fee and a summary of the 

calculations referenced in Sections XXV.B. and C. of this Permit for each calendar year by October 

15 th of the following calendar year in accordance with Env-A 704.04. 

The emission-based tee and summary of the calculations shall be submitted to the following address: 

New Hampshire Department of Environmental Services 

Air Resources Division 

64 North Main Street 

P.O. Box 2033 

Concord, NH 03302-2033 

ATTN: Emissions Inveritory 

Go The DES shall notify the Permittee of any under payments or over payments of the annual emissxonbased fee in accordance with Env-A 704.05. 

XXVl. Du,ty To Provide Information: 

In accordance with 40 CFR 70.6 (a)(6)(v), upon the DES's written request, the Permittee shall furnish, within 

a reasonable time, any information necessary for determining whether cause exists for modifying, revoking 

and reissuing, or terminating the Permit, or to determine compliance with the Permit. Upon request, the 

Permittee shall furnish to the DES copies of records that the Permit-tee is required to retain 

.by this Permit. The Permittee may make a claim of confidentiality as to any information submitted pursuant 

to this condition in accordance with Part Env-A 103 at the time such information is submitted to DES. The 

DES shall evaluate such requests in accordance with the provisions of Part Env-A 103. 

XXVII. Property Rights: 

Pursuant to 40 CFR 70.6 (a)(6)(iv), this Permit does not convey any property rights of any sort, or any 

exclusive privilege. 
Page 28 

XXVIII. Severability Clause: 

Pursuant to 40 CFR 70.6 (a)(5), the provisions of this Permit are severable, and if any provision of this 

Permit, or the application of any provision of this Permit to any circumstances is held invalid, the application 

of such provision to other circumstances, and the remainder of this Permit, shall not be affected thereby. 

XXIX. Emergency Conditions: 

Pursuant to 40 CFR 70.6 (g), the Permittee shall be shielded from enforcement action brought for 

noncompliance with technology based s emission limitations specified in this Permit as a result of an 

emergency •. In order to use emergency as an affirmative defense to an action brought for noncompliance, 

the Permittee shall demonstrate the affirmative defense through properly signed, contemporaneous operating 

logs, or other relevant evidence that: 

A. An emergency occurred and that the Permittee can identify the cause(s) of the emergency; 

B. The permitted facility was at the time being properly operated; 

Co During the period of the emergency, the .Permittee took all reasonable steps as expeditiously as 

possible, to minimize levels of emissions that exceeded the emissions standards, or other 

requirements in this Permit; and 

The Permittee submitted notice of the emergency to the DES within two (2) business days of the 

time when emission limitations were exceeded due to the emergency. This notice must contain a 

description of the emergency, any steps taken to mitigate emission, and corrective actions taken. 

XXX. Permit Malfunctions and Deviations: 

Pursuant to Env-A 902.02 (rule effective 11/16/89), the Permittee shall report to the DES all 

instances of malfunctions or breakdowns by telephone or fax within 8 hours of such an occurrence. 

This report shall include the description of the malfunction or breakdown itself, including those 

attributable to upset conditions as defined in the Permit, the probable cause of such malfunction or 

breakdown, and any corrective actions or preventive measures taken. Said Permit malfunction or 

breakdown shall also be submitted in writing to the DES and the EPA within fifteen (15) days of 

documentation of the malfunction or breakdown by facility personnel. As defined by Env-A 101.164 

and 40 CFR 60.2, malfunctions are any sudden, infrequent, and not reasonably preventable failure 

of air pollution control equipment, process equipment, or a process to operate in a normal or usual 

Technology based emission limits are those established on the basis of emission reductions achievable with various 

control measures or process changes (e.g., a new source performance standard) rather than those established to attain 

health based air quality standards. 

An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of 

the source, including acts of God, which situation would require immediate corrective action to restore normal operation, 

and that causes the source to exceed a technology based limitation under the permit, due to unavoidable increases in 

emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by 

improperly designed equipment, lack of preventive maintenance, careless or improper operations, operator error, or 

decision to keep operating despite knowledge of any of these things. 
Bo 

Page 29 

manner. Failures that are caused in part by poor maintenance or careless operation are not 

malfunctions. 

Reporting a Permit malfunction or breakdown is not an affirmative defense for action brought for noncompliance. 

In accordance with 40 CFR 70.6(a)(3)(iii)(B), the Permittee shall report to the DES all instances of deviations from Permit requirements, by telephone or fax, within 24 hours of discovery of such deviation. This report shall include the deviation itself, including those attributable to upset conditions, the probable cause of such deviations, and any corrective actions or preventive measures taken. Said Permit deviation shall also be submitted in writing to the DES and the EPA within fifteen (15) days of documentation of the deviation by facility personnel. Deviations are instances where any Permit condition is violated and has not already been reported as a malfunction or an 

emergency pursuant to Section XXIX. of this Permit. 

Reporting a Permit deviation is not an affirmative defense for action brought for noncompliance. 

C:\MYDOCU- \PINETAMW.MMD 

Final Permit Issued September 15, 1999; Minor Permit Modification issued on April 9, 2001 

STATE OF NEW HAMPSHIRE 

Department of Environmental Services 

Air Resources Division 

Permit No: 

Date Issued: 

Title V Operating Permit 

TV-OP.031 Reopened and Reissued October 19, 2001 

September 28, 2000 

This certifies that: 

Indeek Energy Alexandria, LLC 

151 Smith River Road 

Alexandria, NH 03222 

has been granted a Title V Operating Permit for the following facility and location: 

Indeek Energy Alexandria, LLC 

151 Smith River Road 

Alexandria, NH 03222 

Grafton County 

AFS No. 3300900029 

This Title V Operating Permit is hereby issued pursuant to RSA 125-C and Part Env-A 609. This permit has 

been prepared based on information specified in the Title V Operating Permit Application filed with the New Hampshire Department of Environmental Services, Air Resources Division (DES) on January 13, 1998 and 

the supplemental information for the Title V application received on January 18, 2000 under the signature of 

the following responsible official certifying to the best of their knowledge that the statements and information 

therein are true, accurate and complete. 

Responsible Official: 

Bruce Spencer 

Plant Manager 

lndeek Energy Alexandria, LLC 

(603) 744-6355 

Technical Contact: 

Jim Schneider 

Senior Environmental Engineer 

Indeck Energy Services, Inc. 

(847) 520-3212 

This Permit is issued by the DES pursuant to its authority under New Hampshire RSA 125-C and in accordance 

with the provisions of Code of the Federal Regulations 40 Part 70. 

This Title V Operating Permit shall expire on September 30• 2005. 

SEE ATTACHED SHEETS FOR ADDITIONAL PERMIT CONDITIONS 

For the New Hampshire Department of Environmental Services, Air Resource Division 

Director, Air Resources Division 
TABLE OF CONTENTS 

II. 

III. 

Facility Description of Operations 

Permitted Activities 

Significant Activities Identification and Stack Criteria Tables 

l&2 

Page 2 

4-6 

IV. Insignificant Activities Identification 6 

V. 6 

VII. 

Exempt Activities Identification 

Pollution Control Equipment Identification Table 3 

Alternative Operating. Scenarios 

Applicable Requirements 

State-only Enforceable Operational and Emissions Limitations 

Table 4 

Federally Enforceable Operational and Emissions Limitations 

Table 5 

VIII. 

VIII.A. 

VIII.B. 

VIII.C. Emission Reductions Trading Requirements 

VIII.D. Monitoring/Testing Requirements Table 6 

VIII.E. Record keeping Requirements Table 7 

Reporting Requirements Table 8 

Requirements Not Currently Applicable 

Issuance of a Title V Operating Permit 

Title V Operating Permit Renewal Procedures 

Application Shield 

Permit Shield 

Reopening.for Cause 

Administrative Permit Amendments 

VIII.F. 

IX. 

Xo 

XI. 

XII. 

XIII. 

XIV. 

XV. 

XVI. 

6-7 

8-31 

8-11 

12-13 

14 

15-25 

26-28 

29-31 

32 

32 

32 

32-33 

34 

34 

Operational Flexibility 34-35 
Page 3 

XVII. Minor Permit Amendments 35-36 

XVIII. 

XIX. 

XX. 

XXI. 

Significant Permit Amendments 

Title V Operating Permit Suspension, Revocation, or Nullification 

Inspection and Entry 

Certifications 

XXII. Enforcement 

XXIII. Emission Based Fee Requirements 

XXIV. Duty to Provide Information 

XXV. 

XXVI. 

Property Rights 

Severability Clause 

XXVII. Emergency Conditions 

XXVIII. Permit Deviation 

36 ̧ 

36-37 

37-38 

38 

38-39 

39 

39 

39 

4o 

4O 
Page 4 

Facility Specific Title V Operating Permit Conditions 

I. Facility Description of Operations: 

Indeck Energy Alexandria, LLC (Indeck Energy) is located on Smith River Road in Alexandria, New 

Hampshire. The electric generating station is designed to consume wood fuel consisting of sawmill residue 

and/or whole tree chips and "processed wood chip" fuel derived from construction/demolition (C/D) waste 

wood chips to generate 16 MW (gross) of electrical power. No. 2 fuel oil and specification used oil are also 

used as alternative fuels for light off and flame stabilization. 

II. Permitted Activities: 

In accordance with all of the prox;isions of the New Hampshire Rules Governing the Control of Air Pollution 

(effective date 12/31/96) and as revised thereafter, the permittee is authorized to operate the devices and or 

processes identified in Sections III., IV., VI, and VI. within the terms and conditions specified in this Permit. 

Indeck Energy must also obtain a permit from the Department of Environmental Services, Waste 

Management Division for storage and handling of the C/D waste wood chips. Hence, Indeck Energy can not 

accept shipments of this material or begin burning this material until it has received its final Solid Waste 

Management Facility Permit. 

III. Significant Activities Identification and Stack Criteria: 

A. Significant Activity Identification 

The activities identified in the following table (Table 1) are subject to and regulated by this Title V 

Operating Permit: 

E •]•criptioh:•of EmisSiOn:Unit Ex!i•ustStack- aximum 

Number , ]- --• tion ign CaPacity (EU#) •/l • r•.: 

EU1 Boiler Zum Wood-tirol, Boiler wit• a Zurn 

Model SAO-24 Burner 

Stack #1 Maximum Firing Rate of 250 

mmBTU/hr gross heat input 

derived from a mixture of 

sawmill residue and/or whole 

tree chips blended with C/D 

waste wood chips. 

Max Firing Rate of 50 

mmBTU/hr gross heat input 

derived from any combination 

of No. 2 fuel oil or 

specification used oil. 

EU2 -Cooling Tower Circulation Water Cooling Tower Cooling Tower Drift Factor 0.00005 gal 

drift/gal cite 

Circulation Rate 11,600 gpm 

269 Hp operating less than 500 
Page 5 

Table i:=•ignificani•Acti•i•-Idei•tifie•tion • :•,• •i •1 •,:: 

EU3-EG Cummins Emergency Diesel Generator Stack #2 hours operation in any 

consecutive 12 month period; 

maximum fuel firing rate of 13 

gal/hour and max firing rate of 

1.8 mmBTU/hr 

1. Based on facility operations, fuel fed to the Boiler shall consist of any of the following: 

no Whole tree wood chips at approximately 50% moisture (approximately 9.0 

mmBTU/ton wet basis); 

Clean processed wood fuel (approximately 17.4 mmBTU/ton dry basis for 

"processed wood chips" derived from C/D wood waste); 

Clean processed wood fuel and whole tree wood chips at approximately 50% 

moisture; 

do Clean processed wood fuel and/or whole tree wood chips and specification used oil at 

a maximum of 1.2% sulfur by weight or No. 2 fuel oil at maximum of 0.4% sulfur by weight; or 

Specification used oil with a maximum of 1.2% sulfur by weight or No. 2 fuel oil 

with a maximum of 0.4% sulfur by weight for startup and flame stabilization. 

See the State-only and Federally Enforceable Operational and Emissions Limitations found in 

Sections VIII.A. and VIII.B. for limits on the amounts of the individual types of fuel fed to 

the Boiler. 

B. Stack Criteria 

The following stacks for the above listed significant devices at this facility shall discharge vertically 

without obstruction (including rain caps) and meet the following criteria in accordance with the stateonly air pollution dispersion modeling requirements specified in Env-A 606. 

Stack #1 EUl-(Boiler) 150 

Stack #2 EU3-Emergenc• 9 

5.0 

0.3 

Clean processed wood fuel is considered to be fuel that exhibits fuel characteristics equivalent to "whole 

tree wood chips" and "sawdust" with respect to the ultimate and proximate analysis of the fuel 
Page 6 

IV. 

Wt 

VI. 

Preauthorized changes to the state-only requirements pertaining to stack parameters (set forth in 

this permit) shall be permitted only when an air quality impact analysis meeting the criteria of 

Part Env-A 606 is performed either by the facility or by the DES (if requested by the facility in 

writing) in accordance with the "NHARD Policy and Procedure for Air Quality Impact 

Modeling". All air modeling data shall be kept on file at the facility for review by the DES upon 

request. 

Insignificant Activities Identification: 

All activities at this facility that meet the criteria identified in the New Hampshire Rules Governing the 

Control of Air Pollution Part Env-A 609.03(g), shall be considered insignificant activities. Emissions 

from the insignificant activities shall be included in the total facility emissions for the emission-based 

fee calculation described in Section XXIII. of this Title V Operating Permit. 

Exempt Activities Identification: 

All activities identified in the New Hampshire Rules Governing the Control of Air Pollution Part Env-A 

609.03(c) shall be considered exempt activities and shall not be subject ,to or regulated by this Title V 

Operating Permit. 

Pollution Control Equipment Identification: 

The devices and/or processes identified in Table 3 below are considered pollution control equipment for 

the identified emissions unit. 

PollutionControl•i•--- DesCriptiono•uipmen ,,--,: k_-'L•: •I•u# 

PC 1-Multiclone Multiclone primary particulate control for the EU1 Bioiler 

PC2-ESP Electrostatic Precipitator (ESP) secondary particulate control for the 

EU1 Boiler 

EU1-Boiler 

EU1-Boiler 

Ao All equipment, facilities and systems installed and used to achieve compliance with the terms 

and conditions of this permit shall at all times be maintained in good working order and shall be 

operated as efficiently as possible so as to minimize air pollutant emissions and meet all 

applicable air pollutant emission limits. These controls shall be fully operational upon facility 

startup and shall not be bypassed during startup, operation, or shutdown of the steam generating 

unit. 
VII. 

Page 7 

The pollution control equipment shall be maintained regularly, in accordance with the 

manufacturer's Operation and Maintenance (O&M)manual and monitored based on the 

schedules as described in Section VIII.D. 

Co The Multiclone shall be operated in series at all times with the ESP unit while the Boiler is in 

operation. 

Alternative Operating Scenarios: 

Indeck Energy did not propose any alternative operating scenarios. 
Page 8 

VIII. Applicable Requirements: 

A. State-only Enforceable Operational and Emissions Limitations: 

Indeck Energy shall be subject to the state-only operational and emission limitations identified in 

Table 4 below: 

Table 4 State-only Enforceable Operational and Emission Limitations 

1. Env-Wm 403 Boiler 

2. Env-Wm 807.02(b) Boiler 

3. Env-Wm 80%06 Boiler 

Env-Wm 807.10 

4. Env-A 1002.03 Facility Wide 

The used oil burned in the Boiler as an auxiliary fuel shall not exhibit any of the 

hazardous waste characteristics specified ih Env-Wm 403. 

The used oil must be below the following maximum allowable concentrations in 

order to be combusted in the Boiler: 

Maximum Allowable Concentrations in Used Oil: 

arsenic 5.0 ppm maximum 

cadmium 2:0 ppm max!mum 

chromium 10.0 ppm maximum 

lead 2 60.0 ppm maximum 

total halogens 1000.0 ppm maximum 

PCB's < 2 ppm 

sulfur 1.6 lbs/mmBtu, 1.2% sulfur by weight 

flash point 100 deg. F minimum 

Used oil which does not meet the specifications above for 0n-spec used oil shall 

not be burned in the Boiler. Indeck Energy, must contact the New Hampshire 

Department of Environmental Services Waste Management Division for 

alternative options. 

The New Hampshire Department of Environmental Services Waste Management 

Division and U.S. Environmental Protection Agency must be notified and 

compliance achieved pursuant to Part Env-Wm 807.06 Standards for Generator's 

of Used-Oil Being Recycled and Part Env-Wm 807.10 Standards for Burners of 

Used-Oil Fuel. 

Indeck Energy shall take precautions to prevent, abate, and control the emissions 

of fugitive dust for those activities contained in Env-A 1002.02. Such 

precautions shall include wetting, covering, shielding, or vacuuming. 

5. Env-A 305 Boiler To operationally control CO emissions in accordance with Env-A 305, Indeck 

shall comply with the following operational limitations: 

Indeck shall control CO emissions by varying the total quantity of input 

combustion air and/or the lo•al distribution of that air into the Boiler. The 

amount of combustion air required to optimize the Boiler efficiency and reduce 

CO emissions is dependent on the wood moisture content and the type of wood, 

among other factors. The steam generating unit shall be equipped with a fuel 

2 The limit for lead is 60 ppm due to modeling violations predicted with the 100 ppm level allowed in the 

specification used oil criteria in the DES Waste Management Rules. 
Table 4 State-only Enforceable Operational and Emission Limitations 

Page 9 

6. Env-A 1305.01(a) 

7. Env-A 1305.02 

8. Env-A 1403.01 

9. Env-A 1403.02(a) 

10. Env-A 1403.02(b) 

11. Env-A 1404.01(d) 

12. Env-A 1405.02 

13. End-A1405.03 

14. "Env-A1406.01 

15. Env-A 2003.04(d) 

16. 

Facility Wide 

Facility Wide 

Facility Wide 

Facility Wide 

Facility Wide 

Facility Wide 

Facility Wide 

Facility Wide 

Facility Wide 

Boiler 

Env-A Boiler 

distribution, overfire air and undergrate air control systems for optimum NOx, 

CO, and hydrocarbon emission control. 

New or modified devices, new or modified area sources, and existing devices or 

area sources for which new applications for permits are filed that have the 

potential to emit, in any amount, substances that meet the criteria of Env-A 1301 

shall be subject to Env-A 1300, until such time as the Env-A 1400 requirements 

supersede the Env-A 1300 requirements. (As outlined below) 

Air quality impact analysis of devices and area sources emitting substances 

meeting the criteria of Env-A 1301 shall be performed in accordance with the 

"DES Policy and Procedure for Air Quality Impact Modeling" or other 

comparable dispersion modeling methods approved by EPA. 

In accordance with Env-A 1403.01, new or modified devices or processes 

installed after May 8, 1998, shall be subject to the requirements of Env-A 1400. 

In accordance with 1403.02(a), all existing unmodified devices or processes 

which are in operation during the transition period ending three years from May 

8, 1998 (May 8, 2001), shall Comply with either Env-A 1300 or Env-A 1400. 

In accordance with Env-A 1403.02(b), all existing devices or processes in 

operation after the transition period ending three years from May 8, 1998 (May 

8, 2001), shall comply with Env-A 1400. Env-A 1300 will no longer be in effect. 

In accordance with Env-A 1404.01(d), documentation for the demonstration of 

compliance shall be retained at the site; and shall be made available to the DES 

for inspection. 

In accordance with Env-A 1405.02 the owner of an existing device or process 

requiring a permit modification under chapter Env-A 1400 shall submit to the 

DES no later than one year prior to the end of the transition period (May8, 

2000), an application for a modification to a title V permit in accordance with 

Env-A 609.18, and a request to the DES to perform air dispersion modeling. 

In accordance with Env-A 1405.03 the owner of an existing device or process 

requiring a permit under Env-A 1300 shall submit to the DES no later than one 

year prior to the end of the transition period (May 8, 2000), a compliance plan identifying how the device or process will comply with chapter Env-A 1400 by 

the end of the transition period. The compliance plan shall contain the daies 

when the information required in Env-A 1405.02 will be filed with the DES. 

In accordance with Env-A 1406.01 the owner of any device or process which 

emits a regulated toxic air pollutant shall determine compliance with the ambient 

air limits by using one ofth e methods provided in Env-A 1406.02, Env-A 

1406.03, or Env-A 1406.04. Upon request, the owner of any device or process 

which emits a regulated toxic air pollutant shall provide documentation of 

compliance with the ambient air limits to the DES. 

Exceedances of the opacity standard shall not be considered violations of this 

part if the facility demonstiates to the division that such exceedances were the 

result of the adherence to good boiler operating practices which, in the long term, 

results in the most efficient or safe operation of the boiler. 

Opacity exceedances experienced during periods of cold startup of a boiler over 
Page 10 

Table 4 State-only Enforceable Operational and Emission Limitations 

2003.04(e)(2) 

17. Env-A 2003.04(f) 

18. 

Boiler 

a continuous period of time resulting in efficient heat-up and stabilization of its 

operation and the expeditious achievement of normal operation of the unit shall 

not be considered violations. 

Exceedances of the opacity standard shall not be considered violations of this 

part if the source demonstrates to the DES that such exceedances were the result 

of the occurrence of an unplanned incident in which the opacity exceedance was 

beyond the control of the operator and in response to such an incident, the 

operator took appropriate steps in conformance with good boiler operating practice to eliminate the excess opacity as quickly as possible. 

Compliance Demonstration Requirements for the EU2 Cooling Tower State-only Enforceable 

In accordance with Env-A 1400, prior to changing cooling water treatment chemicals, Indeck shall 

evaluate the impact of the proposed chemicals on the 24-hour and annual de minimus limits of the DES 

Air Toxics List. If the impact exceeds the de minimus 24-hour or annual levels, Indeck shall notify the 

DES in writing of the proposed chemical changes. Written approval from the DEs shall be received prior 

to making the chemical changeif the de minimus levels are exceeded. If the impact does not exceed the de 

minimus levels, Indeck may make the chemical change and shall keep the records of the impact analysis in 

the facility files in accordance with the Record keeping requirements of Section X.D. of this permit. 

The following equations shall be used to evaluate the impact of cooling water chemicals on the 24-hour 

and annual de minimus levels. This equation shall be used for each chemical used in the cooling water that 

is included on the DES Air Toxics List. Also, this equation shall be used to estimate particulate emissions 

from both chemical additives to the water and total dissolved solids contained in the water for emissionbased fees as described in Section XXV. of this permit. 

24-hour Emissions (lb/hr) (DR)*(Hourly CR)*(8.34 lb/gal)*(C) 

Example Calculation: 24-hour emissions of total dissolved solids (TDS) in (lb/hr) 

(0.00005 gal/gal)*(696,000 gal/hr)*(8.34 lb/gal)*(1200 ppmw TDS) 

lxl06 

0.35 lb/hr TDS 

Annualized Emissions (lb/yr) (24-hour Emissions, lb/hr)*(Operating hours/year) 

Example Calculation: Annualized emissions of TDS (lb/yr) = (0.35 lb/hr)*(8760 hrs/yr) 

3,051 lbs/¥r TDS 

Where: DR drift rate for cooling tower (based on manufacturer's data for facility cooling tower), 

gal drift/gal circulation water (0.00005 gal/gal) 

Hourly CR water circulation rate, gal/hr 

C concentration of chemical of interest (or total dissolved solids 

concentration) in circulation water, ppmw (use raaximum potential 

concentration for de minimus impact evaluation and average or actual 

data for emission-based fee calculations). 
Page 11 
Page 12 

VIII. Applicable Requirements: 

B. Federally Enforceable Operational and Emissions Limitations: 

The Permittee shall be subject to the federally enforceable operational and emission limitations 

identified in Table 5 below: 

Table 5 Federally Enforceable Operational and Emission Limitations 

1. 40 CFR 60 Boiler 

Subpart Db 

§60.44b(c), 

RSA.125-C:6, 

RSA 125-C:11, & 

Env-A 606.04 

RSA 125-C:6, 

RSA 125-C:11, & 

Env-A 606.04 

RSA 125-C:6, 

RSA 125-C:11, & 

Env-A 606.04 

Boiler 

Boiler 

To allow for an exemption of Indeck from.the NOx emission limitation in 40 

CFR 60, Subpart Db, and to satisfy the DES modeling requirements, the 

maximum consumption of No. 2 fuel oil and specification used oil, at maximum 

0.4% and 1.2%sulfur by weight, respectively, combined by the Boiler shall be 

limited to 1,080,000 gallons during any consecutive 12-month period with no 

more than 90,000 gallons during any consecutive 30-day period with a nitrogen 

content of 0.30 weight percent or less (equivalent to 12,600 mmBtu during any 

consecutive 30-day period). The maximum gross heat input rate of No. 2 fuel oil 

or specification used oil at a maximum of 0.4% and 1.2% sulfur by weight, 

respectively, tothe Boiler shall be limited to 50 mmBtaghr. This is equivalent to 

367 gallons per hour on an annual average of No. 2 fuel oil or specification used 

oil based on a heating value of 140,000 BTUs/gallon. Also, Indeck shall not 

exceed 3,000 gallons of these fuels in any consecutive 24-hour period. 

Based on equipment design, the maximum operating rate of the Boiler shall be 

limited to a total of 250 million BTU per hour (mmBtu/hr) gross heat input. This 

is the equivalent of 161,000 pounds per hour (lbs/hr) Of steam production as 

averaged over any consecutive 24-hour period at 850 degrees F and 925 PSIG, 

assuming a boiler efficiency of 70 • and boiler feedwater temperature of 430 

degrees F. 

Based on the equipment design, the maximum gross heat input rate of any 

combination of No. 2 fuel oil and specification used oil to the Boiler shall be 

limited to 50 mmBtu/hr during all phases of operation, including startup. 

Based on DES modeling results, Indeck Shall not use more than 3,000 gallons of 

No. 2 fuel oil or specification used oil in any consecutive 24-hour period. Also, 

Indeck shall not exceed 367 gal/hr of these fuels for more than eight consecutive 

hours. These limits are applicable during all phases of operation, including 

Startup. 

Based on the DES modeling results, the maximum monthly gross heat input rate 

Of any.combination of No. 2 fuel oil and used specification 0il to the Boiler shall 

be limited to 12,600 mmBtu during any consecutive 30-day period. This is 

equivalent to a total of 90,000 gallons during any consecutive 30-day period 

based on 140,000 BTU/gal. Since these modeling limits are less than the 10% 

limit of 40 CFR 60, Subpart Db, an exemption of Indeck from the NOx emission 

limitation found in 40 CFR 60, Subpart Db will be allowed. 

Based on equipment design, operating 36• operating days per year, and air 

dispersion modeling limiting C/D derived wood chips to less than or equal to 

75% of the total heat input when using a blend of sawmill residue/whole tree 

wood chips and C/D derived chips, Indeck Energy shall be limited to a maximum 
Table 5 Federally Enforceable Operational and Emission Limitations 

Page 13 

of 94,397 bone dry tons C/D derived chips during any consecutive 12 month 

period. In addition, Indeck Energy shall limit the use of C/D derived chips such 

that the total heat input rate derived from such source is less than or equal to 75% 

of the total heat input rate derived from M1 C/D derived wood chips plus whole 

tree chips/sawmill residue during any consecutive 12 month period. For 

compliance demonstration requirements, see Monitoring/Testing Requirements 

listed in Section VIII.D. 

Env-A 

1211.020)(1 ) & 

Env-A 

1211.020)(2) 

5. Env-A 1211.04(d) 

& Env-A 

1211.05(d)(5) 

EG 

Boiler 

6. Env-A 1604.01(a) Facility Wide 

7. Env-A 2003.02& 

40 CFR 60 

SubpartDb 

§60.43b(0 

Boiler 

The emergency generator shall be limited to less than 500 hours of operation 

during any consecutive 12-month period, and the combined theoretical potential 

emissions of NOx from all such generators are limited to less than 25 tons for any 

consecutive 12-month period. 

The Boiler, firing wood fuel or capable of firing a combination of wood fuel and 

oil and equipped with a traveling grate, shall comply with the oxides of nitrogen 

(NOx) Reasonably Available Control Technology (RACT) emission limit of 0.33 

pounds per million BTU (lb/mmBtu), based on a 24-hour calendar day average. 

The sulfur content of No. 2 oil, off-road diesel oil, and used oil bumedat this 

facility shall not exceed 0.40 percent sulfur by weight. 

In accordance with Env-A 2003.02 and 40 CFR Part 60, Subpart Db, Indeck 

Energy shall not cause or allow average opacity from fuel burning devices 

installed after May 3, 1970 in excess of 20 percent for any continuous 6-minute 

period in any 60-minute period. The Boiler may apply no more than one of the 

following exemptions in accordance with Env-A 2003.04(a): 

8. 40 CFR 

52.21 (b)(1)(i)(b) 

9. 40 CFR 

52.21(b)(1)(i)(b) 

10. RSA 125-C:6, RSA 

125-C:11, and 

Env-A 606.04 

11. 40 CFR 60 

Subpart Db 

§60.43b(c)(1) 

Facility Wide 

Facility Wide 

Boiler 

Boiler 

During periods of startup, shutdown, and malfunction, average opacity 

shall be allowed to be in excess of 20 percent for one period of 6 

continuous minutes in any 60-minute period; or 

During periods of normal Operation, soot blowing, grate cleaning, and 

cleaning of fires, average opacity shall be allowed to be in excess of 20 

percent, but not more than 27 percent, for one period of 6 continuous 

minutes in any 60-minute period. 

To avoid the requirements of the federal Prevention of Significant Deterioration 

(PSD) regulation 40 CFR 52.21(b)(1)(i)(b), the combined Nox emission rate for 

the facility fuel burning devices shall be limited to 57.0 pounds per hour (lbs/hr) 

average for any consecutive 365-day period. 

To avoid the requirements of the federal Prevention of Significant Deterioration 

(PSD) regulation 40 CFR 52.21(b)(1)(i)(b), the comt•ined CO emission rate for 

the facility fuel burning devices shall be limited to 57.0 ltmund• • hour (lbs/hr) 

average f• any consecutive 365-day period. 

The carbon monoxide (CO) emission rate for the Boiler shall be limited to 125 

lb•/hr for each calendar day average, as calculated on the CEM syste m or using 

the calculation shown in Section VIII.D., Item 6. of this permit. 

The PM emission rate for the Boiler shall be limited to 0.10 lb/mmBtu heat 

input. 
Page 14 

VIII. C. Emission Reductions Trading Requirements 

The Permittee did not request emissions reductions trading in its operating permit application. At this 

point, DES has not included any permit terms authorizing emissions trading in this permit. All emission 

reductions trading, must be authorized under the applicable requirements of either Env-A 3000 (the 

"Emissions Reductions Credits (or ERCs) Trading Program") or Env-A 3100 (the "Discrete Emissions 

Reductions (or DERs) Trading Program") and 42 U.S.C. §7401 et seq. (The "Act"), and must be 

provided for in this Permit. 
VIII. D. Monitoring/Testing Requirements 

The Permittee is subject to the monitoring/testing requirements as contained in Table 6 below: 

Page 15 

Boiler Initial (1) As a condition of this pe•it, Indeck Energy shall 

Performance 

Test 

conduct USEPA method stack tests at maximum load 

conditions while burning 75% C/D wood chips and 

25% whole tree. chips for the following pollutants: 

a. NOx 

b. PM10 

c. CO 

d. Non-methane VOC's 

e. As, Cd, Cr, Pb, Mn, Hg, Zn 

(2) The compliance tests shall be conducted and the 

results reported in accordance with the test methods 

set forth in 40 CFR 60, Subpart A, Section 60.8 and 

Appendix A. The following test methods or DES 

approved alternatives shall be used: 

a. Method and 2, to determine the 

exit velocity of stack gases from 

stationary sources. 

b. Method 3 or 3A, to determine 

carbon dioxide, oxygen, excess air, 

and molecular weight (dry basis) of 

stack gases from stationary sources. 

c. Method 4, to determine moisture 

content (volume fraction of water 

vapor) of stack gases from 

stationary sources. 

d. Method 5, to determine particulate 

emissions from stationary sources. 

e. Method 7E, to determine nitrogen 

oxide emissions from stationary 

sources (Instrumental Analyzer 

Procedure). 

f. Method 9, for visual determination 

of the opacity of emissions from 

stationary sources. 

g. Method 10, to determine carbon 

monoxide emissions from stationary 

sources or an alternative method 

approved by the DES in advance. 

h. Method 25 or 25Aor 25B, 40 CFR 

60, Appendix A, to determine nonmethane organic concentrations in 

emissions from stationary sources. 

i. Method 29, 40 CFR 60, Appendix 

A, to determine As, Cd, Cr, Pb, Mn, 

Hg, and Zn concentrations in 

emissions from stationary sources. 

Once, within 

60 days after 

achieving the 

maximum 

production 

rate, but not 

later than 180 

days after 

initial startup 

of the affected 

emissions unit 

and at other 

times upon 

request by the 

DES or EPA 

Env-A 802 

Federally 

Enforceable 
Page 16 

Boiler Initial 

Performance 

Test 

(Continued) 

(3) At least 30 days prior to the cormnencement of 

testing, a pretest report presenting the following 

information shall be submitted to the DES: 

a. Calibration methods and sample 

data sheets; 

b. Test methods to be used; 

c. Pre-test preparation procedures; 

d. Sample collection and analysis 

methods; 

e. Process data to be taken during the 

tests and frequency of data 

collection; and 

f. A complete test program 

description. 

(4) At least 15 days prior to commencement of 

testing, Indeck Energy and any contractor that Indeck 

Energy may retain for testing, shall participate in a 

pretest conference with a DES representative. 

(5) Within 30 days after completion of testing, Indec.k 

Energy shall submit a test repOrt to the DES. 

(6) Emission testing shall be observed by a DES 

representative. 

(7) Any compliance test results, determined following 

40 CFR 60, Subpart A, Section 60.8, which show 

exceedances of any emission limits stated in this 

permit shall be violations.. 

Once, within 

60 days after 

achieving the 

maximum 

production 

rate, but not 

later than 180 

days after 

initial startup 

of the affected 

emissions unit 

and at other 

times upon 

request by the 

DES or EPA 

Env-A 802 

Federally 

Enforceable 

Facility Allows for Conduct an annual inspection of each stack and fuel Annually 40 CFR 

Stacks and adequate burning device. Inspections shall include 70.6(a)(3 ) 

Boiler dispersion of documenting any leaks, holes, rusting and/or disrepair Federally 

HAPs and of stacks, and the manufacturer's recommended Enforceable 

other periodic physical, mechanical, and electrical system 

regulated checks for the fuel burning equipment. Records of 

pollutants inspections and subsequent maintenance conducted as 

a result of the annual inspections shall be kept on file 

at the Facility for review by the DES and/or EPA 

upon request. 

Boiler Used Oil Indeck Energy shall require all suppliers of used oil to Prior to Env-Wm 

Analysis provide with each delivery, a fuel analysis certifying burning any 807.02(b) 

compliance with Env-Wm 807.02 (Maximum load of used 

Allowable Concentrations in Used Oil, listed below) oil in the 

and the sulfur content limit of 1.2 percent by weight.. Boiler 

This data shall be retained by the facility in 

accordance with record keeping requirements 

described in Section VIII.E. and reported in 

accordance with Section VIII.F. of this permit• The 

used oil must be below the following maximum 

allowable concentrations in order to be burned in the 

Boiler: 

3 The limit for lead is 60 ppm due to modeling violations predicted with the 100 ppm level allowed in the 

specification used oil criteria in the DES Waste Management Rules. 
Page 17 

PC1- 

Multiclone 

Maximum Allowable Concentrations in Used Oil: 

arsenic 5.0 ppm maximum 

cadmium 2.0 ppm maximum 

chromium 10.0 ppm maximum 

lead 60.0 ppm maximum 

total halogens 1000.0 ppm maximum 

PCB's < 2 ppm 

sulfur 1.6 lbs/mmBtu, 1.2% 

sulfur by weight 

flash point 100 deg. F minimum 

Used oil which does not meet the specifications above 

for onrspec used oil shall not be burned in the Boiler. 

Indeck Energy must contact the New Hampshire 

Department of Environmental Services Waste 

Management Division for alternative options. 

Periodic 

Monitoring 

(Total 

Suspended 

Particulate 

Control) 

ao 

bo 

Conduct monitoring of pressure differential 

across the PC1 Multiclone unit every two 

hours. An acceptable pressure differential 

shall be in accordance with standard 

operating practices and manufacturer's 

recommended operating parameters, and 

shall be maintained between 3 and 7 inches 

of water column. 

Pressure differential readings shall be 

recorded on standard forms and kept on file 

at the facility for review by the DES upon 

request. The standard forms shall include the 

acceptable operating parameters for quick 

reference by facility personnel. 

Facility personnel shall conduct a daily 

inspection for visible emissions of the PC1 

Multiclone unit to observe leaks using EPA 

Method 22, 40 CFR Part 60, Appendix A. If 

a leak(s) is observed, facility personnel shall 

take immediate steps to repair the.leak(s). 

Daily observations, maintenance, and repairs 

performed on the unit shall be recorded in 

the log book. 

C° 

d° 

During down-time maintenance periods, 

facility personnel shall inspect inlet and 

oUtlet vanes and boots for any build up of 

caked dust. All caked dust shall be removed 

during each down-time maintenance period. 

Observations of operating parameters outside 

of the standard operating practices included 

in this permit shall be recorded, investigated, 

and corrected immediately. If this results in 

Every 2 hours Env-A 

and as 806.01 (4) 

specified and 

40 CFR 

70.6(a)(3) 

Federally 

Enforceable 
Page 18 

PC2-ESP Periodic 

Monitoring 

(Total 

Suspended 

Particulate 

Control) 

a permit limit exceedance, Indeck personnel 

shall contact the DES within 8 hours in 

accordance with Section XXVIII.. of this 

permit. 

In accordance with Indeck's O&M manual and 

standard operating practices for this equipment, on a. 

bi-hourly basis, facility personnel shall: 

i. Check and record the primary voltage and 

pressure drop readings on the PC2 ESP. 

The primary voltage shall be maintained 

between 45 and 55 kva and the pressure drop 

across the PC2-ESP shall be maintained 

between 0 and 2 inches of water column. 

Voltage or pressure drop readings outside 

these ranges indicate a malfunction with the 

PC2- ESP and the operator shall correct the 

malfunction immediately. 

ii. The facility operator shall respond to all 

equipment alarms immediately. 

iii. Bi-hourly monitoring data shall be recorded 

daily on standard forms and kept on file at 

the facility for review by the DES upon 

request. The standard forms shall include the 

acceptable operating parameters for quick 

reference by facility personnel. 

iv. Observations of operating parameters outside 

of the standard operating practices included 

in this permit shall be recorded, investigated, 

and corrected immediately. If this results in 

a permit limit exceedance, Indeck personnel 

shall contact the DES within 8 hours in 

accordance with Section XXVIII. of this 

pemait. 

Daily Monitoring/Testing Requirements 

i. The PC2-ESP shall be inspected at least once 

each shift. The casing, piping, and ducts 

shall be inspected for leaks, abnormal nois•, 

hot spots, and fires. Local instrumentation 

shall be monitored for normal values. The 

local control panel shall be monitored for 

proper indication of normal Values and 

alarms. 

ii. Observations of operating parameters outside 

of the standard operating practices included 

in this permit shall be recorded, investigated, 

and corrected immediately. If this results in 

a permit limit exceedance, Indeck personnel 

shall contact the DES within 8 hours in 

accordance with Section XXVIII. of this 

permit. 

Every 2 hours 

and daily as 

specified 

Env-A 

806.01(4) 

and 

40 CFR 

70.6(a)(3) 

Federally 

Enforceable 
Page 19 

6o Boiler 

Boiler 

CEM 

Requirements 

CEM 

Requirements 

(Continued) 

Indeck Shall install, maintain, and operate the 

following CEM systems in the EU1-Boiler exhaust 

piping: 

1. Opacity CEM 

The opacity CEM system shall meet the 

requirements of 40 CFR Part 60, Appendix 

B, Performance Specification and Env-A 

805 (rule effective 11/15/92). Determination 

of compliance with the opacity limits 

established Sections VIII.A. and VIII.B. in 

this permit shall be made by the plant opacity 

CEM or visible emission readings taken once 

per shift following the procedures specified 

in 40 CFR Part 60, Appendix A, Method 9. 

Calculations shall be performed as specified 

below in subitem 7. Calculations. 

2. NOx CEM 

The NOx CEM shall meet the requirements 

of 40 CFR Part 60, Appendix B, 

Performance Specification 2 and Env-A 805 

(rule effective 11/15/92). Determination of 

Compliance with the NOx emission limits 

established in Section VIII.B. of this permit 

shall be made by the plant NOx CEM. The 

NOx emission rate shall be calculated daily 

as the average of the calendar day averages 

as calculated on the plant NOxCEM. 

Calculations shall be performed as specified 

in subitem 7. Calculations. 

3. CO CEM 

The CO CEM system shall meet the 

requirements of 40 CFR Part 60, Appendix 

B, Performance Specification 4 and Env-A 

.805 (rule effective 11/15/92). Detemaination 

of compliance with the CO emission limits 

established in Section VIII.B of this permit 

shall be made by the plant CO CEM. The 

CO emission rate shall be calculated daily as 

the average of the calendar day averages as 

calculated on the plant CO CEM. 

Calculations shall be performed as specified 

in subitem 7. Calculations. 

Carbon Dioxide (CO2) or Oxygen (Oz) CEM 

The CO2 or 02 CEM system shall meet the 

requirements of 40 CFR Part 60, Appendix 

B, Performance Specification 3 and Env-A 

805 (rule effective 11/15/92). 

4. 

5. Volumetric Flow CEM 

The stack volumetric flow measuring device shall 

meet all of the requirements of 40 CFR Part 60, 

Appendix B, Performance Specification 6. The stack 

flow monitor shall have an automatic blow-back purge 

As specified 

As specified 

Env-A 805.02 

& 

40 CFR Part 

70.6(a)(3) 

Federally 

Enforceable 

Env-A 805.02 

& 

40 CFR Part 

70.6(a)(3) 

Federally 
Page 20 

6. Boiler 

system installed and activated during 'all'iil•'es of 

boiler operation. The stack volumetric flow 

measuring device combined with the concentration 

CEM equipment for CO and NOx shall be used to 

calculate mass emission rates for comparison with the 

emission standard specified in permit conditions listed 

in Sections VIII.A. and VIII.B. The stack volumetric 

flow monitor shall also meet the following 

requirements: 

a. All differential pressure flow 

monitors shall have an automatic 

blow-back purge system installed, 

and in wet stack emissions shall 

have the capability for drainage of 

the sensing lines. 

b. The stack flow monitoring system 

shall have the capability for on-line 

manual transducer calibration and 

for a zero check. 

c. The stack flow monitoring system 

shall be capable of displaying the 

individual parameters used in the 

stack flow calculation. For 

example, a differential pressure 

monitoring system shall be able to 

display instantaneous values of 

differential pressure, stack 

temperature, and relevant constants 

used in the calculation which reflect 

the static pressure assumed, gas 

molecular weight assumed, and the 

pitot tube coefficient utilized. 

6. Steam Flow CEM 

Indeck shall install, maintain, and operate a 

continuous steam flow rate 

monitoring/recording system which shall 

meet all applicable ASME specifications. 

Calibration of the steam flow transducer and 

inspection of the orifice plates shall occur at 

least once annually. If adequate straight 

length of piping is not available, then in lieu 

of a measuring system that meets ASME 

specifications, Indeck may use a steam flow 

rate monitoring system that can be calibrated 

by instruments installed, maintained, and 

calibrated per ASME specifications, or by 

other methods approved by the DES. 

CEM 

Requirements 

(Continued) 

Calculations: 

CEM calendar day averages shall be 

calculated as follows: 

i. Calendar Day average (sum of all 

valid hourly lb/hr averages for the 

As specified 

Enforce•bi'e 

Env-A 805.02 

& 

40 CFR Part 

70.6(a)(3) 

Federally 
Page 21 

Boiler CEM 

Requirements 

(Continued) 

bo 

calendar day)/(24 hours of CEM 

system downtime for the day); 

ii. Calendar day averages shall only be 

valid for days with 18 or more valid 

hours of CEM data; 

iii. A valid hour of CEM data shall be 

defined as a minimum of 45 minutes 

collection of CEM readings taken in 

a calendar hour; and 

iv. Hours of CEM system downtime 

shall be defined as the number of 

calendar hours when the CEM 

system has not collected data or is 

out-of-control for greater than 15 

minutes for any reason (i.e., audits, 

CEM system calibration, CEM 

system failures, etc.). 

CEM consecutive 365-day averages shall be 

calculated as follows: 

i. Consecutive 365-day average 

(sum of all valid calendar day 

averages for the 365-day 

period)/(365 days O f CEM system 

downtime); and 

ii. Days of CEM system downtime 

shall be defined as the number of 

calendar days when the CEM 

system has collected less than 18 

valid hours of CEM data. 

Hours or days when the CEM system has 

been intentionally shutdown when the facility 

is not operating shall not be counted as CEM 

system downtime. 

Indeck shall be subject to all of the CEM 

requirements of Env-A 805 (rule effective 

11/15/92) which shall include, but not be 

limited to: quarterly audit requirements, 

excess emission report requirements, quality 

control written procedure requirements for 

gaseous CEM monitors, and record keeping 

requirements. The specific record keeping 

and reporting requirements are described in 

Sections VIII.E. and VIII.F. of this permit. 

Indeck shall continuously monitor and record 

data from the gaseous CEM system during 

all periods of operation, including periods of 

startup, shutdown, malfunctions, or 

emergency conditions, except when the stack 

flow is less than 23,0.00 wet SCFM. The 

opacity CEM shall be continuously 

As specified 

Enforceable 

Env-A 805.02 

& 

40 CFR Part 

70.6(a)(3) 

Federally 

Enforceable 
Page 22 

Boiler Periodic 

Monitoring 

Chip Testing 

Boiler Periodic 

Monitoring 

Chip Testing 

10. 

monitoring and recording data during all 

periods of operation, regardless of the stack 

flow rate. 

Excess emissions indicated by the CEM 

system shall be considered violations of the 

applicable emission limit for purposes of this 

permit, except wheye Indeck can adequately 

demonstrate to the DES that the recorded 

exceedance resulted from a CEM 

malfunction. 

Indeck Energy shall collect a separate weekly 

composite chip sample from each supplier of C/D 

chips and each supplier of whole tree chips or sawmill 

residue chips from each delivery of such material. 

Indeck Energy shall then conduct testing to determine 

moisture content of the composite chip samples and 

record the results. 

Indeck Energy shall collect a separate monthly 

composite chip sample from each supplier of C/D 

chips and each supplier of whole tree chips or sawmill 

residue chips from each delivery of such material. 

Equal proportions from four successive weekly 

composite samples may be used for the monthly 

composite samples from each supplier. Indeck 

Energy, or a certified laboratory selected by Indeck 

Energy, shall conduct the following testing on 

composite samples: 

(A) Ultimate/proximate analysis including: 

1. Heating value (Btu/lb) 

2. Elemental analyses of the following 

expressed as a percent by weight: 

hydrogen total carbon 

ash fixed carbon 

sulfur volatiles 

nitrogen chlorine 

oxygen (by difference) 

alkalis as sodium oxide 

3. Test methods to be used are ASTM 

Methods D3176, D3173, and D2361. 

(B) Elemental Metals Analysis Determine the. 

ppm by weight of the following: 

arsenic mercury 

barium selenium 

cadmium silver 

chromium lead 

copper nickel 

titanium zinc 

Weekly 

composite 

chip samples 

from each 

supplier 

Monthly 

composite 

chip samples 

from each 

supplier 

Env-A 

806.01(4) 

& 

40 CFR Part 

70.6(a)(3) 

Federally 

Enforceable 

Env-A 

806.01(4) 

& 

40 CFR Part 

70.6(a)(3) 

Federally 

Enforceable 
Page 23 

Facility 

Wide. 

Fuel Sulfur 

Content 

Verification 

(c) 

Each sample will be prepared in accordance 

with ASTM Part 05.05, Method D3683 and 

tested in a manner to give the appropriate 

results of total metal content. 

Phenols Phenols will be determined in ppm 

by weight concentration by 

USEPA Method 8270 

(SW-846). 

(D) Toxicity Characteristic Leaching Procedure 

(TCLP) TCLP will be run from ash 

generated at the testing laboratory from the 

above analyses in (A) 2. of composite 

samples for each of the following elements: 

arsenic mercury 

barium selenium 

cadmium silver 

chromium lead 

The operator shall conduct testing using the 

appropriate ASTM method or retain certified delivery 

tickets provided by the supplier which contain sulfur 

content of the delivered fuel. Sulfur contents 

documented on delivery tickets shall b.e obtained 

using appropriate ASTM Methods. Copies of fuel oil 

delivery receipts provided by the supplier shall be 

retained for a period of five years for review by the 

DES, upon request. 

For each 

delivery 

Env-A 809 

Federally 

Enforceable 
VIII. 

Page 24 

Record keepim, Reouirements 

The Permittee is subject to the Record keeping requirements as contained in Table 7 below: 

2° 

3° 

5o 

The Permittee shall retain records of all required monitoring 

data, record keeping and reporting requirements, and support 

information for a period of at least 5 years from the date of the 

origination. 

The permittee shall maintain records of monitoring and testing as specified in Table 6 of this permit for: 

(A) Preventative maintenance and inspection results for 

stacks and fuel burning devices; 

(B) Initial boiler compliance test results; 

(C) Subsequent boiler performance test results; 

(D) Boiler fuel use records; 

(E) Used oil testing results; 

(F) Sulfur content in fuel verification for No. 2 fuel oil and 

used oil received; 

(G) Periodic monitoring data for pollution control 

equipment; and 

(H) Results of weekly and monthly Chip testing required. 

Delivery tickets from each fuel oil supplier for each shipment of 

No. 2 fuel oil and/or used oil received shall be kept On file in a 

form suitable for inspection and shall be made available to the 

DES and/or the EPA upon request. Each delivery ticket shall 

indicate the name, address, and telephone number of the 

fuel/used 0il supplier, the quantity of fuel/used oil delivered, 

and the percent sulfur by weight of the fuel/used oil being 

delivered. If delivery tickets do not contain sulfur content of 

fuel being delivered, Indeck shall perform testing in accordance 

with appropriate ASTM test methods to determine compliance 

with the sulfur content limitation provisions in Env-A 

1604.01(a) for liquid fuels. 

Daily, monthly, and 12 month rolling total records of on-spec 

used oil and No. 2 fuel oil used as fuel for the Boiler and the 

following: 

(A) Fuel consumption; 

Retain for a 

minimum of 5 

ye•s 

Maintain on a 

continuous basis 

as specified in 

Table 5 of this 

permit 

Maintain on a 

continuous basis 

• plle• fle,•i;•: )•Reg•!i•tt• 

Faei!i • 40 CFR 

Wide 70.6(a)(3)(ii)(B) 

Federally 

Enforceable 

Facility 

Wide 

Boiler 

40 CFR 

70.6(a)(3)(iii) 

(A) 

Federally 

Enforceable 

40 CFR 

70.6(a)(3)(iii) 

(A) 

Daily, monthly 

& consecutive 

12 month rolling 

total of on-spec 

Boiler 

Federally 

Enforceable 

(B) 

(C) 

(D) 

(E) 

Daily, monthly, and consecutive 12 month rolling totals of solid 

Fuel type; 

Viscosity; 

Sulfur content as percent sulfur by weight of fuel; and 

Btu content per gallon. 

used oil 

consumption 

Daily, monthly, Boiler Env-A 901.03 

Env-A 901.03 

Federally 

Enforceable 
Page 25 

fuel utilization shall be kept at the facility and contain the 

following information for each fuel burning device: 

(A) Fuel consumption (tons); 

(B) Moisture content (weight percent); 

(C) Fuel type (whole tree chips, sawmill residue, C/D 

derived wood chipS); and 

(D) Btu content (mmBm/bone dry ton chips). 

Records shall be kept of the hours of operation of the Boiler. 

Monthly records of fuel utiliZation & hours of operation for the 

emergency generator and twelve consecutive month rolling 

totals of fuel utilization & hours of operation for the emergency 

generator shall be kept at the facility and contain the following 

information: 

(B) 

(C) 

(D) 

(E) 

Fuel consmnption; 

Fuel type; 

Sulfur content as percent sulfur by weight 6f 

fuel; 

Viscosity;' and 

Btu content per gallon of fuel. 

NOX Record keeping Requirements: 

For fuel burning devices, including boilers and internal 

combustion engines, the following information shall be recorded 

and maintained: 

(A) Facility information, including: 

1. Source name; 

2. Source identification; 

3. Ph.ysical address; 

4. Mailing address; and 

(B) Identification of fuel burning device; 

(C) Operating schedule information for each fuel 

burning device identified in (B), above, 

including; 

1. Days per calendar week during the 

normal operating schedule; 

2. Hours per day during the normal 

operating schedule and for a typical ozone season day, if different from 

the normal operating schedule; and 

3. Hours per year during the normal 

operating schedule; 

(D) Type, and amount of fuel burned, for each 

fuel burning device, duriiag normal operating 

conditions and for a typical ozone season day, 

if different from normal operating conditions, 

on an hourly basis in million Btu's per hour; 

(E) The following NOX emission data, including 

records of total annual emissions, in tons per 

year, and typical ozone season day emissions, 

in pounds per day: 

and consecutive 

12 month rolling 

total of fuel 

consumption 

Daily, monthly, 

and annual 

Monthly & 

consecutive 12 

month rolling 

totals 

As specified 

Boiler 

Emergency 

Generator 

Facility 

WideEnv-A 901.03 

Federally 

Enforceable 

Env-A 901.03 

Federally 

Enforceable 

Env-A 901.08 

Federally 

Enforceable 

Federally 

Enforceable 
1. Theoretical potential emissions for 

the calculation year for each fuel 

burning device; and 

2. Actual NOX emissions for each fuel 

burning device. 

CEM Record keeping Requirements: 

All data required to be collected by the continuous monitors as 

specified in the monitoring and testing section of the permit and 

covered under Env-A 805. 

As specified Boiler 

Page 26 

Env-A 805 

Federally 

Enforceable 

VIII. F. Reporting Requirements 

The Permittee is subject to the reporting requirements as contained in Table 8 below: 

NOx Reporting Requirements: 

For fuel bm'ning devices and incinerators, including boilers, 

turbines and engines, as well as asphalt plant dryers and 

miscellaneous sources, the owner or operator shall submit to the 

director, annually (no later than April 15th of the following year), 

reports of the data required by Condition VIII.E., Table 7, Item 8., 

including total annual quantities of all NOx emissions. The NOx 

emissions for the Boiler shall be generated from the NOx CEM 

Data acquisition system. 

The permittee shall annually submit to the director, an annual fuel 

usage report indicating monthly fuel usage with corresponding 12 

consecutive month fuel usage totals for the Boiler. In addition, the 

permittee shall submit a summary report including test analyses 

for each load of used oil and No. 2 fuel oil received. 

Annually (no Facility Wide Env-A 901.09 

later than April Federally 

15th of the Enforceable 

following year) 

Annually (no Facility Wide 40 CFR 70.6 

later than April (a)(1) 

15th of the Federally 

following yem- ) Enforceable 
Page 27 

The permittee shall submit an annual fuel usage report indicating 

monthly and rolling twelve consecutive month fuel utilization and 

consecutive 12 month rolling total hours of operatiOn for the 

emergency generator. 

Prompt reporting of deviations from Permit requirements within 

24 hours of such an occurance by phone or fax in accordance with 

Section XXVIII. of this Permit. 

Annually (no 

later than April 

15th of the 

following year) 

Prompt 

reporting 

(ie; within 24 

hours of an 

occurrence). 

The Permittee shall submit to DES a summary report of 

monitoring and testing requirements every 6 months. All 

instances of deviations from Permit requirements must clearly be 

identified in such reports. All required reports must be certified 

by a responsible official consistent with section 70.5(d). The 

report shall contain a summary of the following information: 

(A) Preventative maintenance and inspection results 

for stacks and fuel burning devices; 

(B) Monitoring and preventative maintenance results 

for the Multiclone and ESP; 

(C) All instances of deviations from permit 

requirements shall be clearly identified; 

(D) Copies of any Initial Boiler, Compliance Test 

results or subsequent Boiler Performance Test 

Results; 

(D) Summary report of fuel sulfur content 

verifications; 

(E) Summary report of used oil certified delivery 

receipts containing results of analyses conducted 

on used oil shipments received; 

(F) Summary report of weekly chip moisture test 

results; and 

(G) Summary report of monthly chip testing results. 

Indeck Energy shall submit to the DES excess emission reports -for 

the CEM systems and the Boiler as approved by the DES 

containing information specified in Env-A 805 (rule effective 

11/15/92) as well as the following information: 

(A) Calendar daily averages of NOx and CO emissions in 

lb/hr and part per million (ppm) dry, whether or not an 

excess emission has occurred; 

(B) Calendar daily averages of percentage oxygen (02) on a 

dry basis or carbon dioxide (CO2) on a wet basis; 

(C) Calendar daily averages of steam generation rate; 

(D) Calendar daiiy averages of stack flow (dscfm); 

(E) Average steam production rate for each consecutive 24- 

Every 6 months 

by July 31 st 

and January 

31 st of each 

calendar year. 

Within 30 days 

of the close of 

each calendar 

quarter 

Emergency 

Generator 

Facility Wide 

Facility Wide 

Boiler 

40 CFR 70.6 

(a)(1) 

Federally 

Enforceable 

40 CFR 

70.6(a)(3)(iii) 

(B) 

Federally 

Enforceable 

40 CFR 

70.6(a)(3)(iii) 

(A) 

Federally 

Enforceable 

Env-A 805 

Federally 

Enforceable 
Page 28 

(F) 

(G) 

(H) 

(I) 

hour period where the production rate exceeds any of the 

limits set forth in Section VIII.A. of this permit; 

CEM system availability data; 

Estimated amount in tons (wet basis) of raw wood chip 

and C/D fuel consumption per month and a consecutive 

twelve month total; 

Amount in gallons of fuel consumption per calendar 

month where the fuel usage cap set forth in Section 

VIII.A. or VIII.B. of this permit has been exceeded; and 

All periods of gaseous and opacity exceedances including 

start time, end time, and magnitude and cause of the 

exceedance. 

7. Indeck shall Submit to the DES a CEM audit report for all audits Within 30 days Boiler 

conducted as specified in Env-A 805.06 (rule effective 11/15/92) of the close of 

and Section VIII.D, Item 7. of this permit, each calendar 

quarter 

8. Any report submitted to the DES and/or EPA shall include the As specified 

compliance certification statement as outlined in Section XXI.B. 

of this Permit and shall be signed by the responsible official. 

9. Annual reporting and payment of emission based fees shall be As specified in 

conducted in accordance with Section XXIII. of this Permit. Section XXIII. 

Facility Wide 

Env-A 805.06 

Federally 

Enforceable 

Facility Wide 

10. Annual compliance certification shall be submitted in accordance April 15th Facility Wide 

with Section XXI. of this Permit. 

40 CFR 

70.6(c)(1) 

Federally 

Enforceable 

Env-A 704.03 

Federally 

Enforceable 

40 CFR 

70.6(c)(1) 

Federally 

Enforceable 

IX. Requirements Currently Not Applicable: 

Indeck Energy did not request that any non-applicable requirements be specifically listed in this permit. 

General Title V Operating Permit Conditions 

X. Issuance of a Title V Operating Permit: 

A. This Permit is issued in accordance with the provisions of Part Env-A 609. In accordance with 

40 CFR 70.6(a)(2) this Permit shall expire on the date specified on the cover page of this Permit, 

which shall not be later than the date five (5) years after issuance of this Permit. 

Permit expiration terminates the Permittee's right to operate the Permittee's emission units, 

control equipment, or associated equipment covered by this permit, unless a timely and complete 
XI. 

Page 29 

renewal application is submitted at least 6 months before the expiration date. 

Bo Pursuant to Env-A 609.02(b), this Permit shall be a state permit to operate as defined in RSA 

125-C:11, III. 

Title V Operating Permit Renewal Procedures: 

Pursuant to Env-A 609.06(b), an application for renewal of this Permit shall be considered timely if it is 

submitted to the Director at least six months prior to the designated expiration date of this Permit. 

Application Shield: 

Pursuant to Env-A 609.07: if an applicant submits a timely and complete application for the issuance or 

renewal of a Permit, the failure to have a Permit shall not be considered a violation of this part until the 

Director takes final action on the application. 

Permit Shield: 

A. Pursuant to Env-A 609.08(a), a permit shield shall provide that: 

For any applicable requirement or any state requirement found in the New Hampshire 

Rules Governing the Control of Air Pollution specifically included in this Permit, 

compliance with the conditions of this Permit shall be deemed in compliance with said 

applicable requirement or said state requirement as of the date of permit issuance; and 

For any potential applicable requirement or any potential state requirement found in the 

New Hampshire Rules Governing the Control of Air Pollution specifically identified in 

this Title V Operating Permit as not applicable to the stationary source or area source, the 

Permittee need not comply with the specifically identified federal or state requirements. 

Bo The permit shield identified in Section XIII.A. of this Permit shall apply only to those conditions 

incorporated into this Permit in accordance with the provisions of Env-A 609.08(b). It shall not 

apply to certain conditions as specified in Env-A 609.08(c) that may be incorporated into this 

Permit following permit issuance by the DES. 

Co If a Title V Operating Permit and amendments thereto issued by the DES does not expressly 

include or exclude an applicable requirement or a state requirement found in the New Hampshire 

Rules Governing the Control of Air Pollution, that applicable requirement or state requirement 

shall.not be covered by the permit shield and the Permittee shall comply with the provisions of 

said requirement to the extent that it applies to the Permittee. 

Do If the DES determines that this Title V Operating Permit was issued based upon inaccurate or 

incomplete information provided by the applicant or Permittee, any permit shield provisions in 

said Title V Operating Permit shall be void as to the portions of said Title V Operating Permit 

which are affected, directly or indirectly, by the inaccurate or incomplete information. 
Page 30 

Pursuant to Env-A 609.08(0, nothing contained in Section XIII. of this Permit shall alter or affect 

the ability of the DES to reopen this Permit for cause in accordance with Env-A 609.18 or to 

exercise its summary abatement authority. 

Pursuant to Env-A 609.08(g), nothing contained in Section XIII. of this Permit or in any Title V 

operating permit issued by the DES shall alter or affect the following: 

The ability of the DES to order abatement requiring immediate compliance with 

applicable requirements upon finding that there is an imminent and substantial 

endangerment to public health, welfare, or the environment; 

The state of New Hampshire's ability to bring an enforcement action pursuant to RSA 

125-C: 15,II; 

The provisions of Section 303 of the Act regarding emergency orders including the 

authority of the EPA Administrator under that section; 

The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance; 

The applicable requirements of the acid rain program, consistent with Section 408(a) of 

the Act; 

The ability of the DES or the EPA Administrator to obtain information about a stationary 

source, area source, or device from the owner or operator pursuant to Section 114 of the 

Act; or 

The ability of the DES or the EPA Administrator to enter, inspect, and/or monitor a 

stationary source, area source, or device. 

Reopening for Cause: 

The Director shall reopen and revise a Title V Operating Permit for cause if any of the circumstances 

contained in Env-A 609.18(a) exist.. In all proceedings to reopen and reissue a Title V Operating Permit, 

the Director shall follow the provisions specified in Env-A 609.18(b) through (g). 

XV. Administrative Permit Amendments: 

Pursuant to Env-A 612.01, the Permittee may implement the changes addressed in the request for 

an administrative permit amendment, as defined in Part Env-A 100, immediately upon submittal 

of the request. 

Bo Pursuant to Env-A 612.01, the Director shall take final action on a request for an administrative 

permit amendment in accordance with the provisions of Env-A 612.01 (b) and (c). 
Page 31 

XVI. Operational Flexibility: 

Pursuant to Env-A.612.02(a), the Permittee subject to and operating under this Title V Operating 

Permit may make changes involving trading of emissions under this existing Title V Operating 

Permit at the permitted stationary source or area source without filing a Title V Operating Permit 

application for and obtaining an amended Title V Operating Permit, provided that all the 

conditions are met as specified in Sections XVI.A. 1. through 7. of this permit and a notice is 

submitted to the DES and the EPA describing the intended changes. The DES has not included 

any permit terms authorizing intra- or inter-facility emissions trading in this permit. 

1. The change is not a modification under any provision of Title I of the Act; 

The change does not cause emissions to exceed the emissions allowable under the Title V 

operating permit, whether expressed therein as a rate of emissions or in terms of total 

emissions; 

3. The owner or operator has obtained any temporary permit required by Env-A 600; 

The owner or operator has provided written notification to the director and administrator 

at least 15 days prior to the proposed change, and such written notification includes: 

a. The date on which each proposed change will occur; 

b. A description of each such change; 

Co Any change in emissions that will result and how this change in emissions will 

comply with the terms and conditions of the permit; 

d. A written request that the operational flexibility procedures be used; and 

e. The signature of the responsible official, consistent with Env-A 605.04(b); 

The Title V operating permit issued to tlae stationary source or area source already 

contains terms and conditions including all terms and conditions which determine 

compliance required under 40 CFR 70.6(a) and (c) and which allow for the trading of 

emissions increases and decreases at the permitted stationary source or area source solely 

for the purpose of complying with a federally-enforceable emissions cap that is 

established in the permit independent of otherwise applicable requirements; 

The owner or operator has included in the application for the Title V operating permit proposed replicable procedures and proposed permit terms which ensure that the 

emissions trades are quantifiable and federally enforceable for changes to the Title V 

operating permit which qualify under a federally-enforceable emissions cap that is 

established in the Title V operating permit independent of the otherwise applicable 

requirements; and 
Page 32 

7. The proposed change complies with Env-A 612.02 (e). 

Pursuant to Env-A 612.02(c), the Permittee subject to and operating under this Title V Operating 

Permit may make changes not addressed or prohibited by this existing Title V Operating Permit 

at the permitted stationary source or area source without filing a Title V Operating Permit 

application, provided that all the conditions specified in Env-A 612.02(c)(1) through (6) are met 

and a notice is submitted to the DES and the EPA describing the intended changes. 

If Indeck Energy would like to use C/D chips from a new supplier (not ERRCO), Indeck 

Energy must submit a notification prior to such changes in accordance with Env-A 

612.02(c) and attach such off-permit change to its current Title V Operating Permit. In 

addition, Indeck Energy will conduct periodic monitoring and testing of C/D chips from 

the new supplier as outlined in the Monitoring/Testing Requirements of this Title V 

Operating Permit. 

Co Pursuant to Env-A 612.02(d), the Permittee, Operator, Director, and Administrator shall attach 

each notice of an off-permit change completed in accordance with Section XVI. of this Title V 

Operating Permit to their copy of the current Title V Operating Permit. 

Do Pursuant to Env-A 612.02(e), any change under Section XVI. shall not exceed any emissions 

limitations established under the New Hampshire Rules Goveming the Control of Air Pollution, 

or result in an increase in emissions, or result in new emissions of any toxic air pollutant or 

hazardous air pollutant other than those listed in the existing Permit. 

Eo Pursuant to Env-A 612.02(0, the off-permit change shall not qualify for the permit shield under 

Env-A 609.08. 

XVII. Minor Permit Amendments: 

Pursuant to Env-A 612.04 prior to implementing a minor permit modification, the Permittee shall 

submit a written request to the Director in accordance with the requirements of Env-A 612.04(b). 

Bo The Director shall take final action on the minor permit amendment request in accordance with 

the provisions of Env-A 612.04(c) through (g). 

Co Pursuant to Env-A 612.04(g), the permit shield specified in Env-A 609.08 shall not apply to 

minor permit amendments under Section XVII. of this Permit. 

Do Pursuant to Env-A 612.04(i), the Permittee shall be subject to the provisions of Part Env-A 614 

and Part Env-A 615 if the change is made prior to the filing with the Director a request for a 

minor permit amendment. 

XVIII. Significant Permit Amendments: 

Pursuant to Env-A 612.05, a change at the facility shall qualify as a significant permit 

amendment if it meets the criteria specified in Env-A 612.05(a)(1) through (7). 
Page 33 

Bo Prior to implementing the significant permit amendment, the Permittee shall submit a written 

request to the Director and to the EPA which includes all the information as referenced in Env-A 

612.05(b) and (c) and shall be issued an amended Title V Operating Permit from the DES. The 

Permit-tee shall be subject to the provisions of Env-A 614 and Env-A 615 if a request for a 

significant permit amendment is not filed with the Director and/or the change is made prior to the 

issuance of an amended Title V Operating Permit. 

The Director shall take final action on the significant permit amendment in accordance with the 

procedures specified in Env-A 612.05(d), (e) and (f). 

XIX. Title V Operating Permit Suspension• Revocation• or Nullification: 

Ao Pursuant to RSA 125-C: 13, the Director may suspend or revoke any final permit issued 

hereunder if, following a hearing, the Director determines that: 

the Permittee has committed a.violation of any applicable statute or state requirement 

found in the New Hampshire Rules Governing the Control of Air Pollution, order, or 

permit condition in force and applicable to it; or 

that the emissions frown any device to which this Permit applies, alone or in conjunction 

with other sources of the same pollutants, presents an immediate danger to the public 

health. 

B° The Director shall nullify any Permit, if following a hearing in accordance with RSA 541-A:30, 

II, a finding is made that the Permit was issued in whole or in part based upon any information 

proven to be intentionally false or misleading. 

XX. Inspection and Entry: 

Pursuant to Env-A 614.01, EPA and DES personnel shall be granted access to the facility covered by 

this Permit, in accordance with RSA 125-C:6, VII for the purposes of: inspecting the proposed or 

permitted site; investigating a complaint; and assuring compliance with any applicable requirement or 

state requirement found in. the New Hampshire Rules Governing the Control of Air Pollution and/or 

conditions of any Permit issued pursuant to Chapter Env-A 600. 

XXI. Certifications: 

A. Compliance Certification Report 

In accordance with 40 CFR 70.6(c) the Responsible Official shall certify, annually from the date 

of issuance, that the facility is in compliance with the requirements of this permit. The report 

shall be submitted to the DES and to the Regional Administrator, U.S. Environmental Protection 

Agency New England Region. The report shall be submitted in compliance with the 

submission requirements below. 
Bo 

Page 34 

In accordance with 40 CFR 70.6(c)(5), the report shall describe: 

1. The terms and Conditions of the Permit that are the basis of the certification; 

The current compliance status of the source with respect to the terms and conditions of 

this Permit, and whether compliance was continuous or intermittent during the reporting period; 

The methods used for determining compliance, including a description of the monitoring, 

Record keeping and reporting requirements, and test methods; and 

Any additional information required by the DES to determine the compliance status of the 

source. 

Certification of Accuracy Statement 

All documents submitted to the DES shall contain a certification of accuracy statement by the 

responsible official of truth, accuracy, and completeness. Such certification shall be in 

accordance with the requirements of 40 CFR 70.5(d) and contain the following languag.e: 

"I am authorized to make this submission on behalf of the facility for 

which the submission is made. Based on information and belief formed 

after reasonable inquiry, I certify that the statements and information in the 

enclosed documents are, to the best of my knowledge and belief, true, 

accurate, and complete. I am aware that there are significant penalties for 

submitting false statements and information or omitting required 

statements and information, including the possibility of fine or 

imprisonment." 

All reports submitted to the DES (except those submitted as emission based fees as outlined in 

Section XXV. of this permit) shall be submitted to the following address: 

New Hampshire Department of Environmental Services 

Air Resources Division 

6 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

Attn: Compliance Bureau 

XXII. Enforcement: 

Any noncompliance with a permit condition constitutes a violation of RSA 125-C: 15, and, as to the 

conditions in this permit which are federally enforceable, a violation of the Clean Air Act, 42 U.S.C. 

Section 7401 et seq., and is grounds for enforcement action, for permit termination or revocation, or for 

denial of an operating permit renewal application by the DES and/or the EPA. Noncompliance may also 

be grounds for assessment of administrative, civil, or criminal penalties in accordance with RSA 125- 
Page 35 

C:15 and/or the Clean Air Act. This Permit does not relieve the Permittee from the obligation to comply 

with any other provisions of RSA 125-C, the New Hampshire Rules Governing the Control of Air 

Pollution, or the Clean Air Act, or to obtain any other necessary authorizations from other governmental 

agencies, or to comply with all other appliCable Federal, State, or Local rules and regulations not 

addressed in this Permit. 

In accordance with 40 CFR 70.6 (a)(6)(ii) a Permittee shall not claim as a defense in an enforcement 

action that it would have been necessary to halt or reduce the permitted activity in order to maintain 

compliance with the conditions of this Permit. 

XXIII. Emission-Based Fee Requirements: 

The Permittee shall pay an emission-based fee annually for this facility as calculated each 

calendar year pursuant to Env-A 704.03. 

The Permittee shall determine the total actual annual emissions from the facility to be included in 

the emission-based multiplie• specified in Env-A 704.03(a) for each calendar year in accordance 

with the methods specified in Env-A 620. 

Co The Permittee shall calculate the annual emission-based fee for each calendar year in accordance 

with the procedures specified in Env-A 704.03 and the following equation: 

FEE E * DPT * CPIm * ISF 

Where: 

FEE The annual emission-based fee for each calendar year as specified in Env-A 704. 

E The emission-based multiplier is based on the calculation of total annual 

emissions as specified in Env-A 704.02 and the provisions specified in Env-A 

704.03(a). 

DPT The dollar per ton fee the DES has specified in Env-A 704.03(b). 

CPIm= The Consumer Price Index Multiplier as calculated in Env-A 704.03(c). 

ISF The Inventory Stabilization Factor as specified in Env-A 704.03(d). 

The Permittee shall contact the DES each calendar year for the value of the Inventory 

Stabilization Factor. 

Eo The Permittee shall contact the DES each calendar year for the value of the Consumer Price 

Index Multiplier. 

The Permittee shall submit, to the DES, payment of,the emission-based fee and a summary of the 

calculations referenced in Sections XXIII.B. and C. of this Permit for each calendar year by 

October 15 th of the following calendar year in accordance with Env-A 704.04. 

The emission-based fee and summary of the calculations shall be submitted to the following 

address: 
Page 36 

XXVI. 

New Hampshire Department of Environmental Services 

Air Resources Division 

6 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

ATTN: Emissions Inventory 

Go The DES shall notify the Permittee of any under payments or over payments of the annual 

emission-based fee in accordance with Env-A 704.05. 

Duty To Provide Information: 

In accordance with 40 CFR 70.6 (a)(6)(v), upon the DES's written request, the Permittee shall furnish, 

within a reasonable time, any information necessary for determining whether cause exists for modifying, revoking and reissuing, or terminating the Permit, or to determine compliance with the Permit. Upon 

request, the Permittee shall furnish to the DES copies of records that the Permittee is required to retain 

by this Permit. The Permittee may make a claim of confidentiality as to any information submitted 

pursuant to this condition in accordance with Part Env-A 103 at the time such information is submitted 

to the DES. The DES shall evaluate such requests in accordance with the provisions of Part Env-A 103. 

Property Rights: 

Pursuant to 40 CFR 70.6 (a)(6)(iv), this Permit does not convey any property rights of any sort, or any 

exclusive privilege, 

Severability Clause: 

Pursuant to 40 CFR 70.6 (a)(5), the provisions of this Permit are severable, and if any provision of this 

Permit, or the application of any provision of this Permit to any circumstances is held invalid, the 

application of such provision to other circumstances, and the remainder of this Permit, shall not be 

affected thereby. 

XXVII. Emergency Conditions: 

Pursuant to 40 CFR 70.6 (g), the Permittee shall be shielded from enforcement action brought for 

noncompliance with technology based 4 emission limitations specified in this Permit as a result of an 

emergency s. In order to use emergency as an affirmative defense to an action brought for 

Technology based emission limits are those established on the basis of emission reductions achievable with various 

control measures or process changes (e.g., a new source performance standard) rather than those established to attain 

health based air quality standards. 

An "emergency" means any situation arising from sudden and reasonably unforeseeable evems beyond the control of 

the source, including acts of God, which situation would require immediate corrective action to restore normal operation, 

and that causes the source to exceed a technology based limitation under the permit, due to unavoidable increases in 

emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by 
Page 37 

noncompliance, the Permittee shall demonstrate the affirmative defense through properly signed, 

contemporaneous operating logs, or other relevant evidence that: 

A. An emergency occurred and that the Permittee can identify the cause(s) of the emergency; 

B. The permitted facility was at the time being properly operated; and 

Co During the period of the emergency, the Permittee took all reasonable steps as expeditiously as 

possible, to minimize levels of emissions that exceeded the emissions standards, or other 

requirements in this Permit; and 

The Permittee submitted notice of the emergency to the DES within two (2) business days of the 

time when emission limitations were exceeded due to the emergency. This notice must contain a 

description of the emergency, any steps taken to mitigate emission, and corrective actions taken. 

XXVIII. Permit Deviation: 

In accordance with 40 CFR 70.6(a)(3)(iii)(B), the Permittee shall report to the DES all instances of 

deviations from Permit requirements, by telephone or fax, within 24 hours of discovery of such 

deviation. This report shall include the deviation itself, including those attributable to upset conditions 

as defined in the Permit, the probable cause of such deviations, and any corrective actions or preventive 

measures taken. Said Permit deviation shall also be submitted in writing to the DES, at the address 

listed in permit condition XXI.A. in the semi-annual report of monitoring and testing requirements due 

January 31 st and July 31 st of each calendar year. Deviations are instances where any Permit condition is 

violated and has not already been reported as an emergency pursuant to Section XXVII. of this Permit. 

Reporting a Permit deviation is not an affirmative defense for action brought for noncompliance. 

h:\laughton\permitskindeck•reopenfi.nal 

Reopened Final Permit Issued October 19, 2001 

improperly designed equipment, lack of preventive maintenance, careless or improper operations, operator error or 

decision to keep operating despite knowledge of any of these things. 

STATE OF NEW HAMPSHIRE 

Department of Environmental Services 

Air Resources Division 

Title V Operating Permit 

Permit No: TV-OP-008 

Date Issued: November 5, 1998, Amended November 15, 1999 

This certifies that: 

Bridgewater Power Company, L.P. 

P.O. Box 678 

Ashland, NH 03217 

has been granted a Title V Operating Permit for the following facility and location: 

Bridgewater Power Company 

Routes 3 and 25 

Bridgewater, NH 

Grafton County 

AFS No. 3300900021 

This Title V Operating Permit is hereby issued under the terms and conditions specified in the Title V Operating 

Permit Application filed with the New Hampshire Department of Environmental Services Air Resources Division 

(DES) on June 14, 1996 under the signature of the following responsible official certifying to the best of their 

knowledge that the statements and information therein are true, accurate and complete. 

Responsible Official: 

Michael O'Leary 

Plant Manager 

(603) 968-9602 

Technical Contact: 

Michael O'Leary 

Plant Manager 

(603) 968-9602 

This Permit is issued by the DES pursuant to its authority under New Hampshire RSA 125-C and in accordance 

with the provisions of Code of the Federal Regulations 40 Part 70. 

This Title V Operating Permit shall expire on November 30, 2003. 

SEE ATTACHED SHEETS FOR ADDITIONAL PERMIT CONDITIONS 

For the New Hampshire Department of Environmental Services, Air Resource Division 

Director, Air Resources Division 
TABLE OF CONTENTS 

Page 2 

I. Facility Description of Operations 4 

II. 

III. 

Permitted Activities 

Significant Activities Identification and Stack Criteria Tables 1 & 2 4-6 

IV. Insignificant Activities Identification 6 

V. 6 

VI. 

VII. 

VIII. 

IX. 

X. 

XI. 

XII. 

XIII. 

XIV. 

XV. 

XVI. 

XVII. 

XVIII. 

XIX. 

XX. 

XXI. 

XXII. 

XXIII. 

Exempt Activities Identification 

Pollution Control Equipment Identification- Table 3 6-7 

Requirements Not Currently Applicable 

•;•i•i•.,,,.ii •W,•i 

Issuance of a Title V Operating Permit 

Title V Operating Permit Renewal Procedures 

Application Shield 

Permit Shield 

Reopening for Cause 

Administrative Permit Amendments 

Operational Flexibility 

Minor Permit Amendments 

Significant Permit Amendments 29 

Title V Operating Permit Suspension, Revocation or Nullification 29 

Inspection and Entry 29 

Certifications 

25 

25 

25 

25-26 

27 

27 

27-28 

28-29 

3O 

Alternative Operating Scenarios Table 4 7-8 

Applicable Operational and Emission Limitations 8-11 

Emission Reductions Trading Requirements 12 

Compliance Demonstration Requirements 12-24 

-Monitoring and Testing Requirements 

-Record Keeping and Reporting Requirements 
Page 3 

XXIV. Enforcement 31 

XXV. Emission Based Fee Requirements 31-32 

XXVI. Duty to Provide Information 32 

XXVII. Property ,Rights 32 

XXVIII. Severability Clause 32 

XXIX. Emergency Conditions. 33 

XXX. Permit Malfunctions and Deviations 33 
Facility Specific Title V Operating Permit Conditions 

I. 

II. 

III. 

Page 4 

Facility Description of Operations: 

Bridgewater Power Company (Bridgewater) is located in on Routes 3 and 25 in Bridgewater, New 

Hampshire. The primary fuel source for the 15 megawatt (MW) net output electric generating station is 

whole tree wood chips. No. 2 fuel oil is used for start up and flame stabilization. 

Permitted Activities: 

In accordance with all of the provisions of the New Hampshire Rules Governing the Control of Air Pollution 

(effective date 12/31/96) and as revised thereafter, the permittee is authorized to operate the devices and or 

processes identified in Sections III, IV, V and VI within the terms and conditions specified in this Permit. 

Significant A•tivities Identification and Stack Criteria: 

A. Significant ACtivity Identification 

The activities identified in the following table (Table 1) are subject to and regulated by this Title V 

Operating Permit: 

EU1 Boiler T• •fw• •r S•ck #1 Maximum Firing Rate of 250 

EU2 -Cooling Pond Circulation Water Cooling Pond Cooling Pond 

EU3 EG Caterpillar Emergency Diesel Generator Stack #3 

mmBTU/hr with wood 

Maximum Firing Rate of 50 

mmBTU/hr with #2 oil 

Drift Factor (12 cycles) 

0.00001636 

(16 cycles) 0.000012 

(20 cycles) 0.000009474 

Circulation Rate 15,800 gpm 

225 hp operating less than 500 

hours per •¢ear 

Based on equipment design, the maximum operating rate of the EU1 Boiler shall be limited 

to a total of 250 million BTU per hour (mmBTU/hr) gross heat input. This is the equivalent 

of 160,000 pounds per hour (lbs/hr) of steam production as averaged over any consecutive 

24-hour period at 850 degrees F and 695 PSIG assuming a boiler efficiency of 68% and boiler 

feedwater temperature of 340°F. 

Based on facility operations, fuel fed to the EU1 Boiler shall consist of any of the following: 

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IIl. 

Page 5 

Significant Activities Identification and Stack Criteria (continued): 

Whole tree wood chips at approximately 50% moisture (approximately 8.5 

mmBTU/ton). 

bo Whole tree wood chips at approximately 8.5 mmBTU/ton and #2 fuel oil or 

specification used oil at maximum 0.4% sulfur by weight. 

Clean processed wood fuel 2 (approximately 8.5 mmBTU/ton to 13.5 mmBTU/ton) 

and #2 fuel oil or specification used oil at maximum 0.4% sulfur by weight. 

d. Clean processed wood fuel and whole tree wood chips at approximately 50% 

moisture. 

eo Clean processed wood fuel and whole tree wood chips at approximately 50% 

moisture and #2 fuel oil or specification used oil at maximum 0.4% sulfur by weight. 

f. No. 2 fuel oil at maximum 0.4% sulfur by weight. 

g. Clean processed wood fuel (approximately 8.5 mmBTU/ton to 13.5 mmBTU/ton). 

h... Specification used oil at maximum 0.4% sulfur by weight. 

A combination of No. 2 fuel oil and specification used oil at maximum 0.4% sulfur by 

weight. 

Based on equipment design and 365 operating days per year, the maximum wood 

consumption by the EU1 Boiler shall be limited to 251,000 tons wet basis of whole tree 

wood chips at approximately 50% moisture during any consecutive twelve month period. 

To allow for an exemption of Bridgewater from the NOx emission limitation in 40 CFR 60, 

Subpart Db, the maximum consumption of #2 fuel oil and specification used oil combined by 

the EU1 Boiler at maximum 0.4% sulfur by weight shall be limited to 1,564,000 gallons 

during any consecutive twelve month period with no more than 128,600 gallons used during 

any consecutive 30-day period. The maximum gross heat input rate of #2 fuel oil or 

specification used oil at maximum 0.4% sulfur by weight to the EU1 Boiler shall be limited 

to 25 mmBTU/hr on a 30-day average. This is equivalent to 179 gallons per hour on a 30- 

day average of #2 fuel oil or specification used oil based on a heating value of 140,000 

BTUs/gallon. As described in Section VII.B., the maximum hourly oil usage shall be limited 

to 345 gallons per hour. 

Specification used oil shall be meet the requirements described in Section VII of this permit. 

Clean processed wood fuel is considered to be fuel that exhibits fuel characteristics equivalent to "whole tree wood chips" and 

"sawdust" with respect to the ultimate and proximate analysis of the fuel. 

h:\permits\current\titlev•amendmnt\tvbridg2.amd 

Revised 1/15/98 
IlL Significant Activities Identification and Stack Criteria (continued): 

B. Stack Criteria 

Page 6 

The following stack for the above listed significant devices at this facility shall discharge vertically 

without obstruction (including rain caps) and meet the following criteria in accordance with the stateonly air pollution dispersion modeling requirements specified in Env-A 606. 

Stack #1 196.5 6.0 

Stack #2 32 1.17 

Stack #3 10 0.33 

IV. 

We 

VI. 

Preauthorized changes to the state-only requirements pertaining to stack parameters (set forth in 

this permit) shall be permitted only when an air quality impact analysis meeting the criteria of Part 

Env-A 606 is performed either by the facility or by the DES (if requested by the facility in writing) 

in accordance with the "NHARD Policy and Procedure for Air Quality Impact Modeling". All air 

modeling data shall be kept on file at the facility for review by the DES upon request. 

Insignificant Activities Identification: 

All activities at this facility that meet the criteria identified in the New Hampshire Rules Governing the 

Control of Air Pollution Part Env-A 609.03(g), shall be considered insignificant activities. Emissions 

from the insignificant activities shall be included in the total facility emissions for the emission-based fee 

calculation described in Section XXV of this Title V Operating Permit. 

Exempt Activities Identification: 

All activities identified in the New Hampshire Rules Governing the Control of Air Pollution Part Env-A 

609.03(c) shall be considered exempt activities and shall not be subject to or regulated by this Title V 

Operating Permit. 

Pollution Control Equipment Identification: 

The devices and/or processes identified in Table 3 below are considered pollution control equipment for 

the identified emissions unit. 

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Revised 11/15/98 
VI. Pollution Control Equipment Identification (continued): 

Page 7 

PC 1-Multiclone Multiclone primary particulate control for the EU Boiler 

PC2-GBF 

PC3-Bag House 

Gravel Bed Filter secondary particulate control for the EU1 

Boiler 

Dry Dust Collector final particulate control for the GBF 

ambient countercurrent air flow 

EU1-Boiler 

EU1-Boiler 

Stack # 1 

Stack #1 

Stack #2 

VII. 

Ao Based on the AP-42 uncontrolled particulate matter (PM) emissions of 8.8 lb/ton, the combined 

minimum efficiency of the PM control equipment (PC1 through PC3) shall be at least 90.4% to 

meet the applicable permit limit for PM of 0.10 lb/mmBTU. 

Bo All equipment, facilities and systems installed and used to achieve compliance with the terms and 

conditions of this permit shall at all times be maintained in good working order and shall be 

operated as efficiently as possible so as to minimize air pollutant emissions and meet all applicable 

air pollutant emission limits. These controls shall be fully operational upon facility startup and 

shall not be bypassed during startup, operation or shutdown of the steam generating unit. 

Co The pollution control equipment shall be maintained regularly, in accordance with the 

manufacturer's Operation and Maintenance (O&M) manual and based on the schedules as 

described in Sections VIII.A. and X.A. 

Alternative Operating Scenarios: 

Bridgewater requested the ,alternative operating scenario of burning used oil in their Title V application. Bridgewater proposed to bum used oil in the EU1-Boiler as an auxiliary fuel. The used oil shall meet the 

criteria for specification used oil as described in Waste Management Rules Env-Wm 807.02 and shown in 

Table 4 below: 

A. The oil shall not be mixed with hazardous waste; and 

Bo The oil shall meet all of the standards in the following table and shall not otherwise exhibit any of 

the hazardous waste characteristics specified in Env-Wm 403. 

VII. Alternative Operating Scenarios (continued): 

h:\pennits\cu rrent\titlev•amendmnt\tvbridg2.amd Revised 11115/98 
VIII. 

VIII. 

Page 8 

Arsenic 5.0 ppm maximum 

Cadmium 2.0 ppm maximum 

Chromium 

Lead 

10 ppm maximum 

60 ppm maximum 

PCBs Less than 2. ppm 

Total Halogens 1,000 ppm maximum 

Flash Point 100 degrees F minimum 

Bridgewater will bum the specification used oil under the same conditions as the No. 2 fuel oil. The 

sulfur content shall be limited to 0.4% by weight and the gross heat input of used oil shall be limited to 25 

mmBTU/hr (approximately 180 gallons per hour) on an average annual basis. 

Based on DES modeling results, Bridgewater shall not use more than 345 gallons per hour of 

specification used oil for a period not to exceed 22 hours during startup operations. The typical startup 

fuel requirements are 100 gallons/hour for 6-12 hours. The 100 gallons/hour rate may be used 24 

hours/day until the monthly fuel limit is reached. The limits described in Section III.A.4 Shall also apply 

during periods of startup. 

Bridgewater shall monitor compliance with the used oil specifications by requiring the used oil vendor to 

provide with each delivery, a fuel analysis certifying compliance with Env-Wm 807.02 and the sulfur 

content of 0.4% by weight. This data shall be retained at the facility in accordance with record keeping 

requirements described in Section X.D. of this permit. 

Applicable Operational and Emission Limitations: 

Bridgewater is subject to the following operational and emission limitations as contained in this permit. 

A. Operational Limitations 

Based on equipment design, the maximum operating rate of the EU1-Boiler shall be limited to a 

total of 250 mmBTU/hr gross heat input. This is equivalent to 160,000 lbs/hr of steam 

production as averaged over any consecutive 24-hour period at 850 degrees F and 695 PSIG 

assuming a boiler effiency of 68% and boiler feedwater temperature of 340°F. 

Applicable Operational and Emission Limitations (continued): 

The limit for lead is 60 ppm due to modeling violations predicted with the 100 ppm level allowed in the specification used oil 

criteria in the DES Waste Management Rules. 

h:\pemaits\current\titlev•amendrmxt\t•bridg2.amd 

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Page 9 

To operationally control CO emissions in accordance with Env-A 305, Bridgewater shall comply 

with the following operational limitations. 

Bridgewater shall control CO emissions by varying the total quantity of input combustion air 

and/or the local distribution of that air into the EU1 Boiler. The amount of combustion air 

required to optimize the EU1 Boiler efficiency and reduce CO emissions is dependent on the 

wood moisture content and the type of wood, among other factors. The steam generating unit 

shall be equipped with a fuel distribution, overfire air and undergrate air control systems for 

optimum NOx and CO emission control. 

State-Only Applicable Emission Limitations 

In accordance with Env-A 1002.03, Bridgewater shall take precautions to prevent, abate 

and control the emission of fugitive dust for those activities contained in Env-A 1002.02. 

Such precautions shall include wetting, covering, shielding or vacuuming. 

New or modified devices, new or modified area sources, and existing devices or area 

sources for which new applications for permits are filed that have the potential to emit, in 

any amount, substances that meet the criteria of Env-A 1301 shall be subject to Env-A 

1300, until such time as the Env-A 1400 requirements supersedethe Env-A 1300 

requirements. 

Air quality impact analysis of devices and area sources emitting substances meeting the 

criteria of Env-A 1301 shall be performed in accordance with the "DES Policy and 

Procedure for Air Quality Impact Modeling" or other comparable dispersion modeling 

methods approved by EPA. 

In accordance with Env-A 1403.01, new or modified devices or processes installed after 

May 8, 1998, shall be subject to the requirements of Env-A 1400. 

In accordance with 1403.02(a), all existing unmodified devices or processes which are in 

operation during the transition period ending three years from May 8, 1998 (May 8, 

2001), shall comply with either Env-A 1300 or Env-A 1400. 

In accordance with Env-A 1403.02(b), all existing devices or processes in operation after 

the transition period ending three years from May 8, 1998 (May 8, 2001), shall comply 

with Env-A 1400. Env-A 1300 will no longer be in effect. 

In accordance with Env-A 1404.01(d), documentation for the demonstration of 

compliance shall be retained at the site, and shall be made available to the DES for 

inspection. 

VIII. Applicable Operational and Emission Limitations (continued): 

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Revised 1/I 5/98 
Page 10 

In accordance with Env-A 1405.02, the owner of an existing device or process requiring a 

permit modification under Env-A 1400 shall submit to the DES no later than one year 

prior to the end of the transition period (by May 8, 2000), an application for a 

modification to a Title V permit in accordance with Env-A 609.18, and a request to the 

DES to perform air dispersion modeling. 

In accordance with Env-A 2003.04 (d), exceedances of the opacity standard shall not be 

considered violations of this part if the facility demonstrates to the division that such 

exceedances were the result of the adherence to good boiler operating practices which, in 

the long term, results in the most-efficient or safe operation of the boiler. 

10. In accordance with Env-A 2003.04 (e)(2), opacity exceedances experienced during 

periods of cold startup of a boiler over a continuous period of time resulting in efficient 

heat-up and stabilization of its operation and the expeditious achievement of normal 

operation of the unit shall not be considered violations. 

11. In accordance with Env-A 2003.04 (f), exceedances of the opacity standard shall not be 

considered violations of this part if the source demonstrates to the DES that such 

exceedances were the result of the occurrence of an unplanned incident in which the 

opacity exceedance was beyond the control of the operator and in response to such an 

incident, the operator took appropriate steps in conformance with good boiler operating 

practice to eliminate the excess opacity as quickly as possible. 

C. Federally Enforceable Emission Limitations 

To allow for an exemption of Bridgewater from the NO emission limitation in 40 CFR 60, 

Subpart Db, the maximum consumption of #2 fuel oil and specification used oil combined 

by the EU1 Boiler at maximum 0.4% sulfur by weight shall be limited to 1,564,000 

gallons during any consecutive twelve month period with no more than 128,600 gallons 

used during any consecutive 30-day period with a nitrogen content of 0.30 weight percent 

or less. The maximum gross heat input rate of #2 fuel oil or specification used oil at 

maximum 0.4% sulfur by weight to the EU1 Boiler shall be limited to 25 mmBTU/hr. 

This is equivalent to 179 gallons per hour on an annual average of #2 fuel oil or 

specification used oil based on a heating value of 140,000 BTUs/gallon. 

In accordance vcith Env-A 1211.020)(1 and 2), EU2-EG shall be limited to less than 500 

hours of operation during any consecutive 12-month period and the combined theoretical 

potential emissions of NOx from all such generators are limited to less than 25 tons for any 

consecutive 12-month period. 

VIII. 

3. In accordance with Env-A 1211.04(d) and,Env-A 1211.05(d)(5), the EU1 Boiler, firing 

wood fuel or capable of firing a combination of wood fuel and oil and equipped with a 

vibrating grate, shall comply with the oxides of nitrogen (NOx) Reasonably Available 

Control Technology (RACT) emission limit of 0.33 poundsper million BTU 

Applicable Operational and Emission Limitations (continued): 

(lb/mmBTU), based on a 24-hour calendar day average. 

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In accordance with Env-A 1604.01(a), the sulfur content of No. 2 oil, specification used 

oil and off-road diesel oil shall not exceed 0.40 percent sulfur by weight. 

In accordance with Env-A 2003.02 and 40 CFR Part 60, Subpart Db, Bridgewater shall 

not cause or allow average opacity from fuel burning devices installed after May 13, 1970 

in excess of 20 percent for any continuous 6-minute period in any 60-minute period, 

except for one of the following exemptions in accordance with Env-A 2003.04(a): 

ao During periods of startup, shutdown and malfunction, average opacity shall be 

allowed to be in excess of 20 percent for one period of 6 continuous minutes in 

any 60 minute period; or 

b° During periods of normal operation, soot blowing, grate cleaning, and cleaning of 

fires, average opacity shall be allowed to be in excess of 20 percent but not more 

than 27 percent for ohe period of 6 continuous minutes in any 60 minute period. 

To avoid the requirements of the federal Prevention of Significant Deterioration (PSD) 

regulation 40 CFR 52.21(b)(1)(i)(b), the NOx emission rate for the EU1 Boiler shall be 

limited to 57.0 potmds per hour (lbs/lu') average for any consecutive 365-day period. 

Compliance with this emission limit shall be demonstrated using the NOx CEM data. 

To avoid the requirements of the federal PSD regulation 40 CFR 52.21 (b)(1)(i)(b), the 

carbon monoxide (CO) emission rate for the EU1 Boi• e, hatl be limited to 57.0 lbs/hr 

average for any consecutive 365-day period. Continuous Emission Monitoring (CEM) 

requirements are described in Section X.B. of this permit. 

In accordarice with RSA 125-C:6, RSA 125-C:11 and Env-A 606.04, the carbon 

monoxide (CO) emission rate for the EU1 Boiler shall be limited to 125 lbs/lar for each 

calendar day average as calculated on the CEM system or using the calculation shown in 

Section X.B.6. of this permit. 

In accordance with 40 CFR Part 60, Subpart Db, the PM emission rate for the EU1 

Boiler shall, be limited to 0.10 lb/mmBTU heat input. 

h:\permits\eurrent\tit lev\amendmn t\tvbridg2.arad Revised 11/15/98 
Page 12 

IX. Emission Reductions Trading Requirements: 

The Permittee did not request emissions reductions trading in the facility operating permit application. At 

the time of this permit preparation, DES did not included any permit terms authorizing emissions trading 

in this permit. All emissions reductions trading must be authorized under the applicable requirements of 

either Env-A 3000 (the "Emissions Reductions Credits (or ERCs) Trading Program") or Env-A-3100 

(the "Discrete Emissions Reductions (or DERs) Trading Program) and 42 U.S.C. §7401 et seq. (The 

"Act"), and must be provided for in this Permit." 

X. Compliance Demonstration Requirements: 

The permittee is subject to the monitoring/testing, record keeping and reporting requirements as 

contained in the following permit sections. Refer to the standard operating practices and the 

manufacturer's O&M manual for additional information. The pollution control equipment and EU1 

Boiler shall be monitored and maintained in accordance with the appropriate manufacturers' O&M 

manuals. 

Monitoring/Testing Requirements for Total Suspended Particulate Controls 

(Regulatory cite Env-A 806.01(a) and 40 CFR Part 70.6(a)(3)) 

1. PC1 Multiclone Monitoring and Testing Requirements 

The PC1-Multiclone shall be operated in series with the PC2-GBF unit. 

Conduct monitoring of pressure differential across the PC1 Multiclone unit every 

two hours. An acceptable pressure differential shall be in accordance with 

standard operating practices and manufacturer's recommended operating 

parameters and shall be maintained between 2" and 5" of water column. Pressure 

differential readings shall be recorded on standard forms and kept on file at the 

facility for review by the DES upon request. Th6 standard forms shall include the 

acceptable operating parameters for quick reference by facility personnel. 

Facility personnel shall conduct a daily inspection for visible emissions of the PC 1 

Multiclone unit to observe leaks using EPA Method22, 40 CFR Part 60, 

Appendix A. If a leak(s) is observed, facility personnel shall take immediate steps 

to repair the leak. Daily observations, maintenance and repairs performed to the 

unit shall be recorded in the log book. 

During down-time, maintenance periods, facility personnel shall inspect inlet and 

outlet vanes and boots for any build up of caked dust. All caked dust shall be 

removed during each down-time maintenance period. 

Observations of operating parameters outside of the standard operating practices 

included in this permit shall be recorded, investigated and corrected immediately. 

If this results in a permit limit exceedance, Bridgewater personnel shall contact 

DES within 8 hours in accordance with Section XXX of this permit. 

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XQ 

Page 13 

Compliance Demonstration Requirements (continued): 

2. PC2 GBF Monitoring and Testing Requirements 

The PC2-GBF is used to control particulate matter emissions. The particulate removal 

section of the PC2-GBF shall be blown by a rotary blower to the reverse pulse jet 

baghouse. Bridgewater has been able to maintain compliance with particulate emission 

standards without operating the electrostatic grid. If the compliance status changes, 

Bridgewater will initiate use of the electrostatic grid to comply with the applicable 

particulate emission standards. 

a. Bi-Hourly Monitoring/Testing Requirements 

In accordance with the Bridgewater's O&M manual and standard operating 

practices for this equipment, on a bi-hourly basis, facility personnel shall: 

Check and record the pressure on the PC2 GBF differential pressure 

gauge. The differential pressure across the PC2-GBF shall be maintained 

between 2" and 12" of water column. Lift blower discharge pressure shall 

be maintained between 2 and 6 psig. 

ii. Check and record the purge air flow pressure. Purge air discharge flow 

pressure shall be maintained between 2 and 5 psig. 

iii. Check and record the purge air temperature. Purge air temperature shall 

be maintained between 150°F and 350°F, with the optimal temperature 

being 250°F. 

iv. The facility operator shall respond to all equipment alarms immediately. 

Check and record, if in operation, the voltage on the PC2 GBF 

voltmeters. The PC2 GBF voltage shall be maintained, when in 

operation, between 20 to 30 KV. 

vi. Check and record, if in operation, the PC2 GBF current amperage on the 

PC2 GBF ammeters. The PC2 GBF amperage, when in operation, shall 

be maintained between 200 and 400 milliamps. 

vii. Bi-hourly monitoring data shall be recorded daily on standard forms and 

kept on file at the facility for review by the DES upon request. The 

standard forms shall include the acceptable operating parameters for quick 

reference by facility personnel. 

viii. Observations of operating parameters outside of the standard operating 

practices included in this permit shall be recorded, investigated and 

corrected immediately. If this results in a permit limit exceedance, 

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Compliance Demonstration Requirements (continued): 

Bridgewater personnel shall contact DES within 8 hours in accordance 

with Section XXX of this permit. 

b. Daily Monitoring/Testing Requirements 

The PC2-GBF shall be inspected at least once each shift. The casing, 

piping and ducts shall be inspected for leaks, abnormal noise, hot spots and 

fires. Local instrumentation shall be monitored for normal values. Blower 

bearings shall be checked for normal temperature and vibration. The local 

control panel shall be monitored for proper indication of normal values and 

alarms. 

ii. Observations of operating parameters outside of the standard operating 

practices included in this permit shall be recorded, investigated and 

corrected immediately. If this results in a permit limit exceedance, 

Bridgewater personnel shall contact DES within 8 hours in accordance 

with Section XXX of this permit. 

3. PC3 Baghouse Monitoring and Testing Requirements 

a. Bi-Hourly Monitoring/Testing Requirements 

In accordance with the manufacturer's O&M manual for the PC3- 

Baghouse, facility personnel shall check and record the pressure on the 

PC3-Baghouse differential pressure gauge on a bi-hourly basis. The 

differential pressure shall be maintained between 2" and 6" of water. In the 

event of a bag failure, particulate matter can be by-passed back to the 

furnace until repairs are made. 

ii. Bi-hourly monitoring data shall be recorded daily on standard forms and 

kept on file at the facility for review by the DES upon request. The 

standardforms shall include the acceptable operating parameters for quick 

reference by facility personnel. 

b. Daily Monitoring/Testing Requirements 

Bridgewater shall conduct daily visual inspections of the baghouse 

emissions in accordance with 40 CFR Part 60 Appendix A Method 22. 

ii. Check and record any abnormal operation conditions of the rotary valve or 

ash removal auger. These parameters are continually monitored through 

the plant's PLC and an annunciator is initiated upon fault. 

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Page 15 

Compliance Demonstration Requirements (continued): 

iii. Check and record the pressure on the pulse air pressure gauge, located at 

the pulse air inlet manifold. The pressure shall be maintained between 60 

to 110 psi. 

iv, Daily monitoring data shall.be recorded daily on standard forms and kept 

on file at the facility for review by the DES upon request. The standard 

forms shall include the acceptable operating parameters for quick reference 

by facility personnel. 

Vo Observations of operating parameters outside of the standard operating 

practices included in this permit shall be recorded, investigated and 

corrected immediately. If this results in a permit limit exceedance, 

Bridgewater personnel shall contact DES within 8 hours in accordance 

with Section XXX of this permit. 

4. Stack Testing Requirements 

At such times as specified by the DES, Bridgewater shall conduct USEPA method 

compliance, stack test for emissions at maximum production rate conditions, and/or at the 

request of the DES, at any Other production rate at which maximum emissions might 

occur. 

If requested, the emissions stack test shall be conducted in accordance, with 40 CFR Part 

60, Sections 60.8(a), (b), (d), (e) and (f), Appendix A and the DES' policy "Procedures 

and Minimum Requirements for Stack Tests". 

Compliance testing shall be planned and carried out in accordance with the following 

schedule. If requested by the DES or if the testing protocol currently used changes, 

Bridgewater shall submit to the DES, at least 30 days prior to the commencement of 

testing, a pretest report presenting the following information: 

a. Calibration methods and sample data sheets; 

b. Description of the test methods to be used', 

c. Pre-test preparation procedures; 

d. Sample collection and analysis methods; 

e. Process data to be collected; and 

f. Complete test program description. 

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Compliance Demonstration Requirements (continued): 

If requested by DES or if the current testing protocol is changed, at least 15 days prior to 

the test date, Bridgewater, and any contractor that Bridgewater retains for performance of 

the test, shall participate in a pretest conference with a DES representative. Emission 

testing shall be carried out under the observation of a DES representative. Within 60 days 

after completion of testing, Bridgewater shall submit a test report to the DES. 

Any compliance stack test results determined following 40 CFR Part 60 paragraph 60.8, 

which show violations of the emission limitations shall be considered violations of this 

permit. 

5. Stack Inspections 

In accordance with 40 CFR 70.6(a)(3), Bridgewater shall conduct annual visual 

inspections of each stack and fuel burning device. Records of inspections and subsequent 

maintenance conducted as a result of the annual inspections shall be kept on file at the 

facility for review by the DES and/or EPA upon request. 

CEM Monitoring/Testing Requirements 

(Regulatory Cite Env-A 805.02 and 40 CFR Part 70.6(a)(3)) 

Bridgewater shall install, maintain and operate the following CEM systems in the EU1-Boiler 

exhaust piping. 

1. Opacity CEM 

The opacity CEM system shall meet the requirements of 40 CFR Part 60, Appendix B, 

Performance Specification and Env-A 805. Determination of compliance with the 

opacity limits established in Section VIII.C. of this permit shall be made by the plant 

opacity CEM or visible emission readings taken once per shift following the procedures 

specified in 40 CFR Part 60, Appendix A, Method 9. Calculations shall be performed as 

specified in Section X.B.6. of this permit. 

2. NO• CEM 

The NO CEM shall meet the requirements of 40 CFR Part 60, Appendix B, Performance 

Specification 2 and Env-A 805. Detrrmination of compliance with the NO emission 

limits established in Section VIII.C. of this permit shall be made by the plant NOx CEM. 

The NO emission rate shall be calculated daily as the average of the calendar day averages 

as calculated on the plant NO CEM. Calculations shall be performed as specified in 

Section X.B.6. of this permit. 

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X. Compliance Demonstration Requirements (continued): 

3. CO CEM 

The CO CEM system shall meet the requirements of 40 CFR Part 60, Appendix B, 

Performance Specification 4 and Env-A 805. Determination of compliance with the CO 

emission limits established in Section VIII.C. of this permit shall be made by the plant CO 

CEM. The CO emission rate shall be calculated daily as the average of the calendar day 

averages as calculated on the plant CO CEM. Calculations shall be performed as specified 

in Section X.B.6. of this permit. 

4. Oxygen (0•) CEM 

The 02 CEM system shall meet the requirements of 40 CFR Part 60, Appendix B, 

Performance Specification 3 and Env-A 805. 

5. Volumetric Flow CEM 

The stack volumetric flow measuring device which shall meet all of the requirements of 40 

CFR Part 60, Appendix B, Performance Specification 6. The stack flow monitor shall 

have an automatic blow-back purge system installed and activated during all times of 

boiler operation. The stack volumetric flow measuring device combined with the 

concentration CEM equipment for CO and NOx shall be used to calculate mass emission 

rates for comparison with the emission standard specified in permit condition VIII.C. The 

stack volumetric flow monitor shall also meet the following requirements: 

ao All differential pressure flow monitors shall have an automatic blow-back purge 

system installed and in wet stack emissions shall have the capability for drainage of 

the sensing lines. 

bo The. stack flow monitoring system shall have the capability for on-line manual 

transducer calibration and for a zero check. 

The stack flow monitoring system shall be capable of displaying the individual 

parameters used in the stack flow calculation. For example, a differential pressure 

monitoring system shall be able to display instantaneous values of differential 

pressure, stack temperature, and relevant constants used in the calculation which 

reflect the static pressure assumed, gas molecular weight assumed and the pitot 

tube coefficient utilized. 

6. Calculations: 

a. CEM calendar day averages shall be calculated as follows: 

Calendar Day average (sum of all valid hour lb/hr averages for the 

calendar day)/(24 hours of CEM system downtime for the day); 

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Compliance Demonstration Requirements (continued): 

ii. Calendar day averages shall only be valid for days with 18 or more valid 

hours of CEM data; 

iii. A valid hour of CEM data shall be defined as a minimum of 45 minutes 

collection of CEM readings taken in a calendar hour; and 

Hours of CEM.system downtime shall be defined as the number of calendar 

hours when the CEM system has not collected data or is out-of-control for 

greater than 15 minutes for any reason (i.e. audits, CEM system 

calibration, CEM system failures, etc.) 

b. CEM consecutive 365-day averages shall be calculated as follows: 

Consecutive 365-day average (sum of all valid calendar day averages for 

the 365-day period)/(365 days of CEM system downtime); and 

ii. Days of CEM system downtime shall be def'med as the number of calendar 

days when the CEM system has collected less than 18 valid hours of CEM 

data. 

Co Hours or days when the CEM system has been intentionally shutdown when the 

facility is not operating shall not be counted as CEM system downtime. 

Bridgewater shall be subject to all of the CEM requirements of Env-A 805 which shall 

include but not be limited to: quarterly audit requirements, excess emission report 

requirements, quality control written procedure requirements for gaseous CEM monitors 

and record keeping requirements. The specific record keeping and reporting requirements 

are described in Section X.D. and X.E. of this permit. 

Bridgewater shall continuously monitor and record data from the gaseous CEM system 

during all periods of operation, including periods of startup, shutdown, malfunctions or 

emergency conditions, except when the stack flow is less than 13,100 dry SCFM (17,500 

wet SCFM). The opacity CEM shall be continuously monitoring and recording data 

during all periods of operation, regardless of the stack flow rate. 

Excess emissions indicated by the CEM system shall be considered violations of the 

applicable emission limit for purposes of this permit, except where Bridgewater can 

adequately demonstrate to the DES that the recorded exceedance resulted from a CEM 

malfunction. 

10. Bridgewater shall install, maintain and operate a continuous steam flow rate 

monitoring/recording system which shah meet all applicable ASME specifications. 

Calibration of the steam flow transducer shall occur at least once annually. If 

adequate straight length of piping is not available, then in lieu of a measuring 

system that meets 

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Xo Compliance Demonstration Requirements fcontinued): 

ASME specifications, Bridgewater may use a steam flow rate monitoring system 

that can be calibrated by instruments installed, maintained and calibrated per 

ASME specifications or by other methods approved by the DES. 

C. Compliance Demonstration Requirements for the EU2 Cooling Pond State Enforceable Only 

In accordance with Env-A 1400, prior to changing cooling water treatment chemicals, 

Bridgewater shall evaluate the impact of the proposed chemicals on the 24-hour and 

annual deminimus limits of the DES Air Toxics List. If the impact exceeds the deminimus 

24-hour or annual levels, Bridgewater shall notify DES in writing of the proposed 

chemical changes. Written approval from DES shall be received prior to making the 

chemical change, if the deminimus levels are exceeded. If the impact does not exceed the 

deminimus levels, Bridgewater may make the chemical change and shall keep the records 

of the impact analysis in the facility files in accordance with the recordkeeping 

requirements of Section X.D. of this permit. 

The following equations shall be used to evaluate the impact of cooling water chemicals 

on the 24-hour and annual deminimus levels. This equation shall be used for each 

chemical used in the cooling water that is included on the DES Air Toxics List. Also, this 

equation shall be used to estimate particulate emissions from both chemical additives to 

the water and total dissolved solids contained in the water for emission-based fees as 

described in Section XXV. of this permit. 

24-hour Emissions (lb/hr) (DR)*(Hourly CR)*(8.34 lb/gal)*(C) 

Example Calculation: 24-hour emissions of total dissolved solids (TDS) (lb/hr) 

(0.000012 gal/gal)*(948.000 gal/hr)*(8.34 lb/gal)*(3600 ppmw TDS) 

lxl06 

0.342 lb/hr TDS 

Annualized Emissions (lb/yr) (24-hour Emissions, lb/hr)*(Operating hours/year) 

Example Calculation: Annualized emissions of TDS (lb/yr) (0.342 lb/hr)*(8760 hrs/yr) 

2,992 lbs/yr TDS 

Where: DR drift rate for pond (based on manufacturer's data for facility pond), 

gal drift/gal circulation water (0.000009474 gal/gal 0.00001636 

gal/gal) 

Hourly CR water circulation rate, gal/hr 

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Page 20 

Compliance Demonstration .Requirements (continued): 

C concentration of chemical of interest (or total dissolved solids 

concentration) in circulation water, ppmw (use maximum potential 

concentration for deminimus impact evaluation and average or actual 

data for emission-based fee calculations). 

D. Record Keeping Requirements 

In accordance with 40 CFR Part 70.6(a)(3)(ii)(B), Bridgewater shall retain records of all 

required monitoring data, record keeping and reporting requirements and support 

information for a period of at least 5 years from the date of the origination. These data 

and reports shall not be discarded, removed or destroyed thereafter without the express 

written approval of the director in accordance with Env-A 901.11. 

In accordance with 40 CFR 70.6(c)(5), Bridgewater shall meet the requirements for 

compliance certification with terms and conditions contained in this permit, including 

emission limitations, standards, or work practices. Compliance certifications shall meet the 

requirements outlined in Section XXIII of this permit. 

Pursuant to Env-A 901.03, for each fuel burning device at the facility, the owner or 

operator shall keep records on fuel utilization in accordafice with the following: 

a° Monthly records of liquid fuel utilization for each fuel burning device at the facility 

shall include: 

consumption of each fuel type per calendar month and a consecutive 12- 

month total; 

ii. fuel type; 

iii. viscosity; 

iv. sulfur content as percent sulfur by weight of fuel; and 

v. BTU content per gallon of fuel. 

bo Delivery tickets from each fuel oil supplier for each shipment of fuel oil received 

shall be kept on file in a form suitable for inspection and shall be made available to 

the DES and/or EPA upon request. Each delivery ticket shall indicate the name, 

address and telephone number of the fuel oil supplier, the quantity of fuel oil 

delivered, and the percent sulfur by weight of the fuel oil being delivered. If 

delivery tickets do not contain sulfur content of fuel being delivered, Bridgewater 

shall perform testing in accordance with appropriate ASTM test methods to 

deternaine compliance with the sulfur content limitation provisions in Env-A 

1604.01(a) and 1604.01(c)2 for liquid fuels. 

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Xo Compliance Demonstration Requirements (continued): 

Page 21 

c. Records shall be kept of hours of operation corresponding to the utilization and 

distribution of all fuels. 

NO Record Keeping Requirements 

In accordance with Env-A 901.08, for each fuel burning device, including boilers, turbines 

and internal combustion engines, the following information shall be recorded and 

maintained: 

a. Facility information, including: 

i. Source name; 

ii. Source identification; 

iii. Physical address; 

iv. Mailing address; 

v. Date of origination for reports; 

vi. Facility contact and rifle; 

vii. Facility telephone number; 

Identification of each fuel burning device at the facility. 

Operating schedule information for each identified fuel burning device, including: 

i. days per calendar week during the normal operating schedule 

ii. Hours per day during the normal operating schedule and for a typical 

ozone season day, if different from the normal operating schedule 

iii. Hours per year during the normal operating schedule. 

Type and amount of fuel or waste burned, for each fuel burning device, during 

normal operating conditions and for a typical ozone season day 4, if different from 

normal operating conditions, on an hourly basis in mmBTU/hr. 

bo 

Co 

Typical ozone season day is defined any day between May and October. 

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Compliance Demonstration Requirements (continued): 

eo The following NO emission data, including records of total annual emissions, in 

tons per year (tpy), and typical ozone season day emissions, in pounds per day 

(lbs/day), shall be maintained at the facility for a minimum of 4 years: 

Theoretical potential emissions for the calculation year for each fuel 

burning device; and 

ii. Actual NOx emissions for each fuel burning device. 

E. Reporting Requirements 

In accordance with Env-A 901.09(b), NO emission data for all facility fuel burning 

devices shall be reported to the DES annually by April 15 of the following year. The NO 

emissions shall be collected from the CEM data. 

2. Malfunction Reporting 

In accordance with Env-A 902.02 and 40 CFR Part 70.6(a)(3)(iii)(B), the owner or 

operator shall notify the DES of a malfunction or breakdown of air pollution control 

equipment within 8 hours of each such occurrence, as described in Section XXX of this 

permit. 

3. Fuel Usage Reporting 

In accordance with Env-A 901.08(c), monthly fuel usage information, by device, fuel type, 

and sulfur content shall be submitted in writing to the DES on a quarterly basis within 30 

days after the end of the quarter for which reporting is required. 

4. Excess Emission Reporting 

In accordance with Env-A 805, within 30 days following the close of each calendar 

quarter, Bridgewater shall submit to the DES excess emission reports for the CEM 

systems and the EU1 Boiler as approved by the DES containing information specified in 

Env-A 805 as well as the following information:" 

a° Calendar daily averages of NO and CO lb/hr and part per million (ppm) dry 

whether or not an excess emission has occurred; 

b. Calendar daily averages of percentage oxygen (02) on a dry basis; 

c. Calendar daily averages of steam generation rate; 

d, Calendar daily averages of stack flow (dscfm); 

h:\permits\current\fitlev•mend mnt\tvbridg2.nmd Revised 11/15/98 
Compliance Demonstration Requirements (continued): 

Page 23 

e• Average steam production rate for each consecutive 24-hour period where the 

production rate exceeds any of the limits set forth in Section VIII.C. of this permit; 

£ CEM system availability data; 

Estimated amount in tons (wet basis) of wood chips consumption per month and a 

consecutive twelve month total; 

h° Amount in gallons Of #2 fuel oil and specification used oil consumption per 

calendar month where the fuel usage cap set forth in Section VIII.C. 1 of this 

permit has been exceeded. 

All periods of gaseous and opacity exceedances including start time, end time and 

magnitude and the cause of the exceedance. 

CEM Audit Reporting 

Within 30 days following the close of each calendar quarter, Bridgewater shall submit to 

the DES, a CEM audit report for all audits conducted as specified in Env-A 805.06 and 

Section X.B. of this permit. 

In accordance with 40 CFR 70.6(a)(3)(iii)(A), a summary report of monitoring and testing 

requirements shall be submitted every six months. Semi-annual reports shall be submitted 

no later than July 31 for the January through June report and no later than January 31 for 

the July through December report. All instances of deviations from permit requirements 

shall be clearly identified in such reports. All required reports Shall be certified for 

accuracy by a responsible official consistent with 40 CFR 70.5(d). This certification and 

any other certification required under this part shall include the certification of accuracy 

statement included in Section XXIII.B. of this permit. 

The report shall contain a summary of the following information: 

a. Monitoring and preventive maintenance results for PC through PC3. 

bo Preventive maintenance and inspection results for EU1-Boiler and related stacks 

and EU3-EG. 

c. All instances of deviations from permit requirements shall be clearly identified. 

Annual reporting and payment of emission based fees shall be conducted in accordance 

with Section XXV of this Permit. 

Compliance Demonstration Requirements (continued): 

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Revised I/I 5/98 
Page 24 

An annual compliance certification as presented in Section XXIII of this Permit shall be 

submitted to DES and USEPA by April 15 following each reporting year. 

Pursuant to 40 CFR Part 70.6 (c)(1), all documents submitted to the DES and/or EPA 

shall contain certification by the responsible official of truth, accuracy, and completeness as described in Section XXIII.B. of this permit. 

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IX. Requirements Currently Not Applicable: 

The Permitee did not identify any requirements not currently applicable to the facility. 

General Title V Operating Permit Conditions 

X. Issuance of a Title V Operating Permit: 

This Permit is issued in accordance with the provisions of Part Env-A 609. In accordance with 

40 CFR 70.6(a)(2) this Permit shall expire on the date specified on the cover page of this Permit, 

which shall not be later than the date five (5) years after issuance of this Permit. 

Permit expiration terminates the Permittee's right to operate the Permittee's emission units, control 

equipment or associated equipment covered by this permit, unless a timely and complete renewal 

application is submitted at least 6 months before the expiration date. 

Bo Pursuant to Env-A 609.02(b), this Permit shall be a state permit to operate as defined in RSA 

125-C:11, III. 

XI. Title V Operating Permit Renewal Procedures: 

Pursuant to Env-A 609.06(b), an application for renewal of this Permit shall be considered timely if it is 

submitted to the Director at least six months prior to the designated expiration date of this Permit. 

XII. Application Shield: 

Pursuant to Env-A 609.07, if an applicant submits a timely and complete application for the issuance or 

renewal of a Permit, the failure to have a Permit shall not be considered a violation of this part until the 

Director takes final action on the application. 

XIII. Permit Shield: 

A. Pursuant to Env-A 609.08(a), a permit shield shall provide that: 

For any applicable requirement or any state requirement found in the New Hampshire 

Rules Governing the Control of Air Pollution specifically included in this Permit, 

compliance with the conditions of this Permit shall be deemed compliance with said 

applicable requirement or said state requirement as of the date of permit issuance; and 

For any potential applicable requirement or any potential state requirement found in the 

New Hampshire Rules Governing the Control of Air Pollution specifically identified in this 

TitleV Operating Permit Section IX Table 8 as not applicable to the stationary source or 

area source, the Permittee need not comply with the specifically identified federal or state 

requirements. 

B. The permit shield identified in Section XIII.A. of this Permit shall apply only to those conditions 

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Co 

Page 26 

incorporated into this Permit in accordance with the provisions of Env-A 609.08(b). It shall not 

apply to certain conditions as specified in Env-A 609.08(c) that may be incorporated into this 

Permit following permit issuance by DES. 

If a Title V Operating Permit and amendments there to issued by the DES does not expressly 

include or exclude an applicable requirement or a state requirement found in the NH Rules 

Governing the Control of Air Pollution, that applicable requirement or state requirement shall not 

be covered by the permit shield and the Permittee shall comply with the provisions of said 

requirement to the extent that it applies to the Permittee. 

If the DES determines that this Title V Operating Permit was issued based upon inaccurate or 

incomplete information provided by the applicant or Permittee, any permit shield provisions in 

said Title V Operating Permit shall be void as to the portions of said Title V Operating Permit 

which are affected, directly or indirectly, by the inaccurate or incomplete information. 

Pursuant to Env-A 609.08(f), nothing contained in Section XIII of this Permit shall alter or affect 

the ability of the DES to reopen this Permit for cause in accordance with Env-A 609.18 or to 

exercise its summary abatement authority. 

Pursuant to Env-A 609.08(g), nothing contained in this section or in any title V operating permit 

issued by the DES shall alter or affect the following: 

The ability of the DES to order abatement requiring immediate compliance with applicable 

r •equirements upon finding that there is an imminent and substantial endangerment to 

public health, welfare, or the environment; 

The state of New Hampshire's ability to bring an enforcement action pursuant to RSA 

125-C: 15,11; 

The provisions of section 303 of the Act regarding emergency orders including the 

authority of the EPA Administrator under that section; 

The liability of an owner or operator of a source for any violation of applicable 

requirements prior to or at the time of permit issuance; 

The applicable requirements of the acid rain program, consistent with section 408(a) of the 

Act; 

The ability of the DES or the EPA Administrator to obtain information about a stationary 

source, area source, or device from the owner or operator pursuant to section 114 of the 

Act; or 

The ability of the DES or the EPA Administrator to enter, inspect, and/or monitor a 

stationary source, area source, or device. 

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XIV. 

XV. 

XVI. 

Page 27 

Reopening for Cause: 

The Director shall reopen and revise a Title V Operating Permit for cause if any of the circumstances 

contained in Env-A 609.18(a) exist. In all proceedings to reopen and reissue a Title V Operating Permit, 

the Director shall follow the provisions specified in Env-A 609.18(b) through (g). 

Administrative Permit Amendments: 

Pursuant to Env-A 612.01, the Permittee may implement the changes addressed in the request for 

an administrative permit amendment as defined in Part Env-A 100 immediately upon submittal of 

the request. 

no Pursuant to Env-A 612.01, the Director shall take final action on a request for an administrative 

permit amendment in accordance with the provisions of Env-A 612.01(b) and (c). 

Operational Flexibility_: 

Pursuant to Env-A 612.02(a), the Permittee subject to and operating under this Title V Operating 

Permit may make changes involving trading of emissions under this existing Title V Operating 

Permit at the permitted stationary source or area source without filing a Title V Operating Permit 

application for and obtaining an amended Title V Operating Permit, provided that all the 

conditions are met as specified in section XVI. A. 1. through 7. of this permit and a notice is 

submitted to the DES and EPA describing the intended changes. At this point, DES has not 

included any permit terms authorizing emissions trading in this permit. 

1. The change is not a modification under any provision of title I of the Act; 

The change does not cause emissions to exceed the emissions allowable under the 

title V operating permit, whether expressed therein as a rate of emissions or in 

terms of total emissions; 

3. The owner or operator has obtained any temporary permit required by Env-A 600; 

The owner or operator has provided written notification to the director and 

administrator at least 15 days prior to the proposed change and such written 

notification includes: 

a. The date on which each proposed change will occur; 

b. A description of each such change; 

Co Any change in emissions that will result and how this change in emissions 

will comply with the terms and conditions of the permit; 

d. A written request that the operational flexibility procedures be used; and 

e. The signature of the responsible official, consistent with Env-A 605.04(b); 

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The Title V Operating Permit issued to the stationary source or area source 

already contains terms and conditions including all terms and conditions which 

determine compliance required under 40 CFR 70.6(a) and (c) and which allow for 

the trading of emissions increases and decreases at the permitted stationary source 

or area source solely for the purpose of complying with a federally-enforceable 

emissions cap that is established in the permit independent of otherwise applicable 

requirements; 

The owner or operator has included in the application for the Title V Operating 

Permit proposed replicable procedures and proposed permit terms which ensure 

that the emissions trades are quantifiable and federally enforceable for changes to 

the Title V Operating Permit which qualify under a federally- enforceable 

emissions cap that is established in the Title V Operating Permit independent of the 

otherwise applicable requirements; and 

7. The proposed change complies with Env-A 612.02 (e). 

Bo Pursuant to Env-A 612.02(c), the Permittee subject to and operating under this Title V Operating 

Permit may make changes not addressed or prohibited by this existing Title V Operating Permit at 

the permitted stationary source or area source without filing a Title V Operating Permit 

application, provided that all the conditions specified in Env-A 612.02(c)(1) through (6) are met 

and a notice is submitted to the DES and EPA describing the intended changes. 

Co Pursuant to Env-A 612.02(d), the Permittee, Operator, Director and Administrator shall attach 

each notice of an off-permit change completed in accordance with Section XVI of this Title V 

Operating Permit to their copy of the current Title V Operating Permit. 

Do Pursuant to Env-A 612.02(e), any change under Section XVI shall not exceed any emissions 

limitations established under the NH Rules Governing the Control of Air Pollution, or result in an 

increase in emissions, or result in new emissions, of any toxic air pollutant or hazardous air 

pollutant other than those listed in the existing Permit. 

Eo Pursuant to Env-A 612.02(f), the off-permit change shall not qualify for the permit shield under 

Env-A 609.08. 

XVII. Minor Permit Amendments: 

Ao Pursuant to Env-A 612.04 prior to implementing a minor permit modification, the Permittee shall 

submit a written request to the Director in accordance with the requirements of Env-A 612.04(b). 

Bo The Director shall take final action on the minor permit amendment request in accordance with 

the provisions of Env-A 612.04(c) through (g). 

Pursuant to Env-A 612.04(g), the permit shield specified in Env-A 609.08 shall not apply to 

minor permit amendments under Section XVII. of this Permit. 

h:\permits\current\titlev•amendmnt\tvbridg2.amd 

Revised III 5/98 
Page 29 

Pursuant to Env-A612.04(i), the Permittee shall be subject to the provisions of Part Env-A 614 

and Part Env-A 615 if the change is made prior to the filing with the Director a request for a 

minor permit amendment. 

XVIII. Significant Permit Amendments: 

Ae Pursuant to Env-A .612.05, a change at the facility shall qualify as a significant permit amendment 

if it meets the criteria specified in Env-A 612.05(a)(1) through (7). 

Bt Prior to implementing the significant permit amendment, the Permittee shall submit a written 

request to the Director which includes all the information as referenced in Env-A 612.05(b) and 

(c) and shall be issued an amended Title V Operating Permit from the DES. The Permittee shall 

be subject to the provisions of Env-A 614 and Env-A 615 ifa request for a significant permit 

amendment is not filed with the Director and/or the change is made prior to the issuance of an 

amended Title V Operating Permit. 

Cm The Director shall take final action on the significant permit amendment in accordance with the 

procedures specified in Env-A 612.05(d), (e) and (f). 

XIX. Title V Operating Permit Suspension, Revocation or Nullification: 

At Pursuant to RSA 125-C: 13, the Director may suspend or revoke any final permit issued hereunder 

if, following a hearing, the Director determines that: 

the Permittee has committed a violation of any applicable statute or state requirement 

found in the NewHampshire Rules Governing the Control of Air Pollution, order or 

permit condition in force and applicable to it; or 

that the emissions from any device to which this Permit applies, alone or in conjunction 

with other sources of the same pollutants, presents an immediate danger to the public 

health. 

The Director shall nullify any Permit, if following a heating in accordance with RSA 541-A:30, II, a finding is made that the Permit was issued in whole or in part based upon any information 

proven to be intentionally false or misleading. 

XX. Inspection and Entry: 

Pursuant to Env-A 614.01, EPA and DES personnel shall be granted access to the facility covered by this 

Permit, in accordance with RSA 125-C:6,VII for the purposes of: inspecting the proposed or permitted 

site; investigating a complaint; and assuring compliance with any applicable requirement or state 

requirement found in the NH Rules Governing the Control of Air Pollution and/or conditions of any 

Permit issued pursuant to Chapter Env-A 600. 

h:\permits\eurrent\fitlev•amendmnt\tvbridg2.amd 

Revised 11/15/98 
XXI. Certifications: 

Page 30 

A. Compliance Certification Report 

In accordance with 40 CFR 70.6(c) the Responsible Official shall certify, for the previous calender 

year, that the facility is in compliance with the requirements of this permit. The report shall be 

submitted annually, no later than April 15th of the following year. The report shall be submitted 

to the DES and to the U.S. Environmental Protection Agency New England Region. The report 

shall be submitted in compliance with the submission requirements below. 

In accordance with 40 CFR 70.6(c)(5), the report shall describe: 

1. The terms and conditions of the Permit that are the basis of the certification; 

The current compliance status of the source with respect to the terms and conditions of this 

Permit, and whether the method was continuous or intermittent during the reporting 

period; 

The methods used for determining compliance, including a description of the monitoring, 

record keeping, and reporting requirements and test methods; and 

Any additional information required by the DES to determine the compliance status of the 

source. 

B. Certification of Accuracy Statement 

All documents submitted to the DES shallcontain a certification of accuracy statement by the responsible 

official of truth, accuracy, andcompleteness. Such certification shall be in accordance with the 

requirements of 40 CFR 70.5(d) and contain the following language: 

"I am authorized to make this submission on behalf of the facility for which the submission is 

made. Based on information and belief formed after reasonable inquiry, I certify that the 

statements and information in the enclosed documents are to the best of my knowledge and belief 

true, accurate and complete. I am aware that there are significant penalties for submitting false 

statements and information or omitting required statements and information, including the 

possibility of f'me or imprisonment." 

All reports submitted to DES (except those submitted as emission based fees as outlined in Section XXIII 

of this Permit) shall be submitted to the following address; 

New Hampshire Department of Environmental Services 

Air Resources Division 

6 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

ATTN: Compliance Bureau 

h:\permits\eurrent\titlcv•mendmnt\tvbridg2.amd 

Revised I/15/98 
XXIII. 

Page 31 

All reports submitted to EPA shall be submitted to the following address; 

Office of Environmental Stewardship 

Director Air Compliance Program 

United States Environmental Protection Agency 

Congress Street 

Suite 1100 (SEA) 

Boston, MA 02114-2023 

ATTN: Air Compliance Clerk 

Enforcement: 

Any noncompliance with a permit condition constitutes a violation of RSA 125-C: 15, and, as to the 

conditions in this permit which are federally enforceable, a violation of the Clean Air Act, 42 U.S.C. 

Section 7401 et seq., and is grounds for enforcement action, for permit termination or revocation, or for 

denial of an operating permit renewal application by the DES and/or EPA. Noncompliance may also be 

grounds for assessment of administrative, civil or criminal penalties in accordance with RSA 125-C: 15 

and/or the Clean Air Act. This Permit does not relieve the Permittee from the obligation to comply.with 

any other provisions of RSA 125-C, the New Hampshire Rules Governing the Control of Air Pollution, 

or the Clean Air Act, or to obtain any other necessary authorizations from other governmental agencies, 

or to comply with all other applicable Federal, State, or Local rules and regulations, not addressed in this 

Permit. 

In accordance with 40 CFR 70.6 (a)(6)(ii) a Permittee shall not claim as a defense in an enforcement 

action that it would have been necessary to halt or reduce the permitted activity in order to maintain 

compliance with the conditions of this Permit. 

Emission-Based Fee Requirements: 

Ao The Permittee shall pay an emission-based fee annually for this facility as calculated each calendar 

year pursuant to Env-A 704.03. 

BJ The Permittee shall determine the total actual annual emissions from the facility to be included in 

the emission-based multiplier specified in Env-A 704.03(a) for each calendar year in accordance 

with the methods specified in Env-A 620. 

Co The Permittee shall calculate the annual emission-based fee for each calendar year in accordance 

with the procedures specified in Env-A 704.03 and the following equation: 

FEE E DPT • CPIm ISF 

Where: 

FEE 

E 

The annual emission-based fee for each calen•lar year as specified in Env-A 704. 

The emission-based multiplier is based on the calculation of total annual emissions 

as specified in Env-A 704.02 and the provisions specified in Env-A 704.03(a). 

h:\permits\current\fitlev•amendmnt\tvbridg2.amd 

Revised 11/15/98 
Page 32 

DPT 

CPIm= 

ISF 

The dollar per ton fee the DES has specified in Env-A 704.03(b). 

The Consumer Price Index Multiplier as calculated in Env-A 704.03(c). 

The Inventory Stabilization Factor as specified in Env-A 704.03(d). 

Do The Permittee shall contact the DES each calendar year for the value of the Inventory 

Stabilization Factor. 

The Permittee shall contact the DES each calendar year for the value of the Consumer Price Index 

Multiplier. 

FJ The Permittee shall submit, to the DES, payment of the emission-based fee and a summary of the 

calculations referenced in Sections XXIII.B. and C of this Permit for each calendar year by 

October 15 th of the following calendar year in accordance with Env-A 704.04. The emissionbased fee and summary of the calculations shall be submitted to the following address: 

New Hampshire Department of Environmental Services 

Air Resources Division 

6 Hazen Drive 

P.O. Box 0095 

Concord, NH 03302-0095 

ATTN.: Emissions Inventory 

GQ The DES shall notify the Permittee of any under payments or over payments of the annual 

emission-based fee in accordance with Env-A 704.05. 

XXIV. Duty To Provide Information 

In accordance with 40 CFR 70.6 (a)(6)(v), upon the DES's written request, the Permittee shall furnish, 

within a reasonable time, any information necessary for determining whether cause exists for modifying, 

revoking and reissuing, or terminating the Permit, or to determine compliance with the Permit. Upon 

request, the Permittee shall furnish to the DES copies of records that the Permittee is required to retain 

by this Permit. The Permittee may make a claim of confidentiality as to any information submitted 

pursuant to this condition in accordance with Part Env-A t03 at the time such information is submitted to 

DES. DES shall evaluate such requests in accordance with the provisions of Part Env-A 103. 

XXV. Property Rights 

Pursuant to 40 CFR 70.6 (a)(6)(iv), this Permit does not convey any property rights of any sort, or any 

exclusive privilege. 

XXVI. Severability Clause 

Pursuant to 40 CFR 70.6 (a)(5), the provisions of this Permit are severable, and if any provision of this 

Permit, or the application of any provision of this Permit to any circumstances is held invalid, the 

application of such provision to other circumstances, and the remainder of this Permit, shall not be 

affected thereby. 

h:\permies\current\titlev•ameadmnt\lvbridg2.amd 

Revised 11/15/98 
Page 33 

XXVII. Emergency Conditions 

Pursuant to 40 CFR 70.6 (g), the Permittee shall be shielded from enforcement action brought for 

noncompliance with technology based s emission limitations specified in this Permit as a result of an 

emergency 6. In order to use emergency as an affirmative defense to an action brought for 

noncompliance, the Permittee shall demonstrate the affirmative defense through properly signed, 

contemporaneous operating logs, or other relevant evidence that: 

A. An emergency occurred and that the Permittee can identify the cause(s) of the emergency; 

B. The permitted facility was at the time being properly operated; 

Co During the period of the emergency, the Permittee took all reasonable steps as expeditiously as 

possible, to minimize levels of emissions that exceeded the emissions standards, or other 

requirements in this Permit; and 

DJ The Permittee submitted notice of the emergency to the DES within two (2) business days of the 

time when emission limitations were exceeded due to the emergency. This notice must contain a 

description of the emergency, any steps taken to mitigate emission, and corrective actions taken. 

XXVIII. Permit Deviation 

In accordance with 40 CFR 70.6(a)(3)(iii)(B), the Permittee shall report to the DES all instances of 

deviations from Permit requirements, by telephone or fax, within 8 hours of discovery of such deviation 

pursuant to Env-A 902.02.. This report shall include the deviation itself, including those attributable to 

upset conditions as defined in the Permit, the probable cause of such deviations, and any corrective 

actions or preventative measures taken. Said Permit deviation shall also be submitted in writing to the 

DES within fifteen (15) days of documentation of the deviation by facility personnel. Deviations are 

instances where any Permit condition is violated and has not already been reported as an emergency 

pursuant to Section XXVII of this Permit. 

Reporting a Permit deviation is not an affirmative defense for action brought for noncompliance. 

Technology based emission limits are those established' on the basis of emission reductions achievable with various 

control measures or process changes (e.g., a new source performance standard) rather than those established to attain 

health based air quality standards. 

An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of 

the source, including acts of God, which situation would require immediate corrective action to restore normal operation, 

and that causes the source to exceed a technology based limitation under the permit, due to unavoidable increases in 

emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by 

improperly designed equipment, lack of preventative maintenance, careless or improper operations, operator error or 

decision to keep operating despite knowledge of any of these things. 

h:\permits\eurrent\titlev•amendmnt\Wbridg2.amd 

Revised 11/15/98 

STATE OF NEW HAMPSHIRE 

Department of Environmental Services 

Air Resources Division 

TITLE V OPERATING PERMIT 

Permit No: TV-OP-033 

Date Issued: December 13, 2000 

This certifies that: 

Concord Steam Corporation 

105 1⁄2 Pleasant Street 

Concord, NH 03302-1377 

has been granted a Title V Operating Permit for the following facility and location: 

Concord Steam Corporation 

105 1⁄2 Pleasant Street 

Concord, NH 03302-1377 

AFS Point Source Number 3301300032 

This Title V Operating Permit is hereby issued under the terms and conditions specified in the Title V 

Operating Permit Application filed with the New Hampshire Department of Environmental Services on 

July 1, 1996 with additional .information submitted on December 2, 1996, under the signature of the 

following responsible official certifying to the best of their knowledge that the statements and information 

therein are true, accurate and complete. 

Responsible Official: 

Peter Bloomfield 

President 

(603) 224-1461 

Technical Contact: 

Mark Saltsman 

General Manager 

(603) 224-1461 

This Permit is issued by the New Hampshire Department of Environmental Services, Air Resources 

Division pursuant to its authority under New Hampshire RSA 1.25-C and in accordance with the 

provisions of Code of the Federal Regulations 40 Part 70. 

This Title V Operating Permit shall expire on December 13, 2005. 

SEE ATTACHED SHEETS FOR ADDITIONAL PERMIT CONDITIONS 

For the New Hampshire Department of Environmental Services, Air Resources Division 

Director, Air Resources Division 
TABLE OF CONTENTS 

Page 2 of 34 

ABBREVIATIONS 3 

Facility Specific Title V Operating Permit Conditions 5 

I. Facility Description of Operations: 5 

II. Permitted Activities: 5 

III. Significant Activities Identification: 5 

A. Significant Activities: 5 

B. Stack Criteria: 6 

IV. Insignificant Activities Identification: 7 

V. Exempt Activities Identification: 7 

VI. Pollution Control Equipment/Technique Identification: 7 

VII. Alternative Operating Scenarios: 8 

VIII. Applicable Requirements: 8 

A. State-only Enforceable Operational and Emission Limitations: 8 

B. Federally Enforceable Operational and Emission Limitations 11 

C. Emission Reductions Trading Requirements 14 

D. Monitoring and Testing Requirements: 14 

E. Performance Testing Requirements: 19 

F. Recordkeeping Requirements: 20 

G. Reporting Requirements: 25 

IX. Requirements Currently Not Applicable: 27 

General Title V Operating Permit Conditions ,...27 

X. Issuance of a Title V Operating Permit: 27 

XI. 

XII. 

XIII. 

XIV. 

XV. 

XVI. 

XVII. 

XVIII. 

XIX. 

XX. 

XXI. 

A. 

B. 

XXII. 

XXIII. 

XXIV. 

XXV. 

XXVI. 

XXVII. 

XXVIII. 

Title V Operating Permit Renewal Procedures: 27 

Application Shield: 27 

Permit Shield: 27 

Reopening for Cause 28 

Administrative Permit Amendments 28 

Operational Flexibility 28 

Minor Permit Amendments 30 

Significant Permit Amendments 30 

Title V Operating Permit Suspension, Revocation or Nullification 30 

Inspection and Entry 30 

Certifications 31 

Compliance Certification Report 31 

Certification of Accuracy Statement 3 

Enforcement 32 

Emission-Based Fee Requirements 32 

Duty To Provide Information 33 

Property Rights 33 

Severability Clause 33 

Emergency Conditions 33 

Permit Deviation:..i 34 

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Final Issued 12/13/2000 
ABBREVIATIONS 

Page 3 of 34 

AAL 

AP-42 

ARD 

ASTM 

BACT 

BHP 

BTU 

CAA 

CAM 

CAS 

CEMS 

CFR 

CNG 

CO 

CO2 

COMS 

DER 

Env-A 

Env-Wm 

ECS 

ERC 

FR 

HAP 

HCI 

Hr 

kGal 

LAER 

Lb/hr 

LNB 

LNG 

LPG 

MACT 

mg/L 

MMBTU 

MMCF 

NAAQS 

NCCEM 

NESAPS 

NG 

Ambient Air Limit 

Compilation of Air Pollutant Emission Factors 

Air Resources Division 

American Society for Testing and Materials 

Best Available Control Technology 

Break Horse Power 

British Thermal Units 

Clean Air Act 

Compliance Assurance Monitoring 

Chemical Abstract Service 

Continuous Emission Monitoring System 

Code of Federal Regulations 

Compressed Natural Gas 

Carbon monoxide 

Carbon dioxide 

Continuous Opacity Monitoring System 

Discrete Emission Reduction 

New Hampshire Code of Administrative Rules Air Resources Division 

New Hampshire Code of Administrative Rules Waste Management Division 

Emission Control System 

Emission Reduction Credit 

Federal Register 

Hazardous Air Pollutant 

Hydrochloric acid 

Hour 

1,000 gallons 

Lowest Achievable Emission Rate 

Pounds per hour 

Low NOx Burner 

Liquid Natural Gas 

Liquid Petroleum Gas (Propane) 

Maximum Available Control Technology 

Milligrams per liter (ppm) 

Million British Thermal Units 

Million Cubic Feet 

National Ambient Air Quality Standard 

Non-certified Continuous Emissions Monitoring System 

National, Emissions Standards for Hazardous Air Pollutants 

Natural .Gas 

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Final Issued 1211312000 
Page 4 of 34 

ABBREVIATIONS (CONT.) 

NHDES (or DES) 

NOx 

NSPS 

NSR 

PCB 

PE 

PM 

PM•0 

ppm 

ppmv 

ppmdv 

PSD 

PSI 

PTE 

RACT 

RTAP 

SIP 

SO2 

T-12M 

TAP 

TSP 

TPY 

USEPA 

VOC 

New Hampshire Department of Environmental Services 

Oxides of Nitrogen 

New Source Performance Standard 

New Source Review 

Polychlorinated biphenyl 

Potential Emission 

Particulate Matter 

Particulate Matter less than 10 microns diameter 

part per million 

part per million by volume 

part per million by dry volume 

Prevention of Significant Deterioration 

Pounds per Square Inch 

Potential to Emit 

Reasonably Available Control Technology 

Regulated Air Toxic Pollutant 

State Implementation Plan 

Sulfur Dioxide 

Tons during any consecutive 12-month period 

Toxic Air Pollutant 

Total Suspended Particulate Matter 

Tons per Year 

United States Environmental Protection Agency 

Volatile Organic Compound 

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Fhlal Issued 12/[3/2000 
Page 5 of 34 

Facility Specific Title V Operating Permit Conditions 

Facility Description of Operations: 

Concord Steam Corporation (CSC) operates a steam generating facility on the grounds of the New 

Hampshire State Hospital in Concord, New Hampshire. CSC generates steam for sale to local 

businesses for use as building heat, to generate electricity via steam driven turbines for use in-house 

and put up for sale the excess electricity to the local utility. Each boiler exhausts to a common stack 

equipped with a continuous emissions monitoring system (CEMS) and a continuous opacity monitoring system (COMS). The primary source of air pollutant emissions at the facility, are 

generated from fuel-burning devices, which produce criteria pollutant and hazardous air pollutant 

(HAP) emissions. 

II. Permitted Activities: 

In accordance with all of the applicable requirements identified in the Permit, the Permittee is 

authorized to operate the devices and/or processes identified in Sections III, IV, V, and VI within the 

terms and conditions specified in this permit. 

III. Significant Activities Identification: 

A. Significant Activities: 

EU01 

EU02 

The activities identified in Table 1 are subject to and regulated by this Title V Operating Permit. 

Bigelow Boiler (Boiler #i) Limited to a maximum gross heat input of •.0-MMB•/hr, while •fing #6 

•el oil having a maximum sul• content of 1.3% by weight, or #6 •el 

oi•specification used oil' mixture having a maximum sul•r content of 1.3% 

by weight. 

Bigelow Boiler (Boiler #3) Limited to a maximu• gross heat input of •.•MMBTU/hr while firing #6 

•el oil having a maximum sd•r content of 1.3% by weight, or #6 fuel 

oil/specification used oil mixture having a maximum sul•r content of 1.3% 

by weight. 

Limited to a maximum gross heat input of 60.0 MMBTU/• •oss heat input 

while firing natural gas. 

Specification used oil shall be defined in accordance with Env-Wm 110.01(b) and shall meet the standards set forth in Env-Wm 807.02. 

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Final Issued 12/13/2000 
Page 6 of 34 

EU03 

EU04 

EU05 

Bigelow Boiler (Boiler #5) 

Union HP Boiler (Boiler #6) 

Cummings VT A1710GS2 

Emergency Generator 

Limited to a m•ximum of 60.0-MMBTU/• •oss heat input while firing #6 

•el oil having a maximum sulfur content of 1.3% by weight, or #6 fuel 

oiUspecification used oil mixture having a maximum sulfur content of 1.3% 

by weight. 

Limited to a maximum of 60.0-MMBTU/hr •oss heat input while firing 

wood. 

Limited to a maximum of 65.0-•BTU/• gross heat input while co-firing 

#6 •el oil having a maximum sul•r content of 1.3% by weight and wood, or 

#6 fuel oiUspecification used oil mix,re'having a maximum sul• content of 

1.3% by weight and wood. 

Limited to a maximum of 75.0-MMBTU/hr gross heat input while firing #6 

fuel oil having a maximum sulfur content of 1.3% by weight. 

Limited to a maximum of 65.0-MMBTU/hr gross heat input while firing 

wood. 

Limited to a maximum of 80.0-MMBTU/hr gross heat input while firing 

natural gas. 

Limited to a maximum of 80.0 MMBTU/hrgross heat input while co-firing 

#6 fuel oil having a maximum sulfur content of 1.3% by weight and wood. 

This fuel burning deyice shall fire only one of the following: 

a) Wood; 

b) Natural gas; 

c) #6 fuel oil having a maximum sulfur content of 1.3%; or 

d) #6 fuel oil having a maximum sulfur content of 1.3%, and wood. 

All emergency generators at a stationary source which: 

a) Operate less than 500 hours, and 

b) The emissions of NOx from all such generators are less than 25 tons 

during any consecutive 12-monthperiod; 

shall be exempt from the requirements 0f Env-A1211.02(i). The emergency 

generators shall be limited to 500 hours of operation per any consecutive 12- 

month period. 

B. Stack Criteria: 

The significant devices indicated in Table 1 discharge through a common tapered masonry stack 

which rises 150 feet above ground level and has an inside exit diameter of 7.0 feet. This stack 

shall, discharge vertically without obstruction and meet criteria in accordance with the state-only 

modeling requirements specified in Env-A 1400 and the Federally Enforceable NAAQS. 

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Finnl Issued 12/13/2000 
IV. 

Page 7 of 34 

Preauthorized changes to the state-only requirements 2 pertaining to stack parameters set forth in 

this permit, shall be permitted only when an air-quality impact analysis, which meets the criteria 

of Env-A 606 is performed either by the facility or the DES (if requested by the facility in 

writing) in accordance with the "DES Policy and Procedures for Air Quality Modeling". All air 

modeling data shall be kept on file at the facility for review by the DES upon request. 

Insignificant Activities Identification: 

All activities at this facility that meet the criteria identified in the New Hampshire Rules Governing 

the Control of Air Pollution Part Env-A 609.03(g), shall be considered insignificant activities. 

Emissions from the insignificant activities shall be included in the total facility emissions for the 

emission-based fee calculation described in Section XXIII of this Permit. 

Wo Exempt Activities Identification: 

All activities identified in the New Hampshire Rules Governing the Control of Air Pollution Part EnvA 609.03(c), shall be considered exempt activities and shall not be included in the total facility 

emissions for the emission based fee calculation described in Section XXIII of this permit. 

Pollution Control Equipment/Technique Identification: 

The devices identified in Table 2 below, are considered pollution control equipment for each 

identified activity. 

:Number (PCE•)fI:.I; 

PCE#i EU03 

EU04 

EU04 

VI. 

PCE#2 

PCE#3 

Zurn Cycl0•.e Separator 

Model: MSTA-48-9CYT-XD-STD 

Installed: 1979 

Tube Size: 9" inlet/6" outlet 

Number of tubes: 48 

Fuel: Wood 

Zurn Cyclone Separator 

Model: MSTA-56-9CYT-XD-STD 

Installed: 1983/84 

Tube Size: 9" inlet/6" outlet 

Number of tubes: 56 

Fuel: Wood 

Barron Side Stream Cyclone Separator 

Model: 9K15-0402 

Installed: 1994 

Tube Size: 9" inlet/6" outlet 

Number of tubes: 8 

Fuel: Wood 

•.ols particulate matter 

errllSSlOnS. 

Controls particulate matter 

emissions. 

Controls particulate matter 

emissions. 

The term "state-only requirement" is used to refer to those requirements that are not federally enforceable but are state requirements as 

defined in Env-A 101.259. 

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Final Issued 12/13/2000 
Page 8 of 34 

All equipment, facilities and systems installed and used to achieve compliance with the terms and 

conditions of this Permit, shall at all times be maintained in good working order, and shall be operated as efficiently as possible so as to minimize air pollutant emissions and meet all applicable air pollution 

emissions limits. The controls listed shall be fully operational upon facility startup and shall not be 

bypassed during startup, operation, or shutdown of EU03 or EU04. 

The pollution control equipment shall be maintained regularly, in accordance with the manufacturers 

recommended maintenance schedules and specifications. The Facility shall keep all maintenance 

records, on file for review upon request by DES and/or EPA. 

VII. Alternative Operatin• Scenarios: 

No alternative operating scenarios were identified for this permit. 

VIII. Applicable Requirements: 

A. State-only Enforceable Operational and Emission Limitations: 

The Permittee shall be subject to the state-only operational and emission limitations identified in 

Table 3 below. 

New or modified d•evices, new or modified area sources for which new 

applications for permits are filed that have the potential to emit, in any amount, 

substances that meet the criteria of Env-A 1301 shall be subject to Env-A 1300, 

until such time as the Env-A 1400 requirements supersede the Env-A 1300 

requirements. (As outlined below.) 

Air quality impact analysis of devices and area sources emitting substances 

meeting the criteria of Env-A 1300, shall be performed in accordance with the 

"DES Policy and Procedures for Air Quality Impact Modeling" or other 

comparable dispersion modeling methods approved by EPA. 

In accordance with Env-A 1403.01, new or modified devices or processes 

installed after May 8, 1998, shall be subject to the requirements of Env-A 1400 

In accordance with 1403.02(a), all existing unmodified devices or processes, 

which are in operation during the transition period ending three years from May 

8, 1998 (May 8, 2001), shall comply with either Env-A 1300 or Env-A 1400. 

In accordance with Env-A 1403.02(b), all existing devices or processes in 

operation after the transition period ending three years from May 8, 1998 (May 

8, 2001), shall comply with Env-A 1400. Env-A 1300 will no longer be in 

effect. 

Facility Wide 

Facility Wide 

Facility Wide 

Facility Wide 

In accordance with Env-A 1404.01(d), documentation for the demonstration of 

compliance shall be retained at the facility, and shall be made available to the 

DES for inspection. 

.Facility Wide 

Env-A 

1305.01(a) 

Env-A 

1305.02 

Env-A 

1403.01. 

Env-A 

1403.02(a) 

Env-A 

.1403.02(b) 

Env-A 

1404.01(d) 

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Final Issued 12/13/2000 
The owner of an existing device or process requiring a permit under chapter Facility Wide 

Env-A 1400, shall submit to the DES no later than one year prior tothe end of 

the transition period (May 8, 2000), an application for modification to a title V 

permit in •ccordance with EnvTA 609.18. A request to the DES to perform air 

dispersion modeling shall also be submitted at that time. 

The owner of an existing device or process requiring a permit under Env-A Facility Wide 

1300, shall submit to the DES no later than one year prior to the end of the 

transition period (May 8, 2000), a compliance plan identifying how the device or 

process will comply with chapter Env-A 1400 by the end of the transition 

period. The compliance plan shall contain the dates wlien the information 

required in Env-A 1405.02 will be filed with the DES. 

In accordance with Env-A 1406.01, the owner of any device or process, which Facility Wide 

emits a regulated toxic pollutant, shall determine compliance with the ambient 

air limits by using one of the methods provided in Env-A 1406.02, Env-A 

1406.03, or Env-A 1406.04. Upon request, the owner of any device or process, 

which emits a regulated, toxic air pollutant, shall provide documentation of 

compliance with the ambient air limits to the DES. 

Page 9 of 34 

Env-A 

1405.02 

Env-A 

1405.03 

Env-A 

1406.01 

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Final Issued 12/13/2000 
Page 10 of 34 

10. The owner or operator is permitted to burn specification used oil under the 

following conditions: 

a) The specification used oil shall have a maximum sulfur content of 1.3% 

by weight and have the following allowable limits of contaminants: 

b) 

c) 

d) 

Arsenic 5.0 mg/l* maximum 

Cadmium 2.0 mg/l* maximum 

Chromium 10 mg/l* maximum 

Lead 100 mg/l* maximum 

Halogens as HC1 1000 mg/l* maximum 

PCBs Less than 2 mg/l* 

Flash Point 100 °F minimum 

The used oil shall not otherwise exhibit any hazardous waste 

characteristics specified in Env-Wm 403. The used oil shall not be mixed 

with hazardous waste. 

If any contaminant exceeds the maximum allowable limit listed above, "•: 

the used oil does not meet the definition of specification used oil and can 

not be accepted or burned as fuel. 

The facility may blend incoming shipments of specification used oil, as 

defined in a) above, with fuel oil contained in the on-site storage tank. 

After blending, the fuel oil mix in the storage tank shall not exceed the 

following levels of contaminants: 

Arsenic 

Cadmium 

Chromium 

Lead 

Halogens as HC1 

PCBs 

Flash point 

3.5 mg/l* maximum 

2.0 mg/l* maximum 

3.5 mg/l* maximum 

19 mg/l* maximum 

1000 mg/l* amximum 

Less than 2 mg/l* 

100°F minimum 

dry weight basis 

EU01, EU02 

& EU03 

Env-A 

1406.01 

The facility may make adjustments to parameters that affect the air dispersion modeling analysis conducted by DES on August 23, 2000 in 

order to demonstrate that an alternative mixture limit can be established which would demonstrate compliance with the 24-hour and annual 

AALs for arsenic, cadmium, chromium, lead, HC1 and PCBs. Any adjustments to parameters which affect the air dispersion modeling 

analysis, conducted by DES on August 23, 2000 and which result in new-modeled impacts shall be reported to DES. DES shall then notify 

the facility win writing of any revised emission limitation as a result of such adjustments, Such written notification shall be attached to this 

Title V Operating Permit as an addendum. The revised emission limit shall be incorporated into this Permit upon re-issuance. 

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Final Issued 12/13/2000 
Page 11 of 34 

Bo Federally Enforceable Operational and Emission Limitations 

The Permittee shall be subject to the Federally enforceable operational and emission limitations 

identified in Table 4 below: 

The Facility shall comply with the National Ambient Air Quality Standards Facility Wide 

(NAAQS) and the applicable requirements of RSA 125-C:6, RSA C: 11 and EnvA 606.04. These sections include, but are not limited to, descriptions of the 

powers and duties of the commissioner, and requirements for adherence to permit 

application procedures and air pollution dispersion modeling impact analyses. 

The combined heat input rate at all devices operating at this facility shall at all Facility Wide 

times be limited to le• thaa 

The sulfur content of No. 2 oil and off road diesel fuel oil shall not exceed 0.40 Facility Wide 

percent sulfur by weight. 

The sulfur content of No. 6 fuel oil shall not exceed 1.3 percent sulfur by weight. Facility Wide 

The sulfur content of the specification used oil shall not exceed 1.3 percent sulfur 

by weight. 

Gaseous fuel shall contain no more than 5 grains of sulfur per 100 cubic feet of 

gas, calculated as hydrogen sulfide at standard temperature and pressure. 

7. The maximum usage of#6 fuel oil, #6 fuel oil/specification used oil mixture, or 

any combination thereof shall be limited to 2,421,300 gallons during any 

consecutive 12-month period. 'This fuel consumption may be adjusted such that 

the gallons of fuel consumed may be increased proportionately to the average 

sulfur content of fuel burned. The SO: emissions from the .facility may not 

exceed 249 tons during any consecutive 12-month period. 

8. No owner or operator shall cause or allow average opacity from fuel buming 

devices in excess of 20 percent for any continuous 6-minute period in any 60- 

minute period except during periods of startup, shutdown and malfunction, average opacity shall be allowed to be in excess of 20 percent for one period of 6 

continuous minutes in any 60 minute period. 

No owner or operator shall cause or allow emissions of particulate matter from 

fuel burning devices in excess of 0.24 pounds per million BTU heat input. 

RSA 125-C:6, 

RSA 125-C: 11 

& Env-A 

606.04 

Facility Permi 

No. FP-S-0111 

Env-A 

1604.01(a) 

Env-A 

1604.01(c)(2) 

Facility Wide Env-A 

1604.01(c)(2) 

Facility Wide 40 CFR 524 

Facility Wide Facility Permit 

No. FP-S-0111 

Facility Wide Env-A 2003.02 

& Facility 

Permit No. FPS-0111 

Facility Wide 40 CFR 51 

Env-A 402.03, effective December 27, 1990, was adopted as part of the State Implementation Plan (SIP) on September 14, 1992 and is still 

considered federallyenforceable until such time as the SIP is amended and approved by EPA. 

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Final Issued 12/13/2000 
Page 12 of 34 

10. 

11. 

12. 

The Permittee has accepted a Permit restriction limiting the (acility wid e NOx 

emissions to less than 28.3 pounds per hour for any consecutive 365-day period. 

This emission rate shall becalculated daily as the average of the calendar day 

averages as calculated on the plant non-certified continuous emissions 

monitoring system (NCCEM) for the boilers. The calculation shall be performed 

using Formulas #1, #2, and #3 below. 

The Permittee shall limit the NOx emissions from: 

2) 

a) EU02: 

1) When firing #6 fuel oil or #6 fuel oil/specification used oil mixture, 

limited to 0.3 lb/MMBTU heat input or install, operate, and maintain 

Low NOx Burners (LNB)5; 

When firing natural gas, limited to 0.1 lb/MMBTU heat input or 

install, operate and maintain LNBsS; and 

3) When firing natural gas/#6 fuel oil or natural gas/#6 fuel 

oil/specification used oil mixture, limited to 0.25 lb/MMBTU heat 

input or install, operate, and maintain LNBs 5. 

b) EU03: 

1) When firing #6 fuel oil or #6 fuel oil/specification used oil mixture,. 

limited to 0.3 lb/MMBTU heat input or install, operate, and maintain 

LNBs; and 

2) When firing wood, wood/#6 fuel oil, or wood/#6 fuel oilspecification used oil oixture, limited to 0.25 lb/MMBTU heat 

input. 

c) EU04: 

1) When firing #6 fuel oil, limited to 0.3 lb/MMBTU heat input; or 

install, operate, and maintain LNBs6; 

2) When firing natural gas/#6 fuel oil combination, limited to 0.3 

Ib/MMBTU heat input; or install, operate, and maintain LNBs6; 

3) When firing wood or wood/#6 fuel oil combination, limited to 0.25 

Ib/MMBTU heat input; and 

4) When firing natural gas, limited to 0.1-1b/MMBTU heat input or 

install, operate, and maintain LNBs 6. 

The Permittee has accepted a Permit restriction limiting the carbon monoxide 

(CO) emissions from the facility to less tl•n 125 lb/hr for each calendar day 

average as calculated on the NCCEM. Calculations shall be performed using 

Formula #1 below. 

TI• em, bon monoxide (CO) emission rate for EU01, EU02, EU03; EU04, and 

EU05 combined shall be limited to 57.0 lb/hr for any consecutive 365-day 

period. The emission rate shall be calculated daily as the average of the calendar 

day averages as calculated on the plant NCCEMS for the boilers. Calculations 

shall be performed using Formulas #1, 2, and 3 below. 

•,rl •.:-•,, •:,,.• •;- :•i- •i• 

Facility Wide 

EU02, EU03 

& EU04 

Env-A 

1211.02(n) 

Env-A 

1211.05(c) 

Facility Wide 40 CFR 51 & 

Facility Permit 

No. FP-S-0111 

EU01, EU02, 40 CFR 51 & 

EU03, EU04, Facility Permit 

EU05 No. FP-S-0111 

Two LNBs as defined by DES, were installed on EU02. The first LNB was installed in 1997, and the second LNB was installed in 1998. 

Two LNBs as defined by DES, were installed on EU04. The first LNB was installed in 1993, and the second LNB was installed in 1996. 

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Final Issued 12/13/2000 
Page 13 of 34 

14. Accidental Release Program Requirements: 

Storage of regulated chemicals at the facility, are less than the applicable 

threshold quantities established in 40 CFR 68.130. Administrative controls will 

b• established in order to ensure that inventories of regulated substances are 

maintained below the specified threshold quantities. The facility is subject to the 

Purpose and General Duty clause of the 1990 Clean Air Act, Section 112(r)(1). 

General Duty includes the following responsibilities: 

a) Identify potential hazards which result from such releases using 

appropriate hazard assessment techniques; 

b) Design and maintain a safe facility; 

c) Take steps necessary to prevent releases; and 

d) Minimize the consequences of accidental releases, which do occur. 

If, in the future, the facility wishes to store quantities of high risk regulated 

'substances above the threshold levels, an emergency response plan shall be 

submitted to the DES prior to exceeding threshold quantity limits. This plan 

shall include the information listed in 40 CFR 68, Subpart E. 

Facility Wide 40 CFR 68 

Federally 

Enforceable 

The Permittee shall use the following formulas, calculated on a rolling 365-day basis to verify 

compliance with the CO and NOx emissions limitations specified in Table 4 of this Permit: 

Formula #1: NCCEM Calendar Day Average Emissions 

Where: 

CDA= 

BOHDT 

CDA [(BO)]/[24- HDT] 

Facility wide calendar day emission average 7' for CO or NOx; 

Sum of all valid hour lbs CO/hr or lbs NOx/hr averages for the calendar day for EU01, EU02, 

EU03, EU04 and EU05; and 

Hours of NCCEM downtime for the calendar day. 

Formula #2: Sum of Valid Calendar Day Emissions 

Where: 

SCDA= 

N= 

N 

SCDA •_, xj + x•+,..:. ÷ xj=•¢ i=1 

Sum of all valid calendar day averages for CO or NOx from Formula #1; 

An integer from to N; 

Total number of valid data points to be summed; and 

Calendar day averages shall only be valid for days with 18 or more valid hours of NCCEM data. 

A valid hour of NCCEM data shall be defined as a minimum of 45 minutes collection of NCCEM readings taken in a consecutive 60- 

m•nute period. 

Hours of NCCEM downtime shall be defined as the number of calendar hours when the NCCEM has not collected data or was out-of 

control for greater than 18 minutes for any reason (i.e. audits, NCCEM calibration, NCCEM system failures, etc.), and does not include 

hours or days when the NCCEM has been intentionally shutdown when the facility is not operating. 

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Final Issued 1211312000 
A valid data point for CO or NO×. 

Page 14 of 34 

Formula #3: Facility Wide consecutive 365-day Average Emissions 

Where: 

CYA= 

SCDA= 

TDTCYA [SCDA + (365- TDT)] 

Actual facility wide consecutive 365-day average CO.or NOx emissions; 

Sum of all valid calendar day average CO or NOx emissions using Formula #2; and 

Total days of NCCEM downtime l° in 365-consecutive days. 

C. Emission Reductions Trading Requirements 

The Permittee did not request emissions reductions trading in its operating permit application. 

At this point, DES has not included any permit terms authorizing emissions trading in this 

permit. All emission reduction trading, must be authorized under the applicable requirements of 

either Env-A 3000 (the "Emissions Reductions Credits [ERCs] Trading Program"), or Env-A 

3000 (the "Discrete Emissions Reductions [DERs] Trading Program) and 42 U.S.C § 7401 et 

seq. (The "Act"); and must be provided for in this permit. 

D. Monitoring and Testing Requirements: 

The Permittee is subject to the monitoring and testing requirements as contained in Table 5 

below: 

1. Allows for Annually Facility Env-A 

adequate stacks and 806.01(4) & 40 

dispersion of fuel CFR 70.6(a)(3) 

HAPs and burning Federally 

other devices Enforceable 

regulated 

pollutants 

:•:•,!,•::•: •?:•,•: :•i•?,•:•::,:•i:i:i,•;: '.•• •i•i:i:,=::• •i•:•',ki• •i•:,•i;-•'!:i• •}• !•',i,!•i.•:! 

The Permittee shall conduct annual visual inspections 

Of each stack and fuel-burning device. Annual 

inspections shall include a thorough inspection of the 

condition of each stack exterior and each fuel burning 

device, and be focused on identifying holes, leaks, 

deposits, deficiencies, or deterioration of equipment 

and stacks. Every five (5) years, the Permittee shall 

inspect the interior of each stack for evidence of 

corrosion, cracks, or holes. Records of inspections, 

and subsequent, maintenance, conducted as a result of 

the annual inspections, shall be kept on file at the 

facility and will be made available for review by DES 

and/or EPA upon request. 

•0 Days of NCCEM downtime shall be defined as the number of calendar days when the NCCEM has not collected data or was out-of control 

for any reason (i.e. auditS, NCCEM calibration, NCCEM system failures, etc.), and does not include hours or days when the NCCEM has 

been intentionally shutdown when the facility is not operating. 

TATransfer\TVWEBPAG\TV Website\coneordsteamtvfl 2- |3-00.doe 

Final Issued 12113/2000 
Sulfur 

content of 

liquid fuels 

Page 15 of 34 

The operator shall conduct testingin accordance with 

appropriate ASTM test methods or retain delivery 

tickets which certify the weight percent of sulfur for 

each delivery of fuel oil to determine compliance with 

the sulfur content limitation provisions specified in this 

permit for liquid fuels in order to meet the reporting 

requirements, specified in Env-A 900. 

Sulfur The Permittee shall conduct testing to determine 

content of compliance with the sulfur content limitation provision 

gaseous fuels in Env-A 1600 for gaseous fuels in accordance with 

appropriate ASTM test methods or retain supplier 

certificates which substantiate the weight percent of 

sulftu" of gaseous fuel in order to meet the reporting requirements specified in Env-A 900. 

The operator shall conduct testing in accordance with 

appropriate ASTM test methods or retain delivery 

tickets which certify the amounts of allowable 

contaminants for each delivery of specification waste 

oil to determine compliance with the used oil 

specification limitation provisions specified in this 

permit in order to meet the reporting requirements 

specified in Env-A 900. 

The pollution control equipment (cyclones) shall be 

maintained regularly, and in accordance with the 

manufacturers recommended maintenance schedules 

and specifications. The Facility shall keep all 

maintenance and repair records, on file for review 

upon request.by DES and/or EPA. 

4 HAPs 

content of 

liqUid fuels 

5. Particulate 

Matter 

For each 

delivery of 

fuel oil to 

the facility 

Upon written 

request by 

EPA or DES 

For each 

delivery of 

specification 

used oil to 

the facility 

As required 

by the 

manufacturer 

Facility 

Wide 

Facility 

Wide 

Facility 

Wide 

EU03 & 

EU04 

Env-A 809.01 

Federally 

Enforceable 

Env-A 1610.01 

Federally 

Enforceable 

Env-A 809.01 

& Env-Wm 

807.10(b)(5) 

State-only 

Enforceable 

40 CFR 

70.6(a)(3) & 

Env-A 

806.01(4) 

Federally 

Enforceable 

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Final Issued 12/13/2000 
Page 16 of 34 

6. Continuous 

Emission 

Monitoring 

Continuous 

Emissions 

Monitoring 

Continuous 

Emissions 

Monitoring 

The Permittee shall maintain and operate a CEMS in 

the common stack for NOx, CO, CO•, and volumetric 

flow meeting all the requirements of 40 CFR Part 60, 

Appendix B, Appendix F, and Env-A 805 except for 

the audit requirements specified below: 

a) Quarterly gaseous monitoring audits (i.e. 

cylinder gas audits, and relative accuracy 

audits); 

b) Quarterly volumetric flow monitoring audits 

(i.e. quarterly relative accuracy audits); 

c) Annual gaseous monitoring audits (i.e. relative 

accuracy test audit [RATA]); and 

d) Annual volumetric flow monitoring audits (i.e. 

relative accuracy test audits). 

The requirements for this NCCEM system shall 

include all those items as applicable and as specified in 

this section. 

The Permittee shall certify, operate, and maintain the 

CEM system in accordance with all applicable 

requirements of 40 CFR Part 60 Appendix B, 

Appendix F, and Env-A 805 within 60-days of any of 

the following events: 

a) The 365-day rolling average •l for NOx exceeds 

21.0 lb/hour (80% of the standard) for any 

calendar day; 

b) The 365-day rolling average • for CO exceeds 

45.6 lb/hour (80% of the standard) for any 

calendar day; or 

c) When required by NHDES-ARD when 

justification exists for such operation of a 

certified CEM system. 

When required by NHDES-ARD, the Permittee shall 

certify, operate, and maintain the CEM system in 

accordance with all applicable requirements of 40 CFR 

Part 60 Appendix B, Appendix F, and Env-A 805 

within 60-days of the following event: 

a) The 24-hour average t• for CO exceeds 100 

lb/hour (80% of the standard) for any calendar 

day. 

Continuous 

As required 

by this 

Permit 

NCCEM Env-A 805, 

System 40 CFR 60, & 

40 CFR 51 

Federally 

Enforceable 

NCCEM 

System 

Env-A 805 & 

RSA 125-C 

Federally 

Enforceable 

As required NCCEM Env-A 805 & 

.by this System RSA 125-C 

Permit Federally 

Enforceable 

• The 365-day rolling and 24-hour averages for CO and NOx shall be calculated as specified in Section VIII.B, Formulas #1, #2 and #3. 

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Final Issued 12/13/2000 
Page 17 of 34 

9. Volumetric 

Flow 

Monitoring 

10. 

11. 

The Permittee shall operate and maintain a volumetric 

flow-measuring device. The stack flow measuring 

device shall conform to the requirements of 40 CFR 

Part 60, Appendix B, Performance Specification 6 and 

shall also meet the following: 

a) The differential pressure flow monitors 

installed shall be an automatic blowback purge 

system and shall have the capacity for drainage 

of the sensing lines; and 

b) The stack flow monitoring system shall have 

the capability for on-line manual transducer 

calibration and for a zero check. 

12. 

Volumetric 

Flow 

Monitoring 

Volumetric 

Flow 

Monitoring 

Continuous 

Emissions 

Monitoring 

The Permittee shall execute daily calibrations on the 

volumetric flow monitor (single pitot type) for zero 

and span. 

Continuous NCCEM 40 CFR Part 60 

System Appendix B, & 

Env-A 

805.03(h) 

Federally 

Enforceable 

Daily 

13. Continuous 

Opacity 

Monitoring 

The Permittee shall maintain the automatic blowback Annually or 

cycle on the stack flow monitor to keep the pitot tube more 

unit clear and shall remove the stack flow monitor frequently as 

annually for inspection and cleaning. Frequency of needed 

removing the pitot tube shall be increased if the trait is 

shown to be plugged. 

14. Continuous 

Emissions 

Monitoring 

The stack volumetric flow measuring device combined 

with the concentration NCCEM equipment for CO and 

NOx shall be used to calculate mass emission rates for 

comparison with the emission standards specified in 

Table 4. 

The Permittee shall maintain and operate a continuous 

opacity monitoring system (COMS) which shall meet 

all the requirements of. 40 CFR Part 60, Paragraph 

60.13; Appendix B, Performance Specification and 

Env-A 805. 

Continuous 

NCCEM 

System 

Env-A 805 & 

40 CFR 51 

Federally 

Enforceable 

NCCEM 

System 

Env-A 805.03 

& 40 CFR 51 

Federally 

Enforceable 

Continuous 

NCCEM 

System 

40 CFR 51 

Federally 

Enforceable 

The Permittee shall: Continuous 

a) Maintain the Quality Control program on the 

NCCEM system as specified in the plan 

submitted May 2, 1994 or any revision to the 

plan submitted thereafter minus the quarterly 

audits described in the "Quarterly QC" section 

of the plan; 

b) To the best of its ability, maintain the accuracy 

and integrity of the NCCEM system through 

maintenance and periodic quality checks; and 

c) The Permittee shall continue to review, update, 

submit, and implement as applicable, revised 

QC plans annually. 

COMS 

System 

NCCEM 

and 

COMS 

system 

40 CFR Part 60 

Appendix B, & 

Env-A 805 

Federally 

Enforceable 

Env-A 805 

Federally 

Enforceable 

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Final Issued 12/13/2000 
Page 18 of 34 

16. 

17. 

18. 

19. 

Continuous 

Emissions 

Monitoring 

Periodic 

Monitoring 

Periodic 

Monitoring 

Continuous 

Emissions 

Monitoring 

Periodic 

Monitoring 

r• :•?%5!•i•:•;•/!•:•'•ff'':i''•'•'•' 

The Permittee shall continuously monitor the data 

from the NCCEM/CEM system during all periods of 

startup, shutdo•vn, malfunctions, and emergency 

conditions. 

All fuel-flow metering/recording devices shall be 

calibrated in accordance with the manufacturers 

specifications. 

Fuel usage will be monitored for each emissions Unit 

along with daily hours of operation. 

In all cases when the NCCEM system requires recertification, the Permittee shall use all previously 

obtained NCCEM data as representative data and shall 

include it in all averaging periods with respect to 

determining compliance with any of the required 

emission limitations. 

Annually, before April •t of each year, the Permittee 

shall perform efficiency testing using the test 

procedures specified in ASME/ANSI Boiler Test Code 

4.1 and adjust the combustion process of the boiler in 

accordance with the procedures specified in chapter 5, 

Combustion Efficiency Tables, Taplin, Harry R., 

Fairmont Press, 1991. 

Continuous 

As required 

by the 

manufacturer 

NCCEM 

and 

COMS 

System 

EU01, 

EU02, 

EU03 & 

EU04 

Env-A 805 & 

40 CFR 70;6 

Federally 

Enforceable 

40 CFR 70.6 

(a)(3)(i)(B) & 

Env-A 806 

Federally 

Enforceable 

Daily 

On a 

continuous 

basis 

EU01, 

EU02, 

EU03, 

EU04 & 

EU05 

40 CFR 70.6 

(a)(3)(i)(B) & 

Env-A 806 

Federally 

Enforceable 

EU01, Env-A 1211.21 

EU02, Federally 

EU03, Enforceable 

EU04 & 

EU05 

Annually 

(before April 

l•t of each 

year) 

EUO1 Env-A 

1211.05(b) 

Federally 

Enforceable 

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Final Issued 12/13/2000 
Page 19 of 34 

20. Compliance The Permittee shall perform compliance testing for 

Certification NOx, lb/MMBTU input, and lb/hr once every three 

years and no later than three years following the 

previous NOx RACT testing performed by the 

Permittee. The NCCEM system can be used as an 

alternative to this requirement if the following 

conditions are met: 

a) The NCC'EM shall be re-certified every 3 years 

by performing a relative .accuracy test audit on 

the unit and following all of the requirements of 

40 CFR Part 60, Appendix B and Env-A 805 

for re-certification; 

b) Measure NOx emissions in units of the standard 

specified in Env-A 1211 for three 1-hour runs 

for each boiler operating on its own in order to 

verify compliance with the NOx RACT 

emission standard. Such NOx emission 

measurements shall be measured only from the 

certified CEM; and 

c) Performance testing shall be conducted in 

accordance with the requirements detailed in 

Table 6. 

Minimum of 

every three 

years 

EU02, 

EU03, & 

EU04 

Env-A 802, & 

Env-A 1211.21 

Federally 

Enforceable 

Eo Performance Testing Requirements: 

The Permittee shall conduct emissions testing on EU01, EU02, EU03 and EU04 according to the 

requirements identified in Table 6 below: 

1. At such times as specified by the Division or EPA, the Pe•ittee shall conduct USEPA method stack Env-A 802 & 

tests at maximum load conditions for any or all of the following pollutants: 40 CFR 

70.6(a)(3) a) Total Suspended Paniculate Matter (TSP); 

b) Carbon monoxide (CO); Federally 

Enforceable c) Oxides of nitrogen (NOx); an•or 

d) Other pollutants desi•ated by DES or EPA. 

2. The compliance tests shall be conducted and the results reposed in accordance with the test methods Env-A 802.04 

set fo•h in 40 CFR Pa• 60, 60.8, Appendix A, and Env-A 802. The following test methods or Federally 

Division approved alternatives shall be used: Enforceable 

a) Perfo•ance tests for the emissions of total suspended paaiculate ma•er and opaci• shall be 

conducted using EPA Methods 1-5 and 9; 

b) Peffo•ance tests for the emissions of CO shall be conducted using EPA Method 10; and 

c) Peffo•ance tests for the emissions of NO• shall be conducted using EPA Method 7E. 

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Final Issued.: 12/I 3/2000 
Page 20 of 34 

3. At least 30 days prior to the commencement of testing, the Permittee shall submit to the Division a Env-A 802.01 pretest report presenting the following information: Federally 

Enforceable a) Calibration sheets; 

b) Test methods to be used; 

c) Process data to be taken during the test, including steam flow, steam pressure, .and steam 

temperature, along with the frequency of data collection; and 

d) Complete test program description the contents of which will be discussed with the Division. 

4. At least 15-days prior to commencement of testing, the Permittee and any contractor that may be Env-A 802 

retained for the testing shall participate in a pretest conference with a Division representative. Federally 

Enforceable 

Division representatives shall observe the emission testing. Upon commencement of any Env-A 802.02 

performance testing, the testing shall not be aborted without approval of the on-site DES and/or EPA Federally 

representative Enforceable 

6. The Permittee shall provide sampling ports, platforms, and access in accordance with 40 CFR Part Env-A 802.05 

60, 60.8(e). Federally 

Enforceable 

F. Recordkeeping Requirements•: 

The Permittee shall be subject to the recordkeeping requirements identified in Table 7 below: 

The Permittee shall retain records of all required monitoring and 

testing data, recordkeeping and reporting requirements, and 

support information for a period of at least 5 years from the date 

of origination. 

Retain for a 

minimum of 5 

years 

Facili• 

Wide 

40 CFR 

70.6(a)(3)(ii)(B) 

Federally 

Enforceable 

•2 On April 23, 1999, DES promulgated new Env-A 900 regulations in an attempt to streamline the recordkeeping and reporting requirements 

sections of the New Hampshire Code of Administrative Rules. Until such time that the new Env-A 900 regulations are approved and 

adopted into the State Implementation Plan (SIP) by EPA, all Title V permits will be incorporating the old Env-A 900 regulations (which 

became effective on November 11, 1992), unless the new Env-A 900 regulations are more stringent. The recordkeeping and reporting 

requirements contained in this permit are those requirements, which the facility shall be required to comply with. These recordkeeping and 

reporting requirements shall fall under the Permit Shield prov•mons as contained in Section XIII of this permit. 

F:\Transfer•TV WEBPAG\TV Website\eoneords/eamtvfl2-13-00.doe 

Final Issued 12/13/2000 
Page 21 of 34 

2. The Permittee shall maintain records of monitoring/testing 

requirement s as specified in Table 5, of this Permit including: 

a) Preventative maintenance and inspection results for 

stacks, processes and boilers; 

b) Summary of maintenance and/or repair of the pollution 

control equipment (cyclones); 

c) Summary of maintenance and/or repair of the pitot tube 

associated with the stack volumetric flow measuring 

device; 

d) Summary of maintenance and/or repair of the CEM and 

COM systems; and 

e) Summary of maintenance, repair, and calibration records 

for all fuel flow meters. 

The Permittee shall maintain records of all monitoring and 

calibration data generated by the NCCEM and COMS systems 

as specified in Table 5. 

Maintain on a Facility 40 CFR. 

continuous Wide 70.6(a)(3)(iii)(A) 

basis Federally 

Enforceable 

Maintain on a 

continuous 

basis 

Facility 

Wide 

40 CFR 

70.6(a)(3)(iii)(A) 

Federally 

Enforceable 

The Permittee shall maintain in a permanently bound logbook, 

the following: 

a) The date(s) on which: 

1) The efficiency test was conducted; and 

2) The combustion process was last adjusted; 

b) The names(s), title and affiliation of the pers0n(s) who: 

1) Conducted the efficiency test; 

2) Made the adjustments; 

c) The NOx emission rate in parts per million (ppmv), 

corrected to 15% Oxygen, after the adjustments are made; 

d) The CO emission rate, in ppmv, corrected to 15% 

oxygen, after the adjustments are made; and 

e) The opacity readings, 

Delivery tickets from each fuel oil supplier for each shipment of 

fuel oil received shall be l•ept on file in a form suitable for 

inspection and shall be available to the DES and/or EPA upon 

request. Each delivery ticket shall indicate: 

a) The name of the fuel supplier; 

b) The address of the fuel oil supplier; 

c) The telephone number of the fuel oil supplier; 

d) The quantity of fuel oil delivered; and 

e) The percentsulfur by weight of the fuel oil being 

delivered. 

If delivery tickets do not contain sulfur content of fuel being 

delivered, the Permittee shall perform testing in accordance with 

appropriate ASTM test methods to determine compliance with 

the sulfur content limitation provisions for each delivery of fuel 

oil. 

Maintain on a 

continuous 

basis 

Maintain on a 

continuous 

basis 

EU01 

Facility 

Wide 

Env-A 1211.05 

Federally 

Enforceable 

40 CFR 

70.6(a)(3) & EnvA 1604.01 

Federally 

Enforceable 

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Final Issued 12/13/2000 
Page 22 of 34 

Delivery tickets from each used oil supplier for each shipment 

of specification used oil received shall be kept on file in a form 

suitable for inspection and shall be available to the DES and/or 

EPA upon request. Each delivery ticket shall indicate: 

a) The name of the supplier; 

b) The address of the supplier; 

c) The telephone number of the supplier; 

d) The quantity of specification waste oil delivered; 

e) The reason for rejection of any delivery of specification 

waste oil; 

f) The concentrations of each of the following 

contaminants in the specification used oil being 

delivered: 

1) Sulfur as weight percent; 

2) Lead in mg/L (ppm)*; 

3) Arsenic in mg/L (ppm)*; 

4) Cadmium in mg/L (ppm)*; 

5) Chromium in mg/L (ppm)*; 

6) Halogens as HC1 in mg/L (ppm)*; 

7) PCBs in mg/L (ppm)*; and 

8) Flash point. 

* These concentrations shall be reported on a dry basis. 

If delivery tickets do not contain the information listed in f) 

above for the specification used oil being delivered, the 

Permittee shall perform testing in accordance with appropriate 

ASTM test methods to determine compliance with the 

hazardous constituent content limitation and sulfur content 

limitation provisions for each delivery of specification used oil 

prior to its addition to the fuel storage tank. 

The Permittee shall record the following information: 

a) The amount of virgin #6 fuel oil and/or specification 

used oil blend contained in the storage tank at the time of 

specification used oil delivery; 

b) The amount of specification used oil added to the fuel oil 

storage tank; and 

c) The calculated contaminant concentration of the blended 

fuel oil in the storage tank after delivery. 

Maintain on a 

continuous 

basis 

Facility 

Wide 

Env-A 1604.01 & 

Env-Wm 807.02 

State-Only 

Enforceable 

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Final Issued 12/13/2000 
Page 23 of 34 

The Permittee shall record daily fuel usage information.for each 

boiler in a bound logbook, including: 

a) The quantity of fuel used on a 24-hour basis; 

b) The fuel type; and 

c) The measured MMBTU/ton or gallon of fuel; and 

d) The sulfur content as percent sulfur by weight of fuel if 

applicable. 

If more than one type of fuel is used, data on each tiael type shall 

be recorded separately. 

Monthly records of fuel utilization, hours of operation,, and 

twelve consecutive month rolling totals of fuel utilization and 

hours of operation for each emergency generator shall be kept at 

the facility and contain the following information: 

a) Consumption; 

b) Fuel type; 

c) Sulfur content as percent sulfur by weight of fuel; 

d) BTU content per gallon or cubic feet of fuel; and 

e) Hours of operation of each emergency generator. 

Annual records of actual emissions for each significant and 

insignificant activity for determination of emission based fees. 

Maintain on a EU01, ENV-A 901.03 

continuous EU02, EU03 Federally 

basis & EU04 Enforceable 

Monthly & 

consecutive 12 

month rolling 

total of fuel 

consumption, 

and monthly & 

consecutive 12 

month rolling 

total hours of 

operation 

Maintain at 

facility at all 

times 

EU05 Env-A 901.03 

Federally 

Enforceable 

Significant 

and 

insignificant 

activities 

Env-A 901.04 

Federally 

Enforceable 

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Final Issued 12/13/2000 
Page 24 of 34 

NOx Recordkeeping Requirements: 

For fuel burning devices, including boilers, and internal 

combustion engines, the following information shall be recorded 

and maintained: 

Facility information, including: 

1) Source name: 

2) Source identification; 

3) Physical address; and 

a) 

4) Mailing address. 

b) A copy of the certificate of accuracy required to be 

maintained pursuant to Env-A 901.04. 

c) Identification of each fuel burning device; 

d) Operating schedule information for each fuel burning 

device identified in (b), above, including: 

1) Days per calendar week during the normal 

operating schedule; 

2) Hours per day during the normal operating schedule 

and for a typical ozone season day, if different from 

the normal operating schedule; and 

3) Hours per year during the normal operating 

schedule; 

e) Type, and amount of fuel burned, for each fuel burning 

device, during normal operating conditions and for a 

typical ozone season day, if different from normal 

operating conditions, on an hourly basis in MMBTU/hr 

and; 

f) The following NOx emission data, including records of 

total annual emissions, in tons per year, and typical 

ozone season day emissions, in pounds per day; 

1) Theoretical potential emissions for the calculation 

year for each fuel burning device; and 

2) Actual NOx emissions for each fuel-burning device. 

•iii•iiR¢¢ords ;:•! 

On a 

continuous 

basis 

•!•!•cal•lc 

Facili• 

Wide 

Env-A 901.08 

Federally 

Enforceable 

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Final Issued 12/13/2000 
Page 25 of 34 

G. Reporting Requirementsl2: 

The Permittee shall be subject to the reporting requirements identified in Table 8 below: 

1. The Permittee shall submit a.summary report of monitoring data 

as specified in Table 7 of this permit including: 

a) Preventative maintenance and inspection results 

performed during the annual inspection as specified in 

Table 5, Item #1 for stacks and emission units; 

b) Summary of testing and/or delivery ticket certifications 

for fuel sulfur content limitation provisions; 

c) Summary of testing and/or delivery ticket certifications 

for specification waste oil sulfur content and contaminant 

content limitation provisions; and 

d) Summary of maintenance and repair records for the 

pollution control equipment (cyclones); 

e) Summary of maintenance and repair record s for the stack 

volumetric flow measuring device; 

f) Summary of maintenance and repair records for the 

CEM and COM systems; 

g) Summary of maintenance, repair, and calibration records 

for all fuel flow meters; and 

h) A Permit deviation report. 

Eve• 6 months Facili• Wide 40 CFR 

(no later than the 70.6(a)(3)(iii) 

30th day of the (A) Federally 

following month. Enforceable 

of each calendar 

half year) 

2. The Permittee shall submit a summary report of boiler 

efficiency testing and the adjustments to the combustion 

processes as specified in Table 7 Item 4 of this permit 

3. The Permittee shall submit an annual fuel usage report 

indicating consecutive 24-hour period and consecutive 12 month 

rolling totals of fuel utilization for the four boilers and 

corresponding fuel information as outlined in Condition VIII.E., 

Table 7, Item 7. 

4. The Permittee shall submit an annual fuel usage report 

indicating consecutive 24•hohr period and consecutive 12 month 

rolling totals of fuel utilization for the emergency generator and 

corresponding fuel information as outlined in Condition VIII. E, 

Table 7, Item 8. 

NOx Reporting Requirements: 

For fuel burning devices, including boilers, and engines, as well 

as miscellaneous sources, the owner or operator shall submit to 

the Director, annually (no later than April 15 th of the following 

.year), reports of the data-required by Condition VIII.E, Table 7, 

Item 10 including total annual quantities of all NOx emissions. 

Annually (no 

later than April 

15 th of the 

following year) 

Annually (no 

later than April 

15th of the 

following year) 

Annually (no 

later than April 

15 th of the 

following year) 

Annually (no 

later than April 

15th of the 

following year) 

EU01 

EU01, EU02, 

EU03 & EU04 

EU05 

Facility Wide 

40 CFR 

70.6(a)(3)(iii) 

(A) Federally 

Enforceable 

Env-A 

901.09 

Federally 

Enforceable 

Env-A 

901.09 

Federally 

Enforceable 

901.09 

Federally 

Enforceable 

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Final Issued 12/13/2000 
Page 26 of 34 

6. 

7. 

Within 30-days after completion of performance testing, the 

Permittee shall submit a test report to the Division. 

The Permittee shall submit a written quarterly report which 

contains the following information: 

a) Calendar daily averages of CO and NO• lbs/Hr whether 

b) or not excess emissions have occurred; Calendar daily averages of percentage diluent (Oa or 

CO•); and 

c) Calendar daily averages of stack flow. 

8. Excess emissions indicated by the CEM system Shall be 

considered a violation of the applicable emission limit for the 

purposes of this Permit. The Permittee shall also include the 

following information in the quarterly report: 

a) Magnitude of each excess emission; 

b) Date and time of commencement and completion of each 

time period of excess emission; 

c) Date and time(s) of each period where the CEM was not 

operational, and the total percentage of time where the 

CEM was not operational; 

d) When no excess emissions have occurred or the CEM 

system has not been inoperative, repaired, or adjusted, 

such information shall be stated in the report; and 

For gaseous measuring CEM systems, daily averages of the 

measurements made and emission rates calculated shall be 

reported whether or not excess emissions have occurred. 

11. 

10. 

12. 

Prompt reporting of deviations from Permit requirements shall 

be conducted in.accordance with Section XXVIII of this Permit. 

No later than 30 EU01, EU02, Env-A 

days after EU03, & 1211.21(c) 

completion ofa EU04 Federally 

test Enforceable 

Quarterly (no Facility Wide Env-A 

later than 30 805.08 & 

days of the last 40 CFR 51 

date of the Federally 

reporting period) Enforceable 

Quarterly (no Facility Wide Env-A 

later than 30 805.08 & 

days of the last 40 CFR 51 

date of the Federally 

reporting period) Enforceable 

Prompt reporting Facility Wide 40 CFR 

(within 24 hours 70.6(a)(3)(iii) 

of an occurrence) (B) Federally 

Enforceable 

Any report submitted to the DES and/or EPA shall include the As specified in 

certification of accuracy statement outlined in Section XXI.B. of section XXI. B. 

this Permit and shall be signed by the responsible official. 

Annual reporting and payment of emission based fees for 

pollutants, including but not limited to SO2, NOx, CO, TSP, 

VOCs and New Hampshire Regulated Air Toxic Pollutant 

(NHRATP) emissions, shall be c9nducted in accordance with 

Section XXIII of this Permit. 

Annual compliance certification shall be submittedin 

accordance with Section XXI of this Permit. 

Annually (no 

later than April 

15 th of the 

following year) 

Annually (no 

later than April 

15th of the 

following year) 

Facility Wide 40 CFR 

70.6(c)(1) 

Federally 

Enforceable 

Facility Wide Env-A 

704.03 

Federally 

Enforceable 

Facility Wide 40 CFR 

70.6(c)(1) 

Federally 

Enforceable 

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Final Issued 12113/2000 
IX. 

Page 27 of 34 

Requirements Currently Not Applicable: 

Requirements not currently applicable to the facility were not identified by the Permittee. 

General Title V Operating Permit Conditions 

XI. 

Issuance of a Title V Operatim, Permit: 

This Permit is issued in accordance with the Provisions of Part Env-A 609. In accordance with 40 

CFR 70.6(a)(2) this Permit shall expire on the date specified on the cover page of this Permit, which 

shall not be later than the date five (5) years after issuance of this Permit. 

Permit expiration terminates the Permittees' fight to operate the Permittees' emissions units, control 

equipment or associated equipment covered by this permit, unless a timely and complete renewal 

application is submitted at least 6 months before the expiration date. 

Pursuant to Env-A 609.02(b), this Permit shall be a state permit to operate as defined in RSA 125- 

C: 11, III. 

Title V Operating Permit Renewal Procedures: 

Pursuant to Env-A 609.06(b), an application for renewal of this Permit shall be considered timely if it 

is submitted to the Director at least six months prior to the designated expiration date of this Permit. 

XII. Application Shield: 

Pursuant to Env-A 609.07, if an applicant submits a timely and complete application for the issuance 

or renewal of a Permit, the failure to have a Permit shall not be considered a violation of this part until 

the Director takes final action on the application. 

XIII. Permit Shield: 

Pursuant to Env-A 609.08(a), a permit shield shall provide that: 

1. For any applicable requirement or any state requirement found in the New Hampshire Rules 

Governing the Control of Air Pollution specifically included in this Permit, compliance with the 

conditions of this Permit shall be deemed compliance with said applicable requirement or said 

state requirement as of the date of permit issuance; and 

2. For any potential applicable requirement or any potential state requirement fotmd in the New 

Hampshire Rules Governing the Control of Air Pollution specifically identified in this Title V 

Operating Permit Section IX Table 8 as not applicable to the stationary source or area source, the 

Permittee need not comply with the specifically identified federal or state requirements. 

The permit shield identified in Section XIII. of this Permit shall apply only to those conditions 

incorporated into this Permit in accordance with the provisions of Env-A 609.08(b). It shall not apply 

to certain conditions as specified in Env-A 609.08(c) that may be incorporated into this Permit 

following permit issuance by DES. 

If a Title V Operating Permit and amendments there to issued by the DES does not expressly include 

or exclude an applicable requirement or a state re.quirement found in the NH Rules Governing the 

Control of Air Pollution, that applicable requirement or state requirement shall not be covered by the 

permit shield and the Permit-tee shall comply with the provisions of said requirement to the extent that 

it applies to the Permittee. 

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Final Issued 12/13/2000 
Page 28 of 34 

If the DES determines that this Title V Operating Permit was issued based upon inaccurate or 

incomplete information provided by the applicant or Permittee, any permit shield provisions in said 

Title V Operating Permit shall be void as to the portions of said Title V Operating Permit, which are 

affected, directly or indirectly, by the inaccurate or incomplete information. 

Pursuant to Env-A 609.08(0, nothing contained in Section XIII of this Permit shall alter or affect the 

ability of the DES to reopen this Permit for cause in accordance with Env-A 609.18 or to exercise its 

summary abatement authority. 

Pursuant to Env-A 609.08(g), nothing contained in this section or in any Title V Operating Permit 

issued by the DES shall alter or affect the following: 

1. The ability of the DES to order abatement requiring immediate compliance with applicable requirements upon finding that there is an imminent and substantial endangerment to public 

health, welfare, or the environment; 

The state of New Hampshire's ability to bring an enforcement action pursuant to RSA 125-C: 15, 

II; 

The provisions of section 303 of the Act regarding emergency orders including the authority of 

the EPA Administrator under that section; 

The liability of an owner or operator of a source for any violation of applicable requirements prior 

to or at the time of permit issuance; 

The applicable requirements of the acid rain program, consistent with section 408(a) of the Act; 

The ability of the DES or the EPA Administrator to obtain information about a stationary source, 

area source, or device from the owner or operator pursuant to section 114 of the Act; or 

The ability of the DES or the EPA Administrator to enter, inspect, and/or monitor a stationary 

source, area source, or device. 

4• 

XIV. Reopening for Cause 

The Director shall reopen and revise a Title V Operating Permit for cause if any of the circumstances 

contained in Env-A 609.18(a) exist. In all proceedings to reopen and reissue a Title V Operating 

Permit, the Director shall follow the provisions specified in Env-A 609.18(b) through (g). 

XV. Administrative Permit Amendments 

Pursuant to Env-A 612.01, the Permit-tee may implement the changes addressed in the request for an 

administrative permit amendment as defmed in Part Env-A 100 immediately upon submittal of the 

request. 

Pursuant to Env-A612.01, the Director shall take final action on a request for an administrative permit 

amendment in accordance with the provisions of Env-A 612.01(b) and (c). 

XVI. Operational Flexibility 

Pursuant to Env-A 612.02(a), the Permittee subject to and operating under this Title V Operating 

Permit may make changes involving trading of emissions under this existing Title V Operating Permit 

at the permitted stationary source or area source without filing a Title V Operating Permit application 

for and obtaining an amended Title V Operating Permit, provided that all the conditions are met as 

specified in section XVI. A. 1. through 7. of this permit and a notice is submitted to the DES and EPA 

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Final Issued 12/13/2000 
Page 29 of 34 

describing the intended changes. At this point, DES has not included any permit terms authorizing 

emissions trading in this permit. 

1. The change is not a modification under any provision of title I of the Act; 

2. The change does not cause emissions to exceed the emissions allowable under the Title V 

Operating Permit, whether expressed therein as a rate of emissions or in terms of total emissions; 

3. The owner or operator has obtained any temporary permit required by Env-A 600; 

4. The owner or operator has provided written notification to the director and administrator at least 

15 days prior to the proposed change and such written notification includes: 

a.) The date on which each proposed change will occur; 

b.) A description of each such change; 

c.) Any change in emissions that will result and how this change in emissions will comply with 

the terms and conditions of the permit; 

d.) A written request that the operational flexibility procedures be used; and 

e.) The signature of the responsible official, consistent with Env-A 605.04(b); 

5. The Title V Operating Permit issued to the stationary source or area source already contains terms 

and conditions including all terms and conditions which determine compliance required under 40 

CFR 70.6(a) and (c) and which allow for the trading of emissions increases and decreases at the 

permitted stationary source or area source solely for the purpose of complying with a federallyenforceable emissions cap that is established in the permit independent of otherwise applicable 

requirements; 

6. The owner or operator has included in the application for the Title V Operating Permit proposed 

replicable procedures and proposed permit terms which ensure that the emissions trades are 

quantifiable and federally enforceable for changes to the Title V Operating Permit which qualify 

under a federally- enforceable emissions cap that is established in the Title V Operating Permit 

independent of the otherwise applicable requirements; and 

7. The proposed change complies with Env-A 612.02 (e). 

Pursuant to Env-A 612.02(c), the Permittee subject to and operating under this Title V Operating 

Permit may make changes not addressed or prohibitedby this existing Title V Operating Permit at the 

permitted stationary source or area source without filing a Title V Operating Permit application, 

provided that all the conditions specified in Env-A 612.02(c)(1) through (6) are met and a notice is 

submitted to the DES and EPA describing the intended changes. 

Pursuant to Env-A 612.02(d), the Permittee, Operator, Director and Administrator shall attach each 

notice of an off-permit change completed in accordance with Section XVI of this Title V Operating 

Permit to their copy of the current Title V Operating Permit. 

Pursuant to Env-A 612.02(e), any change under Section XVI shall not exceed any emissions 

limitations established under the NH Rules Governing the Control of Air Pollution, or result m an 

increase in emissions, or result in new emissions, of any toxic air pollutant or hazardous air pollutant 

other than those listed in the existing Permit. 

Pursuant to Env-A 612.02(f), the off-permit change shall not qualify for the permit shield under EnvA 609.08. 

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Final Issued 12/13/2000 
XVII. 

Page 30 of 34 

Minor Permit Amendments 

Pursuant to Env-A 612.04 prior to implementing a minor permit modification, the Permittee shall 

submit a written request to the Director in accordance with the requirements of Env-A 612.04(b). 

The Director shall take final action on the minor permit amendment request in accordance with .the 

provisions of Env-A 612.04(c) through (g). 

Pursuant to Env-A 612.04(g), the permit shield specified in Env-A 609.08 shall not apply to minor 

permit amendments under Section XVII. of this Permit. 

Pursuant to Env-A 612.04(1), the Permittee shall be subject to the provisions of Part Env-A 614 and 

Part Env-A 615 if the change is made prior to the filing with the Director a request for a minor permit 

amendment. 

XVIII. Significant Permit Amendments 

Pursuant to Env-A 612.05, a change at the facility shall qualify as a significant permit amendment if it 

meets the criteria specified in Env-A 612.05(a)(1) through (7). 

Prior to implementing the significant permit amendment, the Permittee shall submit a written request 

to the Director, which includes all the information as referenced in Env-A 612.05(b) and (c) and shall 

be issued an amended Title V Operating Permit from the DES. The Permittee shall be subject to the 

provisions of Env-A 614 and Env-A 615 if a request for a significant permit amendment is not filed 

with the Director and/or the change is made prior to the issuance of an amended Title V Operating 

Permit. 

The Director shall take final action on the significant permit amendment in accordance with the 

Procedures specified in Env-A 612.05(d), (e) and (f). 

XIX. Title V Operating Permit Suspension, Revocation or Nullification 

Pursuant to RSA 125-C:13, the Director may suspend or revoke any final permit issued hereunder if, 

following a hearing, the Director determines that: 

1. The Permittee has committed a violation of any applicable statute or state requirement found in 

the New Hampshire Rules Governing the Control of Air Pollution, order or permit condition in 

force and applicable to it; or 

2. That the emissions from any device to which this Permit applies, alone or in conjunction with 

other sources of the same pollutants, presents an immediate danger to the public health. 

The Director shall nullify any Permit, if following a heating in accordance with RSA 541-A:30, II, a 

finding is made that the Permit was issued in whole or in part based upon any information proven to 

be intentionally false or misleading. 

XXt Inspection and Entry 

Pursuant to Env-A 614,01, EPA and DES personnel shall be granted access to the facility covered by 

this Permit, in accordance with RSA 125-C:6,VII for the purposes of: inspecting the proposed or 

permitted site; investigating a complaint; and assuring compliance with any applicable requirement or 

state requirement found in the NH Rules Governing the Control of Air. Pollution and/or conditions of 

any Permit issued pursuant to Chapter Env-A 600. 

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Final Issued 12/13/2000 
XXIo 

Page 31 of 34 

Certifications 

A. Compliance Certification Report 

In accordance with 40 CFR 70.6(c) the Responsible Official shall certify, for the previous 

calendar year, that the facility is in compliance with the requirements of this permit. The report 

shall be submitted annually, no later than April 15th of the following year. The report shall be 

submitted to the DES and to the U.S. Environmental Protection Agency New England Region. 

The report shall be submitted in compliance with the submission requirements below, 

In accordance with 40 CFR 70.6(c)(5), the report shall describe: 

1. The terms and conditions of the Permit that are the basis of the certification; 

2. The current compliance status of the source with respect to the terms and conditions of 

this Permit, and whether the method was continuous or intermittent during the 

reporting period; 

3. The methods used for determining compliance, including a description of the 

monitoring, record keeping, and reporting requirements and test methods; and 

4. Any additional information required by the DES to determine the compliance status of 

the source. 

B. Certification of Accuracy Statement 

All documents submitted to the DES shall .contain a certification of accuracy statement by the 

responsible official of truth, accuracy, and completeness, Such certification shall be in 

accordance with the requirements of 40 CFR 70.5(d) and contain the following language: 

"1 am authorized to make this submission on behalf of the facility for which the 

submission is made. Based on information and belief formed after reasonable 

inquiry, certify that the statements and information in the enclosed documents 

are to the best of my knowledge and belief true, accurate, and complete. am 

aware that there are significant penalties for submitting false statements and 

information or omitting required statements and information, including the 

possibility of fine or imprisonment." 

All reports submitted to DES (except those submitted as emission based fees as outlined in 

Section XXIII of this Permit.) shall be submitted to the following address: 

New Hampshire Department of Environmental Services 

Air Resources Division 

6 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

ATTN: Compliance Bureau 

All reports submitted to EPA shall be submitted to the following address: 

Office of Environmental Stewardship 

Director Air Compliance Program 

United States Environmental Protection Agency 

Congress Street 

Suite 1100 (SEA) 

Boston, MA 02114-2023 

ATTN: Air Compliance Clerk 

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Final Issued 12/13/2000 
Page 32 of 34 

XXII. Enforcement 

Any noncompliance with a permit condition constitutes a violation of RSA 125-C: 15, and, as to 

the conditions in this permit which are federally enforceable, a violation of the Clean Air Act, 42 

U.S.C. Section 7401 et seq., and is grounds for enforcement action, for permit termination or 

revocation, or for denial of an operating permit renewal application by the DES and/or EPA. 

Noncompliance may also be grounds for assessment of administrative, civil or criminal penalties 

in accordance with RSA 125-C:15 and/or the Clean Air Act. This Permit does not relieve the 

Permittee from the obligation to comply with any other provisions of RSA 125-C, the New 

Hampshire Rules Governing the Control of Air Pollution, or the Clean Air Act, or to obtain any 

other necessary authorizations from other governmental agencies, or to comply with all other 

applicable Federal, State, or Local rules and regulations, not addressed in this Permit. 

In accordance with 40 CFR 70.6 (a)(6)(ii) a Permittee shall not claim as a defense in an 

enforcement action that it would have been necessary to halt or reduce the permitted activity in 

order to maintain compliance with the conditions of this Permit. 

XXIII. Emission-Based Fee Requirements 

The Permittee shall pay an emission-based fee annually for this facility as calculated each calendar 

year pursuant to Env-A 704.03. 

The Permittee shall determine the total actual annual emissions from the facility to be included in the 

emission-based multiplier specified in Env-A 704.03(a) for each calendar year in accordance with the 

methods specified in Env-A 620. 

The Permittee shall calculate the annual emission-based fee for each calendar year in accordance with 

the procedures specified in Env-A 704.03 and the following equation: 

FEE E * DPT * CP Im* ISF 

Where: 

FEE 

E 

DPT 

CPImISF 

The annual emission-based fee for each calendar year as specified in Env-A 704. 

The emission-based multiplier is based on the calculation of total annual emissions as specified 

in Env-A 704.02 and the provisions specified in Env-A 704.03(a). 

The dollar per ton fee the DES has specified in Env-A 704.03(b). 

The Consumer Price Index Multiplier as calculated in Env-A 704.03(c). 

The Inventory Stabilization Factor as specified in Env-A 704.03(d). 

The Permittee shall contact the DES each calendar year for the value of the Inventory Stabilization 

Factor and for the value of the Consumer Price Index Multiplier. 

The Permittee shall submit, to the DES, payment of the emission-based fee and a summary of the 

calculations referenced in paragraphs 2 and 3 in Section XXIII. of this Permit for each calendar year 

by October 15 th of the following calendar year in accordance with Env-A 704.04. The emission-based 

fee and summary of the calculations shall be submitted to the following address: 

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Final Issued 12/13/2000 
Page 33 of 34 

New Hampshire Department of Environmental Services 

Air Resources Division 

6 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

ATTN.: Emissions Inventory 

The DES shall notify the Permittee of any under payments or over payments of the annual emissionbased fee in accordance with Env-A 704.05. 

XXIV, Duty To Provide Information 

In accordance with 40 CFR 70.6 (a)(6)(v), upon the DES's written request, the Permittee shall furnish, 

within a reasonable time, any information necessary for determining whether cause exists for modifying, 

revoking and reissuing, or terminating the Permit, or to determine compliance with the Permit. Upon 

request, the Permittee shall furnish to the DES copies of records that the Permittee is required to retain by 

this Permit. The Permittee may make a claim of confidentiality as to any information submitted pursuant 

to this condition in accordance with Part Env-A 103 at the time such information is submitted to DES. 

DES shall evaluate such requests in accordance with the provisions of Part Env-A 103. 

XXV. Property Rights 

Pursuant to 40 CFR 70.6 (a)(6)(iv), this Permit does not convey any property rights of any sort, or any 

exclusive privilege. 

XXVI. Severability Clause 

Pursuant to 40 CFR 70.6 (a)(5), the provisions of this Permit are severable, and if any provision of this 

Permit, or the application .of any provision of this Permit to any circumstances is held invalid, the 

application of such provision to other circumstances, and the remainder of this Permit, shall not be 

affected thereby. 

XXVII. Emergency Conditions 

Pursuant to 40 CFR 70.6(g), the Permittee shall be shielded from enforcement action brought for 

noncompliance with technology based 13 emission limitations specified in this Permit as a result of an 

emergency 14. In order to use emergency as an affirmative defense to an action brought for 

noncompliance, the Permittee shall demonstrate the affirmative defense through properly signed, 

contemporaneous operating logs, or other relevant evidence that: 

1. An emergency occurred and that the Permit-tee can identify the cause(s) of the emergency; 

2. The permitted facility was at the time being properly operated; 

13 Technology based emission limits are those established on the basis of emission reductions achievable with various control measures 

or process changes (e.g., a new source performance standard) rather than those established to attain health based air quality standards. 

14 An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, 

including acts of God, which situation would require immediate corrective action to restore normal operation, and that causes the source to 

exceed a technology based limitationunder the permit, due to unavoidable increases in emissions attributable to the emergency. An 

emergency shall not include noncompliance to the extent caused by •mproperly designed equipment, lack of preventative maintenance, 

careless or improper operations, operator error or decision to keep operating despite knowledge of any of these things. 

T:\Transfer\TVWEBPAG\TV Website\eoncordsteamW fl 2-13 -00.doe 

Final Issued 12/13/2000 
XXVIII. 

Page 34 of 34 

3. During the period of the emergency, the Permittee took all reasonable steps as expeditiously as 

possible, to minimize levels of emissions that exceeded the emissions standards, or other 

requirements in this Permit; and 

4. The Permittee submitted notice of the emergency to the DES within two (2) business days of the 

time when emission limitations were exceeded due to the emergency. This notice must contain a 

description of the emergency, any steps taken to mitigate emission, and corrective actions taken. 

Permit Deviation: 

In accordance with 40 CFR 70.6(a)(3)(iii)(B), the Permittee shall report to the DES all instances of 

deviations from Permit requirements, by telephone or fax, within 24 hours of discovery of such 

deviation. This report shall include the deviation itself, including those attributable to upset 

conditions as defmed in the Permit, the probable cause of such deviations, and any corrective actions 

or preventative measures taken. Said Permit deviation shall also be submitted in writing to the DES in 

the semi-annual summary report of monitoring and testing requirements due July 31 st and January 31 st 

of each calendar year. Deviations are instances where any Permit-condition is violated and has not 

already been reported as an emergency pursuant to Section XXVII of this Permit. 

Reporting a Permit deviation is not an affirmative defense for action brought for noncompliance. 

T:\Transfer\TV WEBPAG\TV Website\eoneordsteamtvfl2-13-00.doc 

Final Issued 12/13/2000 
STATE OF NEW HAMPSHIRE 

Department of Environmental Services 

Air Resources Division 

Title V Operating Permit 

Permit No: TV-OP-014 

Date Issued: March 17, 1999 

This certifies that: 

Tillotson Healthcare Corporation 

20 Spaulding Avenue 

Rochester, NH 

has been granted a Title V Operating Permit for the following facility and location: 

Tfllotson Healthcare Corporation 

20 Spaulding Avenue 

Rochester, NH 

AFS Point Source Number 3301700013 

This Title V Operating Permit is hereby issued under the terms and conditions specified in the Title V Operating 

Permit Application filed with the New Hampshire Department of Environmental Services on June 28, 1996 

under the signature of the following responsible official certifying to the best of their knowledge that the 

statements and information therein are true, accurate and complete. 

Responsible Official: 

John Harrington 

General Manager 

(603)-335-0400 

Technical Contact: 

Richard Hall 

Plant Manager 

(603)-335-0400 

This Permit is issued by the New Hampshire Department of Environmental Services, Air Resources Division 

pursuant to its authority under New Hampshire RSA 125-C and in accordance with the provisions of Code of the 

Federal Regulations 40 Part 70. 

This Title V Operating Permit shall expire on March 31, 2004 

SEE ATTACHED SHEETS FOR ADDITIONAL PERMIT CONDITIONS 

For the New Hampshire Department of Environmental Services, Air Resource Division 

Director, Air Resources Division 
Page 2 

TABLE OF CONTENTS 

II. 

III. 

VI. 

VII. 

VIII. 

VIII A. 

VIII B. 

Facility Description of Operations 

Permitted Activities 

Significant Activities Identification Table 1. 

Stack Criteria Table 2. 

Insignificant Activities Identification 

Exempt Activities Identification 

Pollution Control Equipment Identification Table 3. 

Alternative Operating Scenarios 

Applicable Requirements 

State-only Enforceable Operational and Emission Limitations Table 4. 

4-6 

6 

6 

7-8 

Federally Enforceable Operational and Emission Limitations Table 5. 9-10 

VIII C. Emissions Reductions Trading Requirements 10 

VIII D. Monitoring and Testing Requirements Table 6. 11-12 

VIII E. Recordkeeping Requirements Table 7. 13-15 

VIII F. Reporting Requirements Table 8. 15-16 

IX. Requirements Not Currently Applicable 17 

X° Issuance of a Title V Operating Permit 17 

XI. Title V Operating Permit Renewal Procedures 17 

XII. Application Shield 17 

XIII. Permit Shield 17-18 

XIV. Reopening for Cause 18 

XV. Administrative Permit Amendments 19 
Page 3 

XVI. 

XVII. 

XVIII. 

IXX. 

XX. 

XXI. 

XXII. 

XXIII. 

XXIV. 

XXV 

XXVI 

XXVII 

XXVIII 

Operational Flexibility 

Minor Permit Amendments 

Significant Permit Amendments 

Title V Oper.ating Permit. Suspension, Revocation or Nullification 

Inspection and Entry 

Compliance Certification 

Enforcement 

Emission-Based Fees 

Duty to Provide Information 

19-20 

20 

20-21 

21 

21 

21-22 

22 

23 

24 

24 

24 

24-25 

25 

Property Rights 

Severability Clause 

Emergency Conditions 

Permit Deviations 
Page 4 

Facility Specific Title V Operating Permit Conditions 

I. Facility_ Description of Operations: 

Tillotson Healthcare Corporation manufactures robber•products in Rochester, New Hampshire. The primary 

source of air pollutant emissions at the facility are generated from fuel-burning devices which produce criteria 

pollutant emissions, and from coating and dipping operations which produce Volatile Organic Compounds 

(VOC) and Hazardous Air Pollutant (HAP) emissions. 

II. Permitted Activities: 

In accordance with all of the applicable requirements identified in this permit, the Permittee is authorized to 

operate the devices and or processes identified in Sections III, IV, V and VI within the terms and conditions 

specified in l•his Permit. 

III. Significant Activities Identification: 

Ao The activities identified in the following table (Table 1) are subject to and regulated by this Title V 

Operating Permit: 

EU1 

EU2 

EU3 

Boiler # 1, Nebraska 

Boiler, model series 

# NSC53. 

Ammonia emissions 

from rubber products 

manufacturing. 

VOC Emissions from 

rubber products 

manufacturing. 

#6 fuel oil at no more than 

1.5% sulfur content by 

weight 

Not Applicable 

Not Applicable 

7,200 gallons/24 hr 

#6 fuel oil and; 

2,420,000 gallons #6 

fuel oil during any 

consecutive 12 month 

period.* 

Not Applicable 

Not Applicable 

Stack #1 

Stacks # 4-7, 

9-12, 15-22, 

& 33-38 

48.6mmBtu/hr 

16.63 tons/yr 

and 3.8 lbs/hr 

averaged over a 

24 hour period. 

Stacks # 4-12, 

9-12, 15-22, 

& 33-38 

5.28 tons/yr 

These daily and annual fuel limitations are necessary in order to comply with the 24 hour and annual National 

Ambient Air Quality Standards for sulfur dioxide. 

Based on potential to emit calculations submitted by Tillotson Healthcare to DES on 

June 28,1996. 

2 Based on potential to emit calculations submitted by Tillotson Healthcare to DES on 

June 28,1996. 
Stack Criteria: 

Page 5 

The following stacks for the above listed significant devices at this facility shall discharge vertically 

without obstruction (including rain caps) and meet the following criteria in accordance with the stateonly modeling requirements specified in Env-A 1300 and Env-A 1400: 

Stack #1 

Stack #4 

Stack #5 

EU1 

EU2 and EU3 

EU2 and EU3 

Stack #6 EU2 and EU3 

Stack #7 EU2 and EU3 

Stack #9 EU2 and EU3 

Stack # 10 

Stack # 11 

Stack # 12 

Stack # 15 

Stack #16 

Stack #17 

Stack#18 

Stack #19 

Stack #20 

Stack #21 

Stack #22 

Stack #33 

Stack #34 

Stack #35 

EU2 and EU3 

EU2 and EU3 

EU2 and EU3 

Stack #36 

Stack #37 

Stack #38 

EU2 and EU3 

EU2 and EU3 

EU2 and EU3 

EU2 and EU3 

EU2 and EU3 

EU2 and EU3 

EU2 and EU3 

EU2 and EU3 

EU2 and EU3 

EU2 and EU3 

EU2 and EU3 

EU2 and EU3 

EU2 and EU3 

EU2 and EU3 

40.0 

49.75 

49.75 

49.75 

49.75 

49.75 

49.75 

49.75 

49.7 

55.5 

55.5 

55.'5 

48 

30 

30 

30 

30 

30 

30 

30 

30 

25x29 

25x29 

25x29 

55.5 25x29 

54 40x24 

54 40x24 

54 25x29 

54 25x29 

54 48 

54 

54 

54 

54 

54 

48 

48 

48 

48 

48 

Preauthorized changes to the state-only requirements pertaining to stack parameters (set forth in this permit), 

shall be permitted only when an air quality impact analysis which meets the criteria of Env-A 606 is. 

performed either by the facility or the DES (if requested by facility in writing) in accordance with the "DES 
IV. 

Wo 

VI. 

Page 6 

Policy and Procedure for Air Quality Impact Modeling", All air modeling data shall be kept on file at the 

facility for review by the DES upon request. 

Insignificant Activities Identification: 

All activities at this facility that meet the criteria identified in the New Hampshire Rules Governing the 

Control of Air Pollution Part Env-A 609.03(g), shall be considered insignificant activities. Emissions from 

the insignificant activities shall be included in the total facility emissions for the emission-based fee calculation 

described in Section XXIII of this Permit. 

Exempt Activities Identification: 

All activities identified in the New Hampshire Rules Governing the Control of Air Pollution Env-A 609.03(c) 

shall be considered exempt activities and shall not be subject to or regulated by this Title V Operating Permit, 

Emissions from exempt activities shall not be included in the total facility emissions for the emission based 

fee calculation described in Section XXIII. of this Permit. 

Pollution Control Equipment Identification: 

The device identified in Table 3 is considered pollution control equipment for each identified activity. 

PCE1 Baghouses and Filter Bags-(2 baghouses total) Baghouse Filter 

Efficiency 99.93% 

(based on max. 

allowable emissions 

allowed by Env-A 

2103.02 and 

manufacturer's 

specifications) 

All units and/or 

equipment generating 

corn starch and 

calcium carbonate duat 

and powder. 

All equipment, techniques, facilities and systems installed and used to achieve compliance with the terms and 

conditions of this Permit shall at all times be maintained in good working order and shall be operated in accordance 

with the minimum efficiencies stipulated in Table 3 and/or in accordance with manufacturers specifications, whichever 

is more stringent, so as to minimize air pollutant emissions. Manufacturer's recommended maintenance schedules 

and specifications shall be kept on file for review by the DES and/or EPA upon request. 

VII. Alternative Operating Scenarios: 

No alternative operating scenarios were identified for this Permit. 
Page 7 

VIII. 

VIII. 

Applicable Requirements: 

A. State-only Enforceable Operational and Emission Limitations: 

The Permittee shall be subject to the state-only operational and emission limitations identified in Table 

4 below. 

1. Env-A 1305.01(a) Facility Wide 

2. Env-A .1305.02 Facility Wide 

3. Env-A 1403.01 Facility Wide 

4. Env-A 1403.02(a) Facility Wide 

5. Env-A 1403.02(b) Facility Wide 

6. Env-A 1404.01(d) Facility Wide 

7. Env-A 1405.02 Facility Wide 

8. Env-A 1405.03 Facility Wide 

9. Env-A 1406.01 Facility Wide 

New or modified devices, new or modified area sources, and existing devices or 

area sources for which new applications for permits are filed that have the potential 

to emit, in any amount, substances that meet the criteria of Env-A 1301 shall be 

subject to Env-A 1•300, until such time as the Env-A 1400 requirements supersede 

the Env-A 1300 requirements. (As outlined below) 

Air quality impact analysis of devices and area sources emitting substances meeting 

the criteria of Env-A 1301 shall be performed in accordance with the "DES Policy 

and Procedure for Air Quality Impact Modeling" or other comparable dispersion 

modeling methods approved by EPA. 

In accordance with Env-A 1403.01• new or modified devices or processes installed 

after May 8, 1998, shall be subject to the requirements of Env-A 1400. 

In accordance with 1403.02(a), all existing unmodified devices or processes which 

are in operation during the transition period ending three years from May 8, 1998 

(May 8, 2001), shall comply with either Env-A1300 or Env-A 1400. 

In accordance with Env-A 1403.02(b), all existing devices or processes in 

operation after the transition period ending three years from May 8, 1998 (May 8, 

2001), shall comply with Env-A 1400. Env-A 1300 will no longer be in effect. 

In accordance with Env-A 1404.01(d), documentation for the demonstration of 

compliance shall be retained at the site, and shall be made available to the DES for 

inspection. 

In accordance with Env-A 1405.02 the owner of an existing device or process 

requiring a permit under chapter Env-A 1400 shall submit to the DES no later than 

one year prior to the end of the transition period (May 8, 2000), an application for a 

modification to a title V permit in accordance with Env-A 609.18, and a request to 

the DES to perform air dispersion modeling. 

In accordance with Env-A 1405.03 the owner of an existing device or process 

requiring a permit under Env-A 1300 shall submit to the DES no later than one 

year prior to the end of the transition period (May 8, 2000), a compliance plan 

identifying how the device or process will comply with chapter Env-A 1400 by the 

end of the transition period. The compliance plan shall contain the dates when the 

information required in Env-A 1405.02 will be filed with the DES. 

In accordance with Env-A 1406.01 the owner of any device orprocess which emits 

a regulated toxic air pollutant shall determine compliance with the ambient air 

limits by using one of the methods provided in Env-A 1406.02, Env-A 1406.03, or 

Env-A 1406.04. Upon request, the owner of any device or process which emits a 

regulated toxic air pollutant shall provide documentation of compliance with the 

ambient air limits to the DES. 
Page 8 

io. Env-A 1300 and 

Env-A 1400 

Facility Wide AmmOnia emissions facility wide shall be limited to less than or equal to 3.8 

lbs/hour averaged over a 24 hour period. 
Page 9 

VIII. Federally Enforceable Operational and Emission Limitations 

The Permittce shall be subject to the Federally Enforceable operational and emission limitations 

identified in Table 5 below. 

.Ife•- Reg•lato•Cite .•:- Ap:pli•able "•'.: •'• • qui;em•t '• 

1. Env-A 2003.02 EU1 Visible Emission Standard for •el burning devices installed after May 13,1970. No 

owner or operator shall cause or Mlow average opaci• from •el burning devices 

installed after May 13, 1970 in excess of 20 percent for any continuous 6 minute 

period in a 60 minute period. 

2. Env-A EU1 No owner or operator shall causeor allow emissions ofpagiculate maRer from Nel 

2003.07(c)(2) burning devices installed after May 13, 1970 but before Janua• 1, 1985 in excess of 

the rates set fo•h below, where: 

For devices with maximum gross heat input rate in 10 BTU/hr) equal to or 

greater than 10 but less than 250, E the maximum allowable particulate matter 

emission rate in lb/106 BTU) shall be calculated by raising I to the -0.234 power, 

and multiplying the result by 1.028, expressed mathematically in the formula below: 

E 1.028 1-0.234 

40 CFR 68 Facility Wide Accidental Release Program Requirements. Storage of regulated chemicals at the 

facility are less than the applicability thresholds presented in 40 CFR 68.130 Table 

and Table 2. The facility, therefore, is not subject to the program requirements of 

40 CFR 68. However, the facility is subject to the Purpose and General Duty 

clause of the 1990 Clean Air Act, Section 112(0(1). General Duty includes the 

following responsibilities: 

1. Identify potential hazards which may result from such releases 

using appropriate hazard assessment techniques; 

2. Design and maintain a safe facility; 

3. Take steps necessary to prevent releases; and 

4. Minimize the consequences of accidental releases which do occur. 

Env-A 

2103.02(c)(1) 

Facility Wide 

Env-A 2107.01(a) Facility Wide 

Calculation of Particulate Matter Emission Standards. 

Particulate matter emissions from a "New Device" (from a process, manufacturing 

and service based industry) installed after February 18, 1972 with a process weight 

rate up to 60,000 pounds per hour, shall not exceed the emission rate averaged over 

a one hour period as specified in the formula below, where P (the process weight 

rate in tons per hour) shall be raised to the 0.67 power and multiplied by 4.10: 

E 4.10 p0.67 

Unless otherwise specified in Env-A 2100, no person shall cause or allow visible 

fugitive emissions or visible stack emissions for any process, manufacturing or 

serviced-based industry subject to this chapter to exceed an average of 20 percent 

opacity for any continuous 6-minute period in any 60 minute period, exceptwere 

opacity is specified differently for fuel burning devices in Env-A 2003. 
Page 10 

RSA 125-C:6, 

RSA 125-C:11 

and 

Env-A 606.04. 

Env-A 404.01 

Facility Wide 

EU1 

National Ambient Air Quality Standards (NAAQS). The facility shall comply with 

the national ambient air quality standards and the applicable requirements of RSA 

125-C:6, RSA 125-C:11 and Env-A 606.04. In order to meet these requirements for 

sulfur dioxide, the Permittee shall not exceed the following usages: 

7,200 gallons of#6 fuel oil during any consecutive 24 hour 

period, and; 

2,420,000 gallons of#6 fuel oil during any consecutive 12 month 

period 

Pursuant to RSA 125-D:3,I(e) annual sulfur dioxide emissions from each Class B 

major source, except as provided by Env-A 405.02, shall have an average emission 

rate not to exceed 1.6 pounds of sulfur dioxide per million BTU input, equivalent to 

no. 6 oil with 1.5 percent sulfur by weight, which is 75 percent of the baseline 

average emission rate for Class B major sources. Recordkeeping and tracking of 

individual fuel deliveries shall beconducted in accordance with Section VIII. E. of 

this Permit. 

VIII. Emission Reductions Trading Requirements 

The Permittee did not request emissions reduction trading in its operating permit application. At this 

point, DES has not included any permit terms authorizing emissions trading in this permit. All 

emission reductions trading, must be authorized under the applicable requirements of either Env-A 

3000 (the "Emissions Reductions Credits (or ERCs) Trading Program") or Env-A-3100 (the 

"Discrete Emissions Reductions (or DECs) Trading Program) and 42 U.S.C. §7401 et seq. (The 

"Act"), and must be provided for in this permit. 
Page 11 

VIII. D. Monitoring and Testing Requirements 

The Permittee is subject to the monitoring and testing requirements as contained in Table 6, below: 

Facility 

Stacks 

and EU1 

Bag 

house 

units and 

filter 

bags 

(PCE#1) 

Bag 

house 

units and 

filter 

bags 

(PCE#1) 

EU1 

Allows for Conduc• an annual inspection of each stack and emission unit. Annually Env-A 

adequate Inspections shall be focused on identifying any holes, leaks, 806.01 (4) 

dispersion deppsits, deficencies or deterioration of equipment and and 

of HAPs stacks. Records of inspections and subsequent maintenance 40 CFR 

and other conducted as a result of the annual inspections shall be kept 70.6(a)(3) 

regulated on file at the Facility for review by the DES and/or EPA upon Federally 

pollutants request. Enforceable 

Total 

suspended 

particulate 

Perform weekly observations of opacity in accordance with 

Method 22, 40 CFR Part 60, Appendix A. Record 

observations in a bound logbook weekly. 

Conduct preventative maintenance necessary to ensure the 

operation of each unit in a manner Consistent with 

manufacturer's recommendations. Manufacturer's 

recommendations regarding unit operation shall be kept on 

file at the facility and made available to the DES and/or EPA 

upon request. 

Total 

suspended 

particulate 

Conduct an annual inspection of each unit consistent with 

manufacturers recommended procedures. The inspection 

shall be conducted by plant personnel familiar with the 

operation of the device and equipment. Records of 

inspections and subsequent maintenance conducted shall be 

kept on file at the facility for review by the DES and/or EPA 

upon request. 

Sulfur 

content in 

liquid fuels 

The bperator shall conduct testing in accordance with 

appropriate ASTM test methods to determine compliance 

with the sulfur content limitation provisions in Env-A 

1604.01(a) and 1604.01(c)2 for liquid fuels in order to meet 

the record keeping requirements as specified in Section VIII 

F. Table 7, Item 5 of this Permit. Delivery tickets which 

contain certified information with regards to the percent 

sul•r by weight of the fuel oil being delivered may be used as 

an alternative to determine compliance with the sulfur content 

limitation provisions in Env-A 1604.01 (a) and 1604.01 (c)2 

for liquid fuels. 

Weekly 

Annually 

For each 

delivery of fuel 

oil to the 

facility 

Env-A 

806.01(4) 

and 

40 CFR Part 

70.6(a)(3) 

Federally 

Enforceable 

Env-A 

806.01(4) 

and 

40 CFR Part 

70.6(a)(3) 

Federally 

Enforceable 

Env-A809.01 
Page 12 

EUI Boiler Annual 

efficiency 

Annually, before April 1st of each year the Permittee shall: 

a. Perform an efficiency test using the test 

procedures specified in ASME/ANSI Boiler Test 

Code 4.1; and 

b. Adjust the combustion process of the boiler in 

accordance with the procedures specified in chapter 

5, Combustion Efficiency Tables, Taplin, Hamy R., 

Fairmont Press, 1991; and 

c. Maintain, in a permanently botmd log book the. 

following information: 

i. The date(s) on which the efficiency test 

was conducted; and when the combustion 

process was last adjusted; 

ii. The name(s), title and affiliation of the 

person(s) who conducted the efficiency test 

and what adjustments were made, the 

corresponding NOx and CO emission 

concentrations, •n ppmvd, corrected to 

15% oxygen and opacity readings after the 

adjustments are made. 

Env-A 

1211.05(b) 
VIII. E. 

Page 13 

•Record keeping Requirements: 

The Pcrmittee shall be subject to the record keeping requirements identified in Table 7 below. 

The Permittee shall retain records of all required monitoring data, 

recordkeeping and reporting requirements and support information 

for a period of at least 5 years from the date of origination. 

The Permittee shall maintain records of monitoring requirements as 

specified in Table 6 of this Permit including: 

(a) Preventative maintenance and inspection results 

for stacks and emission units. 

(b) Documentation of weekly observations of opacity 

in accordance with Method 22, 40 CFR Part 60, 

Appendix A for baghOuse units (PCE#1). 

(c) Sunmaary of preventative maintenance and 

inspection results for baghouse units (PCE#1). 

(d) Summary of testing and/or delivery ticket 

certifications for sulfur content limitation 

provisions. 

(e) Summary of efficiency test results performed on 

each boiler by the Pennittee using the test 

procedures specified in ASME/ANSI Boiler Test 

Code 4.1. 

The Permittee shall record monthly fuel usage information including 

th e quantity of fuel used on a daily basis, the calculated 

MMBTU/Year, fuel type, and sulfur content. If more than one type 

of fuel is used, data on each fuel shall be recorded separately.. 

Retain for a Facility wide 40 CFR 

minimum of 5 70.6(a)(3)(ii)(B) 

years Federally 

Enforceable 

Maintain on a Facility wide 40 cFR 

continuous basis 70.6(a)(3)(iii) 

as specified in (A) 

Table 5 of this Federally 

Permit Enforceable 

Maintain on a 

continuous basis 

EU1 Env-A 901.03 

Federally 

Enforceable 
Page 14 

NOx Record keeping Requirements: 

For fuel burning devices, including boilers, turbines, and internal 

combustion engines, the following information shall be recorded and 

maintained: 

(A) Facility information, including: 

1. Source name; 

2. Source identification; 

3. Physical address; 

4. Mailing address; and 

5. A copy of the certificate of accuracy 

required to be maintained pursuant to EnvA 901.04(c). 

(B) Identification of fuel buming device; 

(C) Operating schedule information for each fuel burning 

device identified in (B), above, including; 

1. Days per calendar week during the normal 

operating schedule; 

2. Hours per day during the normal operating 

schedule and for a typical ozone season 

day, if different from the normal operating 

schedule; and 

3 Hours per year during the normal 

operating schedule; 

(D) Type, and amount of fuel bumed, for each fuel burning 

device, during normal operating conditions and for a 

typical ozone season day, if different from normal operating 

conditions, on an hourly basis in million Btu's per hour 

and; 

(E) The following NOx emission data, including records of 

total annual emissions, in tons per •,ear, and typical ozone 

season day emissions, in pounds per day: 

1. Theoretical potential emissions for the 

calculation year for each fuel burning 

device; and 

Act 

ual 

NO 

X 

emi 

ssi 

ons 

for 

eac 

h 

fuel 

bur 

nin 

g 

dev 

ice. 

On a continuous 

basis. 

Facility wide Env-A 901.08 

Federally 

Enforceable 
Page 15 

5. Delivery tickets from each fuel oil supplier for each shipment of fuel Maintain on a Facility wide 

oil received shall be kept on file in a form suitabl e for inspection and continuous basis 

shall be made available to theDES and/or EPA upon request. Each 

delivery ticket shall indicate the name, address and telephone 

number of the fuel oil supplier, the quantity of fuel oil delivered, and 

the percent sulfur by weight of the fuel oil being delivered. If 

delivery tickets do not contain sulfur content of fuel being delivered, 

the Permittee shall perform testing in accordance with appropriate 

ASTM test methods to determine compliance with the sulfur content 

limitation provisions in Env-A 1604.01(a) and 1604.01(c)2 for 

liquid fuels. 

Annual records of actual emmisions for each significant and 

insignificant activity for determination of emission based fees. 

Records of Ammonia emissions shall bekept at the facility for 

review by DES or EPA upon request to demonstrate compliance 

with Env-A 1300 and Env-A 1400. 

Maintain at 

facility at all 

times. 

Maintain at 

facility on a 

continuous basis. 

Significant 

and 

insignificant 

activities 

Facility wide 

40 CFR 

70.6(a)(3) 

Federally 

Enforceable 

Env-A 901.04 

Federally 

Enforceable 

Env-A 1300 and 

Env-A 1400 

State-onl•¢ 

VIII. F. Reporting Requirements: 

The Permit-tee shall be subject to the reporting requirements identified in Table 8 below. 

1. The Permittee shall submit a summary report of monitoring data as 

specified in Table 6 of this permit including: 

(a) Preventative maintenance and inspection results 

for stacks and emission units. 

(b) Summary of weekly observations of opacity in 

accordance with Method 22, 40 CFR Part 60, 

Appendix A for baghouse units (PCE#1). 

Summary of preventative maintenance and 

inspection results for baghouse units (PCE#i). 

(c) Summary of testing and/or delivery ticket 

certifications for sulfur content limitation 

provisions. 

(d) Summary of efficiency test results performed on 

each boiler by the Permittee using the test 

procedures specified in ASME/ANSI Boiler Test 

Code 4.1. 

Every 6 months Facility wide 

by July 31 st and 

January 31 st of 

each calender 

year. 

40 CFR 

70.6(a)(3)(iii) 

Federally 

Enforceable 
Page 16 

Prompt reporting of deviations from Permit requirements shall be 

conducted in accordance with Section XXVIII of this Permit. 

Prompt 

NOx Reporting Requirements: 

For fuel burning devices, including boilers, turbines and engines, as 

well as miscellaneous sources, the owner or operator shall submit tO 

the director, annually (no later than April 15th of the following year), 

reports of the data required by Condition VIII.E., Table 7, Item 4., 

including total annual quantities of all NOx emissions. 

The Permittee shall report monthly fuel usage information including 

the quantity of fuel used on a daily basis, the calculated 

MMBTU/Year, fuel type, and sulfur content. If more than one type 

of fuel is used, data on each fuel shall be reported separately. This 

fuel usage data shall be submitted to the DES quarterly, on a per 

device basis, and due 30 days from the end of the calendar quarter. 

The fuel usage reports shall include per quarter data from the 

previous 3 quarters in addition to the data requested for the current 

reporting quarter. This data shall be totaled on a 12-month rolling 

basis. 

Any report submitted to the DES and/or EPA shall include the 

certification of accuracy statement as outlined in Section XXI.B. of 

this Permit and shall be signed by the responsible official. 

Annual reporting and payment of emission based fees for pollutants, 

including, but not limited to SO2, NOx, CO, TSP, VOCs and Neff 

Hampshire Air Toxic (NHAT) Ammonia emissions shall be 

conducted in accordance with Section XXIII of this Permit 

Annual compliance certification shall be submitted in accordance 

Section XXI of this Permit. 

reporting 

(ie; within 8 

hours of an 

occurrence). 

Annually (no 

later than April 

15th of the 

following year) 

Quarterly, due 

30 days from 

the end of the 

calendar quarter 

As specified 

Annually (no 

later than April 

15th of the 

following year) 

Annually (no 

later than April 

15th of the 

following )/ear) 

Facility wide 

Facility Wide 

EU1 

Facility wide 

Facility wide 

Facility wide 

Env-A 902.02 

& 

40 CFR 

70.6(a)(3)(iii) 

(13) 

Federally 

Enforceable 

Env-A 901.09 

Federally 

Enforceable 

Env-A 

901.08(c)(4) 

Federally 

Enforceable 

40 CFR 

70.6(c)(1) 

Federally 

Enforceable 

Env-A 704.03 

Federally 

Enforceable 

40 CFR 

70.6(c)(1) 

Federally 

Enforceable 
Page 17 

IX. Requirements Currently Not Applicable: 

The Permitee did not identify any requirements not currently applicable to the facility. 

General Title V Operating Permit Conditions 

X. Issuance of a Title V Operating Permit: 

Ao This Permit is issued in accordance with the provisions of Part Env-A 609. In accordance with 40 

CFR 70.6(a)(2) this Permit shall expire on the date specified on the cover page of this Permit, which 

shall not be later.than the date five (5) years after issuance e fthis Permit. 

Permit expiration terminates the Permittee's right to operate the Permittee's emission units, control 

equipment or associated equipment covered by this permit; unless a timely and complete renewal 

application is submitted at least 6 months before the expiration date. 

Pursuant to Env-A 609.02(b), this Permit shall be a state permit to operate as defined in RSA 125- 

C: 11, III. 

XIo Title V Operatin_• Permit Renewal Procedures: 

Pursuant to Env-A 609.06(b), an application for renewal of this Permit .shall be considered timely if it is 

submitted to the Director at least six months prior to the designated expiration date of this Permit. 

XlI. Application Shield: 

Pursuant to Env-A 609.07, if an applicant submits a timely and complete application for the issuance or 

renewal of a Permit, the failure to have a Permit shall not be considered a violation of this part until the 

Director takes final action on the application. 

XIII. Permit Shield: 

A. Pursuant to Env-A 609.08(a), a permit shield shall provide that: 

me For any applicable requirement or any state requirement found in the New Hampshire Rules 

Governing the Control of Air Pollution specifically included in this Permit, compliance with 

the conditions of this Permit shall be deemed compliance with said applicable requirement or 

said state requirement as of the date of permit issuance; and 

For any potential applicable requirement or any potential state requirement found in the New 

Hampshire Rules Goveming the Control of Air Pollution specifically identified in this TitleV 

Operating Permit Section IX Table 8 as not applicable to the stationary source or area source, 

the Permittee need not comply with the specifically identified federal or state requirements. 

The permit shield identified in Section XIII.A. of this Permit shall apply only to those conditions 

incorporated into this Permit in accordance with the provisions of Env-A 609.08(b). It shall not apply 

to certain conditions as specified in Env-A 609.08(c) that may be incorporated into this Permit 
Page 18 

following permit issuance by DES. 

Co Ifa Title V Operating Permit and amendments there to issued by the DES does not expressly include 

or exclude an applicable requirement or a state requirement found in the NH Rules Governing the 

Control of Air Pollution, that applicable requirement or state requirement shall not be covered by the 

permit shield and the Permittee shall comply with the provisions of said requirement to the extent that 

it applies to the Permittee. 

If the DES determines that this Title V Operating Permit was issued based upon inaccurate or 

incomplete information provided by the applicant or Permittee, any permit shield provisions in said 

Title V Operating Permit shall be void as to the portions of said Title V Operating Permit which are 

affected, directly or indirectly, by the inaccurate or incomplete information. 

Pursuant to Env-A 609.08(0, nothing contained in Section XIII of this Permit shall alter or affect the 

ability of the DES to reopen this Permit for cause in accordance with Env-A 609.18 or to exercise 

its summary abatement authority. 

Pursuant to Env-A 609.08(g), nothing contained in this section or in any title V operating permit 

issued by the DES shall alter or affect the following: 

The ability of the DES to order abatement requiring immediate compliance with applicable 

requirements upon finding that there is an imminent and substantial endangerment to public 

health, welfare, or the environment; 

The state of New Hampshire's ability to bring an enforcement action pursuant to RSA 125- 

C: 15,II; 

The provisions of section 303 of the Act regarding emergency orders including the authority 

of the EPA Administrator under that section; 

The liability of an owner or operator of a source for any violation of applicable requirements 

prior to or at the time of permit issuance; 

The applicable requirements of the acid rain program, consistent with section 408(a) of the 

Act; 

The ability of the DES or the EPA Administrator to obtain information about a stationary 

source, area source, or device from the owner or operator pursuant to section 114 of the Act; 

or 

The ability of the DES or the EPA Administrator to enter, inspect, and/or monitor a 

stationary source, area source, or device. 

Reopening for Cause: 

The Director shall reopen and revise a Title V Operating Permit for cause if any of the circumstances 

contained in Env-A 609.18(a) exist. In all proceedings to reopen and reissue a Title V Operating Permit, the 

Director shall follow the provisions specified in Env-A 609.18(b) through (g). 
STATE OF NEW HAMPSHIRE 

Department of Environmental Services 

Air Resources Division 

Title V Operating Permit 

Permit No: TV-OP-022 MINOR AMENDMENT 

Date Issued: May 23, 2000 

This certifies that: 

Dartmouth College 

6111 McKenzie Hall 

Hanover, NH 03755-3552 

has been granted a Title V Operating Permit for the following facility and location: 

Dartmouth College 

Hanover, NH 

AFS Point Source Number 3300900020 

This Title V Operating Permit is hereby issued under the terms and conditions specified in the Title V Operating 

Permit Application filed with the New Hampshire Department of Environmental Services on June 27, 1996, 

along with a FESOP application filed on February 20, 1996, and Amendments to the Title V Permit 

Application filed on: September 18, 1997; December 10, 1997; January 29, 1998 under the signature of the 

following responsible official certifying to the best of their knowledge that the statements and information 

therein are true, accurate and complete. 

Responsible Official; 

Michael K. Getter 

Director 

(603) 646-1110 

Technical Contact: 

Bo Petersson 

Mechanical Engineer, Facilities Operation and Management 

(603) 646-1790 

This Permit is issued by the New Hampshire Department of Environmental Services, Air Resources Division 

pursuant to its authority under New Hampshire RSA 125-C and in accordance with the provisions of Code of 

the Federal Regulations 40 Part 70. 

This Title V Operating Permit shall expire on February 28, 2005. 

SEE ATTACHED SHEETS FOR ADDITIONAL PERMIT CONDITIONS 

For the New Hampshire Department of Environmental Services, Air Resource Division 

Director, Air Resources Division 
Page 2 

TABLE OF CONTENTS 

Wo 

WI. 

VII. 

VIII. 

VIII. A. 

VIII. B. 

VIII. C. 

VIII. D. 

Facility Description of Operations 

Permitted Activities 

Significant Activities Identification Table 1. 

Stack Criteria Table 2. 

Insignificant Activities Identification 

Exempt Activities Identification 

Pollution Control Equipment Identification 

Alternative Operating Scenarios 

Applicable Requirements 

State-only Enforceable Operational and Emission Limitations Table 3. 

Federally Enforceable Operational and Emission Limitations Table 4. 

Emissions Reductions Trading Requirements 

Monitoring and Testing Requirements Table 5. 

VIII. E. Record keeping Requirements Table 6. 

VIII. F. Reporting Requirements Table 7. 

IX. 

Xo 

XI. 

XII. 

XIV. 

XV. 

XVI/I. 

Requirements Currently Not Applicable 

Issuance of a Title V Operating Permit 

Title V Operating Permit Renewal Procedures 

Application Shield 

Permit Shield 

Reopening for Cause 

Administrative Permit Amendments 

Operational Flexibility 

Minor Permit Amendments 

Significant Permit Amendments 

4-10 

10 

10 

10 

10 

11-37 

11-12 

13-24 

24 

25-28 

29-33 

34-37 

37 

37 

37 

37 

37-39 

39 

39 

39-40 

40-41 

41 
Page 3 

XX. 

•TTI. 

Title V Operating Permit Suspension, Revocation or Nullification 

Inspection and Entry 

Certifications 

Enforcement 

Emission-Based Fees 

XXIV. Duty to Provide Information 

XXV. Property Rights 

XXVI. Severability Clause 

XXVII. 

XXVIII. 

Appendix A 

Appendix B 

Emergency Conditions 

Permit Deviations 

Attachment 1 List of Insignificant Activities at Dartmouth College 

Furnaces/Small Boilers & Miscellaneous Items 

Attachment 2 List of Emergency Generators Located at Dartmouth 

College 

41 

41 

42-43 

43 

43 -44 

44 

44 

44 

45 

45 

46-52 

53-55 
Page 4 

Facility Specific Title V Operating Permit Conditions 

I. Facility Description of Operations: 

Dartmouth College is an educational institution located in Hanover, New Hampshire. The college campus 

is composed of educational facilities, including several academic buildings and residential units owned and 

operated by the college. In addition, the college owns and operates a cogeneration facility at it's Hanover 

campus. 

Emission sources associated with the power plant include four utility boilers, an emergency diesel generator, 

two No. 6 fuel oil storage tanks, and a gasoline pump station utilized by service vehicles on the Hanover 

campus. Emission sources at the college's educational facilities include four large furnace/boiler units for 

building heating and .hot water, several small and large capacity emergency generators for emergency 

lighting and running special heating, ventilation, and air conditioning (HVAC) units in libraries for historic 

record and book preservation, several small space heating units, several chillers, several small capacity fuel 

storage tanks, and several HVAC systems for each of the buildings. 

II. Permitted Activities: 

In accordance with all of the applicable requirements identified in this permit, the permittee is authorized 

to operate the devices and or processes identified in Sections III, IV, and V within the terms and conditions 

specified in this Permit. 

III. Significant Activities Identification: 

AJ The activities identified in the following table (Table 1) are subject to and regulated by this Title V 

Operating Permit: 
Page 5 

EU1 Boiler #1 

Zurn, Serial Number 100978 

Installed 1986 

Low NOx Burners Installed 1995 

Stack #1 

(Common stack shared 

among Boilers #1, #2, #3 

and #4) 

Limited to 117.0 million Btu per 

hour gross heat input, which is 

equivalent to 780 gallons per hour of 

No. 6 fuel oil containing no more 

than 1.5 percent sulfur and 0.6 

percent fuel bound nitrogen by 

weight. Maximum steam production 

rate for Boiler #1 will be limited to 

90,000 pounds per hour of 

superheated steam at 450 psig and 

700 degrees F. The maximum 

production rate for Boilers #1, #2, 

#3, & #4 shall be limited to 180,000 

pounds per hour of steam at 450 psig 

and 700 degrees F for any 1-hour 

period. The maximum production rate for the boilers shall also be 

limited to 143,000 pounds per hour 

of steam at 450 psig and 700 degrees 

F for any 6-hour period (a rolling 6- 

hour average shall be calculated each 

hour as the average of the hourly steam flow rates for the previous 6 

hours) [From Temporary Permit TPB-351]. Facility wide cap of 175.0 

tons of actual nitrogen oxide 

emissions for all four boilers at the 

steam plant, four building 

furnace/boiler units, plus all 

emergency generators during any 

consecutive 365 day period for the 

purposes of NSR/PSD avoidance, 

which was the result of the 

construction of the new Boiler #3 

conducted in 1996 [From Temporary 

Permit TP-B-387]. 
Page 6 

Boiler #2 

Babcock & Wilcox 

Serial Number FJ2709 

Installed 1958 

Stack #1 

(Common stack shared 

among Boilers #1, #2, #3 

and #4) 

EU2 Limited to 45.0 million Btu per hour 

gross heat input, from No. 6 fuel oil 

with a maximum sulfur content of 1.5 

percent by weight. The Boiler #2 

maximum steam production rate shall 

be limited to 37,500 pounds per hour 

of saturated steam at 160 psig and a 

feedwater temperature of 258 degrees 

F. The maximum production rate for 

Boilers #1, #2, #3, & #4 shall be 

limited to 180,000 pounds per hour 

of steam at 450 psig and 700 degrees 

F for any 1-hour period. The 

maximum production rate for the 

boilers shall also be limited to 

143,000 pounds per hour of steam at 

450 psig and 700 degrees F for any 

6-hour period (a rolling 6-hour 

average shall be calculated each hour 

as the average of the hourly steam 

flow rates for the previous 6 hours) 

[From Temporary Permit TP-B-351 ]. 

Facility wide cap of 175.0 tons of 

actual nitrogen oxide emissions for 

all four boilers at the steam plant, 

four building furnace/boiler units, 

plus all emergency generators during 

any consecutive 365 day period for 

the purposes of NSR/PSD avoidance, 

which was the result of the 

construction of the new Boiler #3 

conducted in 1996 [From Temporary 

Permit TP-B-387]. 

In a letter dated June 20, 1996, Dartmouth College has requested that the maximum 

firing rate be revised from 60 to 45 mmBtu/hr and maximum steam production rate be changed 

from 49,500 to 37,500 lb/hr to reflect removing the third burner nozzle.from Boiler #2. 
Page 7 

Boiler #3 

Nebraska Boiler Co. 

Model No. NS-E-65SH 

Installed 1996 

Low NOx Burner Installed 1996 

Flue Gas Recirculation 

Stack #1 

(Common stack shared 

among Boilers #1, #2, #3 

and #4) 

EU3 Limited to 95.5 million Btu per hour 

gross heat input, which is equivalent to 636.7 gallons per hour of No. 6 

fuel oil containing no more than 0.5 

percent sulfur by weight. Maximum 

steam production rate for Boiler #3 

will be limited to 75,000 pounds per 

hour of superheated steam at 450 

psig and 700 degrees F. The 

maximum production rate for Boilers 

#1, #2, #3, & #4 shall be limited to 

180,000 pounds per hour of steam at 

450 psig and 700 degrees F for any 

l-hour period, which is equivalent to 

1557 gallons of No. 6 fuel oil. Themaximum production rate for the 

boilers shall also be limited to 

143,000 pounds per hour of steam al 

450 psig and 700 degrees F for any 

6-hour period (a rolling 6-hour 

average shall be calculated each hour 

as the average of the hourly steam 

flow rates for the previous 6 hours) 

[From Temporary Permit TP-B-387]. 

Facility wide cap of 175.0 tons of 

actual nitrogen oxide emissions for 

all four boilers at the steam plant, 

four building furnace/boiler units, 

plus all emergency generators during 

any consecutive 365 day period for 

the purposes of NSR/PSD avoidance, 

which was the result of the 

construction of the new Boiler #3 

conducted in 1996 [From Temporary 

Permit TP-B-387]. 
Page 8 

EU4 Boiler #4 

Combustion Engmeenng 

Model VP- 12W 

Installed 1967 

Low NOx Burner Installed 1995 

Stack #1 

(Common stack shared 

among Boilers #1, #2, #3 

and #4) 

Limited to 97.3 million Btu per hour 

gross heat input, which is equivalem to 648.7 gallons per hour of No. 6 

fuel oil with a maximum sulfur 

content of 1.5 percent and maximum 

fuel bound nitrogen coment of 0.6 

percent by weight. #4 Boiler is 

limited to 70,000 pounds per hour of 

superheated steam at 450 psig and 

700 degrees F. The maximum 

production rate for Boilers #1, #2, 

#3, & #4 shall be limited to 180,000 

pounds per hour of steam at 450 psig 

and 700 degrees F for any 1-hour 

period, which is equivalent to 1557 

gallons of No. 6 fuel oil. The 

maximum production rate for the 

boilers shall also be limited to 

143,000 pounds per hour of steam at 

450 psig and 700 degrees F for any 

6-hour period (a rolling 6-hour 

average shall be calculated each hour 

as the average of the hourly steam 

flow rates for the previous 6 hours) 

[From Temporary Permit TP-B-352]. 

Facility wide cap of 175.0 tons of 

actual nitrogen oxide emissions for 

all four boilers at the steam plant, 

four building furnace/boiler units, 

plus all emergency generators during 

any consecutive 365 day period for 

the purposes of NSR/PSD avoidance, 

which was the result of the 

construction of the new Boiler #3 

conducted in 1996 [From Temporary 

Permit TP-B-387]. 
Page 9 

EU5 All Dartmouth College Emergency Generators 

(See Appendix B for a listing of all Emergency 

Generators located at the Dartmouth College 

facility.) 

Note: The Power Plant Emergency Generator, 

(Caterpillar Model 3508, 800 kW), may not be 

used as a load shaving unit. If it is ever used as a 

load shaving unit, it will be subject to NOx RACT 

requirements contained in Env-A 1211.13 and the 

facility may become subject to other applicable 

requirements. 

Stacks Vary 500 hours of operation during any 

consecutive 12 month period for any 

individual unit, the combined 

theoretical potential emissions of 

NOx from all such generators are 

limited to less than 25 tons for any 

consecutive 12 month period, and a 

facility wide cap of 175.0 tons of 

actual nitrogen oxides emissions for 

all four boilers at the steam plant, 

plus all emergency generators during 

any consecutive 365 day period for 

purposes of NSIUPSD avoidance, 

which was the result of the 

construction of the new.Boiler #3 

conducted in 1996. 

EU6 Tank #1 125,000 gallon No.6 Fuel Oil (AST), Not Applicable (NA) NA 

Installed in 991 

EU7 Tank #2 125,000 gallon No.6 Fuel Oil (AST), NA NA 

Installed in 1991 

Gasoline Service Station 

10,000 gallons gasoline 

Installed in 1991 

Water Chillers 

A. Psychology Building Backup Water Chiller 

(Trane) 

B. Water Chiller Plant (York Electric Chiller) 

C. Webster Hall Backup Water Chiller (McQuay) 

D. Gilman Buildin• Backup Water Chiller (Carrier) 

EU8 

EU9 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

NA 

Stack Criteria: 

B. The following stacks for the above listed significant devices at this facility shall discharge vertically 

without obstruction (including rain caps) and meet the following criteria in accordance with the stateonly modeling requirements specified in Env-A 1300 and Env-A 1400: 

Stack #1 (Common flue for Boilers #1, #2, 175 10.0 

#3, & #4 at the steam plant [EU1, EU2, EU3, 

& EU4]) 

Stack #2 (Power Plant Emer•enc•¢ Generator) 20 0.83 

2 Dartmouth College is in process of replacing several of its battery-powered emergency 

lighting systems located in various buildings on campus with small capacity emergency 

generators. Prior to installation of any new emergency generator, Dartmouth College shall 

submit a cover letter requesting such changes, vendor information for any new emergency 

generator and completed ARD-1 & ARD-2 forms for the new emergency generator. A written 

response from the DES will be required prior to purchase and installation. 
IV. 

VI. 

Page 10 

Preauthorized changes to the state-only requirements pertaining to stack parameters (set forth in this 

permit), shall be permitted only when an air quality impact analysis which meets the criteria of EnvA 606 is performed either by the facility or the DES (if requested by facility in writing) in accordance 

with the "DES Policy and Procedure for Air Quality Impact Modeling". All air modeling data shall 

be kept on file at the facility for review by the DES upon request. 

Insignificant Activities Identification: 

All activities at this facility that meet the criteria identified in the New Hampshire Rules Governing the 

Control of Air Pollution Part Env-A 609.03(g), shall be considered insignificant activities. Emissions from 

the insignificant activities shall be included in the total .facility emissions for the emission-based fee 

c•lculation described in Section XXIII of this Permit. 

See Attachment 1 in Appendix A for a listing of insignificant activities at Dartmouth College, comprised 

of many small-sized residential furnace/boilers used for building heating and making hot water. 

Exempt Activities Identification: 

All activities identified in the New Hampshire Rules Governing the Control of Air Pollution Env-A 

609.03(c) shall be considered exempt activities and shall not be subject to or regulated by this Title V 

Operating Permit. 

Pollution Control Equipment Identification: 

EU1, EU3, and EU4 identified in Table operate with low nitrogen oxide burners (LNB), which are 

classified as pollution control equipment. Each of the three LNB's were technically evaluated by DES and 

determined to meet LNB requirements as part of nitrogen oxide reasonably available control technology 

(NOx RACT) requirements. 

VII. Alternative Operating Scenarios: 

No alternative operating scenarios were identified for this Permit. 
VIII. 

Page 11 

Applicable Requirements: 

A. State-only Enforceable Operational and Emission Limitations: 

The Permittee shall be subject to the state-only operational and emission limitations identified in 

Table 3below. 

1. Env•A 404.01 Facility Wide 

Env-A 1305.01(a) Facility Wide 

3. Env-A 1305.02 Facility Wide 

4. Env-A 1403.01 

5. Env-A 1403.02(a) 

Facility Wide 

Facility Wide 

6. Env-A 1403.02(b) Facility Wide 

Env-A 1404.01(d) Facility Wide 

8. Env-A 1405.02 Facility Wide 

9. Env-A 1405.03 Facility Wide 

Sulfur Dioxide emissions from each Class B major source, shall have an average 

emission rate of 1.6 pounds of sulfur dioxide per million Btu input. Dartmouth 

College shall be required to use No. 6 oil with a maximum of 1.5 percent sulfur 

by weight, with the exception of #3 Boiler, which is limited to using No. 6 oil 

with a maximum sulfur content of 0.5 percent by weight, as required by its initial 

Temporary Permit No. TP-B-387. 

New or modified devices, new or modified area sources, and existing devices or 

area sources for which new applications for permits are filed that have the 

potential to emit, in any amount, substances that meet the criteria of Env-A 1301 

shall be subject to Env-A 1300, until such time as the Env-A 1400 requirements 

supersede the Env-A 1300 requirements. (As outlined below) 

Air quality impact analysis of devices and area sources emitting substances 

meeting the criteria of Env-A 1301 shall be performed in accordance with the 

"DES Policy and Procedure for Air Quality Impact Modeling" or other 

comparable dispersion modeling methods approved by EPA. 

In accordance with Env-A 1403.01, new or modified devices or processes 

installed after May 8, 1998, shall be subj ect to the requirements of Env-A.1400. 

In accordance with 1403.02(a), all existing unmodified devices or processes 

which are in operation during the transition period ending three yea•s from May 

8, 1998 (May 8, 2001), shall comply with either Env-A 1300 or Env-A 1400. 

In accordance with.Env-A 1403.02(b), all existing devices or processes in 

operation after the transition period ending three years from May 8, 1998 (May 

8, 2001), shall comply with Env-A 1400. Env-A 1300 will no longer be in effect. 

In accordance with Env-A 1404.01(d), documentation for the demonstration of 

compliance shall be retained at the site, and shall be made available to the DES 

for inspection. 

In accordance with Env-A 1405.02 the owner of an existing device or process 

requiring a pemait modification under chapter Env-A 1400 shall submit to the 

DES no later than one year prior to the end of the transition period (May 8, 

2000), an application for a modification to a title V permit in accordance with 

Ertv-A_609.18, and a request to the DESto perform airdispersion modeling. 

In accordance with Env-A 1405.03 the owner of an existing device or process 

requiring a permit under Env-A 1300 shall submit to the DES no later than one 

year prior to the end of the transition period (May 8, 2000), a compliance plan 

identifying how the'device or process will comply with chapter Env-A 1400 by 

the end of the transition period. The compliance plan shall contain the dates 

when the information required in Env-A 1405.02 will be filed with the DES. 
Page 12 

10. Env-A 1406.01 

11. Env-A 2003.04(d) 

12. Env-A 2003.04(e) 

13. Env-A2003.04(0 

Facility Wide 

Boilers #1, #2, 

#3, & #4 

[EU1, EU2, 

EU3, & EU4] 

Boilers #1, #2, 

#3, & #4 

[EU1, EU2, 

EU3, & EU4] 

Boiler s #1, #2, 

#3, & #4 

[EU 1, EU2, 

EU3, & EU4] 

In accordance with Env-A 1406.01 the owner of any device or process which 

emits a regulated toxic air pollutant shall determine compliance with the ambient 

air limits by using one of the methods provided in Env-A 1406.02, Env-A 

1406.03, or Env-A 1406.04. Upon request, the owner of any device or process 

which emits a regulated toxic air pollutantshall provide documentation of 

compliance with the ambient air limits to the DES. 

.Exceedances 0fthe opacity standard shall not be considered violations of this 

part if the source demonstrates to the division that such exceedances were the 

result of the adherence to good boiler operating practices which, in the long term, 

results in the most efficient or safe operation of the boiler. 

Examples of activities that may cause exceedances of the opacity standard that 

shall not be considered violations include the following: 

(1) Continuous soot blowing of the entire boiler tube sections over regular time 

intervals as determined by the operator and in conformance with good boiler 

operating practice; and 

(2) Cold startup of a boiler over a continuous period of time resulting in efficient 

heat-up and stabilization of its operation a•qd the expeditious.achievement of 

normal operation of the unit. 

Exceedances of the opacity standard shall not be considered violations of this 

part if the source demonstrates to the division that such exceedances were the 

result of the occurrence of an unplanned incident in which the opacity 

exceedance was beyond the control of the operator and in response to such an 

incident, the operator took appropriate steps in conformance with good boiler 

operating practice to eliminate the excess opaci• as quickl•¢ as possible. 
VIII. 

Page 13 

Federally Enforceable Operational and Emission Limitations 

The Permittee shall be subject to the federally enforceable operational and emission limitations 

identified in Table 4 below. 

RSA 125-C:6, EU1, EU2, 

RSA 125-C:11, and EU3, & EU4 

Env-A 606.04 (Boilers #1, #2, 

#3, & #4) 

Temporary Permit 

TP-B-351 

& 

RSA 125-C:6, 

RSA 125-C:11, and 

Env-A 606.04 

RSA 125-C:6, 

RSA 125-C: 11, and 

Env-A 606.04 

Temporary Permit 

TP-B-387 

& 

RSA 125-C:6, 

RSA 125-C: 11, and 

Env-A 606.04 

Temporary Permit 

TP-B-352 

& 

RSA 125-C:6, 

RSA 125-C:11, and 

Env-A 606.04 

Boiler #1 

[EU1] 

Boiler #2 

[•U•] 

Boiler #3 

[•U3] 

Boiler #4 

[EU4] 

The maximum combined steam production rate for Boilers #1, #2, #3, & #4 shall 

be limited to 180,000 pounds per hour of steam at 450 psig and 700 degrees F 

for any hour period. 

In addition, the maximum co•abined steam production rate for Boilers #1, #2, #3, 

& #4 shall be limited to 143,000 pounds per hour of steam at 450 psig and 700 

degrees F for any 6 hour period. A rolling 6 hour average shall be calculated 

each hour as the average of the hourly steam flow rates for the previous 6 hours. 

These production limitations are imposed in order to protect the 3 hour and 24 

hour NAAQS's for sulfur dioxide emissions. 

The maximum operating rate for Boiler #1 shall be limited to 117.0 mmBtu/hr 

gross heat input, which is equivalent to 780 gallons per hour of No. 6 fuel oil 

containing no more than 1.5 percent sulfur and 0.6 percent nitrogen by weight 

percent. 

The maximum steam production rate for Boiler #1 shall be limited to 90,000 

pounds per hour of superheated steam at 450 psig and 700 degrees F. 

The maximum operating rate of Boiler #2 shall be limited to 45 mmBtu/hr gross 

heat input of No. 6 fuel oil containing no more than 1.5 percent sulfur by weight. 

The maximum steam production rate for Boiler #2 shall be limited to 37,500 

pounds per hour of steam at 160 psig and a feedwater temperature of 258 degrees 

F. 

Boiler #2 shall be allowed to burn less than 1000 gallons per calendar year of 

No. 2 fuel oil with no more than 0.4 percent sulfur by weight for emergency 

situations (i.e. power outages) for the purpose of reheating No. 6 fuel oil in the 

two 125,000 gallon storage tanks in order to bring the steam plant up to normal 

operation after a power outage. (Refer to August 9, 1999 correspondence on file 

with DES describing this matter.) 

The maximum operating rate for Boiler #3 shall be limited to 95.5 mmBtu/hr 

gross heat input, which is equivalent to 636.7 gallons per hour of No. 6 fuel oil 

containing nor more than 0.5 percent sulfur by weight. 

The maximum steam production rate for Boiler #3 shall be limited to 75,000 

pounds per hour of superheated steam at 450 psig and 700 degrees F. 

The maximum operating rate for Boiler #4 shall be limited to 97.3 mmBtu/hr 

gross heat input, which is equivalent to 648.7 gallons per hour of No. 6 fuel oil 

containing no more than 1.5 percent sulfur and 0.6 percent nitrogen by weight. 

The maximum steam production rate for Boiler #4 shall be limited to 70,000 

pounds per hour of superheated steam at 450 psig and 700 degrees F. 
Page 14 

6. Env-A622.03(0(2 ) 

7. Env-A806 

Boilers #1, #2, 

#3, & #4 (EU1- 

EU4), and EU5 

(All emergency 

generators) 

Boilers #1, #2, 

#3, & #4 

(EUI-EU4) 

Dartmouth College Steam Plant (Boilers #1, #2, #3, & #4 plus the emergency 

generator) and all emergency generators located at the Dartmouth College 

facility shall be limited to 175.0 tons of actual NOx emissions during any 

consecutive 365 day period for purposes of NSR/PSD avoidance, which was the 

result of the construction of the new Boiler #3 conducted in 1996. 

The owner or operator shall operate and maintain continuous flow rate 

monitoring/recording systems to measure steam flow rates in pounds per hour for 

each of the Boilers and for the total steam plant. The systems shall meet all 

applicable ASME specifications. 
Page 15 

8. Env-A 1205.05 EU8 Stage I System Physical Requirements for Gasoline Dispensing Facilities. The 

Gasoline owner of an applicable storage tank at a gasoline dispensing facility shall comply 

Dispensing with all of the following requirements: 

Facility (a) The owner shall install a CARB-certified stage I system. 

(b) Stage I systems shall recover at least 95% of all gasoline vapors at the 

(c) 

(d) 

(e) 

(f) 

(g) 

(h) 

facility or be at least as efficient as the manufacturer's design efficiency, 

whichever is higher. 

Each vent pipe on an underground or aboveground gasoline storage tank 

at such a gasoline dispensing facility shall be equipped with 

pressure/vacuum (P/V) relief valves. 

Settings for P/V relief valves for underground tanks shall be the 

following: 

(1) Where specific pressure and vacuum relief settings for P/V 

relief valves are required by CARB for a particular CARBcertified stage II system, such settings shall be used; and 

(2) Where there are no specific relief settings for P/V relief valves 

required by CARB, the settings shall be 8 oz/in or 13.8 inches 

water column pressure and 1⁄2 oz/in or .87 inch water column 

vacuum. 

Settings for P/V relief valves for aboveground tanks shall be the 

following: 

(1) Where specific pressure and vacuum relief settings for P/V 

relief valves are required by CARB for a particular CARBcertified stage II system, such settings shall be used; and 

(2) Where there are no specific pressure and vacuum relief settings 

for P/V relief valves required by CARB, the following shall 

apply: 

a. The vacuum relief setting shall be equal to, or less than 1.7 

oz/in or 3 inches water column; and 

b. The pressure relief setting shall be either: 

1. A pressure of 10% of the maximum allowable 

working pressure of the tank; or 

2. Whichever is less, 8 oz/in or 13.84 inches water 

column. 

Stage I systems shall be equipped with a submerged fill pipe as follows: 

(1) Where the tank is filled from the top, the fill pipe shall 

discharge within 6 inches from the bottom of the tank; or 

(2) Where the tank is filled from the side, the fill pipe shall 

discharge within 18 inches from the bottom of the tank. 

Gasoline storage tanks with a capacity equal to or greater than 250 

gallons shall be equipped with and filled via a submerged fill pipe. 

Stage I systems shall have devices which prevent the flow of product 

until vapor recovery equipment is in place and operational subject to the 

following: 

(1) If a dual-point system is used, a poppetted drybreak shall be 

used on the vapor return to satisfy this section. 

(2) If a coaxial system is used, a cover with a properly sealing 

gasket on the coaxial fill port shall be attached at all times, 

except when product is being delivered. 
Page 16 

9. Env-A 1205.06 

10. Env-A1205.07 

EU8 

Gasoline 

Dispensing 

Facility 

EU8 

Gasoline 

Dispensing 

Facility 

Stage I System Maintenance Requirements for Gasoline Dispensing Facilities. 

The owner or operator of an applicable storage tank at a gasoline dispensing 

facility shall comply with all of the following requirements: 

(a) 

(b) 

(c) 

Stage I equipment shall be maintained and properly operating as 

specified by the manufacturer and CARB. 

Stage I equipment, except P/V relief valves, shall be maintained to be 

vapor tight. Connections between vent pipes and the P/V relief valves 

shall be vapor tight. 

The division shall inspect stage I systems in order to determine 

compliance with these regulations. 

Stage I System Operational Requirements for Gasoline Dispensing Facilities. 

The owner and operator of an applicable storage tank at a gasoline dispensing 

facility shall comply with the following requirements: 

(a) 

(b) 

(c) 

(d) 

No person shall transfer or allow the transfer of gasoline into a gasoline 

storage tank at a gasoline dispensing facility unless a CARB-certified 

stage I system is utilized. 

No person shall deliberately or negligently vent any captured vapors to 

the atmosphere. 

No person shall deliberately or negligently mishandle gasoline such that 

it would result in evaporation into the atmosphere, including spilling, 

discarding into a sewer, or storing in an open container. 

Where a person is gauging or inspecting a storage tank, it shall not be 

performed under the following conditions: 

(1) When loading or unloading operations are in progress; or 

(2) When such tank is left open for more than 5 minutes. 
11. Env-A1205.08 

12. Env-A1211.02O) 

Page 17 

13.. Env-A1211.11(0 

14. Temporary Permit 

TP-B-351 

15. Env-A 1211.05 

(d)(3)(a.)(2.) 

EU8 

Gasoline 

Dispensing 

Facility 

EU5 

All Emergency 

Generators 

EU5 

All Emergency 

Generators 

Boiler #1 

(a) 

(h) 

(c) 

Boiler #1 

Notification of Changes in a Stage I System. 

Within 60 days prior to any construction, installation, or significant 

modification involving a stage I system, the owner shall notify the 

division. 

Within 60 days after a change of ownership, the new owner shall notify 

the division. 

Within 60 days after a change in usage from gasoline to another product 

or another product tO gasoline, the owner shall notify the division. 

Such notification shall be submitted to the division on a Station 

Notification Form provided by the division. 

The owner shall provide the following on the .Station Notification Form: 

(1) The owner's name, address, and signature; 

(2) The name and location of the gasoline dispensing facility; 

(3) The amount of throughput of such facility; 

(4) The type of equipment to be constructed, installed or modified, 

if applicable; 

(5) The date when construction, installation or significant 

modification is scheduled to begin, if applicable; and 

(6) The anticipated date of completion of construction, installation, 

or significant modification, if applicable. 

(f) The division shall inform such owner within 60 days of receipt if the 

.notification does not sufficiently include the information as stated in (e), 

above. 

(g) Where the division is not able to determine the effectiveness Or design 

of the equipment or system being constructed, installed or' significantly 

modified, the division shall request additional information in order to 

make such determination. 

Each emergency generator shall be limited to less than 500 hours of operation 

per year during any consecutive 12 month period. The combined theoretical 

potential emissions from all emergency generators are limited to less than 25. tons 

for any consecutive 12 month period. 

The emissions from emergency generators shall be included in the calculation of 

both the actual and theoretical potential emissions from a stationary source. 

The NOx emission rate of Boiler #1 shall be limited to the following: 

A. 0.31 lb/mmBtu for any 24 hour calendar day average when buming fuel 

oil with a fuel bound nitrogen (FBN) content of 0.39 percent by weight 

or less (monitored during stack testing); OR 

B. 0.39 lb/mmBtu for any 24 hour calendar day average when burning fuel 

oil with a FBN content of 0.60 percent by weight or less monitored 

during stack testing. 

Install, operate, and maintain low NOx burners (LNB) in Boiler #1. The DES 

has conducted a technical evaluation of the current burners used in Boiler #1 and 

approved it as meeting the requirements for a LNB. 

3please refer to Attachment 2 in Appendix B for a listing of all emergency generators located at the 

Dartmouth College facility. 
Page 18 

16. Temporary Permit 

TP-B-387 

17. Env-A.1211.05 

(c)(2)(b.)(2.) 

Boiler #3 

A. 

Boiler #3 

The NOx emission rate of Boiler #3 shall be limited to the following: 

0.29 lb/mmBtu for any 24 hour calendar day average when burning fuel 

oil with a fuel bound nitrogen (FBN) content of 0.39 percent by weight 

or less (monitored during stack testing); OR 

B. 0.39 lb/mmBtu for any 24 hour calendar day average when burning fuel 

oil with a FBN content of 0.60 percent by weight or less monitored 

during stack testing. 

Install, operate, and maintain low NOx burner (LNB) in Boiler #3. The DES has 

conducted a technical evaluation of the current burner used in Boiler #3 and 

approved it as meeting the requirements for a LNB. 

18. Temporary Permit 

TP-B-387 

19. Env-A1211.05 

(d)(3)(a.)(2.) 

20. 40 CFR 524 

21. 40 CFR 525 

22. Env-A2003.01 

23. Env-A2003.02 

Boiler #4 

Boiler #4 

Facility Wide. 

Facility Wide 

Boiler #2 

Boilers #1, #3, 

& #4, and All 

Emergency 

Generators 

The NOx emission rate of Boiler #4 shall be limited to the following: 

A. 0.31 lb/mmBtu for any 24 hour cglendar day average when burning fuel 

oil with a fuel bound nitrogen (FBN) content of 0.39 percent by weight 

or less (monitored during stack testing); OR 

0.39 lb/mmBtu for any 24 hour calendar day average when burning fuel 

oil with a FBN content of 0.60 percent by weight or less monitored 

during stack testing. 

Install, operate, and maintain low NOx burner (LNB) in Boiler #4. The DES has 

conducted a technical evaluation of the current burner used in Boiler #4 and 

approved it as meeting the requirements for a LNB. 

The sulfur content of No. 2 oil shall not exceed 0.40 percent sulfur by weight. 

Gaseous fuel shall contain no more than 5 grains per 100 cubic feet of sulfur, 

calculated as hydrogen sulfide at standard conditions. 

NO owner or operator shall cause or allow average opacity from fuel burning 

devices installed on or prior to May 13, 1970 in excess of 40 percent for any 

continuous 6 minute period in any 60 minute period. 

No 6wner or operator shall cause or allow average opacity from fuel buming 

devices installed after May 13, 1970 in excess of 20 percent for any continuous 6 

minute period in any 60 minute period. 

Env-A 402.02(a), effective on December 27, 1990, was adopted as part of the State 

Implementation Plan (SIP) on September 14, 1992 and is still considered federally enforceable 

until such time as the SIP is amended and approved by the EPA. 

Env-A 402.03, effective on December 27, 1990, was adopted as part of the State Implementation 

Plan (SIP) on September 14, 1992 and is still considered federally enforceable until such time as 

the SIP is amended and approved by the EPA. 
Page 19 

24. 

25. 

26. 

27. 

Env-A 2003.04(a) 

Env-A 2003.04(c) 

Env-A 

2003.08(c)(2) 

Env-A 2003.06(2) 

Env-A 

2003.08(c)(1) 

Env-A 2003.06(2) 

Boiler #3 

Boilers #1, #2, 

& #4 

Boiler #1 

Boiler #2 

Boiler #3 

Activities Exempt from Visible Emission Standards. 

For those steam generating units subject to 40 (2FR 60, no more than one of the 

following 2 exemptions shall be taken: 

(1) During periods of startup, shutdown and malfunction, average 

opacity shall be allowed to be in excess of 20 percent for one 

period of 6 continuous minutes in any 60 minute period; or 

(2) During periods of normal operation, soot blowing, grate 

cleaning, and cleaning of fires; average opacity shall be 

allowed to be in excess of 20 percent but not more than 27 

percent for one period of 6 continuous minutes inany 60 

minute period. 

Activities Exempt •om Visible Emission Standards 

The average opacity shall be allowed to be in excess 0f those standards specified 

in Env-A 2003.01 and Env-A 2003.02 for one period of 6 continuous minutes in 

any 60 minute period during startup, shutdown, malfunction, soot blowing, grate 

cleaning, and cleaning of fires. 

Dartmouth College shall not cause or allow emissions of particulate matter from 

Boiler#l to exceed 0.i5 lb/mmBtu. 

Dartmouth College shall not cause or allow emissions of particulate matter from 

Boiler #2 to exceed 0.47 lb/mmBtu. 

28. 

29. 

30. 

31. 

32. 

40.CFR 60 

Subpart Db 

§ 60.44b(h),(i) 

40 CFR 60 

Subpart Dc 

§ 60.42c(d) 

Standard for sulfur 

dioxide 

40 CFR 60 

Subpart Dc 

§ 60.43c(c) 

Standard for 

particulate matter 

(Opacity) 

Boiler #4 

Boiler #1 

Boiler #3 

Boiler #3 

Dartmouth College shall not cause or allow emissions of particulate matter from 

Boiler #3 to exceed 0.30 lb/mmBtu. 

Dartmouth College shall not cause or allow emissions of particulate matter from 

Boiler #4 to exceed 0.41 lb/mmBtu. 

The nitrogen oxides emissions limitations for this Boiler apply at all times 

including periods of startup, shutdown, or malfunction. 

Compliance with emission limits for nitrogen oxides are to be determined on a 30 

day. rolling average basis. 

On and after the date on which the initial performance test is completed or 

required to be completed under §60.8 of this part, whichever date comes first, no 

owner or operator of an affected facility that combusts oil shall cause to be 

discharged into the atmosphere from that affected facility any gases that contain 

SO2 in excess of 215 ng/J (0.50 lb/million Btu) heat input; or, as an alternative, 

no owner or operator of an affected facility that combusts oil shall combust oil 

in the affected facility that contains greater than 0.5 weight percent sulfur. The 

percent reduction requirements are not applicable to affected facilities under this 

paragraph. 

On and after the date on which the initial performance test is completed or 

required to be completed under §60.8 of this part, whichever date comes first, no 

owner or operator of an affected facility that combusts coal, wood, or oil and has 

a heat input capacity of 8.7 MW (30 million Btu/hr) or greater shall cause to be 

discharged into the atmosphere from that affected facility any gases that exhibit 

greater than 20 percent opacity (6-minute average), except for one 6-minute 

period per hour of not more than 27 percent opacity. 
Page 20 

33. 

34. 

35. 

36. 

37. 

38. 

39. 

40 CFR 60 

Subpart Kb 

§ 60.116b 

EU6 & EU7 

(No. 6 Fuel Oil 

Storage Tanks 

#1 & #2) 

(a) 

(b) 

1990 CAAA 

Section 112(r)(1) 

Facility Wide 

The owner or operator shall keep copies of all records required by this 

section, except for the record reqflired by paragraph (b) of this section, 

for at least 2 years. The record required by paragraph (b) of this section 

will be kept for the life of the source. 

The owner or operator of each storage vessel as specified in 

§60.110b(a) shall keep readily accessible records showing the 

dimension of the storage vessel and an analysis showing the capacity of 

the storage vessel. Each storage vessel with a design capacity less than 

20,000 gallons is subject to no Provision of this Subpart other than those 

required by this paragraph. 

The facility is subject to the Purpose and General Duty clause of the 1990 Clean 

Air ,Act, Section 112(r)(1). General Duty includes the following responsibilities: 

(40 CFR 68) 

2. 

3. 

4. 

Identify potential hazards which may result from such releases 

using appropriate hazard assessment techniques; 

Design and maintain a sgfe facility; 

Take steps necessary to prevent releases; and 

Minimize the consequences of accidental releases which do 

occur. 

Stratospheric Ozone 

Protection 

40 CFR 82 

§ 82.154(a) 

Prohibitions 

EU9 

§ 82.154(b) 

Prohibitions 

§ 82.154(e) 

Prohibitions 

§ 82.154(0 

Prohibitions 

§ 82.154(i) 

Prohibitions 

EU9 

EU9 

EU9 

EU9 

Effective June 14, 1993, no person maintaining, servicing, repairing, or disposing 

of appliances may knowingly vent o r otherwisereleaseinto the environment any 

class I or class II substance used as refrigerant in such equipment. De minimis 

releases associated with good faith, attempts to recycle or recover refrigerants are 

not subject to this prohibition. Releases sh•.ll be considered de minimis if they 

occur when: 

(1) The required practices set forth in §82.156 are observed and recovery or 

recycling machines that meet the requirements set forth in §82.158 are used; or 

(2) The requirements set forth in 40 CFR part 82, Subpart B are observed. 

The knowing release of refrigerant subsequent to its recovery from an appliance 

shall be considered a violation of this prohibition. 

Effective July 13, 1993, no person may open appliances except MVACs for 

maintenance, service, or repair, and no person may dispose of appliances except 

for small appliances, MVACs, and MVAC-like appliances: 

(1) Without observing the required practices set forth in §82.156; and 

(2) Without using equipment that is certified for that type of appliance pursuant 

to §82.158. 

Effective August 12, 1993, no person may open appliances except MVACs for 

maintenance, service, or repair, and no person may dispose of appliances except 

for small appliances, MVACs, and MVAC-Iike appliances, unless such person 

h•s certified tothe Administrator pursuant to §82.162 that such person has 

acquired certified recovery or recycling equipment and is complying with the 

applicable requirements of this Subpart. 

Effective August12, 993, no person may recover refrigerant from small 

appliances, MVACs, and MVAC-like appliances for purposes of disposal of 

these appliances unless such person has certified to the Administrator pursuant to 

§82.162 that such person has acquired recovery equipment that meets the 

standards set forth in §82.158 (1) and/or (m), as applicable, and that such person 

is complying with the applicable requirements of this Subpart. 

Effective August 12, 1993, no person reclaiming refrigerant may release more 

than 1.5% of the refrigerant received by them. 
Page 21 

40. § 82.156(a) 

Required Practices 

41. § 82.162(a) 

Certification by 

owners of recovery 

and recycling 

equipment 

EU9 

EU9 

Effective July 13, 1993, all persons disposing of appliances, except for small 

appliances, MVACs, and MVAC-like appliances must evacuate the refrigerant in 

the entire unit to a recovery or recycling machine certified pursuant to §82.158. 

All persons opening appliances except for MVACs for maintenance, service, or 

repair must evacuate the refrigerant in either the entire unit or the part to be 

serviced (if the latter can be isolated) to a system receiver or a recovery or 

recycling machine certified pursuant to §82.158. Effective January 9, 1995, 

certified technicians must verify that the applicable level of evacuation has been 

reached in the appliance or the part before it is opened. 

(1) Persons opening appliances except for small appliances, MVACs, and 

MVAC-like appliances for maintenance, service, or repair must evacuate to the 

levels in table before opening the appliance, unless 

(i) Evacuation of the appliance to the atmosphere is not to be performed after 

completion of the maintenance, service, or repair, and the maintenance, service,. 

or repair is not major as defined at §82.152(k); or 

(ii) Due to leaks in the appliance, evacuation to the levels in table is not 

attainable, or would substantially contaminate the refrigerant being recovered; or 

(iii) The recycling or recovery equipment was certified pursuant to 

§82.158(b)(2). In any Of these cases, the requirements of §82.156(a)(2) must be 

followed. 

No later than August !2, 1993, or within 20 days of commencing business for 

those persons not in business at the time of promulgation, persons maintaining, servicing, or repairing appliances except for MVACs, and persons disposing of 

appliances except for small appliances and MVACs, must certify to the 

Administrator that such person has acquired certified recovery or recycling equipment and is complying with the applicable requirements of this Subpart. 

Such equipment may include system-dependent equipment but must include 

self-contained equipment, if the equipment is to be used in the maintenance, 

service, or repair of appliances except for small appliances. The owner or lessee 

of the recovery or recycling equipment may perform this cert. ification for his or 

her employees. Certification shall take the form of a statement signed by the 

owner of the equipment or another responsible officer and setting forth: 

(1) The name and address of the purchaser of the equipment, including the 

county name; 

(2) The name and address of the establishment where each piece of equipment is 

or will be located; 

(3) The number of service trucks (or other vehicles) used to transport technicians 

and equipment between the establishment and job sites and the field; 

(4) The manufacturer name, the date of manufacture, and if applicable, the model 

and serial number of the equipment; and 

(5) The certification must also include a statement that the equipment will be 

properly used in servicing or disposing of appliances and that the information 

given is true and correct. Owners or lessees of recycling or recovery equipment having their places of business in: 

Connecticut 

Maine 

Massachusetts 

New Hampshire 

Rhode Island 

Vermont 

must send their certifications to: 

CAA §608 Enforcement Contact, EPA Region I, Mail Code APC, JFK Federal 

Building, One Congress Street, Boston, MA 02203. 
Page 22 

42. 

43. 

44. 

45. 

46. 

§ 82.162(b) 

Certification by owners of recovery 

and recycling 

equipment 

§ 82.166(b) 

Reporting and 

record keeping 

requirements 

§ 82.166(k) 

Reporting and 

record keeping 

requirements 

§ 82.166(m) 

Reporting and 

record keeping 

requirements 

§ 82.166(n) 

Reporting and 

record keeping 

requirements 

EU9 Certificates under paragraph (a) of this section are not transferable. In the event 

of a change of ownership of an entity that maintains, services, or repairs 

appliances except MVACs, or that disposes of appliances except small 

appliances, MVACs, and MVAC-Iike appliances, the new owner of the entity 

shall certify within 30 days of the change of ownership pursuant to paragraph (a) 

of this section. 

EU9 Purchasers of any class I or class II refrigerants who employ certified technicians 

may provide evidence that at least one technician is properly certified to the 

wholesaler who sells them refrigerant; the wholesaler will then keep this 

information on file and may sell refrigerant to the purchaser or his authorized 

representative even if such purchaser or authorized representative is not a 

properly certified technician. In such cases, the purchaser must notify the 

wholesaler in the event that the purchaser no longer employs at least one properly 

certified technician. The wholesaler is then prohibited from selling class I or 

class II refrigerants to the purchaser until such time as the purchaser employs at 

least one properly certified technician. At that time, the purchaser must provide 

new evidence that at least one technician is properly .certified. 

EU9 Owners/operators of appliances normally containing 50 or more pounds of 

refrigerant must keep servicing records documenting the date and type of service, 

as well as the quantity of refrigerant added. The owner/operator must keep 

records of refrigerant purchased and added to such appliances in cases where 

owners add their own refrigerant. Such records should indicate the date(s) when 

refrigerant is added. 

EU9 All records required to be maintained pursuant to this.section must be kept for a 

minimum of three years unless otherwise indicated. Entities that dispose of 

appliances must keep these records on-site. 

EU9 The owners or operators of appliances must maintain on-site and report to EPA 

at the address listed in §82.160 the following information, where such reporting 

and record keeping is required and within the timelines specified under §82.156 

(i)(1), (i)(2), (i)(3) and (i)(5). This information must be relevant to the affected 

appliance and must include: identification of the facility; the leak rate; the 

method used to determine the leak rate and full charge; the date a leak rate of 

greater than the allowable annual leak rate was discovered; the location of 

leaks(s) to the extent determined to date; and any repair work that has been 

completed thus far and the date that work was completed. 
Page 23 

47. 

48. 

49. 

50. 

51. 

§ 82.166(0) 

Reporting and 

record keeping requirements 

1990 CAAA 

Section 608(c)(2) 

Prohibitions 

40 CFR 82 

Subpart G 

Significant New 

Alternatives Policy 

Program 

(SNAP) 

§ 82.174(5) 

Prohibitions 

EU9 

EU9 

EU9 

§ 82.174(c) EU9 

Prohibitions 

§ 82.174(d) EU9 

Prohibitions 

The owners or operators of appliances must maintain on-site and report to EPA 

at the address specified in §82.160 the following information where such 

reporting and record keeping is required and in the timelines specified in §82.156 

(i)(7) and (i)(8), in accordance with §82.156 (i)(7) and (i)(8). This information 

must be relevant to the affected appliance and must include: 

(1) The identification of the industrial process facility; 

(2) The leak rate; 

(3) The method used to determine the leak rate and full charge; 

(4) The date a leak rate of 35 percent or greater was discovered; 

(5) The location of leaks(s) to the extent determined to date; 

(6) Any repair work that has been completed thus far and the date that work was 

completed; 

(7) A plan to complete the retrofit or replacement of the system; 

(8) The reasons why more than one year is necessary to retrofit to replace the 

system; 

(9) The date of notification to EPA; and 

(10) An estimate of when retrofit or replacement work will be completed. 

Effective 5 years after the enactment of the Clean Air Act Amendments of 1990, 

paragraph (1) shall also apply to the venting, release, or disposal of any substitute 

substance for a class I or class II substance by any person maintaining, servicing, 

repairing, or disposing of an appliance or industrial process refrigeration which 

contains and uses as a refrigerant any such substance, unless the Administrator 

determines theat venting, releasing, or disposing of such substance does not pose 

a threat to the environment. For purposes 0fthis paragraph, the term "appliance" 

includes any device which contains and uses as a refrigerant a substitute 

Substance and which is used for household or commercial purposes, including 

any air conditioner, refrigerator, chiller, or freezer. 

No person may use a substitute which a person knows or has reason to know was 

manufactured, processed or imported in violation of the regulations in this 

Subpart, or knows or has reason to know was manufactured, processed or 

imported in violation of any use restriction in the acceptability determination, 

after the effective date of any mlemaking imposing such restrictions. 

No person may use a substitute without adhering to any use restrictions set by the 

acceptability decision, after the effective date of any rulemaking imposing such 

restrictions. 

No person may use a substitute after the effective date of any mlemaking adding 

such substitute to the list of unacceptable substitutes. 

VIII. C. Emission Reductions Trading Requirements 

The Permittee did not request emissions reductions trading in its operating permit application. At 

this point, DES has not included any permit terms authorizing emissions trading in this permit. All 

emission reductions trading, must be authorized under the applicable requirements of either Env-A 

3000 (the "Emissions Reductions Credits (or ERCs) Trading Program") or Env-A 3100 (the 

"Discrete Emissions Reductions (or DERs) Trading Program") and 42 U.S.C. §7401 et seq. (The 

"Act"), and must be provided for in this Permit. 
VIII. 

Page 24 

D. Monitoring/Testing Requirements 

The Permittee is subject to the monitoring/testing requirements as contained in Table 5 below: 

Facility Allows for Conduct an annual inspection of each stack and fuel. Annually 40 CFR 

Stacks adequate burning device. Inspections shall include 70.6(a)(3) 

and dispersion of documenting any leaks, holes, resting and/or disrepair Federally 

boilers HAPs and of stacks, and the manufacturer's recommended Enforceable 

other periodic physical, mechanical, and electrical system 

regulated checks for the fuel burning equipment. Records of 

pollutants inspections and subsequent maintenance conducted as 

a result of the annual inspections shall be kept on file 

at the Facility for review by the DES and/or EPA 

upon request. 

2. Boiler #1 Opacity The owner or operator of an affected facility subject Continuous 

to the opacity standard under §60.43b shall install, 

calibrate, maintain, and operate a continuons 

monitoring system for measuring the opacity of 

emissions discharged to the atmosphere and record 

the output of the system. 

3. Boiler #1 Nitrogen The owner or operator shall insta!l, calibrate, Continuous 

Oxides maintain, and operate a continuous monitoring system 

for measuring nitrogen oxides emissions discharged to 

the atmosphere and record the output of the system. 

4. Boiler #1 Nitrogen 

Oxides 

5. Boiler # Nitrogen 

Oxides 

The continuous monitoring system shall be operated 

and data recorded during all periods of operation of. 

the affected facility except for continuous monitoring 

system breakdowns and repairs. Data is recorded 

during calibration checks, and zero and span 

adjustments. 

The 1-hour average nitrogen oxides emission rates 

measured by the continuous nitrogen oxides monitor 

shall be expressed in lb/million Btu heat input and 

shall be used to calculate the average emission rates 

under §60.44b. The 1-hour averages shall be 

calculated using the data points required under 

§60.13(b). At least 2 data points must be used to 

calculate each 1-hour.average. 

Continuous 

When nitrogen oxides emission data are not obtained 

because of continuous monitoring system 

breakdowns, repairs, calibration checks and zero and 

span adjustments, emission data will be obtained by 

using standby monitoring systems, Method 7, Method 

7A, or other approved reference methods to provide 

.emissiOn data for a minimum of 75 percent of the 

operating hours in each steam generating unit 

operating day, in at least 22 out of 30 successive 

steam generating unit operating days. 

Continuous 

40 CFR 60 

Subpart Db 

§ 60.48b(a) 

Federally 

Enforceable 

40 CFR 60 

Subpart Db 

§ 60.48b(b),(c) 

Federally 

Enforceable 

40 CFR 60 

Subpart Db 

§ 60.48b(d) 

Federally 

Enforceable 

40 CFR 60 

Subpart Db 

§ 60.48b(f) 

Federally 

Enforceable 
Page 25 

6. Boiler #1 

7. Boiler #2 

8. Boiler #3 

Continuous 

Monitors 

Periodic 

Monitoring 

(NOx RACT 

Compliance) 

Opacity 

The procedures under 40 CFR 60, Subpart A, § 60.13 

shall be followed for installation, evaluation, and 

operation of the continuous monitoring systems. 

In addition, the facility will follow and conduct 

quality assurance requirements as specified in 40 

CFR 60, Appendix F. 

Annually, before April st of each year: 

Perform an efficiency test using the test procedures 

specified in ASME/ANSI Boiler Test Code 4.1 and 

adjust the combustion process of the boiler in 

accordance with the procedures specified in Chapter 

5, Combustion Efficiency Tables, Taplin, Harry R., 

Fairmont Press, 1991. 

(a) The owner or operator of an affected facility 

combusting coal, residual oil, or wood that is subject 

to the opacity standards under §60.43c shall install, 

calibrate, maintain, and operate a CEMS for 

measuring the opacity of the emissions discharged to 

the atmosphere and record the output of the system. 

(b) All CEMS for measuring opacity shall be operated 

in accordance with the applicable procedures under 

Performance Specification 1, 40 CFR 60, Appendix 

B. The span value of the opacity CEMS shall be 

between 60 and 80 percent. 

Annually, 

before April 

1st 

Continuous 

40 CFR 60 

Subpart Db 

§ 60.48b(e) 

Federally 

Enforceable 

Env-A 

1211.05(b) 

Federally 

Enforceable 

40 CFR 60 

Subpart De 

§ 60.47c 

Federally 

Enforceable 
Page 26 

Boilers #3 

& #4 

NOx RACT 

Compliance 

Testing 

No less frequently than once every three years, 

Dartmouth College shall Conduct stack testing of 

Boilers #3 & #4 to demonstrate compliance with NOx 

emissions limitations contained in this permit. 

The following test methods shall be used for Boiler 

#l: 

(1) Method 7, 7A, 7C, 7D or 7E, 40 CFR Part 60, 

Appendix A to determine NOx concentrations in stack 

gases from applicable stationary sources. 

(2) Method or 2, 40 CFR Part 60, Appendix A to 

determine the exit velocity of stack gases from 

applicable stationary sources. 

(3) Method 3 or 3A, 40 CFR Part 60, Appendix A to 

determine carbon dioxide, oxygen, excess air and 

molecular weight (dry basis) of stack gases from 

applicable stationary sources. 

(4) Method 4, 40 CFR Part 60, Appendix A to 

determine moisture content (volume fraction of water 

vapor) of stack gases from applicable stationary 

sources. 

The following test methods shall be used for Boilers 

#3 & #4: 

(1) Method 3A, 40 CFR Part 60• Appendix A for 

determination of oxygen and carbon dioxide of stack 

gases from applicable stationary sources. 

(2) Method 7E, 40 CFR Part 60, Appendix A for 

determination of nitrogen oxides concentrations in 

stack gases from applicable stationary sources. 

(3) The diluent and NOx readings are done on a 

consistent wet or dry basis so moisture does not need 

to be performed. Using a Method 19 equation, the lb 

NOx/mmBtu is determined. A calibrated fuel flow 

meter is used to determine the mmBtu/hr heat input. 

Every 3 years Env-A 

1211.21(b),(d) 

Federally 

Enforceable 
Page 27 

10. Boilers Steam Flow 

#1, #2, Rate 

#3, & #4 

11. 

12. 

Boilers Periodic 

#1, #2, Monitoring 

#3, & #4 

Facility Fuel Sulfur 

Wide Content 

Verification 

The owner or Operator shall operate and maintain 

continuous flow rate monitoring/recording systems to 

measure steam flow rates in pounds per hour for each 

ofttie Boilers and for the total steam plant. The 

systems shall meet all applicable ASME 

specifications. 

Average hourly steam production rates in pounds per 

hour for each of the Boilers and the total steam plant 

shall be logged into the data collection system. 

In addition, a rolling 6 hour average shall be 

calculated each hour as the average of the hourly 

steam flow rates for the previous 6 hours for the total 

steam plant and shall be logged into the data 

collection system. 

Fuel flow meters/recorders will be operated and 

maintained for each of the four Boilers to monitor No. 

6 fuel oil usage in each of the boilers. 

The operator shall conduct testing using the 

appropriate ASTM method or retain certified delivery 

tickets from the fuel oil supplier which state the 

weight percent of sulfur for each delivery of fuel oil to 

determine compliance with the sulfur content 

limitation provisions in this permit for liquid fuels in 

order to meet the reporting requirements specified in 

Env-A 900. 

Continuous Env-A 806 

Federally 

Enforceable 

Daily 

For each 

delivery 

Env-A 806 & 

40 CFR 70.6 

(a)(3)(i)(B) 

Federally 

Enforceable 

Env-A 809 

Federally 

Enforceable 
Page 28 

VIII. E. Record keeping Requirements 

The Permittee is subject to the Record keeping requirements as contained in Table 6 below: 

The Permittee shall retain records of all required monitoring Retain for a Facility 40 CFR 

data, record keeping and reporting requirements, and support 

information for a period of at least 5 years from the date of the 

origination. 

The permittee shall maintain records Of monitoring and testing 

as specified in Table 5 of this permit.. 

minimum of 5 

years 

Maintain on a 

The owner or operator shall retain supplier certified delivery 

tickets which state the weight percent sulfur by the supplier for: 

each delivery of No. 6 fuel oil to determine compliance with the 

0.5 percent sulfur content limitation for Boiler #3 and 1.5 

percent sulfur content limitation for Boilers #1, #2, & #4; and 

each delivery of No. 2 fuel oil to determine compliance with the 

0.4 percent sulfur content .limitation for Boiler #2 (emergency 

situations) and all other combustion sources using No. 2 fuel oil 

facility wide. 

The owner or operator shall also compute and keep records of 

the 30 day average sulfur content of No. 6 fuel oil for Boiler #3. 

In addition, reasons for any noncompliance with the sulfur 

content limitation in No. 6 fuel oil shall be recorded. 

The owner or operator of each affected facility shall record and 

maintain records of the amounts of each fuel combusted during 

each day. 

continuous basis 

as specified in 

Table 5 of this 

permit 

Maintain on'a 

continuous basis 

and retain for a 

minimum of 5 

wide 

Facility 

wide 

Boiler #3 

70.6(a)(3)(ii)(B) 

Federally 

Enforceable 

40 CFR 

70.6(a)(3)(iii) 

(a) 

Federally 

Enforceable 

Env-A 809 

& 

40 CFR 60 

years 

Maintain on a 

continuous basis 

and retain for a 

minimum of 5 

years 

Boiler #3 

Subpart Dc 

§ 60.48c(e),(f) 

Federally 

Enforceable 

40 CFR 60 

Subpart Dc 

§ 60.48c(g) 

Federally 

Enforceable 
Page 29 

The owner or operator of an affected facility subject to the 

nitrogen oxides standards undei" §60.44b shall maintain records 

of the following information for each steam generating unit 

operating day: 

(1) Calendar date. 

(2) The average hourly nitrqgen oxides emission rates 

(expressed as NO2) (ng/J or lb/million Btu heat input) measured 

or predicted. 

(3) The 30-day average nitrogen oxides emission rates (ng/J or 

lb/million Btu heat input) calculated at the end of each steam 

generating unit operating day from the measured or predicted 

hourly nitrogen oxide emission rates for the preceding 30 steam 

generating unit operating days. 

(4) Identification of the steam generating unit operating days 

when the calculated 30-day average nitrogen oxides emission 

rates are in excess of the nitrogen oxides emissions standards 

under §60.44b, with the reasons for such excess emissions as 

well as a description of corrective actions taken. 

(5) Identification of the steam generating unit operating days for 

which pollutant data have not been obtained, including reasons 

for not obtaining sufficient data and a description of corrective 

actions taken. 

(6) Identification of the times when emission data have been 

excluded from the calculation of average emission 112 rates and 

the reasons for excluding data. 

(7) Identification of"F" factor used for Calculations, method of 

determination, and type of fuel combusted. 

(8) Identification of the times when the pollutant cqncentration 

exceeded full span of the continuous monitoring system. 

(9) Description of any modifications to the continuous 

monitoring system that could affect the ability of the continuous 

monitoring system to comply with Performance Specification 2 

or 3. 

(10) Results of daily CEMS drift tests and quarterly accuracy 

assessments as required under appendix F, Procedure 1. 

The permittee shall maintain records of average hourly steam 

production rates for each of.the Boilers and the total steam plant 

and rolling 6 hour averages of steam production rates for the 

total steam plant. 

Maintain on a 

continuous basis 

and retain for a 

minimum of 5 

years 

Maintain on a 

continuous basis 

for a period of 5 

years 

Boiler #1 

Boilers #1, 

#2, #3, & #4 

40 CFR 60 

Subpart Db 

§ 60.49b(g) 

Federally 

Enforceable 

40 CFR 

70.06(a)(3) 

Federally 

Enforceable 
Page 30 

7. The permittee shall maintain the following records in a 

permanently bound notebook for the annual Boiler tune-ups for 

Boiler #2, containing the following information: 

1. The date(s) on which: 

a. The efficiency test was conducted; and 

b. The combustion process was last adjusted; 

2. The name(s), title and affiliation of the person(s) who: 

a. Conducted the efficiency test; and 

b. Made the adjustments; 

3. The NOX emission concentration, in ppmvd, corrected to 

15% oxygen, after the adjustments are made; 

4. The CO emission concentration, in ppmvd, corrected to 15% 

oxygen, after the adjustments are made; and 

5. The opacity readings; and 

6. Any other information required by Env-A 901.06 and Env-A 

901.07. 

10. 

11. 

Maintain records of tank capacity; volume and type of VOC 

stored; daily throughput during a normal day and a high ozone 

season day, if different from normal operating conditions; and 

monthly and annual throughput for each of the No. 6 fuel oil 

storage tanks. 

Monthly records of fuel utilization & hours of operation for 

each of the four Boilers shall be kept at the facility and contain 

the foil.owing information: 

(A) Consumption; 

(B) Fuel type; 

(C) Viscosity; 

(D) Sulfur content as percent sulfur by weight of 

fuel; and 

(E) Btu content per gallon or cubic feet of fuel. 

Monthly and calendar year totals of No. 2 fuel oil consumption 

by Boiler #2 for emergency situations. 

Monthly records of fuel utilization & hours of operation for 

each emergency generato r shall be kept at the facility and 

contain the following information: 

Maintain on a 

continuous basis 

Maintain on.a 

continuous basis 

Monthly & 

calendar year 

totals of fuel 

consumption and 

hours of 

operation 

Monthly & 

calendar year 

totals 

Boiler #2 

EU6 & EU7 

(No. 6 Fuel 

Oil Storage 

Tanks #1 & 

#2) 

Boilers #1, 

#2, #3, & #4 

Boiler #2 

All 

Emergency 

Generators 

(A) Consumption; 

(B) Fuel type; 

(C) Viscosity; 

(D) Sulfur content as percent sulfur by weight of 

fuel; and 

(E) Btu content per gallon or cubic feet of fuel. 

Monthly & 

calendar year 

totals of fuel 

consumption and 

hours of 

operation 

Env-A 

1211 ;05(b)(2) & 

40 CFR 

70.6(a)(3)(iii) 

(A) 

Federally 

Enforceable 

Env-A 901.04 

& 

Env-A 901.06 

Federally 

Enforceable 

Env-A 901.03 

Federally 

Enforceable 

Env-A 90i.03 

Federally 

Enforceable 

EnV-A 901.03 

Federally 

Enforceable 
Page 31 

12. 

facility 

(A) 

(B) 

(C) 

(O) 

(E) 

Monthly records of fuel utilization for each furnace/boiler 

located at the Dartmouth College facility shall be kept at the 

and contain the following information: 

Consumption; 

Fuel type; 

Viscosity; 

Sulfur content as percent sulfur by weight of 

fuel; and 

Btu content per gallon or cubic feet of fuel. 

NOX Record keeping Requirements: 

For fuel burning devices, including boilers and internal 

combustion engines, the following information shall be recorded 

and maintained: 

(A) Facility information, including: 

1. Source name; 

2. Source identification; 

3. Physical address; 

4. Mailing address; and 

(B) Identification of fuel buming device; 

(C) Operating schedule information for each fuel 

burning device identified in (13), above, including; 

1. Days per calendar week during the normal 

operating schedule; 

2. Hours per day during the normal operating 

schedule and for a typical ozone season 

day, if different from the normal operating 

schedule; and 

3. Hours per year during the normal 

operating schedule; 

(D) Type, and amount of fuel burned, for each fuel 

burning device, during normal operating conditions 

and for a typical ozone season day, if different from 

normal operating conditions, on an hourly basis in 

.million Btu's per hour; 

(E) The following NOX emission data, including 

records of total annual emissions, in tons per year, and 

typical ozone season day emissions, in pounds per day: 

1. Theoretical potential emissions for the 

calculation year for each fuel burning 

device; and 

2. Actual'NOX emissions for each fuel 

burning device. 

13. 

Monthly & 

calendar year 

totals of fuel 

consumption 

Daily, weekly, 

monthly, and 

annually 

All Furnace/ 

Boiler Units 

Facility 

Wide 

Env-A901.03 

Federally 

Enforceable 

Env-A901.08• 

Federally 

Enforceable 
Page 32 

Stage I S•/stem Record keeping Requirements for Gasoline 

Dispensing Facilities. The owner or operator of an applicable 

storage tank at a gasoline dispensing facility shall maintain on 

site and provide to the division upon request the following: 

(a) 

(b) 

The means to provide access to any and all components 

as necessary to determine compliance with the 

provisions of this part. 

The following records for the length of time specified: 

(1) Record of installation, indefinitely; 

(2) All information pertinent to the proper 

installation, operation and use of gasoline 

vapor recovery equipment, including 

applicable NHDES rules and procedures, 

indefinitely; 

(3) All bulk liquid receipts, and either the amount 

of sales or usage for each operating day, for 

the preceding 3 years; 

(4) All infonnation pertinent to equipment 

failures, repairs, and maintenance, for the 

preceding 3 years; 

(5) Copy of Certificate of Compliance, 

indefinitely; and 

(6) All NHDES correspondence including 

evidence of payment of notification, 

enforcement and renewal fees, for the 

_•recedin 3 ears: 

Maintain records 

for a period of 5 

years 

Gasoline 

Dispensing 

Facility 

Env-A 1205.10 

Federally 

Enforceable 
VIII. Reporting Requirements 

The Permittee is subject to the reporting requirements as contained in Table 7 below: 

Page 33 

voc Reporting Requirements: 

All.sources subject to the reporting requirements of Env-A 

901.07(b) shall submit the following information to the director in 

accordance with the schedule in Env-A 901.07(h): 

(A) Facility infonnation, including: 

1. Source name;. 

2. Source identification; 

3. Physical address; 

4. Mailing address; and 

5. A copy of the certificate of accuracy required 

to be maintained pursuant to Env-A 

901.04(c). 

(B) Identification of each device or process operating at 

the source identified in (A), above; 

(C) Operating schedule information for each device or 

process identified in (B), above, including such 

information for: 

A typical business day; and 

2. A typica! high ozone season day, if different 

from a typical business day; 

(D) Total quantities of actual VOC and NOX emissions 

for the entire facility and for each device or process 

identified in (B), above, inclnding: 

a. Annual VOC emissions, and 

b. Typical high ozone season day VOC 

emissions. 

NOX Reporting Requirementg: 

For fuel burning devices, including boilers and engines, and 

miscellaneous sources, the owner or operator shall submit to the 

director, annually (no later than April 15th of the following year), 

reports of the data required by Condition VIII.E., Table 6, Item 7., 

including total annual quantities of all NOx emissions. 

By April 15, Facility Wide Env-A 

1996 for 901.07(b) 

calendar year Federal D 

1995; evew Enforceable 

third calendar 

year aRer 1995 

by April 15th of 

the following 

year. 

Annually (no 

later than April 

15th of the 

following year) 

Facility Wide Env-A 901.09 

Federally 

Enforceable 
Page 34 

Quarterly Excess Emissions Reporting (Boiler #1): 

The owner or operator of any affected facility in any category 

listed in paragraphs (h)(1) or (2) of this section is required to 

submit exCess emission reports for any calendar quarter during 

which there are excess emissions from the affected facility. If there 

are no excess emissions during the calendar quarter, the owner or 

operator shall submit a report semiannually stating that no excess 

emissions occurred during the semiannual reporting period. 

(1) Any affected facility subject to the opacity standards under 

§60.43b(e) or to the operating parameter monitoring requirements 

under 560.13(i)(1). 

(2) Any affected facility that is subject to the nitrogen oxides 

standard of §60.44b, and that 

(i) Combusts natural gas, distillate oil, or residual oil with a 

nitrogen content of 0.3 weight percent or less, or 

(ii) Has a heat input capacity of 73 MW (250 million Btu/hour) or 

less and is required to monitor nitrogen oxides emissions On a 

continuous basis under §60.48b(g)(1) or steam generating unit 

operating conditions under §60.48b(g)(2). 

(3) For the purpose of §60.43b, excess emissions are defined as all 

6-minute periods during which the average opacity exceeds the 

opacity standaCds under §60.43b(f). 

(4) For purposes of §60.48b(g)(1), excess emissions are defined as 

any calculated 30-day rolling average nitrogen oxides emission 

rate, as determined under §60.46b(e), which exceeds the 

applicable emission limits in §60.44b. 

Quarterly NOx Emissions Report (Boiler #1): 

The owner Or operator of any affected facility subject to the 

continuous monitoring requirements for nitrogen oxides under §60.4•(b) shall submit a quarterly report contain!ng the 

information recorded under paragraph (g) of this section. All 

quarterly reports shall be postmarked by the 30th day following 

the end of each calendar quarter. 

Quarterly Opacity Excess Emissions Reporting (Boiler #3): 

The owner or operator of each coal-fired, residual oil-fired, or 

Wood-fired affected facility subject to the opacity limits under 

§60.43c(c) shall submit excess emission reports for any calendar 

quarter for which there are eXcess emissions from the affected 

facility. If there are no excess emissions during the calendar 

quarter, the owner or operator shall submit a report semiannually 

stating that no excess emissions occurred during the semiannual 

reporting period. The initial quarterly report shall be postmarked 

by.the 30th day of the third month following the completion of the 

initial performance test, unless no excess emissions occur dnring 

that quarter. The initial semiannual report shall be postmarked by 

the 30th day of the sixth month following the completion of the 

initial performance test, or following the date of the previous 

quarterly report, as applicable. Each subsequent quarterly or 

semiannual report shall be postmarked by the 30th day following 

the end of the reporting period. 

Postmarked by 

the 30th day 

after the 

subsequent 

reporting 

period 

Postmarked by 

the 30th day 

after the 

subsequent 

reporting 

period 

Postmarked by 

the 30th day 

after the 

subsequent 

reporting 

period 

Boiler #1 

Boiler #1 

Boiler #3 

40 CFR 60 

Subpart Db 

§60.49b(h) 

Federally 

Enforceable 

40 CFR 60 

Subpart Db 

§60.49b(i) 

Federally 

Enforceable 

40 CFR 60 

Subpart De 

§ 60.48c(c) 

Federally 

Enforceable 
Page 35 

10. 

Quarterly Fuel Oil Sulfur Content for Boiler #3: 

The owner or operator of each affected facility subject to the SO2 

emission limits, fuel oil sulfur limits, or percent reduction 

requirements under §60.42c shall submit quarterly reports to the 

Administrator containing the 30 day average fuel sulfur content for 

each of the three calendar months in the period and any reasons 

for noncompliance with the 0.5 percent sulfur limitation and a 

description of corrective actions taken. 

NOx RACT Stack Testing Results: 

Dartmouth College shall submit a stack testing report to the 

Division within 30 days of the date of the stack test. 

The permittee shall submit an annum fuel usage report indicating 

monthly and calendar year total fuel consumption for all 

combustion devices located at the facility, including, but not 

limited to: boilers emergency generators; furnaces; and 

miscellaneous combustion devices. Type of fuel and fuel sulfur 

content shall be included in the above report. In addition, monthly 

and calendar year totals of No. 2 fuel oil consumption by Boiler 

#2 for emergency situations shall be reported. 

Prompt reporting of deviations from Permit requirements within 

24 hours of such an occurance by phone or fax in accordance with 

Section XXVIII. of this Permit. 

The Permittee shall submit to DES a summary report of 

monitoring and testing requirements every 6 months. All 

instances of deviations from Permit requirements must clearly be 

identified in such reports. All required reports must be certified 

by a responsible official consistent with section 70.5(d). The 

report shall contain a summary of the following information: 

(A) A sumanary report of steam production rate for 

each of the Boilers and the total.steam plant 

wfiich demonstrates compliance with permit 

limitations on individual Boiler hourly steam 

production limits, hourly average steam 

production limits for the total steam plant, and 

the rolling 6 hour average steam production 

limit for the 'total steam plant; 

(B) Preventative maintenance and inspection results 

for stacks and fuel. burning devices. 

(C) A summary of the results of the Boiler Tune-up 

for Boiler #2. 

(D) A summary ]:eport of sulfur content for all fuel 

oil received at the facility, broken out as No. 2 

fuel oil, No. 6 fuel oil for Boiler #3, and No. 6 

fuel oil for Boilers #1, #2, & #4. 

Postmarked by 

the 30th day 

after the 

subsequent 

calendar 

quarter 

Within 30 days 

of stack testing 

Annually (no 

later than April 

15th of the 

following year) 

Prompt 

reporting 

(ie; within 24 

hours of an 

occurrence). 

Every 6 months 

by July 31 st 

and January 

31 st of each 

calendar year. 

Boiler #3 

Boilers #3 & 

#4 

Facility Wide 

Facility Wide 

Facility wide 

40 CFR 60 

Subpart De 

§ 60.48c(d),(e) 

Federally 

Enforceable 

Env-A 

1211.21(c) 

40CFR70.6 

(a)(1) 

Federally 

Enforceable 

Env-A 902.02 

& 

40 CFR 

70.6(a)(3)(iii) 

(B) 

Federally 

Enforceable 

40 CFR 

70.6(a)(3)(iii) 

(A) 

Federally 

Enforceable 
Page 36 

11. 

12. 

13. 

Any report submitted to the DES and/or EPA shall include the 

compliance certification statement as outlined in Section XXI.B. 

of this Permit and shall be signed by the responsible official. 

Annual reporting and payment of emission based fees shall be 

conducted in accordance with Section XXIII of this Pemait 

Annual compliance certification shall be submitted in accordance 

with Section XXI of this Permit. 

As specified 

As specified in 

Section XXIII. 

April 15th 

Facility wide 

Facility wide 

Facility wide 

40 CFR 

70.6(c)(1) 

Federally 

Enfbrceable 

Env-A 704.03 

Federally 

Enforceable 

40 CFR 

70.6(c)(1) 

Federally 

Enforceable 

IX. Requirements Currently Not Applicable: 

The Permittee did not identify any requirements which are not applicable to the facility. 

General Title V Operating Permit Conditions 

X. Issuance of a Title V Operating Permit: 

A. This Permit is issued in accordance with the provisions of Part Env-A 609. In accordance with 40 

CFR 70.6(a)(2) this Permit shall expire on the date specified on the cover page of this Permit, which 

shall not be later than the date five (5) years after issuance of this Permit. 

Permit expiration terminates the Permittee's right to operate the Permittee's emission units, control 

equipment or associated equipment covered bythis Permit, unless a timely and complete renewal 

application is submitted at least 6 months before the expiration date. 

B. Pursuant to Env-A 609.02(b), this Permit shall be a state permit to operate as defined in RSA 125- 

C:ll, III. 

XI. Title V Operating Permit Renewal Procedures: 

Pursuant to Env-A 609.06(b), an application for renewal of this Permit shall be considered timely if it is 

submitted to the Director at least six months prior to the designated expiration date of this Permit: 

XII. Application Shield: 

Pursuant.to Env-A 609.07, if an applicant submits a timely and complete application for the issuance or 

renewal of a Permit, the failure to have a Permit shall not be considered a violation of this part until the 

Director takes final action on the application. 

XIII. Permit Shield: 

A. Pursuant to Env-A 609.08(a), a permit shield shall provide that: 

1. For any applicable requirement or any state requirement found in the New Hampshire Rules 
Bo 

Page 37 

Governing the Control of Air Pollution specifically included in this Permit, compliance with 

the conditions of this Permit shall be deemed compliance with said applicable requirement 

or said state requirement as of the date of permit issuance; and 

For any potentially applicable requirement or any potential state requirement found in the 

New Hampshire Rules Governing the Control of Air Pollution specifically identified in 

Section IX of this Permit as not applicable to the stationary source or area source, the 

Permittee need not comply with the specifically identified federal or state requirements. 

The permit shield identified in Section XIII.A. of this Permit shall apply only to those conditions 

incorporated into this Permit in accordance with the provisions of Env-A 609.08(b). It shall not 

apply to certain conditions as specified in Env-A 609.08(c) that may be incorporated into this Permit 

following permit issuance by DES. 

Ifa Title V Operating Permit and amendments.thereto issued by the DES does not expressly include 

or exclude an applicable requirement or a state requirement found in the NH Rules Governing the 

Control of Air Pollution, that applicable requirement or state requirement shall not be covered by 

the permit shield and the Permittee shall comply with the provisions of said requirement to the extent 

that it applies to the Permittee. 

If the DES determines that this Title V Operating Permit was issued based upon inaccurate or 

incomplete information provided by the applicant or Permittee, any permit shield provisions in said 

Title V Operating Permit shall be void as to the portions of said Title V Operating Permit which are 

affected, directly or indirectly; by the inaccurate or incomplete information. 

Pursuant to Env-A 609.08(0, nothing contained in Section XIII of this Permit shall alter or affect the 

ability of the DES to reopen this Permit for cause in accordance with Env-A 609.18 or to exercise 

its summary abatement authority. 

Pursuant to Env-A 609.08(g), nothing contained in Section XIII of this Permit or in any title V 

operating permit issued by the DES shall alter or affect the following: 

The ability of the DES to order abatement requiring immediate compliance with applicable 

requirements upon finding that there is an imminent and substantial endangerment to public 

health, welfare, or the environment; 

The state of New Hampshire's ability to bring an enforcement action pursuant to RSA 125- 

C:15,II; 

The provisions of section 303 of the Act regarding emergency orders including the authority 

of the EPA Administrator under that section; 

The liability of an owner or operator of a source for any violation of applicable requirements 

prior to or at the time of permit issuance; 

The applicable requirements of the acid rain program, consistent with section 408(a) of the 

Act; 
XV. 

XVI. 

Page 3 8 

The ability of the DES or the EPA Administrator to obtain information about a stationary 

source, area source, or device from the owner or operator pursuant to section 114 of the Act; 

or 

The ability of the DES or the EPA Administrator to enter, inspect, and/or monitor a 

stationary source, area source, or device. 

Reopening for Cause: 

The Director shall reopen and revise a Title V Operating Permit for cause if any of the circumstances 

contained in Env-A 609• 18(a) exist. In all proceedings to reopen and reissue a Title V Operating Permit, 

the Director shall follow the provisions specified in Env-A 609.18(b) through (g). 

Administrative Permit Amendments: 

Ao Pursuant to Env-A 612.01, the Permittee may implement the changes addressed in the request for 

an administrative permit amendment as defined in Part Env-A 100 immediately upon submittal of 

the request. 

Pursuant to Env-A 612.01, the Director shall take final action on a request for an administrative 

permit amendment in accordance with the provisions of Env-A 612.01 (b) and (c). 

Operational Flexibility: 

A. Pursuant to Env-A 612.02(a), the Permittee subject to and operating under this Title V Operating 

Permit may make changes involving trading of emissions under this existing Title V Operating 

Permit at the permitted stationary source or area source without filing a Title V Operating Permit 

application for and obtaining an amended Title V Operating Permit, provided that all the conditions 

are met as specified in Section XVI. A. 1. through 7. of this permit and a notice is submitted to the 

DES and EPA describing the intended changes. At this point, the DES has not included any permit 

terms authorizing emissions trading in this permit. 

1. The change is not a modification under any provision of title I of the Act; 

The change does not cause emissions to exceed the emissions allowable under the 

title V operating permit, whether expressed therein as a rate of emissions or in terms 

of total emissions; 

3. The owner or operator has obtained any temporary permit required by Env-A 600; 

The owner or operator has provided written notification to the director and 

administrator at least 15 days prior to the proposed change and such written 

notification includes: 

a. The date on which each proposed change will occur; 

b. A description of each such change; 
XVII. 

Page 39 

Co Any change in emissions that will result and how this change in emissions 

will comply with the terms and conditions of the permit; 

d. A written request that the operational flexibility procedures be used; and 

e. The signature of the responsible official, consistent with Env-A 605.04(b); 

The title V operating permit issued to the stationary source or area source already 

contains terms and conditions including all terms and conditions which determine 

compliance required under 40 CFR 70.6(a) and (c) and which allow for the trading 

of emissions increases and decreases at the permitted stationary source or area source 

solely for the purpose of complying with a federally-enforceable emissions cap that 

is established in the permit independent of otherwise applicable requirements; 

The owner or operator has included in the application for the title V operating permit 

proposed replicable procedures and proposed permit terms which ensure that the 

emissions trades are quantifiable and federally enforceable for changes to the title V 

operating permit which qualify under a federally- enforceable emissions cap that is 

established in the title V operating permit independent of the otherwise applicable 

requirements; and 

7. The proposed change complies with Env-A 612.02 (e). 

Pursuant to Env-A 612.02(c), the Permittee subject to and operating under this Title V Operating 

Permit may make changes not addressed or prohibited by this existing Title V Operating Permit at 

the permitted stationary source or area source without filing a Title V Operating Permit application, 

provided that all the conditions specified in Env-A 612.02(c)(1) through (6) are met and a notice is 

submitted to the DES and EPA describing the intended changes. 

Co Pursuant to Env-A 612.02(d), the Permittee, Operator, Director and Administrator shall attach each 

notice of an off, permit change completed in accordance with Section XVI of this Title V Operating 

Permit to their copy of the current Title V Operating Permit. 

Do Pursuant to Env-A 612.02(e), any change under Section XVI shall not exceed any emissions 

limitations established under the NH Rules Governing the Control of Air Pollution, or result in an 

increase in emissions, or result in new emissions, of any toxic air pollutant or hazardous air pollutant 

other than those listed in the existing Permit. 

Eo Pursuant to Env-A 612.02(t"), the off-permit change shall not qualify for the permit shield under EnvA 609.08. 

Minor Permit Amendments: 

Ao Pursuant to Env-A 612.04 prior to implementing a minor permit modification, the Permittee shall 

submit a written request to the Director in accordance with the requirements of Env-A 612.04(b). 

The Director shall take f'mal action on the minor permit amendment request in accordance with the 

provisions of Env-A 612.04(c) through (g). 
Page 40 

Ct Pursuant to Env-A 612.04(h), the permit shield specified in Env-A 609.08 shall not apply to minor 

permit amendments under Section XVII. of this Permit. 

Ot Pursuant to Env-A 612.04(i), the Permittee shall be subject to the.provisions of Part Env-A 614 and 

Part Env-A 615 if the change is made prior to the filing with the Director a request for a minor 

permit amendment. 

XVIII. Significant Permit Amendments: 

Ao Pursuant to Env-A 612.05, a change at the facility shall qualify as a significant permit amendment 

if it meets the criteria specified in Env-A 612.05(a)(1) through (7). 

Bo Prior to implementing the.significant permit amendment, the Permittee shall submit a written request 

to the Director and to the EPA which includes all the information as referenced in Env-A 612.05(b) 

and (c) and shall be issued an amended Title V Operating Permit from the DES. The Permittee shall 

be subject to the provisions of Env-A 614 and Env-A 615 if a request for a significant permit 

amendment is not filed with the Director and/or the change is. made prior to the issuance of an 

amended Title V Operating Permit. 

Ct The Director shall take final action on the significant permit amendment in accordance with the 

procedures specified in Env-A 612.05(d), (e) and (f). 

XIX. Title V Operating Permit Suspension, Revocation or Nullification: 

At Pursuant to RSA 125-C: 13, the Director may suspend or revoke any final permit issued hereunder 

if, following a hearing, the Director determines that: 

the Permittee has committed a violation of any applicable statute or state requirement found 

in the New Hampshire Rules Governing the Control of Air. Pollution, order or permit 

condition in force and applicable to it; or 

that the emissions from any device to which this Permit applies, alone or in conjunction with 

other sources of the same pollutants, presents an immediate danger to the public health. 

Bo The Director shall nullify any Permit, if following a hearing in accordance with RSA 541-A:30, II, 

a finding is made that the Permit was issued in whole or in part based upon any information proven 

to be intentionally false or misleading. 

XX. Inspection and Entry: 

Pursuant to Env-A 614.01, EPA and DES personnel shall be granted access to the facility covered by this 

Permit, in accordance with RSA 125-C:6,VII for the purposes of: inspecting the proposed or permitted site; 

investigating a complaint; and assuring compliance with any applicable requirement or state requirement 

found in the NH Rules Governing the Control of Air Pollution and/or conditions of any Permit issued 

pursuant to Chapter Env-A 600. 
Certifications: 

Ao 

BJ 

Page 41 

Compliance Certification Report 

In accordance with40 CFR 70.6(c) the Responsible Official shall certify for the previous calendar 

year that the facility is in compliance with the requirements of this permit. The report shall be 

submitted to the DES and to the U.S. Environmental Protection Agency New England Region. The 

report shall be submitted in compliance with the submission requirements below. 

In accordance with 40 CFR 70.6(c)(5), the report shall describe: 

1. The terms and conditions of the Permit that are the basis of the certification; 

2. The current compliance status of the source with respect to the terms and conditions of this 

Permit, and whether the method was continuous or intermittent during the reporting period; 

3. The methods used for determining compliance, including a description of the monitoring, 

record keeping, and reporting requirements and test methods; and 

4. -Any additional information required by the DES to determine the compliance status of the 

source. 

Certification of Accuracy Statement 

All documents submitted to the DES shall contain a certification of accuracy statement by the 

responsible official of truth, accuracy, and completeness. Such certification shall be in accordance 

with the requirements of 40 CFR 70.5(d) and contain the following language: 

"I am authorized to make this submission on behalf of the facility for which the submission is made. 

Based on information and belief formed after reasonable inquiry, I certify that the statements and 

information in the enclosed documents are to the best of my knowledge and belief true, accurate and 

complete. I am aware that there are significant penalties for submitting false statements and 

information or omitting required statements and information, including the possibility of fine or 

imprisonment." 

All reports submitted to DES (except those submitted as emission based fees as outlined in Section 

XXIII. of this Permit) shall be submitted to the following address: 

New Hampshire Department of Environmental Services 

Air Resources Division 

6 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

ATTN: Compliance Bureau 
Page 42 

All reports submitted to EPA shall be submitted to the following address: 

Office of Environmental Stewardship 

Director Air Compliance Program 

United States Environmental Protection Agency 

1 Congress Street 

Suite 1100 (SEA) 

Boston, MA 02114-2023 

ATTN: Air Compliance Clerk 

XXII. Enforcement: 

Any noncompliance with a permit condition constitutes a violation of RSA 125-C:15, and, as to the 

conditions in this permit which are federally enforceable, a violation of the Clean Air Act, 42 U.S.C. section 

7401 et seq., and is grounds for enforcement action, for permit termination or revocation, or for denial of 

an operating permit renewal application by the DES and/or EPA. Noncompliance may also be grounds for 

assessment of administrative, civil or criminal penalties in accordance with RSA 125-C:15 and/or the Clean 

Air Act. This Permit does not relieve the Permittee from the obligation to comply with any other.provisions 

of RSA 125-C, the New Hampshire Rules Governing the Control of Air Pollution, or the Clean Air Act, or 

to obtain any other necessary authorizations from other governmental agencies, or to comply with all other 

applicable Federal, State, or Local rules and regulations, not addressed in this Permit. 

In accordance with 40 CFR 70.6 (a)(6)(ii) a Permittee shall not claim as a defense in an enforcement action 

that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance 

with the conditions of this Permit. 

XXIII. Emission-Based Fee Requirements: 

The Permittee shall pay an emission-based fee annually for this facility as calculated each calendar 

year pursuant to Env-A 704.03. 

The Permittee shall determine the total actual annual emissions from the facility to be included in 

the emission-based multiplier specified in Env-A 704.03(a) for each calendar year in accordance 

with the methods specified in Env-A 620. 

CQ The Permittee shall calculate the annual emission-based fee for each- calendar year in accordance 

with the procedures specified in Env-A 704.03 and the following equation: 

FEE E * DPT * CPIm * ISF 

Where: 

FEE 

E= 

DPT 

CPIm 

The annual emission-based fee for each calendar year as specified in Env-A 704. 

The emission-based multiplier is based on the calculation of total annual emissions 

as specified in Env-A 704.02 and the provisions Specified in Env-A 704.03(a). 

The dollar per ton fee the DES has specified in Env-A 704.03(b). 

The Consumer Price Index Multiplier as calculated in Env-A 704.03(c). 
Do 

Eo 

Gt 

Page 43 

ISF The Inventory Stabilization Factor as specified in Env-A 704.03(d). 

The Permittee shall contact the DES each calendar year for the value of the Inventory Stabilization 

Factor. 

The Permittee shall contact the DES each calendar year for the value of the Consumer Price Index 

Multiplier. 

The Permittee shall submit, to the DES, payment of the emission-based fee and a summary of the 

calculations referenced in Sections XXIII.B. and C of this Permit for each calendar year by October 

15 th of the following calendar year in accordance with Env-A 704.04. The emission-based fee and 

summary of the calculations shall be submitted to the following address: 

New Hampshire Department of Environmental Services 

Air Resources Division 

6 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

ATTN: Emissions Inventory 

The DES shall notify the Permittee of any under payments or over payments of the annual emissionbased fee in accordance with Env-A 704.05. 

XXIV. Duty To Provide Information 

In accordance with 40 CFR 70.6 (a)(6)(v), upon the DES's written request, the Permittee shall furnish, within 

a reasonable time, any information necessary-for determining whether cause exists for modifying, revoking 

and reissuing, or terminating the Permit, or to determine compliance with the Permit. Upon request, the 

Permittee shall furnish to the DES copies of records that the Permittee is required to retain by this Permit. 

The Permittee may make a claim of confidentiality as to any information submitted pursuant to this 

condition in accordance with Part Env-A 103 at the time such information is submitted to the DES. The 

DES shall evaluate such requests in accordance with the provisions of Part Env-A 103. 

XXV. Property Rights 

Pursuant to 40 CFR 70.6 (a)(6)(iv), this Permit does not convey any property rights of any sort, or any 

exclusive privilege. 

XXVI. Severability Clause 

Pursuant to 40 CFR 70.6 (a)(5), the provisions of this Permit are severable, and if any provision of this 

Permit, or the application of any provision of this Permit to any circumstances is held invalid, the application 

of such provision to other circumstances, and the remainder of this Permit, shall not be affected thereby. 
Page 44 

XXVII. Emergency Conditions 

Pursuant to 40 CFR 70.6 (g), the Permittee shall be shielded from enforcement action brought for 

noncompliance with technology based 6 emission limitations specified in this Permit as a result of an 

emergency 7. In order to use emergency as an affirmative defense to an action brought for noncompliance, 

the Permittee shall demonstrate the affirmative defense through properly signed, contemporaneous operating 

logs, or other relevant evidence that: 

A. An emergency occurred and that the Permittee can identify the cause(s) of the emergency; 

B. The permitted facility was at the time being properly operated; 

Co During the period of the emergency, the Permittee took all reasonable steps as expeditiously as 

possible, to minimize levels of emissions that exceeded the emissions standards, or other 

requirements in this Permit; and 

The Permittee submitted notice of the emergency to the DES within two (2) business days of the 

time when emission limitations were exceeded due to the emergency. This notice must contain a 

description of the emergency, any steps taken to mitigate emission, and corrective actions taken. 

XXVIII. Permit Deviation 

In accordance with 40 CFR 70.6(a)(3)(iii)(B), the Permittee shall report to the DES all instances of 

deviations from Permit requirements, by telephone or fax, within 24 hours of discovery of such deviation 

pursuant to Env-A 902.02. This report shall include the deviation itself, including those attributable to upset 

conditions as defined in the Permit, the probable cause of such deviations, and any corrective actions or 

preventative measures taken. Said Permit deviation shall also be submitted in writing to the DES within 

fifteen (15) days of documentation of the deviation by .facility personnel. Deviations are instances where 

any Permit condition is violated and has not already been reported as an emergency pursuant to Section 

XXVII of this Permit. 

Reporting a Permit deviation is not an affirmative defense for action brought for noncompliance. 

h :'daughton\permits\dartcolg\tvminmod.wpd 

Minor Modification for opacity exceedances March 2000 

Technology based emission limits are those established on the basis of emission reductions achievable with various 

control measures or process changes (e.g., a new source performance standard) rather than those established to attain 

health based air quality standards. 

An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control 

of the source, including acts of God, which situation would require immediate corrective action to restore normal 

operation, and that causes the source to exceed a technology based limitation under the permit, due to unavoidable 

increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused 

by improperly designed equipment, lack of preventative maintenance, careless or improper operations, operator error or 

decision to keep operating despite knowledge of any of these things. 
Page 45 

APPENDIX A 
Page 46 

ATTACHMENT 1 List of Insignificant Activities at Dartmouth College Furnaces/Small Boilers 

List of Insignificant Activities at Dartmouth College Furnaces/Small Boilers 

Location/Description 

Lodge 

Lodge 

29 South Park 

29 South Park 

27 South Park 

27 South Park 

25 South Park 

25 South Park, 

23 South Park 

23 South Park 

19 South Park 

19 South Park 

9 South Park 

# of Units Fuel Type 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

9 South Park 

7 South Park 

7 South Park 

5 South Park 

5 South Park 

67 East Wheelock 

67 East Wheelock 

28 East Wheelock East 

28 East Wheelock East 

28 East Wheelock West 

28 East Wheelock West 

26 East Wheelock 

26 East Wheelock 

24 East Wheelock 

24 East Wheelock 

23 East Wheelock 

Heat Input per Unit 

(mmBtu/hr) 

0.84 

0.32 

0.21 

0.08 

0.21 

0.08 

No. 2 Fuel Oil 0.21 

No. 2 Fuel Oil 0.08 

No. 2 Fuel Oil 0.23 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

NO. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2.Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

NO. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

'0.08 

0.23 

0.08 

0.32 

0.08 

0.18 

0.08 

0.04 

0.08 

0.18 

0.18 

0.21 

0.08 

0.15 

0.08 

0.21 

0.08 

0.37 

0.08 

0.42 
Page 47 

List of Insignificant Activities at Dartmouth College Furnaces/Small Boilers 

23 East Wheelock No. 2 Fuel Oil 

North Park No. 2 Fuel Oil 

North Park No. 2 Fuel Oil 

13 East Wheelock 

13 East Wheelock 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

0.12 

0.37 

0.12 

0.32 

0.12 

11 East Wheelock No. 2 Fuel Oil 0.46 

11 East Wheelock No. 2 Fuel Oil 0.08 

Gould House 1. No. 2 Fuel Oil 0.12 

South Balch 

South Balch 

Valley Road 

Valley Road 

Valley Road 

Austin Avenue 

Austin Avenue 

Hudson House 

Remsen 

Vail 

River Crest 

Fletcher 

Chandler 

Dresdon 

Bridgeman 

Burton 

Masacoma Street 

Masacoma Street 

6 No. 2 Fuel Oil 

6 No. 2 Fuel Oil 

6 

14 No. 2 Fuel Oil 

4 No. 2 Fuel Oil 

No, 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

61 No. 2 Fuel Oil 

29 

13 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

Fullington Farm Garage 

Brown House 

10 West Wheelock 

2 No. 2 Fuel Oil 

5 No. 2 Fuel Oil 

4 No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

10 West Wheelock 

19 West Wheelock 

25 West Wheelock 

0.08 

0.08 

0.12 

0.14 

0.08 

0.12 

0.08 

0.14 

1.68 

1.68 

0.08 

0.12 

0.12 

0.14 

0.14 

0.12 

0.18 

0.08 

0.18 

0.14 

0.49 

0.08 

0.23 

0.42 
Page 48 

List of Insignificant Activities at Dartmouth College, Furnaces/Small Boilers 

27 West Wheelock 

25 1⁄2 West Wheelock 

20 West Street 

20 West Street 

18 Allen Street 

18 Allen Street 

2 Prospect Street 

2 Prospect Street 

9 Webster 

9 Webster 

13 Webster 

13 Webster 

15 Webster 

5 Webster Terrace 

& 30ccum Ridge 

& 30ccum Ridge 

DOC House 

DOC House 

29 Rope Ferry 

29 Rope Ferry 

12 Rope Ferry 

12 Rope Ferry 

35 North Main Street 

36 North Main Street 

36 North Main Street 

Fuller Boat House 

Crew Facilities 

Crew Facilities 

42 College 

42 College 

8 Clement 

4Dana 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

1 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

0.42 

0.32 

0.37 

0.11 

021 

0.11 

0.21 

0.11 

0.23 

0.08 

0.32 

0.11 

0.32 

0.21 

No. 2 Fuel Oil 0.11 

No. 2 Fuel Oil 0.08 

No. 2 Fuel Oil 0.56 

No. 2 Fuel Oil 0.32 

No. 2 Fuel Oil 0.23 

No. 2 Fuel Oil 0.08 

No. 2 Fuel Oil 0.23 

No. 2 Fuel Oil 0.11 

No. 2 Fuel Oil 0.49 

No. 2 Fuel Oil 0.23 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

0.08 

0.08 

0.18 

0.25 

0.21 

0.11 

0.23 

0.21 
Page 49 

List of Insignificant Activities at Dartmouth College Furnaces/Small Boilers 

4 Dana 

Hillcrest 

Hillcrest 

Parker House 

Webster Cottage 

44 East Wheelock 

44 East Wheelock 

56East Wheelock 

5 Woodmare 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

0.08 

0.56 

0.56 

0.37 

0.08 

0.14 

No. 2 Fuel Oil 0.08 

No. 2 Fuel Oil 0.14 

No. 2 Fuel Oil 0.14 

Morton Farm No. 2 Fuel Oil 0.18 

44 College No. 2 Fuel Oil 0.23 

44 College 

18 North Park 

18 North Park 

16 North Park 

16 North Park 

12 Curtis Road 

19 Lyme Road 

1 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil. 

19 Lyme Road 

13 Summer Street 

,13 Summer Street 

Fullington Farm House 

Green House Farm 

Green House Farm 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

0.11 

0.23 

0.11 

0.18 

No. 2 Fuel Oil 

No. 2 Fuel Oil 0.08 

No. 2 Fuel Oil 0.11 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

0.08 

0.14 

0.18 

0.11 

0.21 

0.14 

0.08 

No. 2 Fuel Oil 0.15 

No. 2 Fuel Oil 0.08 

No. 2 Fuel Oil 0.14 

Rennie Farm 

Rennie Farm 

Hanover Country Club 

Hanover Country Club 

Occum Inn Annex 

44 North College Street 

44 North College Street 

200 Sachem 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

0.08 

0.21 

0.35 

0.!1 

1.68 
Page 50 

List of Insignificant Activities at Dartmouth College Furnaces/Small Boilers 

200 Sachem 

13 Choate Road 

13 Choate Road 

Shattuck Observatory 

Pike House 

West Wheelock Bldg. 

21 East Wheelock Street 

4 South Balch Street 

10ccum Ridge 

30ccum Ridge 

1,1 

1,1 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

Propar/e 

No. 2 Fuel Oil 

0.23 

0.42 

0.11 

0.16 

0.39 

No. 2 Fuel Oil 0.56 

No. 2 Fuel Oil 0.175, 0.105 

No. 2 Fuel Oil 0.175, 0.105 

No. 2 Fuel Oil 0.175, 0.105 

No. 2 Fuel Oil 0.175, 0.105 

List of Insignificant Activities at Dartmouth College Miscellaneous Items 

Item Location 

Pathological Waste Incinerator Medical School 

Comment/Justification 

Waste capacity is 145 lb/hr of Type 4 

Waste. Below the 200 lb/hr threshold of 

Env-A 607.01 

Fuel Storage Tank Skiway Emits less than 1000 lb/year VOC 

Fuel Storage Tank MsKenzie Hall Tractor Fuel Emits less than 1000 lb/year VOC 

Fuel Storage Tank Skiway, Holts Lift 

Fuel Storage Tank Skiway, Caterpillar Shed 

Fuel Storage Tank Grounds, Labor Garage 

Fuel Storage Tank Hopkins Center 

Fuel Storage Tank Medical School 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Colbum Building 

Colbum Building 

Baker Remote, Route 120, Hanover 

Skiway Base Lodge, Lyme, NH 

Grounds Garage 

Chemistry Building,-N. College St., 

Hanover 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank Lodge, Route 120, Hanover 

Fuel Storage Tank Hillcrest Building, Route 120, Lebanon 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 
Page 51 

List of Insignificant 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Fuel Storage Tank 

Activities at Dartmouth College Miscellaneous Items 

Minary Conference Center, Route 3, 

Ashland 

Sachem Village, Route 10, Lebanon 

Sachem Village, 200 Sachem, Lebanon 

Gould Road House, West Lebanon 

4 Burton Road 

61 Rivercmst 

25 W. Wheelock 

25 1⁄2 W. Wheelock 

27 W. Wheelock 

DCCCC, Reservoir Rd., Hanover 

Webster Bldg., 9 Webster Ave. 

Webster Bldg., 13 Webster Ave. 

Webster Bldg., 15 Webster Ave. 

Choate Bldg., 13 Choate 

Burke Bldg. 

DOC, 10 Hilton Field Lane 

Montgomery House, 12 Rope Ferry 

Grounds/Labor Garage, Dewey Field 

Parking 

Boat House 

Skiway Caterpillar Shed, Lyme, NH 

Hanover Country Club, 5 Hilton Field 

Lane 

HCC Maintenance, Route 10, Hanover 

Gilman Building 

Berry Library 

Wilder Building 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than i000 Ib/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 

Emits less than 1000 lb/year VOC 
Page 52 

APPENDIX B 
Attachment 2 List of All Emergency Generators Located at Dartmouth College 

Page 53 

Location 

Power Plant 

Berry Library 

Wilder Building 

Cummings Hall 

Burke Building 

College Hall 

Webster Hall 

Psychology Building 

Hanover Inn 

Byrne 

A & B Ward 

Sudikoff 

Brown 

Russell Sage 

Gerry Pent. 

Thompson Arena 

List of All Emergency Generators Located at Dartmouth College 

Mid. Mass 

Number of Units 

1 

1 

•1 

1 

Kiewit East 1 

Wheelock Dorms 1 

Lord 1 

1 

Berry 1 

McLain I 

Maxwell 1 

1 

1 

1 

Topliff 1 

Fayer Weather 1 

Storehouse 1 

Rated Generator Power 

Output (kW) 

800 

668 

166 

100 

300 

125 

•223 

387 

7.5 

15 

16 

45 

15 

15 

15 

15 

12.5 

7.5 

15 

15 

15 

15 

7.5 

15 

15 

.6 

Type of Fuel 

No. 2 Fuel Oil 

Diesel 

Diesel 

LP Gas 

LP Gas 

LP Gas 

No. 2 Fuel Oil 

No. 2 Fuel Oil 

Diesel 

Diesel 

Diesel 

Diesel 

Diesel 

LP Gas 

LP Gas 

LP Gas 

LP Gas 

LP Gas 

LP Gas 

LP Gas 

LP Gas 

LP Gas 

LP Gas 

LP Gas 

LP Gas 

LP Gas 
Page 54 

List of All Emergency Generators Located at Dartmouth College 

Storehouse 1 4.5 LP Gas 

Storehouse 4 LP Gas 

Medical Center 1 200 Diesel 

Wheelock Hall 1 1.5 LP Gas 

1 

15 LP Gas 

65 

Wheeler Hall 

Gilman Building Propane 
STATE OF NEW HAMPSHIRE 

Department of Environmental Services 

Air Resources Division 

Title V Operating Permit 

Permit No: TV-OP-06 

Date Issued: November 18, 1998; amended February 18, 1999 and March 15, 1999, Minor Modification 

January 19, 2000 

This certifies that: 

Phillips Exeter Academy 

20 Main Street 

Exeter, NH 

has been granted a Title V Operating Permit for the following facility and location: 

Phillips Exeter Academy 

20 Main Street 

Exeter, NH 

AFS Point Source Number 3301500004 

This Title V Operating Permit is hereby issued under the terms and conditions specified in the Title V Operating 

PermifApplication filed with the New Hampshire Department of Environmental Services on June 28, 1996 

under the signature of the following responsible official certifying to the best of their knowledge that the 

statements and information therein are true, accurate and complete. 

Responsible Official: 

Don J. Briselden 

Director of Facilities Management 

(603)-778-4454 

Technical Contact: 

Gerald K. Hill 

Heating Station Supervisor 

(603)-778-4454 

This Permit is issued by the New Hampshire Department of Environmental Services, Air Resources Division 

pursuant to its authority under New Hampshire RSA 125-C and in accordance with the provisions of Code of the 

Federal Regulations 40 Part 70. 

This Title V Operating Permit shall expire on November 30, 2003 

SEE ATTACHED SHEETS FOR ADDITIONAL PERMIT CONDITIONS 

For the New Hampshire Department of Environmental Services, Air Resource Division 

Director, Air Resources Division 
Page 2 

TABLE OF CONTENTS 

I. Facili• Descfption of Operations 

II. 

III. 

IV. 

V. 

VI. 

VII. 

VIII. 

VIII A. 

VIII B. 

VIII C. 

VIII D. 

VIII E. 

VIII F. 

IX. 

Permitted Activities 

Significant Activities Identification Table 1, 

Stack Criteria Table 2. 

Insignificant Activities Identification 

Exempt Activities Identification 

Pollution Control Equipment Identification 

Alternative Operating Scenarios 

Applicable Requirements 

State-only Enforceable Operational and Emission Limitations Table 3. 

Federally Enforceable Operational and Emission Limitations Table 4, 

Emission Reductions Trading Requirements 

Monitoring and Testing Requirements Table 5. 

Requirements Not Currently Applicable 

4-5 

6-7 

7-9 

10 

10 

Recordkeeping Requirements Table 6. 11-13 

Reporting Requirements Table 7. 13-14 

15 

XI, 

XII. 

XIII. 

XIV. 

XV. 

Issuance of a Title V Operating Permit 

Title V Operating Permit Renewal Procedures 

Application Shield 

Permit Shield 

Reopening for Cause 

Administrative Permit Amendments 

15 

15 

15 

15-16 

16 

17 
Page3 

XVI. 

XVII. 

XVIII. 

IXX. 

XX. 

XXI. 

XXII. 

XXIII. 

XXIV. 

Operational Flexibility 

XXVIII 

Minor Permit Amendments 

Significan t Permit Amendments 

Title V Operating Permit Suspension, Revocation or Nullification 

Inspection and Entry 

Certifications 

Enforcement 

Emission-Based Fees 

Duty to Provide Information 

17-18 

Permit Deviations and Malfunctions 

18 

18-19 

19 

19 

19-20 

20-21 

21-22 

22 

XXV Property Rights, 22 

XXVI Severability Clause 22 

XXVII Emergency Conditions 22-23 

24 
Page 4 

Facility Specific Title V Operating Permit Conditions 

I. Facility Description of Operations: 

Phillips Exeter Academy (Phillips) is a coeducational college-preparatory boarding school located in 

Exeter, NH. The 

predominant source of 

air pollutant emissions 

at Phillips is their 

central heating plant. 

This plant provides 

high and low pressure 

steam to various 

buildings on campus. 

II. Permitted Activities: 

In accordance with all of the applicable requirements identified in this permit, the permittee is authorized to 

operate the devices and or processes identified in Sections III, IV, V and VI within the terms and conditions 

specified in this Permit. 

III. Significant Activities Identification: 

The activities identified in the following table (Table 1) are subject to and regulated by this. Title V 

Operating Permit: 

EU1 

EU2 

EU3 

EU4 

Boiler #2, 

Babcock and 

Wilcox Boiler 

Boiler #3, 

Babcock and 

Wilcox Boiler 

Boiler #5, 

Union 

Ironworks 

Boiler 

Boiler #6, 

Babcock and 

Wilcox Boiler 

21 mmBtu/hr 

21mmB•/hr 

67.5 mmBtu/hr 

78.0 mmBtu/hr 

#6 fuel oil at no more than 2% sulfur content by weight 

or natural gas and an annual average of less than 1.6 [b 

SO2 per million BTU (mmBTU) for all fuels and 

devices combined. 

#6 fuel oil at no more than 2% sulfur content by weight 

or natural gas and an annual average of less than 1.6 lb 

SO2 per million BTU (mmBTU) for all fuels and 

devices combined. 

Stack #1 

Stack #1 

Stack # 

Stack #2 

#6 fuel oil at no more than 2 % sulfur content by weight 

or natural gas and an annual average of less than 1.6 lb 

SO2 per million BTU (mmBTU) for all fuels and 

devices combined. 

#6 fuel oil a•.no more than 2% sulfur content by weight 

or natural gas and an annual average of less than 1.6 lb 

SO2 per million BTU (mmBTU) for all fuels and 

devices combined. 
Page 5 

EU5 All emergency 

generators with 

individual 

emissions 

greater than 

1000 lbs/yr 

Varies with each 

generator 

Diesel fuel oil at no more than 0.4% •ulfur content by 

weight or natural gas and an annual average of less 

than 1.6 lb SO2 per million BTU (mmBTU) for all 

fuels and devices combined. 

Varies with each 

generator 
Page 6 

Stack Criteria: 

Bo The following stacks for the above listed significant devices at this facility shall discharge vertically 

without obstruction (including rain caps) and meet the following criteria in accordance 

with the state-only modeling requirements specified in Env-A 1300 and Env-A 1400: 

IV. 

We 

VI. 

VII. 

Stack #1 EU1 

EU2 

EU3 

Stack #2 EU4 

145 7 

75 4 

Preauthorized changes to the state-only requirements pertaining to stack parameters (set forth in this permit), 

shall be permitted only when an air quality impact analysis which meets the criteria of Env-A 606 is 

performed either by the facility or the DES (if requested by facility in writing) in accordance with the "DES 

Policy and Procedure for Air Quality Impact Modeling". All air modeling data shall be kept on file at the 

facility for review by the DES upon request. 

Insignificant Activities Identification: 

All activities at this facility that meet the criteria identified in the New Hampshire Rules Governing the 

Control of Air Pollution Part Env-A 609.03(g), shall be considered insignificant activities. Emissions from the 

insignificant activities shall be included in the total facility emissions for .the emission-based fee calculation 

described in Section XXIII of this Permit. 

Exempt Activities Identification: 

All activities identified in the New Hampshire Rules Goveming the Control of Air Pollution Env-A 609.03(c) 

shall be considered exempt activities and shall not be subject to or regulated by this Title V Operating Permit. 

Emissions from exempt activities shall not be included in the total facility emissions for the emission based 

fee calculation described in Section XXIII. of this Permit. 

Pollution Control Equipment Identification: 

Pollution control equipment is not used for any of the devices identified in this Permit. 

Alternative Operating Scenarios: 

No alternative operating scenarios were identified for this Permit. 
Page 7 

VIII. 

VIII. 

Applicable Requirements: 

A. State-only Enforceable Operational and Emission Limitations: 

The Permittee shall be subject to the state-only operational and emission limitations identified in Table 

3 below. 

Table 3 State-only Enforceable Operational and Emission Limitations 

# Emission Unit' 

1. Env-A 404.01 EU1, EU2, 

EU3, &EU4 

Pursuant to RSA 125-D:3,I(e) annual sulfur dioxide emissions from each Class B 

major source, except as provided by Env-A 405.02, shall have an average 

calender year emission rate not to exceed 1.6 pounds of sulfur dioxide per 

million BTU input, equivalent to no. 6 oil with 1.5 percent sulfur by weight, 

which is 75 percent of the baseline average emission rate for Class B major 

sources. Recordkeeping and tracking of individual fuel deliveries shall be 

conducted in accordance with Section VIII. E. of this Permit. 

2. Env-A 1305.01(a) Facility Wide 

3. Env=A 1305.02 Facility Wide 

New or modified devices, new or modified area sources, and existing devi, ces or 

area sources for which new applications for permits are filed that have the potential 

to emit, in any amount, substances that meet the criteria of Env-A1301 shall be 

subject to Env-A 1300, until such time as the Env-A 1400 requirements supersede 

the Env-A 1300 requirements. (As outlined below) 

Air quality impact analysis of devices and area sources emitting substances 

meeting the criteria of Env-A 1301 shall be performed in accordance with the 

"DES Policy and Procedure for Air Quality Impact Modeling" or other comparable 

dispersion modeling methods approved by EPA. 

4. Env-A 1403.01 Facility Wide 

5. Env-A 1403.02(a) Facility Wide 

6. Env-A 1403.02(b) Facility Wide 

In accordance with Env-A 1403.01, new or modified devices or processes 

installed after May 8, 1998, shall be subject to the requirements of Env-A 1400. 

In accordance with 1403.02(a), all existing unmodified devices or processes 

which are in operation during the transition period ending three years from May 8, 

1998 (May 8, 2001), shall comply with either Env-A1300 or Env-A 1400. 

In accordance with Env-A 1403.02(b), all existing devices or processes in 

operation after the transition period ending three years from May 8, 1998 (May 

8, 2001), shall comply with Env-A 1400. Env-A 1300 will no longer be in effect. 

7. Env-A 1404.01(d) Facility Wide 

8. Env-A 1405.02 Facility Wide 

9. Env-A 1405.03 Facility Wide 

In accordance with Env-A 1404.01(d), documentation for the demonstration of 

compliance shall be retained at the site, and shall be made available to the DES 

for inspection. 

In accordance with Env-A 1405.02 the owner of an existing device or process 

requiring a permit under chapter Env-A 1400 shall submit to the DES no later 

than one year prior to the end of the transition period (May 8, 2000), an 

application for a modification to a title V permit in accordance with Env-A 

609.18, and a request to the DES to perform air dispersion modeling. 

In accordance with Env-A 1405.03 the owner of an existing device or process 

requiring a permit under Env-A 1300 shall submit to the DES no later than one 

year prior to the end of the transition period (May 8, 2000), a compliance plan 

identifying how the device or process will comply with chapter Env-A 1400 by the 
Page 8 

Table 3 State-only Enforceable Operational and Emission Limitations 

10. Env-A 1406.01 Facility Wide 

end of the transition period. The compliance plan shall contain the dates when the 

information required in Env-A 1405.02 will be filed with the DES. 

In accordance with Env-A 1406.01 the owner of any device or process which emits 

a regulated toxic air pollutant shall determine compliance with the ambient air 

limits by using one of the methods provided in Env-A 1406.02, Env-A 1406.03, or 

Env-A 1406.04. Upon request, the owner of any device or process which emits a 

regulated toxic air pollutant shall provide documentation of compliance with the 

ambient air limits to the DES. 

VIII. B. Federally Enforceable Operational and Emission Limitations 

The Permittee shall be subject to the operational and emission limitations identified in Table 4 below. 

Table 4 Federally Enforceable Operational and Emission Limitations 

1. Env-A 1604.01(a) Facility Wide The sulfur content of No. 2 oil and off road diesel oil shall not exceed 0.40 

percent sulfur by weight. 

2. Env-A Facility Wide 

1604.01(c)(2) 

3. Env-A 1605.01 Facility Wide 

4. Env-A 2003.01 EU1, EU2 & 

EU3 

The sulfur content of No. 5 oil, No. 6 oil, shall not exceed 2.0 percent sulfur by 

weight. 

Gaseous fuel shall contain no more than 15 grains of sulfur pe r 100 cubic feet of 

gas, calculated a s hydrogen sulfide at standard temperature and pressure. 

5. Env-A 2003.02 EU4 & EU5 

6. Env-A 2003.06 EU1, EU2 & 

EU3 

7. Env-A EU4 & EU5 

2003.07(c)(2) 

Visible Emission Standard for fuel burning devices installed prior to May 13,1970. 

No owner or operator shall cause or allow average opacity from fuel burning 

devices installed on or prior to May 13, 1970 in excess of 40 percent.for any 

continuous 6 minute period in any 60 minute period. 

Visible Emission Standard for fuel buming devices installed after May 13,1970. No 

owner or operator shall cause or allow average opacity from fuel burning devices 

installed after May 13, 1970 in excess of 20 percent for any continuous 6 minute 

period in a 60 minute period. 

No owner or operator shall cause or allow emissions of particulate matter from fuel 

burning devices installed on or prior to May 13, 1970 n excess of the rates set forth 

below, where: • 

For devices with maximum gross heat input rate in 10 BTU/hr) equal to or 

greater thanl 0 but less than 10,000, E ( the maximum allowable particulate matter 

emission rate in lb/10 BTU) shall be calculated by raising to the -0.166 power, 

and multiplying the result by 0.880, expressed mathematically in the formula below: 

E 0.880 I "0'166 

No owner or operator shall cause or allow emissions of particulate matter from fuel 

burning devices installed after May 13, 1970 but before January 1, 1985 in excess of 

the rates set forth below, where: 

For devices with ( maximum gross heat input rate in 10 6 BTU/hr) equal to or 
Page 9 

Table 4 Federally Enforceable Operational and Emission Limitations 

greater; than 10 but less than 250, E ( the maximum allowable particulate matter 

emission rate in lb/106 BTU) shall be calculated by raising to the -0.234 power, 

and multiplying the result by 1.028, expressed mathematically in the formula below: 

E 1.028 1-0.2.34 

8. Env-A EU5 

1211.020)(1) 

Env-A 1211.02(n) Facility Wide 

10. 40 CFR 68 Facility Wide 

11. RSA 125-C:6, Facility Wide 

RSA 125-C: 11 

and 

Env-A 606.04. 

All emergency generators at a stationary source which operate less than 500 hours 

and emissions of NOx from all such generators are less than 25 tons during any 

consecutive 12 month period shall be exempt from the requirements of Env-A 

1211.02(i). Each emergency generator classified as a significant activity shali be 

limited to 500 hours of operation per year. An inventory of all such emergency 

generators shall be kept on file at the facility for review by DES andEPA upon 

request. 

The Permittee has accepted a Permit restriction limiting the Facility wide NOx 

emissions to less than 49.9 tons during any consecutive 12 month period in 

accordance with End-A1211.02(n) to opt out of the requirements ofNOx RACT. 

Actual Facility wide NOx emissions shall be calculated using the formula below. 

Accidental Release Program Requirements. Storage of Anhydrous Ammonia at the 

facility is less than 2 tons (4,000 lbs), which is below the 10;000 lb applicability. 

threshold presented in 40 CFR 68.130 Table and Table 2. The facility, therefore, 

is not subject to the program requirements of 40 CFR 68. However, the facility is 

subject to the Purpose and General Duty clause of the 1990 Clean Air Act, 

Section 112(r)(1). General Duty includes the following responsibilities: 

1. Identify potential hazards which may resuR from such releases 

using appropriate hazard assessment techniques; 

2. Design and maintain a safe facility; 

3. Take steps necessary to prevent releases; and 

4. Minimize the consequences of accidental releases which do occur. 

National Ambient Air Quality Standards (NAAQS). The facility shall comply with 

the national ambient air quality standards and the applicable requirements of 

RSA 125-C:6, RSA 125-C: 11 and Env-A 606.04. 

The Permitee shall use the following formulas, calculated on a rolling 12:month basis to verify compliance with the 

condition specified in Table 4, Item 9 of this Permit: 

Formula #1: Facilitywide 12 Month Rolling NOx Emissions 

NOx f•aci•i•) [NOx •oilers) + NOx (Em-Gen)] -I- [Previous 11 Month Total] 

Where: 

NOX(Facility) 

NOx03oilers) 

NOX(Em-Gen) 

Actual facility wide NOx emissions (in TPY). 

Actual NOx emissions from the Emission Units #1,2,3&4 (in TPY) 

using Formula #2. 

Actual NOx emissions (in TPY) from Emission Unit #5 (Emergency 

Generators) and insignificant activities using the Formula #3. 

Previous 11 
Page 10 

Month Total 

Formula #2: 

Sum of the previous 11 months combined actual NOx emissions from 

Emission Units # 1,2,3,4, &5 and insignificant activities (in 

TPY). 

Monthly NOx Emissions from Boilers 

NOx 0•oi•er•) [(BG * 140.0 Lb/MMCF) + (BO * 68.0 Lb/kGal)]/[2000 Lb/Ton] 

BG 

BO 

MMCF 

kGal 

Combined Actual Boiler (EU#1, #2, #3 and #4) natural gas usage (in MMCF) 

per month. 

Combined Actual Boiler (EU#1, #2, #3 and #4) number 6 fuel oil usage (in 

kGal) per month. 

Millions of Cubic Feet of natural gas. 

1,000 Gallons of fuel oil. 

Formula #3: Monthly NOx Emissions from Emergency Generator and Insignificant 

Activities 2 

Primary Em-Gen 

Insignificant Activities 

NOx 0•m-•e.) [(PrimaryEm-Gens *AP-42Emission Factor) +( Insignificant Activities * 

AP-42Emission Factor / [2000 Lb/Ton] 

Where: 

Total actual fuel usage for all significant emergency 

generators (Emission Unit #5) per month. 

Total actual fuel usages for Insignificant Activities per month 

(include all insignificant activities at the facility for this 

calculation, including but not limited to; other emergency 

generators, small boilers, space heaters etc.). 

The Permitee's actual facilitywide NOx emissions from all devices shall be calculated on a 12- 

month rolling basis according to the calculation method specified above in Secti0n VIII.B. of 

this Permit. The monthly NOx emissions total shall be added to the total aggregated actual 

Actual NOx Emissions from Emission Units 1,2,3, &4 for verification of compliance with the NOx RACT rule 

(Env-A 1211.02(m)) shall be determined by using the appropriate EPA AP-42 NOx emissions factor for natural 

gas and the DES approved emission factor of 68 lb/1000 gal for no. 6 fuel oil obtained from stack testing 

conducted at the facility on Januaq¢ 11, 1996. 

Actual NOx Emissions from Emission Unit #5 and all insignificant activities for verification of compliance with 

the NOx RACT rule (Env-A 1211.02(m)) shall be determined by using the appropriate EPA AP-42 NOx 

emissions factors for natural gas, diesel, liquid propane gas and gasoline. 
VIII. 

VIII. Do 

Page 11 

NOx emissions for the previous 11 months. The resultant 12 month actual emission total shall 

not exceed 49.9 tons as established in Table 4, Item 9 of this permit. 

Emission Reductions Trading Requirements 

The Permittee did not request emissions reduction trading in its operating permit application. At this 

point, DES has not included any permit terms authorizing emissions trading in this permit. All 

emission reductions trading, must be authorized under the applicable requirements of either Env-A 

3000 (the "Emissions Reductions Credits (or ERCs) Trading Program") or Env-A-3100 (the 

"Discrete Emissions Reductions (or DECs) Trading Program) and 42 U.S.C. §7401 et seq. (The 

"Act"), and must be provided for in this permit. 

Monitoring and Testing Requirements 

The Permittee is subject to the monitoring and testing requirements as contained in Table 5, below: 

1. Facility 

Stacks 

and EUs 

1-5 

All 

devices 

using 

liquid 

fuels 

All 

devices 

using 

gaseous 

fuels 

EUs 1-4 

Allows for Conduct an annual inspection of each sNck and emission unit. •ually Env-A 

adequate Records of inspections and subsequent maintenance 806.01 (4) 

dispersion conducted as a result of the a•ual inspections shall be kept and 

of H•s on file at the Facili• for review by the DES anffor EPA upon 40 CFR 

and other request. 70.6(a)(3) 

regulmed Federally 

pollutants Enforceable 

Sulfur The operator shall conduct testing in accordance with For each 

content in appropriate ASTM test methods to determine compliance delivery of fuel 

liquid fuels 'witk the sulfur content limitation provisions in Env-A oil to the 

1604.01(a) and 1604.01(c)2 for liquid fuels in order to meet facility 

the reporting requirements as specified in Section VIII F. 

Table 7, Item4 of this Permit. Delivery tickets which contain 

information with regards to the percent sulfur by weight of 

the fuel oil being delivered may be used as an alternative to 

determine compliance with the sulfur content limitation 

provisions in Env-A 1604.01(a) and 1604.0,1(c)2 for liquid 

fuelg. 

Sulfur The operator shall conduct testing to determine compliance with the Upon request 

content in sulfur content limitation provisions in Env-A 1600 for gaseous fuels, by EPA or 

gaseous DES 

fuels 

Env-A 809.01 

Env-A 809.02 

Boiler 

efficiency Applicable emission units shall be inspected and maintained in accordance with the manufacturers recommendations or 

appropriate National Board Inspection Codes and tested for 

efficient operation at least once each calender year. The 

results of said inspection, maintenance, and testing and the 

date upon which it was perfornaed shall be recorded. 

Annual 40 CFR 

70.6(a)(3)(i)(B) 

Federally 

Enforceable 
Page 12 

VIII. Record keeping Requirements: 

The Permittee shall be subject to the record keeping requirements identified in Table 6 below. 

The Permittee shall retain records of all required monitoring data, 

reeordkeeping and reporting requirements and support information 

for a period of at least 5 years from the date of the origination. 

The Permittee shall maintain records of monitoring requirements as 

specified in Table 5 of this Permit including: 

(A) 

(B) 

(c) 

Preventative maintenance and inspection results 

for stacks and emission units. 

Summary of testing and/or delivery ticket 

certifications for sulfur content limitation 

provisions. 

Summary of inspection, maintenance and test 

results performed on each boiler (EU1-EU4). 

Hourly, consecutive 24 hour period, and consecutive 12 month 

rolling totals of fuel Utilization shall be kept at the facility and 

contain the following information: 

(A) 

(B) 

(C) 

(D) 

(E) 

(F) 

Consumption 

Fuel type; 

Sulfur content as percent sulfur by weight of fuel; 

Btu content per gallon or cubic feet of fuel; 

Hours of operation of each boiler; and 

Viscosity. 

Monthly records of fuel utilization & hours of operation for each 

emergency generator and twelve consecutive month rolling totals of 

fuel utilization & hours of operation for each emergency generator 

shall be kept at the facility and contain the following information: 

(A) Consumption 

(B) Fuel type; 

(C) Sulfur content as percent sulfur by weight of fuel; 

(D) Btu content per gallon or cubic feet of fuel; and 

(E) Hours of operation of applicable emergency 

generators. 

NOx Record keeping Requirements: 

For fuel burning devices, including boilers, turbines, and internal 

combustion engines, the following information shall be recorded and 

maintained: 

(A) Facility information, including: 

Retain for a Facili• wide 40 CFR 

minimum of 5 70.6(a)(3)(ii)(B) 

years Federally 

Enforceable 

Maintain on a Facility wide 40 CFR 

continuous basis 70.6(a)(3)(iii) 

as specified in (A) 

Table 5 of this Federally 

Permit Enforceable 

Hourly, 

consecutive 24 

hour period, and 

consecutive 12 

month rolling 

total of fuel 

consumption 

EU1, EU2, Env-A 901.03 

EU3, & Federally 

EU4 Enforceable 

Monthly & 

consecutive 12 

month rolling 

total of fuel 

consumption, and 

monthly & 

consecutive 12 

month rolling 

total hours of 

operation 

EU5 Env-A 901.03 

Federally 

Enforceable 

Daily, weekly, 

monthly, and 

annually 

Facility Env-A 901.08 

Wide Federally 

Enforceable 
Page 13 

1; Source name; 

2. Source identification; 

3. Physical address; 

4. Mailing address; and 

5. A copy of the certificate of accuracy 

required to be maintained pursuant to EnvA 901.04(c). 

(B) Identification of fuel buming device; 

(C) Operating schedule information for each fuel burning 

device identified in (B), above, including; 

1. Days per calendar week during the normal 

operating schedule; 

2. Hours per day during the normal operating 

schedule and for a typical ozone season 

day, if different from the normal operating 

schedule; and 

3. Hours per year during the normal 

operating schedule; 

(D) Type, and amount of fuel burned, for each fuel burning 

device, during normal operating conditions and for a 

typical ozone season day, if different from normal operating 

conditions, on an hourly basis in million Bfu's per hour or; 

(E) The following NOx emission data, including records of 

total annual emissions, in tons per year, and typical ozone 

season day emissions, in pounds per day: 

1. Theoretical potential emissions for the 

calculation year for each fuel buming 

device; and 

2. Actual N0x emissions for each fuel burning 

device. 

Delivery tickets from each fuel oil supplier for each shipment of fuel. 

oil received shall be kept on file in a form suitable for inspection and 

shall be made available to theDES and/or EPA upon request. Each 

delivery ticket shall indicate the. name, address and telephone 

number of the fuel oil supplier, the quantity of fuel oil delivered, and 

the percent sulfur by weight of the fuel oil being delivered. If 

delivery tickets do not contain sulfur content of fuel being delivered, 

the Permittee shall perform testing in accordance with appropriate 

ASTM test methods to determine compliance with the sulfur content 

limitation provisions in Env-A 1604.01(a) and 1604.01(c)2 for 

liquid fuels. 

Billing tickets from the Naturai Gas supplier for each month shall be 

kept on file in a form suitable for inspection and shall be made 

available to the DES and/or EPA upon request. Each billing ticket 

shall indicate the name, address and telephone number of the Natural 

Gas supplier and the quantity of Natural Gas used. 

Annual records of actual emmisions for each insignificant activity for 

determination of emission based fees. 

Maintain on a 

continuous basis 

Maintain on a 

continuous basis 

Maintain at 

facility at all 

times. 

Facility wide 

Facility wide 

Insignificant 

activities 

40 CFR 

70.6(a)(3) 

Federally 

Enforceable 

40 CFR 

70.6(a)(3) 

Federally 

Enforceable 

Env-A 901.04 

Federally 

Enforceable 

9. The permittee shall keep records of daily and annual steam flow Maintain at EU1, EU2, 40 CFR 
rates for each of the boilers. facility at all 

times. 

EU3, & 

EU4 

Page 14 

70.6(a)(3) 

Federally 

Enforceable 

VIII. F. Reporting Requirements: 

The Permittee shall be subject to the reporting requirements identified in Table 7 below. 

The Permittee shall submit a summary report of monitoring data as 

specified in Table 5 of this permit including: 

(A) Preventative maintenance and inspection results 

for stacks and emission units. 

(B) Summary of testing and/or delivery ticket 

certifications for sulfur content limitation 

provisions. 

(C) Summary of inspections, maintenance and test 

results performed on EUs 1-4.. 

Prompt reporting of deviations from Permit requirements shall be 

conducted in accordance with Section XXVIII of this Permit. 

Eve 16 months Facili• wide 

by July 3 Ist and 

Janua• 3 ist of 

each calender 

year 

Prompt 

reporting 

(ie; within 8 

hours of an 

occurrence): 

Facility wide 

:.:t•egt•Jot0rY C•te, 

40 CFR 

70.6(a)(3)(iii) 

(A) 

Federally 

Bnforceable 

Env-A 902.02 

& 

40 CFR 

70.6(a)(3)(iii) 

(B) 

Federally 

Enforceable 

NOx Reporting Requirements: 

For fuel buming devices, including boilers, turbines and engines, as 

well as miscellaneous sources, the owner or operator shall submit to 

the director, annually (no later than April 15th of the following year), 

reports of the data required by Condition VIII.E., Table 6, Item 5., 

including total annual quantities of all NOx emissions. 

Annually (no Facility Wide Env-A 901.09 

later than April Federally 

15th of the Enforceable 

following year) 

The permittee shall submit quarterly fuel usage reports indicating 

hourly, consecutive 24 hour period, and consecutive 12 month 

rolling totals of fuel utilization for each boiler and corresponding 

fuel information as outlined in Condition VIII.E., Table 6, Item 3. 

Quarterly, due EU1, EU2 40 CFR 70.6 

30 days from EU3& EU4 (a)(1) Federally 

the end of the Enforceable 

calender quarter 

The permittee shall submit quarterly fuel usage reports indicating 

monthly and rolling consecutive twelve month fuel utilization and 

consecutive 12 month rolling total hours of operation for the 

emergency generators as outlined in Condition VIII.E., Table 6, Item 

4. 

Quarterly, due. EU5 40 CFR 70.6 

30 days from (a)(1) Federally 

the end of the Enforceable 

calender quarter 

6. Any report submitted to the DES and/or EPA shall include the As specified Facili.ty wide 40 CFR 
Page 15 

certification of accuracy statement as outlined in Section XXI.B. of 

this Permit and shall be signed by the responsible official. 

Annual reporting and payment of emission based fees for pollutants, 

including, but not limited to SO2, NOx, CO, TSP and VOC shall be 

conducted in accordance with Section XXIII of this Permit 

8. Annual compliance certification shall be submitted in accordance 

Section XXI ofthis Permit. 

Annually (no 

later than April 

15th of the 

following year) 

Annually (no 

later than April 

15th of the 

following year) 

Facility wide 

Facility wide 

70.6(c)(1) 

Federally 

Enforceable 

Env-A 704.03 

Federally 

Enforceable 

40 CFR 

70.6(c)(1) 

Federally 

Enforceable 
Page 16 

IX. Requirements Currently Not Applicable: 

The Permitee did not identify any requirements not currently al•plicable to the facility. 

General Title V Operating Permit Conditions 

X. Issuance of a Title V Operating Permit: 

Ao This Permit is issued in accordance with the provisions of Part Env-A 609. In accordance with 40 

CFR 70.6(a)(2) this Permit shall expire on the date specified on the cover page of this Permit, which 

shall not be later than the date five (5) years after issuance of this,Permit. 

Permit expiration terminates the Permittee's right to operate the Permittee's emission traits, control 

equipment or associated equipment covered by this permit, unless a timely and complete renewal 

application is submitted at least 6 months before the expiration date. 

Bo Pursuant to Env-A 609.02(b), this Permit shall be a state permit to operate as defined in RSA 125- 

C:ll, III. 

XI. Title V Operating Permit Renewal Procedures: 

Pursuant to Env-A 609.06(b), an application for renewal of this Permit shall be considered timely if it is 

submitted to the Director at least six months prior to the designated expiration date of this Permit. 

XII. Application Shield: 

Pursuant to Env-A 609.07, if an applicant submits a timely and complete application for the issuance or 

renewal of a Permit, the failure to have a Permit shall not be considered a violation of this part until the 

Director takes final action on the application. 

XIII. Permit Shield: 

A. Pursuant to Env-A 609.08(a), a permit shield shall provide that: 

For any applicable requirement or any state requirement found in the New Hampshire Rules 

Governing the Control of Air Pollution specifically included in this Permit, compliance with 

the conditions of this Permit shall be deemed compliance with said applicable requirement or 

said state requirement as of the date of permit issuance; and 

For any potential applicable requirement or any potential state requirement found in the New 

Hampshire Rules Governing the Control of Air Pollution specifically identified in this TitleV 

Operating Permit Section IX Table 8 as not applicable to the stationary source or area source, 

the Permittee need not comply with the specifically identified federal or state requirements. 

B4 The permit shield identified in Section XIII.A. of this Permit shall apply only to those conditions 

incorporated into this Permit in accordance with the provisions of Env-A 609.08(b). It shall not apply 

to certain conditions as specified in Env-A 609.08(c) that may be incorporated into this Permit 
Page 17 

following permit issuance by DES. 

Ifa Title V Operating Permit and amendments there to issued by the DES does not expressly include 

or exclude an applicable requirement or a state requirement found in the NH Rules Governing the 

Control of Air POllution, that applicable requirement or state requirement shall not be covered by the 

permit shield and the Permittee shall comply with the provisions of said requirement to the extent that 

it applies to the Permit-tee. 

Do If the DES determines that this Title V Operating Permit was issued based upon inaccurate or 

incomplete information provided by the applicant or Permittee, any permit shield provisions in said 

Title V Operating Permit shall be void as to the portions of said Title V Operating Permit which are 

affected, directly or indirectly, by the inaccurate or incomplete information. 

Pursuant to Env-A 609.08(f); nothing contained in Section XIII of this Permit shall alter or affect the 

ability of the DES to reopen this Permit for cause in accordance with Env-A 609.18 or to exercise its 

summary abatement authority. 

Pursuant to Env-A 609.08(g), nothing contained in this section or in any title V operating permit 

issued by the DES shall alter or affect the following: 

The ability of the DES to order abatement requiring immediate compliance with applicable 

requirements upon finding that there is an imminent and substantial endangerment to public 

health, welfare, or the environment; 

The state of New Hampshire's ability to bring an enforcement action pursuant to RSA 125- 

C:15,II; 

The provisions of section 303 of the Act regarding emergency orders including the authority 

of the EPA Administrator under that section; 

The liability of an owner or operator of a source for any violation of applicable requirements 

prior to or at the time of permit issuance; 

The applicable requirements of the acid rain program, consistent with section 408(a) of the 

Act; 

The ability of the DES or the EPA Administrator to obtain information about a stationary 

source, area source, or device from the owner or operator pursuant to section 114 of the Act; 

or 

The ability of the DES or the EPA Administrator to enter, inspect, and/or monitor a 

stationary source, area source, or device. 

Reopening for Cause: 

The Director shall reopen and revise a Title V Operating Permit for cause if any of the circumstances 

contained in Env-A 609.18(a) exist. In all proceedings to reopen and reissue a Title V Operating Permit, the 

Director shall follow the provisions specified in Env-A 609.18(b) through (g). 
Page 18 

XV. Administrative Permit Amendments: 

XVI. 

Ao Pursuant to Env-A 612.01, the Permittee may implement the changes addressed in the request for an 

administrative permit amendment as defined in Part Env-A 100 immediately upon submittal of the 

request. 

Pursuant to Env-A 612.01, the Director shall take final action on a request for an administrative 

permit amendment in accordance with the provisions of Env-A 612.01(b) and (c). 

Operational Flexibility: 

Ao Pursuant to Env-A 612.02(a), the Permittee subject to and operating under this Title V Operating' 

Permit may make changes involving trading of emissions under this existing Title V Operating Permit 

at the permitted stationary source or area source without filing a Title V Operating Permit application 

for and obtaining an amended Title V Operating Permit, provided that all the conditions are met as 

specified in section XVI. A. 1. through 7. of this permit and a notice is submitted to the DES and 

EPA describing the intended changes. At this point, DES has not included any permit terms 

authorizing emissions trading in this permit. 

1. The change is not a modification under any provision of title I of the Act; 

The change does not cause emissions to exceed the emissions allowable under the title 

V operating permit, whether expressed therein as a rate of emissions or in terms of 

total emissions; 

3. The owner or operator has obtained any temporary permit required by Env-A 600; 

The owner or operator has provided written .notification to the director and 

administrator at least 15 days prior to the proposed change and such written 

notification includes: 

a. The date on which each proposed change will occur; 

b. A description of each such change; 

Any change in emissions that will result and how this change in emissions will 

comply with the terms and conditions of the permit; 

d. A written request that the operational flexibility procedures be used; and 

e. The signature of the responsible official, consistent with Env-A 605.04(b); 

The Title V Operating Permit issued to the stationary source or area source already 

contains terms and conditions including all terms and conditions which determine 

compliance required under 40 CFR 70.6(a) and (c) and which allow for the trading of 

emissions increases and decreases at the permitted stationary source or area source 

solely for the purpose of complying with a federally-enforceable emissions cap that is 
Page 19 

established in the permit independent of otherwise applicable requirements; 

The owner 0r operator has included in the application for the Title V Operating 

Permit proposed replicable procedures and proposed permit terms which ensure that 

the emissions trades are quantifiable and federally enforceable for changes to the Title 

V Operating Permit which qualify under a federally- enforceable emissions cap that is 

established in the Title V Operating Permit independent of the otherwise applicable 

requirements; and 

7. The proposed change complies with Env-A 612.02 (e). 

Be Pursuant to Env-A 61.2.02(c), the Permittee subject to and operating under this Title V Operating 

Permit may make changes not addressed or prohibited by this existing Title V Operating Permit at the 

permitted stationary source or area source without filing a Title V Operating Permit application, 

provided that all the conditions specified in Env-A 612.02(c)(1) through (6) are met and a notice is 

submitted to the DES and EPA describing the intended changes. 

Pursuant to Env-A 612.02(d), the Permittee, Operator, Director and Administrator shall attach each 

notice of an off-permit change completed in accordance with Section XVI of this Title V Operating 

Permit to their copy of the current Title V Operating. Permit. 

DJ Pursuant to Env-A 612.02(e), any change under Section XVI shall not exceed any emissions 

limitations established under the NH Rules Governing the Control of Air Pollution, or result in an 

increase in emissions, or result in new emissions, of any toxic air pollutant or hazardous air pollutant 

other than those listed in the existing Permit. 

Eo Pursuant to Env-A 612.02(0, the off-permit change shall not qualify for the permit shield under EnvA 609.08. 

XVII. Minor Permit Amendments: 

At Pursuant to Env-A 612.04 prior to implementing a minor permit modification, the Permittee shall 

submit a written request to the Director in accordance with the requirements of Env-A 612.04(b). 

The Director shall take final action on the minor permit amendment request in accordance with the 

provisions of Env-A 612.04(c) through (g). 

Pursuant to Env-A 612.04(g), the permit shield specified in Env-A 609.08 shall not apply to minor 

permit amendments under Section XVII. of this Permit. 

Pursuant to Env-A 612.04(i), the Permittee shall be subject to the provisions of Part Env-A 614 and 

Part Env-A 615 if the change is made prior to the filing with the Director a request for a minor permit 

amendment. 

XVIII. Significant Permit Amendments: 

Pursuant to Env-A 612.05, a change at the facility shall qualify as a significant permit amendment if it 

meets the criteria specified in Env-A 612.05(a)(1) through (7). 
Page 20 

XX. 

BJ Prior to implementing the significant permit amendment, the Permittee shall submit a written request 

to the Director which includes all the information as referenced in Env-A 612.05(b) and (c) and shall 

be issued an amended Title V Operating Permit from the DES. The Permittee shall be subject to the 

provisions of Env-A 614 and Env-A 615 ira request for a significant permit amendment is not filed 

with the Director and/or the change is made prior to the issuance of an amended Title V Operating 

Permit. 

Co The Director shall take final action on the significant permit amendment in accordance with the 

procedures specified in Env-A 612.05(d), (e) and (f). 

Title V Operating Permit Suspension, Revocation or Nullification: 

Pursuant to RSA 125-C: 13, the Director may suspend or revoke any final permit issued hereunder if, 

following a hearing, the Director determines that: 

the Permit-tee has committed a violation of any applicable statute or state requirement found in 

the New Hampshire Rules Governing the Control of Air Pollution, order or permit condition 

in force and applicable to it; or 

that the emissions from any device to which this Permit applies, alone or in conjunction with 

other sources of the same pollutants, presents an immediate danger to the public health. 

Bt The Director shall nullify any Permit, if following a heating in accordance with RSA 54 l-A:30, II, a 

finding is made that the Permit was issued in whole or in part based upon any information proven to 

be intentionally false or misleading. 

Inspection and Entry: 

Pursuant to Env-A 614.01, EPA and DES personnel shall be granted access to the facility covered by this 

Permit, in accordance with RSA 125-C:6,VII for the purposes of: inspecting the proposed or permitted site; 

investigating a complaint; and assuring compliance with any applicable requirement or state requirement 

found in the NH Rules Governing the Control of Air Pollution and/or conditions of any Permit issued 

pursuant to Chapter Env-A 600. 

Certifications: 

At Compliance Certification Report 

In accordance with 40 CFR 70.6(c) the Responsible Official shall certify, for the previous calender 

year, that the facility is in compliance with the requirements of this permit. The report shall be 

submitted annually, no later than April 15th of the following year. The report shall be submitted to 

the DES and to the U.S. Environmental Protection Agency New England Region. The report shall 

be submitted in compliance with the submission requirements below. 

In accordance with 40 CFR 70.6(c)(5), the report shall describe: 

1. The terms and conditions of the Permit that are the basis of the certification; 
Page 21 

The current compliance status of the source with respect to the terms and conditions of this 

Permit, and whether the method was continuous or intermittent during the reporting period; 

The methods used for determining compliance, including a description of the monitoring, 

record keeping, and reporting requirements and test methods; and 

Any additional information required by the DES to determine the compliance status of the 

source. 

B. Certification of Accuracy Statement 

All documents submitted to the DES shall contain a certification of accuracy statement by the responsible 

official of truth, accuracy, and completeness. Such certification shall be in accordance with the requirements 

of 40 CFR 70.5(d) and contain the following language: 

"I am authorized to make this submission on behalf of the facility for which the submission is made. Based on 

information and belief formed after reasonable inquiry, I certify that the statements and information in the enclosed 

documents are to the best of my knowledge and belief true, accurate and complete. I am aware that there are significant 

penaltiesfor submitting false statements and information or omitting required statements and information, including 

the possibility of fine or imprisonment." 

All reports submitted to DES (except those submitted as emission based fees as outlined in Section XXIII of 

this Permit) shall be submitted to the following address; 

New Hampshire Department of Environmental Services 

Air Resources Division 

6 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

ATTN: Compliance Bureau 

All reports submitted to EPA shall be submitted to the following address; 

Office of Environmental Stewardship 

Director Air Compliance Program 

United S•tes Environmental Protection Agency 

Congress Street 

Suite 1100 (SEA) 

Boston, MA 02114-2023 

ATTN: Air Compliance Clerk 

Enforcement: 

Any noncompliance with a permit condition constitutes a violation of RSA 125-C:15, and, as to the 

conditions in this permit which are federally enforceable, a violation of the Clean Air Act, 42 U.S.C. 

Section 7401 et seq., and is grounds for enforcement action, for permit termination or revocation, or for 

denial of an operating permit renewal application by the DES and/or EPA. Noncompliance may also be 

grounds for assessment of administrative, civil or criminal penalties in accordance with RSA 125-C: 15 and/or 

the Clean Air Act. This Permit does not relieve the Permittee from the obligation to comply with any other 

provisions of RSA 125-C, the New Hampshire Rules Governing the Control of Air Pollution, or the Clean 
Page 22 

Air Act, or to obtain any other necessary authbrizations from other governmental agencies, or to comply with 

all other applicable Federal, State, or Local rules and regulations, not addressed in this Permit. 

In accordance with 40 CFR 70.6 (a)(6)(ii) a Permittee shall not claim as a defense in an enforcement action 

that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance 

with the conditions of this Permit. 

XXIII. Emission-Based Fee Requirements: 

AJ The Permittee shall pay an emission-based fee annually for this facility as calculated each calendar 

year pursuant to Env-A 704.03. 

Bo The Permi•ee shall determine the total actual annual emissions from the facility to be included in the 

emission-based multiplier specified in Env-A 704.03(a) for each calendar year in accordance with the 

methods specified in Env-A 620. 

C. The Permittee shall calculate the annual emission-based fee for each calendar year in accordance with 

FEE E * DPT * CPIm * ISF 

Do 

the procedures specified in Env-A 704.03 and the following equation: 

Where: 

FEE The annual emission-based fee for each calendar year as specified in Env-A 704. 

E The emission-based multiplier is based on the calculation of total annual emissions as 

specified in Env-A 704.02 and the provisions specified in Env-A 704.03(a). 

DPT The dollar per ton fee the DES has specified in Env-A 704.03(b). 

CPIm The Consumer Price Index Multiplier as calculated in Env-A 704.03(c). 

ISF The Inventory Stabilization Factor as specified in Env-A 704.03(d). 

The Permit-tee shall contact the DES each calendar year for the value of the Inventory Stabilization 

Factor. 

The Permittee shall contact the DES each calendar year for the value of the Consumer Price Index 

Multiplier. 
Page 23 

Fo 

Gt 

The Permittee shall submit, to the DES, payment of the emission-based fee and a summary of the 

calculations referenced in Sections XXIII.B. and C of this Permit for each calendar year by October 

15 th of the following calendar year in accordance with Env-A 704.04. The emission-based fee and 

summary of the calculations shall be submitted to the following address: 

New Hampshire Department of Environmental Services 

Air Resources Division 

6 Hazen Drive 

P.O. Box 0095 

Concord, NH 03302-0095 

ATTN.: Emissions Inventory 

The DES shall notify the Permittee of any under payments or over payments of the annual emissionbased fee in accordance with Env-A 704.05. 

XXIV. Duty To Provide Information 

In accordance with 40 CFR 70.6 (a)(6)(v), upon the DES's written request, the Permittee shall furnish, within 

a reasonable time, any information necessary for determining whether cause exists for modifying, revoking 

and reissuing, or terminating the Permit, or to determine compliance with the Permit. Upon request, the 

Permittee shall furnish to the DES copies of records that the Permittee is required to retain by this Permit. 

The Permittee may make a claim of confidentiality as to any information submitted pursuant to this condition 

in accordance with Part Env-A 103 at the time such information is submitted to DES. DES shall evaluate 

such requests in accordance with the provisions of Part Env-A 103. 

XXV. Property Rights 

Pursuant to 40 CFR 70.6 (a)(6)(iv), this Permit does not convey any property rights of any sort, or any 

exclusive privilege. 

XXVI. Severabflity Clause 

Pursuant to 40 CFR 70.6 (a)(5), the provisions of this Permit are severable, and if any provision of this 

Permit, or the application of any provision of this Permit to any circumstances is held invalid, the application 

of such provision to other circumstances, and the remainder of this Permit, shall not be affected thereby. 

XXVII. Emergency Conditions 

Pursuant to 40 CFR 70.6 (g), the Permittee shall be shielded from enforcement action brought for 

noncompliance with technology based 3 emission limitations specified in this Permit as a result of an 

emergency*. In order to use emergency as an affirmative defense to an action brought for noncompliance, the 

Technology based emission limits are those established on the basis of emission reductions achievable with various 

control measures or process changes (e.g., a new source performance standard) rather than those established to attain health 

based air quality standards. 

An "emergency" means any'situation arising from sudden and reasonably unforeseeable events beyond the control of 

the source, including acts of God, which situation would require immediate corrective action to restore normal operation, 

and that causes the source to exceed a technology based limitation under the permit, due to unavoidable increases in 

emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly 

designed equipment, lack of preventative maintenance, careless or improper operations, operator error or decision to keep 
Page 24 

Permittee shall demonstrate the affirmative defense through properly signed, contemporaneous operating 

logs, or other relevant evidence that: 

A. An emergency occurred and that the Permittee can identify the cause(s) of the emergency; 

B. The permitted facility was at the time being properly operated; 

Co During the period of the emergency, the Permittee took all reasonable steps as expeditiously as 

possible, to minimize levels of emissions that exceeded the emissions standards, or other requirements 

in this Permit; and 

The Permittee submitted notice of the emergency to the DES within two (2) business days of the time 

when emission limitations were exceeded due to the emergency. This notice must contain a 

description of the emergency, any steps taken to mitigate emission, and corrective actions taken. 

operating despite knowledge of any of these things. 
Page 25 

XXVIII. 

A. 

Permit Deviations and Malfunctions 

Pursuant to Env-A 902.02, the Permittee shall report to the DES all instances of malfunctions or 

breakdowns by telephone or fax within 8 hours of such an occurrence. This report shall include the 

description of the malfunction or breakdown itself, including those attributable to upset conditions as 

defined in the Permit, the probable cause of such malftmction or breakdown, and any corrective 

actions or preventative measures taken. Said Permit malfunction or breakdown shall also be 

submitted in writing to the DES within fifteen (15) days of documentation of the malfunction or 

breakdown by facility personnel. Malfunctions are instances where any Permit condition is violated as 

defined in Env-A 101.164 and 40 CFR 60.2 and has not already been reported as an emergency 

pursuant to Section XXVII of this Permit. 

Reporting a Permit malfunction or breakdown is not an affirmative defense for action brought for 

noncompliance. 

In accordance with 40 CFR 70.6(a)(3)(iii)(B), the Permittee shall report to the DES all instances of 

deviations from Permit requirements, by telephone or fax, within 24 hours of such deviation. This 

report shall include the deviation itself, including those attributable to upset conditions, the probable 

cause of such deviations, and any corrective actions or preventative measures taken. Said Permit 

deviation shall also be submitted in writing to the DES within fifteen (15) days of documentation of 

the deviation by facility personnel, Deviations are instances where any Permit condition is violated 

and has not already been reported as a malfunction or an emergency pursuant to Section XXVII of 

this Permit. 

Reporting a Permit deviation is not an affirmative defense for action brought for noncompliance. 

h:'•permits\cutxent\titlev•nodfictn\\tv-phil2.mmd 

revised 01-19-00 

STATE OF NEW HAh•PSHIRE 

Department of Environmental Services 

Air Resources Division 

TITLE V OPERATING PERMIT 

Permit No: TV-OP-026 

Date Issued: May 25, 2000 

This certifies that: 

Tillotson Healthcare Corporation 

RFD 1, Box 2000 

Dixville Notch, NH 03576 

has been granted a Title V Operating Permit for the following facility and location: 

Tillotson Itealtheare Corporation 

RFD 1, Box 2000 

Dixville Notch, NH 03576 

This Title V Operating Permit is hereby issued under the terms and conditions specified in the Title V 

Operating Permit Application filed with the New Hampshire Department of Environmental Services on 

June 28, 1996 under the signature of the following responsible official certifying to the best of their 

knowledge that the statements and information therein are true, accurate and complete. 

Responsible Official: 

Ronald Guerin 

Plant Engineer 

(603) 255-3881 

Technical Contact: 

Ronald Guerin 

Plant Engineer 

(603) 255-3881 

This Permit is issued by the New Hampshire Department of Environmental Services, Air Resources 

Division pursuant to its authority under New Hampshire RSA 125-C and in accordance with the 

provisions of Code of the Federal Regulations 40 Part 70. 

This Title V Operating Permit shall expire on May 25, 2005. 

SEE ATTACHED SHEETS FOR ADDITIONAL PERMIT CONDITIONS 

For the New Hampshire Department of Environmental Services, Air Resources Division 

Director, Air Resources Division 
TABLE OF CONTENTS 

Page 2 of 28 

Facility Specific Title V Operating Permit Conditions 4 

I. Facility Description of Operations: 4 

II. Permitted Activities: 4 

III. Significant Activities Identification: 4 

A, Significant Activities:. 4 

B. Stack Criteria: 5 

IV. Insignificant Activities Identification: 6 

V, Exempt Activities Identification: 6 

VI. Pollution Control Equipment/Technique Identification: 6 

VH, Alternative Operating Scenarios: 7 

VIII, Applicable Requirements: 7 

A. State-only Enforceable Operational and Emission Limitations: 7 

B. Federally Enforceable Operational and Emission Limitations 8 

C. Emission Reductions Trading Requirements.. 11 

D. Monitoring and Testing Requirements: 12 

E Recordkeeping Requirements: 13 

F. Reporting Requirements: 18 

G. Compliance Plan 20 

IX. Requirements Currently Not Applicable: 20 

General Title V Operating Permit Conditions 21 

X. Issuance of a Title V Operating Permit: 21 

XI. 

XII. 

XIII. 

XIV. 

XV. 

XVI. 

XVII. 

XVIII. 

XIX. 

XX. 

XXI. 

A, 

B. 

XXII. 

XXIII. 

XXIV. 

XXV. 

XXVI. 

XXVII. 

XXVIII. 

Title V Operating Permit Renewal Procedures: 21 

Application Shield: 21 

Permit Shield: 21 

Reopening for Cause 22 

Administrative Permit Amendments 22 

Operational Flexibility 23 

Minor Permit Amendments 24 

Significant Permit Amendments 24 

Title V Operating Permit Suspension, Revocation or Nullification 24 

Inspection and Entry 25 

Certifications 25 

Compliance Certification Report 25 

Certification of Accuracy Statement 25 

Enforcement 26 

Emission-Based Fee Requirements 26 

Duty To Provide Information 27 

Property Rights 27 

Severability Clause 27 

Emergency Conditions 28 

Permit Deviation: 28 

T:\Tram fer\Tvwebpag\Tillotson_Dixville.doe Final Issued 05/25/2000 
TABLE OFTABLES 

Page 3 of 28 

Table 1 Significant Activity Identification 4 

Table 2 Stack Criteria 5 

Table 3 Pollution Control Equipment Identification 6 

Table 4 State-only Enforceable Operational and Emission Limitations... 7 

Table 5 Federally Enforceable Operational and Emission Limitations 8 

Table 6 Monitoring/Testing Requirements 12 

Table 7 Applicable Recordkeeping Requirements 13 

Table 8 Applicable Reporting Requirements 18 

T:\Transfer\Tvwebpag•TillotsonDixville.doe 

Final Issued 05/25/2000 
Facility Specific Title V Operating Permit Conditions 

Page 4 of 28 

Facility Description of Operations: 

Tillotson Healthcare Corporation manufactures robber products in Dixville Notch, New Hampshire. 

The primary source of air pollutant emissions at the facility are generated from fuel-burning devices 

which produce criteria pollutant emissions, and from coating and dipping operations which produce 

Volatile Organic Compounds (VOC) and Hazardous Air Pollutant (HAP) emissions. 

II. Permitted Activities: 

In accordance with all of the applicable requirements identified in the Permit, the Permittee is 

authorized to operate the devices and/or processes identified in Sections III, IV, V, and VI within the 

terms and conditions specified in this permit. 

III. Significant Activities Identification: 

A. Significant Activities: 

The activities identified in Table 1 Significant Activity Identification are subject to and 

regulated by this Title V Operating Permit. 

EU1 

EU2 

EU3 

EU4 

EU5 

EU6 

WickesTypeAWood-tiredBokler Stack 11 Limited to a maximum firing rate of 52.8- 

Serial number NB2884 mmBtu/hr gross heat input, with a maximum of 

Wickes Type A Boiler 

Serial number NB2480 

150 HP Dillon Boiler #1 

Serial number 2RLHC024880 

150 HP Dillon Boiler #2 

Serial number HC0269 

400 KW Cat Diesel Generator, 

Serial number 76B415 

Stack #2 

Stack #3 

Stack #4 

Stack #5 600 KW Diesel Generator, 

Serial number 81Z08025 

57,000 tons of wood during any consecutive 12- 

month period. 

.Limited to 33.2-mmBtu/hr gross heat input at a 

maximum of 5,300 gallons per day of #6 furl •il 

with a maximum sulfur content of 0.5% by weight. 

Limited to 8.2-mmBtu/hr gross heat-input each at a 

maximum of 87.0 gallons per hour combined of #6 

fuel oil with a maximum sulfur content of 0.5% by 

weight or a combined maximum of 38 hours of 

operation per consecutive 24-hour period. 

All emergency generators at a stationary source, 

which operate less than 500 hours and emissions of 

NOx from all such generators are less than 25 tons 

during anyconsecutive 12-month period, shall be 

exempt from the requirements of Env-A 1211.02(i). 

EU5 and EU6 shall be limited to 500 hours of 

operation each per any consecutive 12-month 

period. 

T:\Trans fer\Tvwebpag\Tillotson_ Dixville.doe 

Final Issued 05125/2000 
EU7 First Floor Conveyors Stack #6 2 

EU8 Second Floor Compound Room Stack #74 

EU9 Glove Form Ovens First and Stack #85 

Second Floors 

Page 5 of 28 

Facility wide emission limit of 11.98 tons per 

consecutive 12-month period of ammonia based on 

modeling performed by DES on March 10, 2000 to 

demonstrate compliance with the state-only 

requirement Env-A 1400 pertaining to ambient air 

impacts ofregulated toxic a•r pollntants (RTAPS). 

B. Stack Criteria: 

The stacks indicated in Table 2 Stack Criteria for the significant devices indicated in Table 

1 shall discharge vertically without obstruction (including rain caps) and meet the following 

criteria in accordance with the state-only modeling requirements specified in Env-A 1300 and 

Env-A 1400. 

Stack #1 EU1 45.0 25,000 4.0 

Stack #2 EU2 41.0 30,500 2.5 

Stack #3 EU3 & EU4 51.0 28,060 3.5 

Stack #4 

Stack #5 

Stack #62 

Stack #7 4 

Stack #86 

EU5 

EU6 

EU71 

EU83 

EU9 

-14.0 

14.0 

Heights vary reference 

.Drawing No Roof 1, dated 

11/29/95 

Heights vary reference 

Drawing No Roof 1, dated 

11/29/95 

27.0 

4,997 

Flow Rates Vary 

reference Drawing No 

Roof 1, datedH/29/95 

Flow Rates Vary 

reference Drawing No 

Roof 1, dated 11/29/95 

1,500 

0.665 

0.665 

Diameters vary reference 

Drawing No Roof 1, dated 

11/29/95 

Diameters vmT reference 

Drawing No Roof 1, dated 

11/29/95 

3.0 

Consists of various conveyors as designated in Tillotson HealthCare Drawing No Roof 1, dated 11/29/95 submitted with the Title V 

application. 

Stack #6 consists Of exhaust points 1, 2, 3, 39, 7, 8, 9, 10, 11, 12, 13, 18 &l 9 as designated in Tillotson HealthCare Drawing No Roof 1, 

dated 11/29/95, submitted with the Title V application. 

Consists of various tanks and processes in the second floor compound room :as designated in Tillotson HealthCare Drawing No Roof 1, 

dated 11/29/95 submitted with the Title V application. 

Stack #7 consists of exhaust points 6, 14, 17, & 36 as designated in Tillotson HealthCare Drawing No Roof I, dated 11/29/95 submitted 

with the Title V application. 

Stack #8 designated as exhaust point 5 on Tillotson HealthCare Drawing No Roof 1, dated 11/29/95 submitted with the Title V application. 

Stack #8 designated as exhaust point 5 on Tillotson HealthCare Drawing No Roof 1, dated 11/29/95 submitted with the Title V application. 

T:\Transfer\TvwebpagkTillotson_Dixville.doe 

Final Issued 05/25/2000 
IV. 

Page 6 of 28 

Preauthorized changes to the state-only requirements 7 pertaining to stack parameters set 

forth in this permit, shall be permitted only when an air-quality impact analysis, which meets 

the criteria of Env-A 606 is performed either by the facility or the DES (if requested by the 

facility in writing) in accordance with the "DES Policy and Procedures for Air Quality 

Modeling". All air modeling data shall be kept on file at the facility for review by the DES 

upon request. 

Insignificant Activities Identification: 

All activities at this facility that meet the criteria identified in the New Hampshire Rules Governing 

the Control of Air Pollution Part Env-A 609.03(g), shall be considered insignificant activities. 

Emissions from the insignificant activities shall be included in the total facility emissions for the 

emission-based fee calculation described in Section XXIII of this Permit. 

V. Exempt Activities Identification: 

All activities identified in the New Hampshire Rules Governing the Control of Air Pollution Part 

Env-A 609.03(c), shall be considered exempt activities and shall not be included in the total facility 

emissions for the emission based fee calculation described in Section XXIII of this permit. 

VI. Pollution Control Equipment/Technique Identification: 

The device identified in Table 3 Pollution Control Equipment Identification, is considered pollution 

control equipment for each identified activity. 

PCE1 Multi-cyclone dust collector •90% based on modeling performed to Controls particulate matter without ash re-injection. demonstrate compliance with the emissions from operation of 

National Ambient Air Quality Standard EU1. 

(NAAQS) for particulate matter. 

All equipment, facilities and systems installed and used to achieve compliance with the terms and 

conditions of this Permit, shall at all times be maintained in good working order, and shall be 

operated as efficiently as possible so as to minimize air pollutant emissions and meet all applicable 

air pollution emission limits. The control listed shall be fully operational upon facility startup and 

shall not be bypassed during startup, operation, or shutdown of this boiler. 

The pollution control equipment shall be maintained regularly, in accordance with the manufacturers 

recommended maintenance schedules and specifications. The Facility shall keep all maintenance 

records, on file for review upon request by DES and/or EPA. 

The term "state-only requirement" is used to refer to those requirements that are not federally enforceable but are state requirements as 

defined in Env-A 101.259. 

T:\Transfer\Tvwebpag\Tillolson_Dixville.doc 

Final Issued 05/25/2000 
VII. Alternative Operating Scenarios: 

No alternative operating scenarios were identified for this permit. 

Page 7 of 28 

VIII. Applicable Requirements: 

A. State-only Enforceable Operational and Emission Limitations: 

The Permittee shall be subject to the state-only operational and emission limitations identified 

in Table 4 State-only Enforceable Operational and Emission Limitations below. 

.);,!i• I• •:D •!J•:!'•':•i•:!:;•,l: 

I. New or molilel levices, new or molilel area sources for which new Inv-A 

applications for permits are llel that have the potential to emit, in any amount, 1305.01 (a) 

substances that meet the criteria of Env-A 1301 shall be subject to Env-A 1300, 

until such time as the Env-A 1400 requirements supersede the Env-A 1300 

requirements. (As outlined below) 

.Air quality impact analysis of devices and area sources emitting substances 

meeting the criteria of Env-A 1300, shall be performed in accordance with the 

"DES Policy. and Procedures for Air Quality Impact Modeling" or other 

comparable dispersion modeling methods approved by EPA. 

In accordance with Env-A 1403.01, new or modified devices or processes 

installed after May 8, 1998, shall be subject to the requirements of Env-A 1400 

In accordance with 1403.02(a), all existing unmodified devices or processes, 

which are in operation during the transition period ending three years from May 

8, 1998 (May 8, 2001), shall comply with either Env-A 1300 or Env-A 1400. 

In accordance with Env-A 1403.02(b), all existing devices or processes in 

operation after the transition period ending three years from May 8, 1998 (May 

8, 2001), shall comply with Env-A 1400. Env-A 1300 will no longer be in 

effect. 

In accordance with Env-A 1404.01(d), documentation for the demonstration .of 

compliance shall be retained at the facility, and shall be made available to the 

DES for inspection. 

The owner of an existing device or process requiring a permit under chapter 

Env-A 1400, shall submit to the DES no later than one year prior to the end of 

the transition period (May 8, 2000), an appli6ation for modification to a title V 

permit in accordance with Env-A 609.18. A request to the DES to perform air 

dispersion modeling shall also be submitted at that time. 

The owner of an existing device or process requiring a permit under Env-A 

1300, shall submit to the DES no later than one year prior to the end of the 

transition period (May 8, 2000), a compliance plan identifying how the device or 

process will comply with chapter Env-A 1400 by the end of the transition 

period. The compliance plan shall contain the dates when the information 

required in Env-A 1405.02 will be filed with the DES. 

Facility Wide 

Facility Wide 

Facility Wide Env-A 1403.01. 

Facility Wide Env-A 

1403.02(a) 

Facility Wide Env-A 

1403.02(b) 

Facility Wide Env-A 

1404.01(d) 

Facility Wide 

Facility Wide Env-A 1405.03 

Env-A 1305.02 

Env-A 1405.02 

T:\Trans fer\Tvwebpag\Tillolson_Dixville.doe Final Issued 05/25/2000 
Page 8 of 28 

10. 

In accordance with Env-A 1406.01, the owner of any device or process, which 

emits a regulated toxic pollutant, shall determine compliance with the ambient 

air limits by using one of the methods provided in Env-A 1406.02, Env-A 

1406.03, or Env-A 1406.04. Upon request, the owner of any device or process, 

which emits a regulated toxic air pollutant, shall provide documentation of 

compliance with the ambient air limits to the DES. 

The facility shall be limited to 11.98 tons per consecutive 12-month period and 

2.90 pounds per hour of ammonia emissions in order to comply with the 

applicable requirements of RSA 125-C:11, Env-A 606.04 and Env-A 1400. 

These sections include, but are not limited to, descriptions of the requirements 

for adherence to permit application procedures, air pollutant dispersion modeling 

impact analysis, and ambient air limitations of toxic pollutants. 

Facility Wide 

Facility Wide 

Env-A 1406.01 

RSA 125-C:11, 

Env-A 606.04 

& Env-A 1400 

B. Federally Enforceable Operational and Emission Limitations 

The Permittee shall be subject to the Federally enforceable operational and emission 

limitations identified in Table 5 Federally Enforceable Operational and Emission 

Limitations below: 

1. The sulfur content of No. 2 oil and off road diesel fuel oil shall not exceed 0.40 Facility Wide Env-A 

percent sulfur by weight. 1604.01 (a) 

2. The sulfur Content of No. 5 oil and No. 6 fuel oil shall not exceed 0.50 percent Facility Wide Env-A 

sulfur by weight. 1604.01 (c)(2) 

3. No owner or operator shall cause Or allow average opacity from fuel burning 

devices installed after May 13, 1970 in excess of 20 percent for any continuous 6- 

minute period in any 60-minut e period exc•ept! 

a) During periods of startup, shutdown and malfunction, average opacity 

shall be allowed to be in excess of 20 percent for one period of 6 

continuous minutes in any 60 minute period; or 

b) During periods of normal operation, soot blowing, grate cleaning, and 

cleaning of fires, average opacity shall be allowed to be in excess of 20 

percent but not more than 27 percent for one period of 6 continuous 

minutes in any 60 minute period. 

EU 1, EU2 & Env-A 2003.02 

EU6 & Env-A 

2003.04(a) 

The facility may make adjustments to parameters that affect the air dispersion modeling analysis conducted by DES on March 10, 2000 in 

order to demonstrate that an alternative emission limitation can be established which would demonstrate compliance with the 24-hour and 

annual AALs for ammonia. Any adjustments to parameters which affect the air dispersion modeling analysis conducted by DES on March 

10, 2000 and which result in new modeled impacts shall be reported to DES. DES shall then notify the facility in writing of any revised 

emission limitation as a result of such adjustments. Such written notification shall be attached to this Title V Operating Permit as an 

addendum. The revised emission limit will be incorporated into this Permit upon re-issuance. 

TATransfer•Tvwebpag\Tillotson_Dixville.doe 

Final Issued 05/25/2000 
Page 9 of 28 

4. No owner or operator shall cause or allow average opacity from fuel burning EU3, EU4 & Env-A 2003.01 

EU5 devices installed on or prior to May 13, 1970 in excess of 40 percent for any 

continuous 6-minute period in any 60-minute period. 

5. Unless otherwise specified in Env-A 2100, no person shall cause or allow visible Facility Wide Env-A 

fugitive emissions or visible stack emissions for any process, manufacturing or 2107.01(a) 

service-based industry to exceed an average of 20 percent opacity for any 

continuous 6-minute period in any 60-minute period, except were opacity is 

specified differently for fuel burning devices in Env-A 2003. 

6. No owner or operator shall cause or allow emissions of particulate matter from EU1 & EU2 Env-A 

fuel burfiing devices installed after May 13, 1970 but before January 1, 1985 in 2003.07(c)(2) 

excess of the rates set forth below, where: 

For devices with I (maximum gross heat input rate in 106 BTU/hr) equal to or 

greater than 10 but less than 250, E (the maximum allowable particulate matter 

emission rate in lb/106 BTU) shall be calculated by raising I to the -0.234 power, 

and multiplying the result by 1.028, expressed mathematically in the formula 

below: 

E 1.028I-°'234 

7. No owner or operator shall cause or allow emissions of particulate matter form EU6 Env-A 

fuel burning devices installed on or before January 1, 1985, with maximum gross 2003.08(c)(1) 

heat input less than 100 mmBTU/hr, in excess of 0.30 lb/mmBtu. 

8. No owner or operator shall cause or allow emissions of particulate matter from EU3, EU4 & Env-A 

fuel burning devices installed on or prior to May 13, 1970 with maximum gross EU5 2003.06(c)(1) 

heat input rate less than 10 mmBTU/hr in excess of 0.60 lb/mmBtu. 

9. Calculation of Particulate Matter Emission Standards for New Devices. Facility Wide 

Particulate matter emissions from a 'New Device '9, with process weight rate up to 

60,000 pounds per hour, shall not exceed the emission rate averaged over a one 

hour period as specified in the formula below: 

E 4.10×P °'67 

Where p (the process weight rate in tons per hour) shall be raised to the 0.67 

power and multiplied by 4.10. 

10. Calculation of Particulate Matter Emission Standards for Existing Devices. Facility Wide Env-A 

2103.01 (c) 

Where the process weight rate is not explicitly stated in Env-A 2103.01, Table and/or 

2103-1, the maximum allowable particulate matter emissions from a 'Existing 2103.02(b) 

Device •°, with process weight rate up to 60,000 pounds per hour, shall not exceed 

the emission rate averaged over a one hour period as specified in the formula 

below: 

E 5.05 × p0.67 

Where p (the process .weight rate in tons per hour), shall be raised to the 0.67 

power and multiplied by 5.05. 

Env-A 

2103.02(c)(1) 

New Device A process or device, used by a manufacturing and service-based industry installed after February 18, 1972. 

•0 Existing Device A process of device, used by a manufacturing and service-based industry installed prior to or on February 18, 1972. 

T:\Trans fer\Tvwebp ag\Tillotso Dixville.doe 

Final Issued 05/25/2000 
Page 10 of 28 

12. 

14. 

Accidental Release Program Requirements. Facility Wide 40 CFR 68 

Storage of regulated chemicals at the facility, are less than the applicable threshold 

quantities established in 40 CFR 68.130. Administrative controls will be 

established in order to ensure that inventories of regulated substances are 

maintained below the specified threshold quantities. The facility is subject to the 

Purpose and General Duty clause of the 1990 Clean Air Act, Section l12(r)(1). 

General Duty includes the following responsibilities 

a) Identify potential hazards which result from such releases using appropriate hazard assessment techniques; 

b) Design and maintain a safe facility; 

c) Take steps necessary to prevent releases; and 

d) Minimize the consequences of accidental releases, which do occur. 

If, in the future, the facility wishes to store quantities of high risk regulated 

substances above the threshold levels, an emergency response plan shall be 

submitted to the DES in a timely manner. This plan shall include the information 

listed in 40 CFR 68, Subpart E. 

The Permittee has accepted a Permit restriction limiting the Facility wide NOx 'Facility Wide Env-A 

emissions to less than 49.9 tons during any consecutive 12-month period in 1211.02(n) 

accordance with Env-A 1211.02(n) to opt out of the requirements of NOx RACT. 

Actual Facility wide NOx emissions shall b e calculated using the Formulas #1, #2, 

and #3 below. 

The Permittee has accepted a Permit restriction limiting the SO• emissions from EU2, EU3 & 40 CFR 51 

the Wickes Type A boiler (EU2) to less than 39.9 tons during any consecutive 12- EU4 

month period based on ambient air impact modeling conducted by NHDES on 

June 10, 1999 to demonstrate compliance with the NAAQS. EU2 shall be limited 

to 33.2mmBTU per hour gross heat input at a maximum of 5,300 gallons per day 

of #6 fuel oil with a maximum sulfur content of 0.5% by weight. Dillon boiler #1 

(EU3) and Dillon boiler #2 (EU4), shall each be limited to 8.2-mmBTU per hour 

gross heat input, a combined maximum of 87.0 gallons per hour of#6 fuel oil with 

a maximum sulfur content of 0.5% by weight or combined maximum of 38 hours 

of operation per consecutive 24-hour period.• 

The Facility shall comply with the National Ambient Air Quality Standards Facility Wide RSA 125-C:6, 

(NAAQS) and the applicable requirements of RSA 125-C:6, RSA C: 11 and Env- RSA 125-C: 11 

A 606.04. and Env-A 

606.04 

• The facility may make adjustments to parameters that affect air dispersion modeling analysis conducted by DES on June 10, 1999 in order 

to demonstrate that alternative emission limitations can be established which would demonstrate compliance with the NAAQS for SO2. 

Any adjustments to parameters, which affect the air dispersion modeling analysis conducted by DES on June 10, 1999, which result in new, 

modeled impacts shall be reported to DES. DES shall then notify the facility in writing of any revised emission limitation as a result of 

such adjustments. Such written notification shall be attached to this Title V Operating Permit as an addendum. The revised emission limit 

will be incorporated into this Permit upon re-issuance. 

T:\Transfer\Tvwebpag\Tillotson_Dixville.doe 

Final Issued 05/25/2000 
Page 11 of 28 

The Permittee shall use the following formulas, calculated on a rolling 12-month basis to verify 

compliance with the condition specified in Table 5, Item 13 of this Permit: 

Formula #1: Facility Wide 12-month Rolling NOx Emissions 

NOXv,,ci,ie [NOx(,oi,er.•) + NOx(gm_a,,)]+[ellMT] 

Where: 

NOx(F.ci•ity)- Actual facility wide NOx emissions (in TPY) 

NOx(Boi•ers) Actual NOx emissions from.the Emissions Units #1, 2, 3 & 4 (in TPY) using 

Formula #2. 

NOX(Em.Gen) Actual NOx emissions (in TPY) from Emission Units 5 & 6 (Emergency 

Generators) and insignificant activities using Formula #3. 

P11MT= Sum of the previous 11 months combined actual NOx emissions from Emissions 

Units # 1, 2, 3, 4, 5 & 6 and insignificant activities (in TPY). 

Formula #2: Monthly NOx Emissions from Boilers 12 

NOX l•oU•) [(BW* 1.51b//fton)+ (BO * 5 5.01b/•kGal )l/[20001b//fton 

Where: 

BW 

BOActual Boiler (EU#1) wood usage (in tons) per month 

Combined actual boiler (EU#2, EU#3, and EU#4) no. 6 fuel oil usage (in kGal) 

per month. 

KGal 1,000 gallons of fuel oil 

Formula #3: Monthly NOx Emissions from Emergency Generator and Insignificant Activities 13 

NOX(gm_Gen) [(EU#5 * 604.2 lb/£kGal )+ (EU#6 * 604.2 lb/•kGal)+ (IA* AP -42EF)]/[2000 lb•ton 

Where: 

EU#5 

EU#6 

IA 

Actual diesel fuel usage in Emission Unit #5 (in kGal) per month. 

Actual diesel fuel usage in Emission Unit #6 (in kGal) per month 

Total fuel usages for Insignificant Activities per month (including all insignificant 

activities at the facility for this calculation, including but not limited to; other 

emergency generators, small boilers, space heaters etc.). 

AP-42EF AP-42 emission factor 

C. Emission Reductions Trading Requirements 

The Permittee did not request emissions reductions trading !n its operating permit application. 

At this point, DES has not included any permit terms authorizing emissions trading in this 

• Actual NOx emissions from EU1, EU2, EU3 and EU4 for verification of compliance with the NOx RACT rule (Env-A 1211.02(m)), shall 

be determined by using the appropriate EPA AP-42 NOx emission factor for no. 6 fuel oil and wood. 

13 Actual NOx emissions from Emission Units # 5 and #6 and all insignificant activities for verification of compliance with the NOx RACT 

rule (Env-A 1211.02(m)), shall be detemained by using the appropriate EPA AP-42 NOx emission factors for diesel. 

T:\Tr fer\Tvwebpag\Tillotson_ Dixville.do 

Final Issued 05/25/2000 
Page 12 of 28 

permit. All emission reduction trading, must be authorized under the applicable 

requirements of either Env-A 3000 (the "Emissions Reductions Credits (or ERCs) Trading 

Program") or Env-A 3000 (the "Discrete Emissions Reductions (or DERs) Trading Program) 

and 42 U.S.C § 7401 et seq. (The "Act"), and must be provided for in this permit. 

D. Monitoring and Testing Requirements: 

The Permittee is subject to the monitoring and testing requirements as contained in Table 6 

Monitoring/Testing Requirements, below: 

Allows for 

adequate 

dispersion of 

HAPs and 

other 

regulated 

pollutants 

Sulfur 

content of 

liquid fuels 

3. Particulate 

Matter 

4. Periodic 

Monitoring 

5. Periodic 

Monitoring 

Conduct a.n annual inspection of each stack and boiler. Annually 

InspectionS shall be focused on identifying holes, 

leaks, deposits, deficiencies, or deterioration of 

equipment and stacks. The facility shall keep on file 

records, of inspections, and subsequent maintenance, 

conducted as a result of the annual inspections, and 

will be made available for review by DES and/or EPA 

upon request. 

The operator shall conduct testing in accordance with 

appropriate ASTM test methods or retain delivery 

tickets which certify the weight percent of sulfur for 

each delivery of fuel oil to determine compliance with 

the sulfur content limitation provisions specified in this 

permit for liquid fuels in order to meet the reporting 

requirements specified in Env-A 900. 

The pollution control equipment (PCE1) shall be As required 

maintained regularly, in accordance with the by the 

manufacturers recommended maintenance schedules manufacturer 

and specifications to maintain >_90% efficiency. Upon 

request by DES or EPA, compliance shall be 

determined using EPA approved stack testing methods. 

The Facility shall keep all maintenance and repair 

records, on file for review upon request by DES and/or 

EPA. 

The #6 fuel oil usage for Dillon boilers #1 and #2 shall Hourly 

be monitored on an hourly basis along with the daily 

hours of operatio n Fuel flow meters/recorders will be 

operated and maintained for each of the two Dillon 

boilers to monitor individual #6 fuel oil usage. Fuel 

flow meters shall be calibrated in accordance with the 

manufacturers specifications. 

The #6 fuel oil usage for the Wicks Type-A boiler 

shall be monitored on a daily basis along with the 

hours of operation. 

.•:?•Devaee•.:•-•: 

Facility 

Stacks and 

boilers 

For each Facility 

delivery of Wide 

fuel oil to 

the facility 

EUI 

EU3 & 

EU4 

Daily EU2 

Env-A 

806.01(4) and 

40 CFR 

70.6(a)(3) 

Federally 

Enforceable 

Env-A 809.01 

Federally 

Enforceable 

Env-A 

806.01(4) and 

40 CFR 

70.6(a)(3) 

Federally 

Enforceable 

Env-A 806 & 

40 CFR 70.6 

(a)(3)(i)(B) 

Federally 

Enforceable 

Env-A 806 & 

40 CFR 70.6 

(a)(3)(i)(B) 

Federally 

Enforceable 

T:\TransfeATvwebpag\Tillotson_Dixville,doe 

Final Issued 05/25/2000 
Page 13 of 28 

Periodic The wood usage for the Wicks Wood-Fired boiler shall Monthly EU1 Env-A 806 & 

Monitoring be monitored on a monthly basis along with the hours 40 CFR 70.6 

of operation. (a)(3)(i)(B) 

Federally 

Enforceable 

E. Recordkeeping Requirements: 

The Permittee shall be subject to the recordkeeping requirements identified in Table 7 

Applicable Recordkeeping Requirements below: 

I. The Permittee shall retain records of all required monitoring 

data, recordkeeping and reporting requirements, and support 

information for a period of at least 5 years from the date of 

origination. 

The Permittee shall maintain records of monitoring 

requirements as specified in.Table 6, Items 1, 2, 3, and 4 of 

this Permit including: 

a) Preventative maintenance and inspection results for 

stacks, processes and boilers; 

b) Summary of testing and/or delivery ticket 

certifications for sulfur content limitation 

provisions; 

c) Summary of maintenance and repair records for 

PCE1; and 

d) Summary of maintenance, repair, and calibration 

records for the fuel flow meters on Dillon boilers #1 

and #2. 

Retain for a 

minimum of 5 

years 

Maintain on a 

continuous basis 

Facility 

Wide 

Facility 

Wide 

40 CFR 

70.6(a)(3)(ii)(B) 

Federally 

Enforceable 

40 CFR 

7.6(a)(3)(iii)(A) 

Federally 

Enforceable 

T:\Transfer\Tvwebpag\Tillotson_Dixville.doe 

Final Issued 05125/2000 
Page 14 of 28 

3. Delivery tickets from each fuel oil supplier for each shipment 

of fuel oil received shall be kept on file in a form suitable for 

inspection and shall be available to the DES and/0r EPA upon 

request. Each delivery ticket shall indicate: 

a) The name of the fuel supplier; 

b) The address of the fuel oil supplier; 

c) The telephone number of the fuel oil supplier; 

d) The quantity of fuel oil delivered; and 

e) The percent sulfur by weight of the fuel oil being 

delivered. 

If delivery tickets do not contain sulfur Content of fuel being 

delivered, the Permittee shall perform testing in accordance 

with appropriate ASTM test methods to determine 

compliance with the sulfur content limitation provisions in 

Env-A 1604.01(a) and 1604.01(c)(2) for liquid fuels. 

The Permittee shall record monthly fuel usage information 

including: 

a) The quantity of fuel used monthly; 

b) The fuel type; and 

c) The calculated MMBtu/ton of fuel. 

If more than one type of fuel is used, data on each fuel shall 

be recorded separately. 

The Permittee shall record monthly fuel usage information 

including: 

a) The quantity of fuel used per month; 

b) The fuel type; 

c) The calculated MMBtu/gallon of fuel; and 

d) The sulfur content as percent sulfur by weight of 

fuel. 

If more than one type of fuel is used, data on each fuel shall 

be recorded separately. 

Maintain on a Facility 40 CFR 

continuous basis Wide 70.6(a)(3) 

Federally 

Enforceable 

Maintain on a EU1 ENV-A 901.03 

continuous basis Federally 

Enforceable 

Maintain On a EU2 ENV-A 901.03 

continuous basis Federally 

Enforceable 

T:Wrans fer•Tvwebpag\Tillotson_Dixville.doe Final Issued 05/25f2000 
6. The Permittee shall record fuel usage information for each of 

the Dillon boilers in a permanently bound logbook, including: 

a) If the Permittee chooses to limit the boilers hours of 

operation to meet SO2 permit limits, the following 

information shall be recorded: 

1. The dates.when each boiler is run; and 

2. The total number of hours run during each 

consecutive 24:hour period; 

b) If the Permittee chooses to restrict the fuel usage 

(flow rate) to the boilers to meet the permit limits 

for SO2, the following information shall be 

recorded: 

1. The dates when the restrictions are used; 

2. The fuel flow rate; and 

3. The quantity of fuel used during each 

consecutive 24-hour period; 

c) The fuel type; 

d) The calculated MMBtu/gallon of fuel; and 

e) The sulfur content as percent sulfur by weight of the 

fuel consumed. 

If more than one type of fuel is used, data on each fuel shall 

be recorded separately. 

7. Monthly records of fuel utilization and hours of operation for Monthly & 

each emergency generator and twelve consecutive month consecutive 12 

rolling totals of fuel utilization and hours of operation for month rolling 

each emergency generator shall be kept at the facility and total of fuel 

contain the following information: consumption, 

and mOnthly & a) Consumption; consecutive 12 

b) Fuel type; month rolling 

c) Sulfur content as percent sulfur by weight of fuel; total hours of 

d) Btu content per gallon or cubic feet of fuel; and operation 

e) Hours of operation of each emergency generator. 

8. Daily, monthly, and annual records shall be kept regarding 

process operations including the tbllowing information: 

a) Daily hours of operation for each process; 

b) Monthly records of the total quantities of raw 

materials used in each process; 

c) Distribution of the process discharges if the process 

discharges air pollutants through more than one 

discharge point: and 

d) Concentrations of pollutants in pounds per hour for 

each process. 

Maintain on a EU3 & EU4 

continuous basis 

Maintain on a 

continuous basis 

EU5 & EU6 

Facility 

Wide 

Page 15 of 28 

ENV-A 901.03 

Federally 

Enforceable 

Env-A 901.03 

Federally 

Enforceable 

Env-A 901.04 

Federally 

Enforceable 

T;\Tra fer\'rvwe bpag\Till ors Dixville.doe 

Final Issued 05/25/2000 
Page 16 of 28 

Annual records of actual emissions for each significant and 

insignificant activity for determination of emission based fees. 

VOC Recordkeeping Requirements: 

To satisfy the requirements of Env-A 901.06(d) and Env-A 

901.06(g), the Permittee shall record the following 

information: 

a) Facility information, including: 

1. Source name: 

2. Source identification; 

3. Physical ad&'ess; 

4. Mailing address; and 

b) Identification of each VOC emitting device or 

process; 

c) The following production, raw material usages and 

VOC emissions data for each VOC emitting device 

identified in b) above: 

1. Days of operation per calendar week 

during the normal operating schedule; 

2. Hours of operation per day during normal 

operating conditions; 

3. Hours of operation per year under normal 

operating conditions: 

d) Annual theoretical potential emissions, using the 

VOC content for the calculation year for each VOCemitting device or process identified in b) above, in 

tons per year. 

e) Actual emissions, using the VOC content for the 

calculation year for each VOC-emitting device or 

process identified in b) above, in tons per year and a 

typical day during the high ozone season in pounds 

per day. 

f) Applicable emission factors, if used to calculate 

emissions. 

g) Process information, including throughput data, 

shall be recorded for each device or process. 

Maintain at 

facility at all 

times 

On a continuous 

basis 

Significant 

and 

insignificant 

activities 

Facility 

Wide 

Env-A 704.03 

Federally 

Enforceable 

Env-A 901.06 

Federally 

Enforceable 

T:\Transfcr•Tvwebpag•Tillolson_Dixville.doe 

Final Issued 05/25/2000 
e 17 of 28 

11. NOx Recordkeeping Requirements: 

For fuel. burning devices, including boilers, and internal 

combustion engines, the following information shall be 

recorded and maintained: 

a) Facility information, including: 

1. Source name: 

2. Source identification; 

3. Physical address; 

4. Mailing address; and 

5. A copy ,of the certificate of accuracy 

required to be maintained pursuant to EnvA 901.04. 

.b) Identification of each fuel burning device; 

c) Operating schedule information for each fuel 

burning device identified in b), above, including: 

1. Days per calendar week during the normal 

operating .schedule; 

2. Hours per day during the normal operating 

schedule and for a typical ozone season 

day, if different from the normal operating 

schedule; and 

3. Hours per year during the normal operating 

schedule; 

d) Type, and amount of fuel burned, for each fuel 

burning device, during normal operating conditions 

and for a typical ozone season day, if different from 

normal operating conditions, on an hourly basis in 

million Btu's per hour and; 

e) The following NOx emission data, including 

records of total annual emissions, in tons per year, 

and typical ozone season day emissions, in pounds 

per day; 

1. Theoretical potential emissions for the 

calculation year for each fuel burning 

device; and 

2• Actual NOx emissions for each fuelburning device. 

Tillotson Healthcare shall record actual annual emissions On a quarterly Facility speciated by individual regulated air pollutants, including a basis Wide 

breakdown of VOC emissions by compound. 

12. 

On a continuous Facility Env-A 901.08 

basis Wide Federally 

Enforceable 

Env-A 

907.01 (new rule) 

State-only 

Enforceable 

T:\Trans ferVP•vebpag\Tillotson .Dixville.doe Final Issued 05/25/2000 
Page 18 of 28 

F. Reporting Requirements: 

The Permittee shall be subject to the reporting requirements identified in Table 8 Applicable 

Reporting Requirements, below: 

1. The Pe•ittee shall submit a summaw repoi of all pe•it 

deviations, and testing and monitoring data as specified in 

Table 6 of this pe•it including: 

a) -Preventative maintenance and inspection results for 

stacks and emission units; 

b) Summaw of testing an•or delivew ticket 

ceIifications for fuel sul•r content limitation 

provisions; •d 

c) Su•aw of maintenance and repair records fur 

PeEl; 

d) Summa W of maintenance, calibration, and repair 

records for the •el flow meters associated with 

Dillon boilers #1 and #2; and 

e) S• of •el usage for the Wicks Type-A 

boiler, Wic• Wood-Fired boiler and Dillon boilers 

#1 and #2. 

The Permittee shall submit an annual fuel usage report 

indicating consecutive 24-hour and consecutive 12 month 

rolling totals of fuel utilization for the four boilers and 

corresponding fuel information as outlined in Condition 

VIII.E., Table 7 Items 4, 5 and 6. 

The Permittee shall submit an annual fuel usage report 

indicating consecutive 24-hour period and consecutive 12 

month rolling totals of fuel utilization for each of the two 

emergency generators and corresponding fuel information as 

outlined in Condition VIII. E, Table 7 Item 7. 

Every 6 months Facility Wide 40 CFR 

(no later than the V0.6(a)(3)(iii)(A) 

30th day of the Federally 

following month Enforceable 

of each calendar 

half year) 

Annually (no 

later than April 

15 th of the 

following year) 

Annually (no 

later than April 

15th of the 

following year) 

Annually (no 

later than April 

15th of the 

following year) 

EU1, EU2, 

EU3 & EU4 

EU5, & EU6 

4. Facility Wide NOx Reporting Requirements: 

For fuel burning devices, including boilers, and engines, as 

well as miscellaneous sources, the owner or operator shall 

submit to the Director, annually (no later than April 15 th of 

the following year), reports of the data required by Condition 

VIII.E, Table 7, Item 11, including total annual quantities of 

all NOx emissions. 

Env-A 901.09 

Federally 

Enforceable 

Env-A 901.09 

Federally 

Enforceable 

Env-A 901.09 

Federally 

Enforceable 

T:\Transfer\T•vebpagWillotson_Dixville.doe 

Final Issued 05125/2000 
Page 19 of 28 

5. voc Reporting Requirements: 

For all VOC emitting devices and processes, as well as 

miscellaneous sources, the owner or operator shall submit to 

the Director, annually (no later than April 15 ta of the 

following year), reports of the data required by Condition 

VIII;E, Table 7, Items 10, including total annual quantities of 

all VOC emissions. 

6, General VOC Reporting Requirements: 

In addition to the information required in Item 7 above, for 

all VOC emitting devices and processes; as well as 

miscellaneous sources. The owner or operator shall Submit 

to the Director, annually (no later than April 15 t• of the 

following year), reports of the data required by Condition 

VIII.E, Table 7, Items 12, including actual annual emissions 

speciated by individual regulated air pollutant, including a 

breakdown of VOC emissions by compound. 

7. Prompt reporting of deviations from Permit requirements 

shall be conducted in accordance with Section XXVIII of this 

Permit. 

Annually (no 

later than April 

15 t• of the 

following year) 

Facility Wide Env-A 901.07 

Federally 

Enforceable 

Annually (no Facility Wide Env-A 907.01 & 

later than April Env-A 908 (new 

15 th of the rule), State-only 

following year) Enforceable 

Any report submitted to the DES and/or EPA shall include 

the certification of accuracy statement outlined in Section 

XXI.B. of this Permit and shall be signed by the responsible 

official. 

Annual reporting and payment of emission based fees for 

pollutants, including but not limited to SO2, NOx, CO, TSP, 

VOCs and New Hampshire' Regulated Air Toxic Pollutant 

(RTAP) emissions, shall be conducted, in accordance with 

Section XXIII of this Permit. 

10. Annual compliance certification shall be submitted, in 

accordance with Section XXI of this Permit. 

Prompt reporting Facility Wide Env-A 902.02 & 

(within 24 hours 40 CFR 

of an 70.6(a)(3)(iii)(B) 

occurrence) Federally 

Enforceable 

As specified Facility Wide 

Annually (no 

later than April 

15 th of the 

following year) 

Annually (no 

later than April 

15 th of the 

following year) 

Facility Wide 

40 CFR 

70.6(c)(1) 

Federally 

Enforceable 

Env-A 704.03 

Federally 

Enforceable 

Facility Wide 40 CFR 

70.6(c)(1) 

Federally 

Enforceable 

T:\Transfer\Tvwebpag\Tillolson_Dixville.doe 

Final Issued 05/25/2000 
Page 20 of 28 

G. Compliance Plan 

In addition to the above state and federally enforceable requirements, the Permittee shall 

adhere to the schedule put forth in the Compliance Plan submitted on April 25, 2000 and 

outlined in Table 9 Compliance Plan. 

IX. 

Compliance with federally enforceable SO2 emission iimit: 

a) Change over to #6 fuel oil with sulfur content of 0.5% by weight. 

b) Modification to EU2 (Wicks Type A boiler) stack: 

Obtain engineering plans for proposed modification August 1, 2000 

Obtain construction quote of planned modification November 1, 2000 

Begin construction of modification May 1,2001 

Completion of modification July 1, 2001 

Demonstration of compliance September 1,2001 

Compliance with federally enforceable particulate matter emission limit: 

a) Develop a regular maintenance schedule per manufacturer's recommendations 

for the cyclone particulate device attached to EU1 (Wicks Type A wood-fired 

boiler), to ensure an operational efficiency at 90% or greater. 

b) Maintain the maintenance procedures, schedules, and the logbook as par• of 

standard recordkeeping for the Title V permit. 

April 1, 2000 

September 1, 2001 

June 1, 2000 

June 1,2000 

The Permittee shall submit written progress reports to DES within 30-days of completion of 

the major milestones as detailed in Table 9 above. If milestone dates will not be or are not 

met, the Permittee shall submit to DES in writing, the reasons and a good faith estimate of 

completion. Copies of compliance plans and other official correspondences shall be kept on 

file at DES and at the facility. All reports of compliance for the issues specified in VIII.G., 

shall be submitted to the following address: 

New Hampshire Department of Environmental Services 

Air Resources Division 

6 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

ATTN: Andrew M O'Sullivan, Engineering Bureau 

Requirements Currently Not Applicable: 

Requirements not currently applicable to the facility were not identified by the Permit'tee. 

T:\Tra•tsferXTvwebpag\Tillotson_Dixville.doc 

Final Issued 05/25f2000 
General Title V Operating Permit Conditions 

Page 21 of 28 

Xo Issuance of a Title V Operating Permit: 

This Permit is issued in accordance with the Provisions of Part Env-A 609. In accordance with 40 

CFR 70.6(a)(2) this Permit shall expire on the date specified on the cover page of this Permit, which 

shall not be later than the date five (5) years after issuance of this Permit. 

Permit expiration terminates the Permittees' right to operate the Permittees' emissions units, control 

equipment or associated equipment covered by this permit, unless a timely and complete renewal 

application is submitted at least 6 months before the expiration date. 

Pursuant to Env-A 609.02(b), this Permit shall be a state permit to operate as defined in RSA 125- 

C: 11, III. 

XI. Title V Operating Permit,Renewal Procedures: 

Pursuant to Env-A 609.06(b), an application for renewal of this Permit shall be considered timely if it 

is submitted to the Director at least six months prior to the designated expiration date of this Permit. 

XII. Application Shield: 

Pursuant to Env-A 609.07, if an applicant submits a timely and complete application for the issuance 

or renewal of a Permit, the failure to have a Permit shall not be considered a violation of this payt 

until the Director takes final action on the application. 

XIII. Permit Shield: 

Pursuant to Env-A 609.08(a), a permit shield shall provide that: 

1. For any applicable requirement or any state requirement found in the New Hampshire 

Rules Governing the Control of Air Pollution specifically included in this Permit, 

compliance with the conditions of this Permit shall be deemed compliance with said 

applicable requirement or said state requirement as of the date of permit issuance; and 

2. For any potential applicable requirement or any potential state requirement found in the 

New Hampshire Rules Governing the Control of Air Pollution specifically identified in 

this Title V Operating Permit Section IX Table 8 as not applicable to the stationary source 

or area source, the Permittee need not comply with the specifically identified federal or 

state requirements. 

The permit shield identified in Section XIII. of this Permit shall apply only to those conditions 

incorporated into this Permit in accordance with the provisions of Env-A 609.08(b). It shall not 

apply to certain conditions as specified in Env-A 609.08(c) that may be incorporated into this Permit 

following permit issuance by DES. 

If a Title V Operating Permit and amendments there to issued by the DES does not expressly include 

or exclude an applicable requirement or a state requirement found in the NH Rules Governing the 

Control of Air Pollution, that applicable requirement or state requirement shall not be covered by the 

T:\Transfer\Tvwebpag\Tillotson_Dixville.doe 

Final Issued 05/25/2000 
XIV. 

XV. 

Page 22 of 28 

permit shield and the Permittee shall comply with the provisions of said requirement to the extent 

that it applies to the Permittee. 

If the DES determines that this Title V Operating Permit was issued based upon inaccurate or 

incomplete information provided by the applicant or Permit-tee, any permit shield provisions in said 

Title V Operating Permit shall be void as to the portions of said Title V Operating Permit, which are 

affected, directly or indirectly, by the inaccurate or incomplete information. 

Pursuant to Env-A 609.08(f), nothing contained in Section XIII of this Permit shall alter or affect the 

ability of the DES to reopen this Permit for cause in accordance with Env-A 609.18 or to exercise its 

summary abatement authority. 

Pursuant to Env-A 609.08(g), nothing contained in this section or in any Title V Operating Permit 

issued by the DES shall alter or affect the following: 

1. The ability of the DES to order abatement requiring immediate compliance with 

applicable requirements upon finding that there is an imminent and substantial 

endangerment to public health, welfare, or the environment; 

2. The state of New Hampshire's ability to bring an enforcement .action pursuant to RSA 

125-C:15, II; 

3. The provisions of section 303 of the Act regarding emergency orders including the 

authority of the EPA Administrator under that section; 

4. The liability of an owner or operator of a source for any violation of applicable 

requirements prior to or at the time of permit issuance; 

5.. The applicable requirements of the acid rain program, consistent with section 408(a) of 

the Act; 

6. The ability of the DES or the EPA Administrator to obtain information about a stationary 

source, area source, or device from the owner or operator pursuant to section 114 of the 

Act; or 

7. The ability of the DES or the EPA Administrator to enter, inspect, and/or monitor a 

stationary source, area source, or device. 

Reopening for Cause 

The Director shall reopen and revise a Title V Operating Permit for cause if any of the circumstances 

contained in Env-A 609.18(a) exist. In all proceedings to reopen and reissue a Title V Operating 

Permit, the Director shhll follow the provisions specified in Env-A 609.18(b) through (g). 

Administrative Permit Amendments 

Pursuant to Env-A 612.01, the Permittee may implement the-changes addressed in the request for an 

administrative permit amendment as def'med in Part Env-A 100 immediately upon submittal of the 

request. 

Pursuant to Env-A 612.01, the Director shall take final action on a request for an administrative 

permit amendment in accordance with the provisions of Env-A 612.01 (b) and (c). 

T:\Transfer\TvwebpagWillotson_Dixville.doe 

Final Issued 05/25t2000 
XVI. Operational Flexibility 

Page 23 of 28 

Pursuant to Env-A 612.02(a), the Permittee subject to and operating under this Title V Operating 

Permit may make changes involving trading of emissions under this existing Title V Operating 

Permit at the permitted stationary source or area source without filing a Title V Operating Permit 

application for and obtaining an amended Title V Operating Permit, provided that all the conditions 

are met as specified in section XVI. A. 1. through 7. of this permit and a notice is submitted to the 

DES and EPA describing the intended changes. At this point• DES has not included any permit terms 

authorizing emissions trading in this permit. 

1. The change is not a modification under any provision of title I of the Act; 

2. The change does not cause emissions to exceed the emissions allowable under the Title V 

Operating Permit, whether expressed therein as a rate of emissions or in terms of total 

emissions; 

3. The owner or operator has obtained any temporary permit required by Env-A 600; 

4. The owner or operator has provided written notification to the director and administrator 

at least 15 days prior to the proposed change and such written notification includes: 

a) The date on which each proposed change will occur; 

b) A description of each such change; 

c) Any change in emissions that will result and how this change in emissions will comply 

with the terms and conditions of the permit; 

d) A written request that the operational flexibility procedures be used; and 

e) The signature of the responsible official, consistent with Env-A 605.04(b); 

5. The Title V Operating Permit issued to the stationary source or area source already 

contains terms and conditions including all terms and conditions which determine 

compliance required under 40 CFR 70.6(a) and (c) and which allow for the trading of 

emissions increases and decreases at the permitted stationary source or area source solely 

for the purpose of complying with a federally-enforceable emissions cap that is 

established in the permit independent of otherwise applicable requirements; 

6. The owner or operator has included in the application for the Title V Operating Permit 

proposed replicable procedures and proposed permit terms which ensure that the 

emissions trades are quantifiable and federally enforceable for changes to the Title V 

Operating Permit which qualify under a federally- enforceable emissions cap that is 

established in the Title V Operating Permit independent of the otherwise applicable 

requirements; and 

7. The proposed change complies with Env-A 612.02 (e). 

Pursuant to Env-A 612.02(c), the Permittee subject to and operating under this Title V Operating 

Permit may make changes not addressed or prohibited by this existing Title V Operating Permit at the 

permitted stationary source or area source without filing a Title V Operating Permit application, 

provided that all the conditions specified in Env-A 612.02(c)(1) through (6) are met and a notice is 

submitted to the DES and EPA describing the intended changes. 

Pursuant to Env-A 612.02(d), the Permittee, Operator, Director and Administrator shall attach each 

notice of an off-permit change completed in accordance with Section XVI of this Title V Operating 

Permit to their copy of the current Title V Operating Permit. 

T:\Trans fer\q•vwebp ag\Tillotson_Dixvil le.do 

Final Issued 05/25/2000 
Page 24 of 28 

Pursuant to Env-A 612.02(e), any Change under Section XVI shall not exceed any emissions 

limitations established under the NH Rules Governing the Control of Air Pollution, or result in an 

increase in emissions, or result in new emissions, of any toxic air pollutant or hazardous air pollutant 

other than those listed in the existing Permit. 

Pursuant to Env-A 612.02(0, the off-permit change shall not qualify for the permit shield under EnvA 609.08. 

XVII. Minor Permit Amendments 

Pursuant to Env-A 612.04 prior to implementing a minor permit modification, the Permittee shall 

submit a written request to the Director in accordance with the requirements of Env-A 612.04(b). 

The Director shall take final action on the minor permit amendment request in accordance with the 

provisions of Env-A 612.04(c) through (g). 

Pursuant to Env-A 612.04(g), the permit shield specified in Env-A 609.08 shall not apply to minor 

permit amendments under Section XVII. of this Permit. 

Pursuant to Env-A 612.04(I), the Permit-tee shall be subject to the pro•eisions of Part Env-A 614 and 

Part Env-A 615 if the change is made prior to the filing with the Director a request for a minor permit 

amendment. 

XVIII. Significant Permit Amendments 

Pursuant to Env-A 612.05, a change at the facility shall qualify as a significant permit amendment if 

it meets the criteria specified in Env-A 612.05(a)(1) through (7). 

Prior to implementing the significant permit amendment, the Permittee shall submit a written request 

to the Director, which includes all the information as referenced in Env-A 612.05(b) and (c) and shall 

be issued an amended Title V Operating Permit from the DES. The Permittee shall be subject, to the 

provisions of Env-A 614 and Env-A 615 if a request for a significant permit amendment is not filed 

with the Director and/or the change is made prior to the issuance of an amended Tire V Operating 

Permit. 

The Director shall take final action on the significant permit amendment in accordance with the 

Procedures specified in Env-A 612.05(d), (e) and (f). 

XIX. Title V Operating Permit Suspension, Revocation or Nullification 

Pursuant to RSA 125-C: 13, the Director may suspend or revoke any final permit issued hereunder if, 

following a hearing, the Director determines that: 

1. The Permit-tee has committed a violation of any applicable statute or state requirement 

found in the New Hampshire Rules Governing the Control of Air Pollution, order or 

permit condition in force and applicable to it; or 

2. That the emissions from any device to which this Permit applies, alone or in conjunction 

with other sources of the same pollutants, presents an immediate danger to the public 

health. 

T:•Trans fer\Tvwebpag•Tillotson_Dixville,doe Final Issued 05/25/2000 
XXo 

XXIQ 

Page 25 of 28 

The Director shall nullify any Permit, if following a hearing in accordance with RSA 541-A:30, II, a 

finding is made that the Permit was issued in whole or in part based upon any information proven to 

be intentionally false or misleading. 

Inspection and Entry 

Pursuant to Env-A 614.01, EPA and DES personnel shall be granted access to the facility covered by 

this Permit, in accordance with RSA 125-C:6,VII for the purposes of: inspecting the proposed or 

permitted site; investigating a complaint; and assuring compliance with any applicable requirement or 

state requirement found in the NH Rules Governing the Control of Air Pollution and/or conditions of 

any Permit issued pursuant to Chapter Env-A 600. 

Certifications 

A. Compliance Certification Report 

In accordance with 40 CFR 70.6(c) the Responsible Official shall certify, for the previous 

calendar year, that the facility is in compliance with the requirements of this permit. The 

report shall be submitted annually, no later than April 15th of the following year. The report 

shall be submitted, to the DES and to the U.S. Environmental Protection Agency New 

England Region. The report shall be submitted in compliance with the submission 

requirements below. 

In accordance with. 40 CFR 70.6(c)(5), the report shall describe: 

1. The terms and conditions of the Permit that are the basis of the certification; 

2. The current compliance status of the source with respect to the terms and conditions of 

this Permit, and whether the method was continuous or intermittent during the reporting 

period; 

3. The methods used for determining compliance, including a description of the monitoring, 

record keeping, and reporting requirements and test methods; and 

4. Any additional information required by the DES to determine the compliance status of the 

source. 

B. Certification of Accuracy Statement 

All documents submitted to the DES shall contain a certification of accuracy statement by the 

responsible official of truth, accuracy, and completeness. Such certification shall be in 

accordance with the requirements of 40 CFR 70.5(d) and contain the following language: 

"I am authorized to make this submission on behalf of the facility 

for which the submission is made. Based on information and belief 

formed after reasonable inquiry, I certify that the statements and 

information in the enclosed documents are to the best of my 

knowledge and belief tree, accurate, and complete. I am aware that 

there are significant penalties for submitting false statements and 

information or omitting required statements and information, 

including the possibility of fme or imprisonment." 

T:\Transfcr\Tvwebpag\TillotsoluDixville.doe 

Final Issued 05/25/2000 
Page 26 of 28 

All reports submitted to DES (except those submitted as emission based fees as outlined in 

Section XXIII of this Permit) shall be submitted to the following address: 

New Hampshire Department of Environmental Services 

Air Resources Division 

6 Hazen Drive 

P•O. Box 95 

Concord, NH 03302-0095 

ATTN: Compliance Bureau 

All reports submitted to EPA shall be submitted to the following address: 

Office of Environmental Stewardship 

Director Air Compliance Program 

United States Environmental Protection Agency 

Congress Street 

Suite 1100 (SEA) 

Boston, MA 02114-2023 

ATTN: Air Compliance Clerk 

XXII. Enforcement 

Any noncompliance with a permit condition constitutes a violation of RSA 125-C: 15, and, as to the 

conditions in this permit which are federally enforceable, a violation of the Clean Air Act, 42 U.S.C. 

Section 7401 et seq., and is grounds for enforcement action, for permit termination or revocation, or 

for denial of an operating permit renewal application by the DES and/or EPA. Noncompliance may 

also be grotmds for assessment of administrative, civil or criminal penalties in accordance with RSA 

125-C: 15 and/or the Clean Air Act. This Permit does not relieve the Permittee from the obligation to 

comply with any other provisions of RSA 125-C, the New Hampshire Rules Governing the Control 

of Air PollutiOn, or the Clean Air Act, or to obtain any other necessary authorizations from other 

governmental agencies, or to comply with all other applicable Federal, State, or Local rules and 

regulations, not addressed in this Permit. 

In accordance with 40 CFR 70.6 (a)(6)(ii) a Permittee shall not claim as a defense in an enforcement 

action that it would have been necessary to halt or reduce the permitted activity in order to maintain 

compliance with the conditions of this Permit. 

XXIII. Emission-Based Fee Requirements 

The Permittee shall pay an emission-based fee annually for this facility as calculated each calendar 

year pursuant to Env-A 704.03. 

The Permittee shall determine the total actual annual emissions from the facility to be included in the 

emission-based multiplier specified in Env-A 704.03(a) for each calendar year in accordance with the 

methods specified in Env-A 620. 

The Permittee shall calculate the annual emission-based fee for each calendar year in accordance with 

the procedures specified in Env-A 704.03 and the following equation: 

FEE E * DPT * CP Im* ISF 

Where: 

T:\Trans fefiTvwebpag\Tillotson Dixville.doe 

Final Issued 05/25/2000 
DPT 

CPImISF 

Page 27 of 28 

The annual emission-based fee for each calendar year as specified in Env-A 704. 

The emission-based multiplier is based on the calculation of total annual emissions as 

specified in Env-A 704.02 and the provisions specified in Env-A 704.03(a). 

The.dollar per ton fee the DES has specified in Env-A 704.03(b). 

The Consumer Price Index Multiplier as calculated in Env-A 704.03(c). 

The Inventory Stabilization Factor as specified in Env-A 704.03(d). 

The Permittee shall contact the DES each calendar year for the value of the Inventory Stabilization 

Factor and for the value of the Consumer Price Index Multiplier. 

The Permittee shall submit, to the DES, payment of the emission-based fee and a summary of the 

calculations referenced in Sections XXIII.B., and C of this Permit for each calendar year by October 

15 th of the following calendar year in accordance with Env-A 704.04. The emission-based fee and 

summary of the calculations shall be submitted to the following address: 

New Hampshire Department of Environmental Services 

Air Resources Division 

6 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

ATTN.: Emissions Inventory 

The DES shall notify the Permit-tee of any under payments or over payments of the annual emissionbased fee in accordance with Env-A 704.05. 

XXIV. Duty To Provide Information 

In accordance with 40 CFR 70.6 (a)(6)(v), upon the DES's written request, the Permittee shall 

furnish, within a reasonable time, any information necessary for determining whether cause exists for 

modifying, revoking and reissuing, or terminating the Pemfit, or to determine compliance with the 

Permit. Upon request, the Permittee shall furnish to the DES copies of records that the Permittee is 

required to retain by this Permit. The Permittee may make a claim of confidentiality as to any 

information submitted pursuant to this condition in accordance with Part Env-A 103 at the time such 

information is submitted to DES. DES shall evaluate such requests in accordance with the provisions 

of Part Env-A 103. 

XXV. Property Riahts 

Pursuant to 40 CFR 70.6 (a)(6)(iv), this Permit does not convey any property rights of any sort, or 

any exclusive privilege. 

Severability Clause 

Pursuant to .40 CFR 70.6 (a)(5), the provisions of this Permit are severable, and if any provision of 

this Permit, or the application of any provision of this Permit to any circumstances is held invalid, the 

application of such provision to other circumstances, and the remainder of this Permit, shall not be 

affected thereby. 

T:\TransferXTvwebpag\Tillotson_Dixville.doc 

Final Issued 05/25/2000 
XXVII. Emergency Conditions 

Page 28 of 28 

Pursuant to 40 CFR 70.6(g), the Permittee shall be shielded from enforcement action brought for 

noncompliance with technology based t4 emission limitations specified in this Permit as a result of an 

emergency 15. In order to use emergency as an affirmative defense to an action brought for 

noncompliance, the Permittee shall demonstrate the affirmative defense through properly signed, 

contemporaneous operating logs, or.other relevant evidence that: 

A. An emergency occurred and that the Permittee can identify the cause(s) of the emergency; 

B. The permitted facility was at the time being properly operated; 

During the period of the emergency, the Permittee took all reasonable steps as 

expeditiously as possible, to minimize levels of emissions that exceeded the emissions 

standards, or other requirements in this Permit; and 

The Permittee submitted notice of the emergency to the DES within two (2) business days 

of the time when emission limitations were exceeded due to the emergency. This notice 

must contain a description of the emergency, any steps taken to mitigate emission, and 

corrective actions taken. 

XXVIII. Permit Deviation: 

In accordance with 40 CFR 70.6(a)(3)(iii)(B), the Permittee shall report to the DES all instances of 

deviations from Permit requirements, by telephone or fax, within 24 hours of discovery of such 

deviation pursuant to Env-A 902.02. This report shall include the deviation itself, including those 

attributable to upset conditions as defined in the Permit, the probable cause of such deviations, and 

any corrective actions or preventative measures taken. Said Permit deviation shall also be submitted 

in writing to the DES within fifteen (! 5) days of documentation of the deviation by facility personnel. 

Deviations are instances where any Permit condition is violated and has not already been reported as 

an emergency pursuant to Section XXVII of this Permit. 

Reporting a Permit deviation is not an affirmative defense for action brought for noncompliance. 

or process changes (e.g., a new source performance standard) rather than those established to attain health based air quality standards. 

•5 An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation would require immediate corrective action to restore normal operation, and that causes the source to 

exceed a technology based limitation under the permit, due to unavoidable increases in emissions attributable to the emergency. An 

emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, 

careless or improper operations, operator error or decision to keep operating despite knowledge of any of these things. 

T:\Tr fer\'Dcwebp ag\Tillots on_Dixville.d Final Issued 05/25/2000 
STATE OF NEW HAMPSHIRE 

Department of Environmental Services 

Air Resources Division 

Title V Operating Permit 

Permit No: TV-OP-019 

Date Issued: September 15, 1999; Minor Permit Modification Issued December 17, 1999; Significant 

Permit Modification Issued on September 7, 2001. 

This certifies that: 

Tractebel Power, Inc. 

24 Bridge Street 

Concord, NH 03301 

has been granted a Title V Operating Permit for the following facility and location: 

Pinetree Power Bethlehem 

1241 Whitefield Road 

Bethlehem, NH 03574 

Grafton County 

AFS No. 3300900026 

This Title V Operating Permit is hereby issued under the terms and conditions specified in the Title V Operating 

Permit Application filed with the New Hampshire Department of Environmental Services Air Resources 

Division (DES) on June 18, 1996 and the supplemental information for the Title V application submitted on 

September 23, 1996 and March 9, 1998 under the signature of the following responsible official certifying to the 

best of their knowledge that the statements and information therein are true, accurate, and complete. 

Responsible Official: 

Mark Driscoll 

Plant Manager 

(603) 444-9993, Ext. 12 

Technical Contact: 

Mark Driscoll 

Plant Manager 

(603) 444-9993, Ext. 12 

This Permit is issued by the DES pursuant to its authority under New Hampshire RSA 125-C and in accordance 

with the provisions of Code of the Federal Regulations 40 Part 70. 

This Title V Operating Permit shall expire on September 30, 2004. 

SEE ATTACHED SHEETS FOR ADDITIONAL PERMIT CONDITIONS 

For the New Hampshire Department of Environmental Services, Air Resource Division 

Director, Air Resources Division 
II. 

III. 

TABLE OF CONTENTS 

•acd•y•:Spec!fi• •!t!ei•N•Operat!ng•Pe•m•t:!•ondlt•on• %•,a,• 

Facility Description of Operations 

Permitted Activities 

Significant Activities Identification and Stack Criteria Tables 

l&2 

4 

4 

IV. Insignificant Activities Identification 5 

V. Exempt Activities Identification 6 

VI. Pollution Control Equipment Identification Table 3 6 

VII. 

VIII. 

Alternative Operating Scenarios 

4-5 

Applicable Operational and Emission Limitations 

IX. Emission Reductions Trading Requirements 10 

X. 

XI. 

Compliance Demonstration Requirements -Monitoring and Testing Requirements -Recordkeeping and Reporting Requirements 

Requirements Not Currently Applicable 

6 

7-10 

11-20 

21 

XII. Issuance of a Title V Operating Permit .21 

XIII. Title V Operating Permit Renewal Procedures 21 

XIV. Application Shield 21 

XV. Permit Shield 21-22 

XVI. 

XVII. 

XVIII. 

Reopening for Cause 

Administrative Permit Amendments 

Operational Flexibility 

Minor Permit Amendments 

22 

23 

23-24 

XIX. 24 

XX. Significant Permit Amendments 24-25 

XXI. Title.V Operating Permit Suspension, Revocation, or 25 

Nullification 
Page 3 

•'i• 

XXII. Inspection and Entry 

XXIII. Certifications 

XXIV. Enforcement 

XXV. Emission Based Fee Requirements 

XXVI. Duty to Provide Information 

XXVII, 

XXVIII. 

XXIX. 

XXX. 

Property Rights 

Severability Clause 

Emergency Conditions 

Permit Deviations 

25 

25-26 

26 

27 

28 

28 

28 

28-29 

29 
Page 4 

Facility Specific Title V Operating Permit Conditions 

I. Facility Description of Operations: 

The Pinetree Bethlehem wood-fired electric power generating plant (Pinetree Bethlehem) began operation on 

December 10, 1986 using a 17.6 megawatt (MW) turbine to produce electricity. The turbine generator is 

driven by steam produced in a 289.43 million British thermal unit per hour (mmBTU/hr) waterwall boiler. 

At the maximum firing rate (289.43 mmBTU/hr), the boiler produces approximately 165,000 lb/hr of steam 

at 625 psig and 825°F. The boiler is fired using approximately 820 tons/day of wood chips with an average 

heating value of 4,250 BTU/lb, assuming approximately 50% moisture. The facility also operates an 

emergency generator rated at 603 horsepower (hp) with a maximum firing rate of 35.9 gallons per hour of 

diesel fuel. This generator is fired only in the event of a Public Service Company of New Hampshire 

(PSNH) blackout, in the event of a fire, and for maintenance purposes. 

The Pinetree Bethlehem facility received a United States Environmental Protection Agency (EPA) 

Prevention of Significant Air Quality Deterioration (PSD) permit (Permit No. 043-149NH09) on March 27, 

1990. Pinetree Bethlehem appealed this permit on April 25, 1990 and the PSD permit was revised by the 

EPA on July 1, 1991. The PSD permit limits are incorporated in this Title V Operating Permit. 

lI. Permitted Activities: 

In accordance with all of the provisions of the New Hampshire Rules Governing the Control of Air Pollution 

(effective date 12/31/96) and as revised thereafter, Pinetree Bethlehemis authorized to operate the devices 

and or processes identified in Sections III., IV., V., and VI. within the terms and conditions specified in this 

Permit. 

III. Significant Activities Identification and Stack Criteria: 

A. Significant Activity Identification 

The activities identified in the following table (Table 1) are subject to and regulated by this Title V 

Operating Permit: 

EU1 -Boiler 

EU2 Cooling 

Tower 

EU3 EG 

Zurn Two Drum Waterwall Bent 

Tube W•i-fired Boi•I• 

Circulation Water Cooling Tower 

Caterpillar Emergency Diesel 

Generator, Model #3408 

Stack #1 

Cooling Towel 

Stack #2 

Maximum Firing Rate of 

289.43 mmBTU/hr derived 

from whole tree wood chips 

Drift Factor 0,0002 gal 

drift/gal circ 

Circulation Rate 21,224 gpm 

603 hp operating less than 500 

hours per year, max firing rate 

of4.19 mmBTU/hr, 

35.9 gal/hr of diesel 
Bo 

Page 5 

Based on equipment design, the maximum operating rate of the EU1 Boiler shall be limited 

to a total of 289.43 mmBTU/hr gross heat input. 

In accordance with Pinetree Bethlehem's federal PSD permit (No. 043-149NH09), Pinetree 

Bethlehem shall burn in the EU1 Boiler only wood chips uncontaminated by glues, 

preservatives; o!ls, or similar foreign substances in the boiler. Pinetree shall notify the EPA 

and the DES and obtain written EPA and DES approval of all proposed sources of wood fuel 

other than wood chips, and of the nature of said fuels, prior to the securing of any 

purchase/utilization agreements for said fuels. 

Based on equipment design and 365 operating days per year, the maximum wood 

consumption by the EU1 Boiler shall be limited to 298,000 tons wet basis of whole tree 

wood chips at approximately 50% moisture (8.5 mmBTU/ton) during any consecutive twelve 

month period. This is equivalent to 165,000 lbs/hr of steam production as averaged over any 

consecutive 24-hour period at 825 degrees F and 625 PSIG, assuming a boiler efficiency of 

67% and boiler feedwater temperature of 278 degrees F. 

Stack Criteria 

The following stacks for the above listed significant devices at Pinetree Bethlehem shall discharge 

vertically without obstruction (including rain caps) and meet the following criteria in accordance 

with the state-only air pollution dispersion modeling requirements specified in Env-A 606. 

Stack# •'• • ,•l -Mi•imumStack•ht(F imum:•tackDiameter:•(Feet) 

Stack #1 EU1-Boiler 197.5 7.5 

Stack #2 EU3-EG 11.0 0.67 

IV. 

Preauthorized changes to the state-only requirements pertaining to stack parameters (set forth in 

this permit) shall be permitted only when an air quality impact analysis meeting the criteria of 

Part Env-A 606 is performed either by Pinetree Bethlehem or by the DES (if requested by 

Pinetree Bethlehem in writing) in accordance with the "NHARD Policy and Procedure for Air 

Quality Impact Modeling". All air modeling data shall be kept on file at Pinetree Bethlehem for 

review by the DES upon request. 

Insignificant Activities Identification: 

All activities at Pinetree Bethlehem that meet the criteria identified in the New Hampshire Rules 

Governing the Control of Air Pollution Part Env-A 609.03(g), shall be considered insignificant 

activities. Emissions from the insignificant activities shall be included in the total Pinetree Bethlehem 

emissions for the emission-based fee calculation described in Section XXV. of this Title V Operating 

Permit. 

Insignificant sources at the facility include two liquid propane heaters and a maintenance degreasing 

unit. 
VI. 

Page 6 

Exempt Activities Identification: 

All activities identified in the New Hampshire Rules Governing the Control of Air Pollution Part Env-A 

609.03(c) shall be considered exempt activities and shall not be subject to or regulated by this Title V 

Operating Permit. These activities include two diesel fire pumps (195 hp each) at the facility. 

Pollution Control Equipment Identification: 

The devices and/or processes identified in Table 3 below are considered pollution control equipment for 

the identified emissions unit. 

Table 3 e011ution Control 

PC -Multiclone 

PC2-ESP 

Multiclone primary particulate control for the EU1 Boiler 

Electrostatic Precipitator (ESP) secondary particulate control for the 

EU1 Boiler 

EU1-Boiler 

EU1-Boiler 

VII. 

mo All equipment, facilities, and systems installed and used to achieve compliance with the terms 

and conditions of this permit shall at all times be maintained in good working order and shall be 

operated as efficiently as possible so as to minimize air pollutant emissions and meet all 

applicable air pollutant emission limits. These controls shall be fully operational upon Pinetree 

Bethlehem startup and shall not be bypassed during startup, operation, or shutdown of the steam 

generating unit. 

The pollution control equipment shall be maintained regularly, in accordance with the 

manufacturer's Operation and Maintenance (O&M) manual and based on the schedules as 

described in Sections VIII.A. and X.A. Based on available vendor data, the PM emission 

controls are able to achieve a control efficiency of 98.5%. 

Alternative Operating Scenarios: 

Pinetree Bethlehem did not request any alternative operating scenarios in the Title V permit application. 
Page 7 

VIII. Applicable Operational and Emission Limitations: 

Pinetree Bethlehem is subject to the following operational and emission limitations as contained in this 

permit. 

A. Operational Limitations 

Based on equipment design, the maximum operating rate of the EU 1-Boiler shall be 

limited to a total of 289.43 mmBTU/hr gross heat input with wood. This is equivalent to 

165,000 lbs/hr of steam production as averaged over any consecutive 24-hour period at 

825 degrees F and 625 PSIG, assuming a boiler efficiency of 67% and boiler feedwater 

temperature of 278 degrees F, as per Pinetree Bethlehem's federal PSD permit (No. 043- 

149NH09).. 

To operationally control CO emissions in accordance with Env-A 305, Pinetree 

Bethlehem shall comply with the following operational limitations. 

Pinetree Bethlehem shall control CO emissions by varying the total quantity of input combustion 

air and/or the local distribution of that air into the EU1 Boiler. The amount of combustion air 

required to optimize the EU1 Boiler efficiency and reduce CO emissions is dependent on the 

wood moisture content and the type of wood, among other factors. The steam generating unit 

shall be equipped with fuel distribution, overfire air, and undergrate air control systems for 

optimum NOx and CO emission control. 

B. State-Only Applicable Emission Limitations 

The facility shall comply with the national ambient air quality standards and the 

applicable requirements of RSA 125-C:6, RSA 125-C:11, and Env-A 606.04. These 

sections include, but are not limited to, descriptions of the powers and duties of the 

commissioner, and requirements for adherence to permit application procedures and air 

pollutant dispersion modeling impact analyses. 

In accordance with Env-A 1002.03, Pinetree Bethlehem shall take precautions to prevent, 

abate, and control the emission of fugitive dust for those activities described in Env-A 

1002.02. Such precautions shall include wetting, covering, shielding, or vacuuming. 

In accordance with Env-A 1305.0 l(a)• new or modified devices, new or modified area 

sources, and existing devices or area sources for which new applications for permits are 

filed that have the potential to emit, in any amount, substances that meet the criteria of 

Env-A 1301 shall be subject to Env-A 1300, until such time as the Env-A 1400 

requirements supersede the Env-A 1300 requirements. 

In accordance with Env-A 1305.02, air quality impact analysis of devices and area 

sources emitting substances meeting the criteria of Env-A 1301 shall be performed in 

accordance with the "DES Policy and Procedure for Air Quality Impact Modeling" or 

other comparable dispersion modeling methods approved by EPA. 
Page 8 

In accordance with Env-A 1403.01, new or modified devices or processes installed after 

May 8, 1998 shall be subject to the requirements of Env-A 1400. 

In accordance with 1403.02(a), all existing unmodified devices or processes which are in 

operation during the transition period ending three years from May 8, 1998 (May 8, 2001) 

shall comply with either Env-A 1300 or Env-A 1400. 

In accordance with Env-A 1403.02(b), all existing devices or processes in operation after 

the transition period ending three years from May 8, 1998 (May 8, 2001) shall comply with 

Env-A 1400. Env-A 1300 will no longer be in effect. 

In accordance with Env-A 1404.01 (d), documentation for the demonstration of compliance 

shall be retained at the site, and shall be made available to the DES for inspection. 

In accordance with Env-A 1405.02, the owner of an existing device or process requiring a 

permit modification under Env-A 1400 shall submit to the DES iao later than one year prior 

to the end of the transition period (by May 8, 2000) an application for a modification to a 

Title V permit in.accordance with Env-A 609.18, and a request to the DES to perform air 

dispersion modeling. 

10. In accordance with Env-A 1405.03, the owner of an existing device or process requiring a 

permit under Env-A 1300 shall submit to the DES no later than one year prior to the end of 

the transition period (May 8, 2000) a compliance plan identifying how the device or 

process will comply with chapter Env-A 1400 by the end of the transition period. The 

compliance plan shall contain the dates when the information required in Env-A 1405.02 

will be filed with the DES. 

11. In accordance with Env-A 1406.01, the owner of any device or process which emits a 

regulated toxic air pollutant shall determine compliance with the ambient air limits by 

using one of the methods provided in Env-A 1406.02, Env-A 1406.03, or Env-A 1406.04. 

Upon request, the owner of any device or process which emits a regulated toxic air 

pollutant shall provide documentation of compliance with the ambient air limits to the 

DES. 

C. Federally Enforceable Emission Limitations 

In accordance with Env-A 1211.020)(1 and 2), EU3-EG shall be limited to less than 500 

hours of operation during any consecutive 12-month period, and the combined theoretical 

potential emissions of NOx from these types of generators are limited to less than 25 tons 

for any consecutive 12-month period. 

In the event that EU3-EG exceeds 500 hours of operation and 25 tons of NOx emissions in 

any consecutive 12-month period, it shall become subject to the requirements of Env-A 

1211.11. 

3. In accordance with 40 CFR Part 52 and Env-A 1604.01(a), the sulfur content of No. 2 oil 

Env-A 402.02(a), effective on December 27, 1990, was adopted as part of the State Implementation Plan 
Page 9 

and off-road diesel oil burned at this facility shall not exceed 0.40 percent sulfur by weight. 

In accordance with 40 CFR Part 52 2, the sulfur content of gaseous fuels burned at this 

facility shall not exceed 5 grains per 100 cubic feet of gas, calculated as hydrogen sulfide at 

standard temperature and pressure. 

In accordance with Env-A 2003.08, emissions of particulate matter from EU3-EG shall not 

exceed 0.30 lb/mmBtu. 

In accordance with Pinetree Bethlehem's federal PSD Permit No. 043-149NH09, startup 

and shutdown periods for the EU1-Boiler are defined as follows: 

Startup periods are those periods of time from the initiation of wood firing until the 

unit reaches steady-state operation (85% to 100% load conditions). This period 

shall not exceed 8 hours (480 minutes) for a cold startup, nor 4 hours (240 minutes) 

for a hot startup. A cold startup shall be defined as startup when the EU1-Boiler 

has been down for more than 24 hours. 

bo Shutdown periods shall not exceed 4 hours (240 minutes) from the moment the 

wood fuel supply to the EU1- Boiler is eliminated. 

The number of hours that the EU 1-Boiler can operate in a startup or shutdown 

mode shall not exceed 15% of the total operating hours of the plant. 

In accordance with Pinetree Bethlehem's federal PSD Permit No.043-149NH09, Pinetree 

Bethlehem is subject to the following opacity limits: 

a. Startup/Shutdown Conditions 

Pinetree shall not cause or allow visible emissions from the EU 1-Boiler to exceed 

20 percent (6-minute average), except for one 6-minute average per hour of not 

more than 27 percent opacity. 

b. Steady State Operating Conditions 

(SIP) on September 14, 1992 and is still considered federally enforceable until such time as the SIP is amended and 

approved by the EPA. 

2 Env-A 402.03, effective on December 27, 1990, was adopted as part of the State Implementation Plan 

(SIP) on September 14, 1992 and is still considered federally enforceable until such time as the SIP is amended and 

approved by the EPA. 
IX. 

Page 10 

Pinetree shall not cause or allow visible emissions from the EU1-Boiler to exceed 

15 percent (6-minute average), except for one 6-minute average per hour of not 

more than 27 percent opacity. 

Pinetree shall not cause or allow visible emissions from EU3-EG to exceed 20%, in 

accordance with Env-A 2003.02. 

Opacity shall be determined in accordance with procedures set forth in 40 CFR Part 

60, Appendix A, Method 9. 

In accordance with the requirements of Pinetree Bethlehem's federal PSD permit (No. 

043-149NH09), the NOx emission rate from the EU 1- Boiler shall be limited to 86.8 

pounds of NOx per hour (lbs/hr) and 0.3 lbs NO×/mmBTU as averaged over any 

consecutive 24-hour period. Compliance with this emission limit shall be demonstrated 

using the NOx CEM data) 

In accordance with the requirements of Pinetree Bethlehem's federal PSD permit (No. 043- 

149NH09), during steady state operating conditions, the carbon monoxide (CO)emission 

rate fromthe EU1- Boiler shall be limited to 144.7 lbs/hr • 0.5 I•mmBTU as averaged over •ny cons•utive 24-!•. •perio¢. During startup/shutdown conditions, the carbon 

monoxide (CO) emission rate from the EU1- Boiler shall be limited to 144.7 lbs/hr as 

averaged over any consecutive 24-hour period. Compliance with this emission limit shall 

be demonstrated using the CO CEM data. CEM requirements are described in Section 

X.B. of this permit. 

10. 

11. 

In accordance with Pinetree Bethlehem's federal PSD permit (No. 043-149NH09), the PM 

emission rate from the EU1- Boiler shall be limited to 0.03 lb/mmBTU heat input and 8.7 

lb/hr at all times. 

In accordance with Pinetree Bethlehem's federal PSD permit (No. 043-149NH09), the 

volatile organic compound (VOC) emission rate from the EU1- Boiler shall be limited to 

0.096 lb/mmBTU heat input and 27.8 lb/hr at all times. 

12. In accordance with Pinetree Bethlehem's federal PSD permit (No. 043-149NH09), Pinetree 

shall not allow fugitive emissions fromthe facility to exceed 10% opacity at any time. 

Pinetree shall continuously clean and maintain the facility to minimize fugitive particulate 

matter emissions. The fugitive emission control plan prepared and submitted to the EPA 

following issuance of the facility PSD permit shall be reviewed on an annual basis and 

updated as needed to accurately reflect facility conditions. 

Emission Reductions Trading Requirements: 

Pinetree Bethlehem did not request emissions reductions trading in the Pinetree Bethlehem operating 

permit application. At the time of this permit preparation, the DES did not include any permit terms 

This device is subject to both the PSD limit of 0.3 lb NOx/mmBtu, and to the NOx RACT limit of 0.33 lb 

NOx/mmBtu (Env-A 1211.04(d) and Env-A 1211.05(d)(5)), although the PSD limit shall take priority as the most 

stringent federally enforceable limit. 
Page 11 

authorizing emissions trading in this permit. All emissions reductions trading must be authorized under 

the applicable requirements of either Env-A 3000 (the "Emissions Reductions Credits (or ERCs) Trading 

Program") or Env-A-3100 (the "Discrete Emissions Reductions (or DERs) Trading Program") and 42 

U.S.C. §7401 et seq. (The "Act"), and must be provided for in this Permit. 

X. Compliance Demonstration Requirements: 

Pinetree Bethlehem is subject to the monitoring/testing, record keeping, and reporting requirements as 

contained in the followingpermit sections. Refer to the standard operating practices and the 

manufacturer's O&M manual for additional information. The pollution control equipment and EU1 

Boiler shall be monitored and maintained in accordance with the appropriate manufacturer's O&M 

manuals. 

Monitoring/Testing Requirements for Total Suspended Particulate Controls 

(Regulatory cite Env-A 806.01(a) and 40 CFR Part 70.6(a)(3)) 

1. PC 1 Multiclone Monitoring and Testing Requirements 

The PCI•Multiclone shall be operated in series with the PC2-ESP unit. 

Conduct monitoring of pressure differential across the PC 1 Multiclone unit every 

twohours. An acceptable pressure differential shall be in accordance with standard 

operating practices and manufacturer's recommended operating parameters and 

shall be .maintained between 1 and 6 inches of water column. Pressure differential 

readings shall be recorded on standard forms and kept on file at Pinetree Bethlehem 

for review by the DES upon request. The standard forms shall include the 

acceptable operating parameters for quick reference by Pinetree Bethlehem 

personnel. 

Pinetree Bethlehem persormel shall conduct a daily inspection for visible emissions 

of the PC 1 Multiclone unit to observe leaks using EPA Method 22, found in 40 

CFR Part 60, Appendix A. If a leak(s) is observed, Pinetree Bethlehem personnel 

shall take immediate st6ps to repair the leak. Daily observations, maintenance, and 

repairs performed to the unit shall be recorded in the log book. 

During down-time maintenance periods, Pinetree Bethlehem personnel shall inspect 

inlet and outlet vanes and boots for any build up of caked dust. All caked dust shall 

be removed during each down-time maintenance period. Maintenance and repair 

activities shall be recorded in the log book. 

do Observations of operating parameters outside of the standard operating practices 

included in this permit shall be recorded, investigated, and corrected immediately. 

In accordance with Section XXX of this permit, Pinetree Bethlehem personnel 

shall contact the DES within 24 hours of discovery of a permit deviation. 

2. PC2 ESP Monitoring and Testing Requirements 

The PC2-ESP is used to control particulate matter emissions from the EU1 Boiler. 
Page 12 

a. Bi-Hourly Monitoring/Testing Requirements: 

In accordance with Pinetree Bethlehem's O&M manual and standard operating 

practices for this equipment, on a bi-hourly basis, Pinetree Bethlehem personnel 

shall: 

i. Check and record the secondary voltage and pressure drop readings on the 

PC2 ESP. The secondary voltage shall be maintained between 15 and 60 

kv and the pressure drop across the PC2-ESP shall be less than 2 inches of 

water column. The PC2-ESP secondary ,•oltage is digitally controlled to 

maintain opacity at less than or equal to the opacity setpoint of 10 percent, 

using an energy saver option on a continuous basis. Voltage or pressure 

drop readings outside these ranges indicate a malfunction with the PC2- 

ESP, and the operator shall correct the malfunction immediately. 

ii. The Pinetree Bethlehem operator shall respond to all equipment alarms 

immediately. 

iii. Bi-hourly monitoring data shall be recorded daily on standard forms and 

kept on file at Pinetree Bethlehem for review by the DES upon request. The 

standard forms shall include the acceptable operating parameters for quick 

reference by Pinetree Bethlehem personnel. 

iv. Observations of operating parameters outside of the standard operating 

practices included in this permit shall be recorded, investigated, and 

corrected immediately. In accordance with Section XXX of this permit, 

Pinetree Bethlehem personnel shall contact the DES within 24 hours of 

discovery of a permit deviation. 

b. Daily Monitoring/Testing Requirements 

The PC2-ESP shall be inspected at least once each shift. The casing, 

piping, and ducts shall be inspected for leaks, abnormal noise, hot spots, and 

fires. Local instrumentation shall be monitored for normal values. The local 

contrOl panel shall be monitored for proper indication of normal values and 

alarms. Visible emissions from the PC2-ESP shall be checked daily to 

assure compliance with permit limitations. 

ii. Observations of operating parameters outside of the standard operating 

practices included in this permit shall be recorded, investigated, and 

corrected immediately. In accordance with Section XXX of this permit, 

Pinetree Bethlehem personnel shall contact the DES within 24 hours of 

discovery of a permit deviation. 

3. Stack Testing Requirements 

At such times specified by the DES, Pinetree Bethlehem shall conduct USEPA method 

compliance stack tests for emissions at maximum production rate conditions and/or, at the 

request of the DES, at any other production rate at which maximum emissions might occur. 
Bo 

Page 13 

If a stack test is requested, the emissions stack test shall be conducted in accordance with 

40 CFR Part 60, Sections 60.8(a), (b), (d), (e), and (f), Appendix A and the DES' policy 

"Procedures and Minimum Requirements for Stack Tests". 

Compliance testing shall be planned and carried out in accordance with the following 

schedule. At least 30 days prior to the commencement of testing, Pinetree Bethlehem shall 

submit to the DES a pre-test report presenting the following information: 

a. Calibration methods and sample data sheets; 

b. Description of the test methods to be used; 

c. Pre-test preparation procedures; 

d. Sample collection and analysis methods; 

e. Process data to be collected; and 

f. Complete test program description. 

If requested by DES, at least 15 days prior to the test date, Pinetree Bethlehem, and any 

contractor that Pinetree Bethlehem retains for performance of the test, shall participate in a 

pre-test conference with a DES representative. Emission testing shall be carried out under 

the observation of a DES representative. Within 60 days after completion of testing, 

Pinetree Bethlehem shall submit a test report to the DES. 

Any compliance stack test results determined following 40 CFR Part 60 paragraph 60.8, 

which show violations of the emission limitations shall be considered violations of this 

permit. 

5. Stack Inspections 

In accordance with 40 CFR 70.6(a)(3), Pinetree Bethlehem shall conduct annual visual 

inspections of each stack and fuel burning device. Annual inspections shall include a 

thorough inspection of the condition of each stack exterior and each fuel burning device. 

Every 5 years, Pinetree Bethlehem shall inspect the interior of each stack.for evidence of 

corrosion, cracks, or holes. Records of inspections and subsequent maintenance conducted 

as a result of the annual inspections shall be kept on file at Pinetree Bethlehem for review 

by the DES and/or the EPA upon request. 

CEM Monitoring/Testing Requirements 

(Regulatory Cite Env-A 805.02 and 40 CFR Part 70.6(a)(3)) 

Pinetree Bethlehem shall instal1, maintain, and operate the following CEM systems in the EU1- 

Boiler exhaust piping. 

1. Opacity CEM 

The opacity CEM System shall meet the requirements of 40 CFR Part 60, Appendix B, 
Page 14 

Performance Specification 1, and Env-A 805. Determination of compliance with the 

opacity limits established in Section VIII.C. of this permit shall be made by the plant 

opacity CEM or visible emission readings taken once per shift following the procedures 

specified in 40 CFR Part 60, Appendix A, Method 9. Calculations shall be performed as 

specified in Section X.B.8. of this permit. 

NOx CEM 

The NOx CEM shall meet the requirements of 40 CFR Part 60, Appendix B, Performance 

Specification 2, and Env-A 805. Determination of compliance with the NO• emission 

limits established in Section VIII.C. of this permit shall be made by the plant NOx CEM. 

The NOx emission rate shall be calculated daily as the average of the calendar day averages 

as calculated on the plant NOx CEM. Calculations shall' be performed as specified in 

Section X.B.8. of this permit. 

CO CEM 

The CO CEM system shall meet the requirements of 40 CFR Part 60, Appendix B, 

Performance Specification 4, and Env-A 805. Determination of compliance with the CO 

emission limits established in Section VIII.C. of this permit shall be made by the plant CO 

CEM. The CO .emission rate shall be calculated daily as the average of the calendar day 

averages as Calculated on the plant CO CEM. Calculations shall be performed as specified 

in Section X.B.8. of this permit. 

Oxygen (02) CEM 

The 02 CEM system shall meet the requirements of 40 CFR Part 60, Appendix B, 

Performance Specification 3, and Env-A 805, 

Volumetric Flow CEM 

The stack volumetric flow measuring device which shall meet all of the requirements of 40 

CFR Part 60, Appendix B, Performance Specification 6. The stack flow monitor shall have 

an automatic blow-back purge system installed and activated during all times of boiler 

operation. The stack volumetric flow measuring device combined with the concentration 

CEM equipment for CO and NOx shall be used to calculate mass emission rates for 

comparison with the emission standard specified in permit condition VIII.C. The stack 

volumetric flow monitor shall also meet the following requirements: 

ao All differential pressure flow monitors shall have an automatic blow-back purge 

system installed and in wet stack emissions shall have the capability for drainage of 

the sensing lines. 

The stack flow monitoring system shall have the capability for on-line manual 

transducer calibration and for a zero check. 

The stack flow monitoring system shall be capable of displaying the individual 

parameters used in the stack flow calculation. For example, a differential pressure 

monitoring system shall be able to display instantaneous values of differential 

pressure, stack temperature, and relevant constants used in the calculation which 
Page 15 

reflect the static pressure assumed, gas molecular weight assumed, and the pitot 

tube coefficient utilized. 

Steam Flow Monitor 

Pinetree Bethlehem shall install, maintain, and operate a continuous steam flow rate 

monitoring/recording system which shall.meet all applicable ASME specifications. 

Calibration of the steam flow transducer shall occur at least once annually. If adequate 

straight length of piping is not available, then in lieu of a measuring system that meets 

ASME specifications, Pinetree Bethlehem may use a steam flow rate monitoring system 

that can be calibrated byinstruments installed, maintained, and calibrated per ASME 

specifications or by other methods approved by the DES. 

To meet the requirements of Section VIII.C.6. (c), the facility shall record the number of 

hours that the facility is operated in startup or shutdown modes, the total number of hours 

in operation, and the total number of hours that the facility is down for maintenance and 

repairs. This information shall be used to demonstrate that the number of hours that the 

EU1-Boiler operates in a startup or shutdown mode does not exceed 15% of the total 

operating hours of the plant. 

Calculations: 

a. CEM calendar day averages shall be calculated as follows: 

Calendar Day average (sum of all valid hourly averages for the calendar 

day)/(24 hours of CEM system downtime for the day); 

ii. Calendar day averages shall only be valid for days with 18 or more valid 

hours of CEM data; 

111. A valid hour of CEM data shall be defined as a minimum of 45 minutes 

collection of CEM readings taken in a calendar hour; and 

iv. Hours of CEM system downtime shall be defined as the number of calendar 

hours when the CEM system has not collected data or is out-of-control for 

greater than 15 minutes for any reason (i.e., audits, CEM system calibration, 

CEM system failures, etc.). 

b. CEM consecutive 365-day averages shall be calculated as follows: 

Consecutive 365-day average (sum ofall valid calendar day averages for 

the 365-day period)/(365 days of CEM system, downtime); and 

ii. Days of CEM system downtime shall be defined as the number of calendar 

days when the CEM system has collected less than 18 valid hours of CEM 

data. 
Page 16 

Co Hours or days when the CEM system has been intentionally shutdown when 

Pinetree Bethlehem is not operating shall not be counted as CEM system downtime. 

Pinetree Bethlehem shall be subject to all of the CEM requirements of Env-A 805 which 

shall include, but not be limited to: quarterly audit requirements, excess emission report 

requirements, quality control written procedure requirements for gaseous CEM monitors, 

and record keeping requirements. The specific record keeping and reporting requirements 

are described in Sections X.D. and X;E. of this permit. 

10. Pinetree Bethlehem shall continuously monitor and record data from the gaseous, 

volumetric flow, and steam flow CEM systems during all periods of operation, including 

periods of startup, shutdown, malfunctions, or emergency conditions, except when the 

stack flow is less than 26,718 DSCFM. The opacity CEM shall be continuously 

monitoring and recording data during all periods of operation, regardless of the stack flow 

rate. 

11. Excess emissions indicated by the CEM system shall be considered violations of the 

applicable emission limit for purposes of this permit, except where Pinetree Bethlehem can 

adequately demonstrate to the DES that the recorded exceedance resulted from a CEM 

malfunction. 

Compliance Demonstration Requirements for the EU2 Cooling Tower State Enforceable Only 

In accordance with Env-A 1400, prior to changing cooling water treatment chemicals, 

Pinetree Bethlehem shall evaluate the impact of the proposed chemicals on the 24-hour and 

annual de minimus limits of the DES Air Toxics List. If the impact exceeds the de 

minimus 24-hour or annual levels, Pinetree Bethlehem shall notify the DES in writing of 

the proposed chemical changes, and shall either perform modeling or request the DES to 

perform modeling of the proposed substance. Written approval from the DES shall be 

received prior to making the chemical change, if the de minimus levels are exceeded. If the 

impact does not exceed the de minimus levels, Pinetree Bethlehem may make the chemical 

change and shall keep the records of the impact analysis in the Pinetree Bethlehem files in 

accordance with the record keeping requirements of Section X.D. of this permit. 

The following equations shall be used to evaluate the impact of cooling water chemicals on 

the 24-hour and annual de minimus levels. These equations shall be used for each 

chemical used in the cooling water that is included on the DES Air Toxics List. Also, 

these equations shall be used to estimate particulate emissions from both chemical 

additives to the water and total dissolved solids contained in the water for emission-based 

fees as described in Section'XXV. of this permit. 

24-hour Emissions (lb/hr) (DR)*(Hourly CR)*(8.34 lb/gal)*(C) 

Example Calculation: 24-hour emissions of total dissolved solids (lb/hr) 

(0.0002 gal/gal)*(1,273,440 gal/hr)*(8.34 lb/gal)*(1200 ppmw TDS) 

lxl06 

2.55 lb/hr TDS 
Page 17 

Annualized Emissions (lb/yr) (24-hour Emissions, lb/hr)*(Operating hours/year) 

Example Calculation: Annualized emissions ofTDS (lb/yr) (2.55 lb/hr)*(8760 hrs/yr) 

(2000 lb/ton) 

11.2 tons/yr TDS 

Where:DR drift rate for cooling tower (based on manufacturer's data for Pinetree 

Bethlehem cooling tower), 

gal drift/gal circulation water (0.0002 gal/gal) 

Hourly. CR water circulation rate, gal/hr 

C concentration of chemical of interest (or total dissolved solids 

concentration) in circulation water, ppmw (use maximum potential 

concentration for de minimusimpact evaluation and average or actual 

data for emission-based fee calculations). 

Record keeping Requirements 

In accordance with 40 CFR Part 70.6(a)(3)(ii)(B), Pinetree Bethlehem shall retain records 

of all required monitoring data, record keeping and reporting requirements, and support 

information for a period of at least 5 years from the date of the origination. These data and 

reports shall not be discarded, removed, or destroyed thereafter without the express written 

approval of the director in accordance with Env-A 901.11. 

In accordance with 40 CFR 70.6(c)(5), Pinetree Bethlehem shall meet the requirements for 

compliance certification with terms and conditions contained in this permit, including 

emission limitations, standards, or work practices. Compliance certifications shall meet 

the requirements outlined in Section XXIII. of this permit. 

Pursuant to Env-A 901.03, for each fuel buming device at Pinetree Bethlehem, the owner 

or operator shall keep records on fuel utilization in accordance with the following: 

Monthly records of all fuel utilization for each fuel burning device at Pinetree 

Bethlehem shall include: 

Consumption of each fuel type per calendar month and a consecutive 12- 

month total; 

ii. Fuel type; 

iii. Viscosity; 

iv. Sulfur content as percent sulfur by weight of fuel; and 

v. BTU content per gallon offuel. 

Delivery tickets from each fuel oil suppliei for each shipment of fuel oil and/or 

diesel fuel received shall be kept on file in a form suitable for inspection and shall 

be made available to the DES and/or the EPA upon request. Each delivery ticket 
Page 18 

shall indicate the name, address, and telephone number of the fuel supplier, the 

quantity of fuel delivered, and the percent sulfur by weight of the fuel being 

delivered. If delivery tickets do not contain sulfur content of fuel being delivered, 

Pinetree Bethlehem shall perform testing in accordance with appropriate ASTM test 

methods to determine compliance with the sulfur content limitation provisions in 

Env-A 1604.01(a) for liquid fuels. 

c. As specified in Env-A 809.02, the operator shall (upon written request by the DES) 

conduct testing in accordance with appropriate ASTM test methods to determine 

compliance with the sulfur content limitation provisions in Env-A 1605.01 for 

gaseous fuels. If requested, such information shall be submitted to DES. 

d. Records shall be kept of hours of operation corresponding to the utilization and 

distribution of all fuels. 

NOx Record keeping Requirements 

In accordance with Env-A 901.08, for each fuel burning device, including boilers, turbines, 

and internal combustion engines, the following information shall be recorded and 

maintained: 

Pinetree Bethlehem information, including: 

i. Source name; 

ii. Source identification; 

iii. Physical address; 

iv. Mailing address; 

v. Date of origination for reports; 

vi. Pinetree Bethlehem contact and title; 

vii. Pinetree Bethlehem telephone number; 

Identification of each fuel burning device at Pinetree Bethlehem. 

Operating schedule information for each identified fuel burning device, including: 

i. Days per calendar week during the normal operating schedule; 

ii. Hours per day during the normal operating schedule and for a typical ozone 

season day, if different from the normal operating schedule; and 

iii. Hours per year during the normal operating schedule. 

Type and amount of fuel burned, for each fuel burning device, during normal 

ao 

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Page 19 

eo 

operating conditions and for a typical ozone season day 4, if different from normal 

operating conditions, on an hourly basis in mmBTU/hr. 

The following NOx emission data, including records of total annual emissions, in 

tons per year (tpy), and typical ozone season day emissions, in pounds per day 

(lb/day), shall be maintained at Pinetree Bethlehem for a minimt/m of 4 years: 

Theoretical potential emissions for the calculation year for each fuel burning 

device; and 

ii. Actual NOx emissions for each fuel burning device. 

E. Reporting Requirements 

In accordance with Env-A 901.09(b), NOx emission data for all Pinetree Bethlehem fuel 

burning devices shall be reported to the DES annually by April 15 of the following year. 

The NOx emissions for the EU1-Boiler shall be collected from the applicable CEM data. 

The NOx emissions for EU3-EG shall be based on NOx record keeping requirements and 

calculations using EPA-published emission factors. 

2. Permit Deviations 

Prompt reporting of all deviations from Permit requirements including those 

attributed to upset conditions as defined in the permit, the probable cause of 

such deviations, and any corrective actions or preventative measures taken 

shall be conducted in accordance with Section XXX of this Permit. 

3. Fuel Usage Reporting 

In accordance with Env-A 901.03, monthly fuel usage information, by device, fuel type, 

and sulfur content shall be submitted in writing to the DES on a quarterly basis within 30 

days after the end of the quarter for which reporting is required. 

4. Excess Emission Reporting 

In accordance with Env-A 805, within 30 days following the close of each calendar quarter, 

Pinetree Bethlehem shall submit to the DES excess emission reports for the CEM systems 

and the EU1 Boiler as approved by the DES containing information specified in Env-A 

805, as well as the following information: 

a° Calendar daily averages of NOx and CO lb/hr and part per million (ppm) dry, 

whether or not an excess emission has occurred; 

4 Typical ozone season day is defined as any day between April and October 31. 
Page 20 

b. Calendar daily averages of percentage oxygen (02) on a dry basis; 

c. Calendar daily averages of steam generation rate; 

d. Calendar daily averages of stack flow (dscfm); 

eo Average steam production rate for each consecutive 24-hour period where the 

production rate exceeds any of the limits set forth in Section VIII.C. of this permit; 

f. CEM system availability data; 

Estimated amount in tons (wet basis) of wood chip consumption per month and a 

consecutive twelve month total; 

Amount in gallons of fuel consumption per calendar month where the fuel usage 

cap set forth in Section VIII.C. 1. of this permit has been exceeded; and 

All periods of gaseous, opacity, and steam flow rate exceedances including start 

time, end time, and magnitude and cause of the exceedance. This shall include 

exceedances of the consecutive 24-hour average limits for NOx and CO, as 

measured by the CEM systems. 

5. CEM Audit Reporting 

Within 30 days following the close of each calendar quarter, Pinetree Bethlehem shall 

submit to the DES a CEM audit report for all audits conducted as specified in Env-A 

805.06 (rule effective 11/15/92) and Section X.B. of this permit. 

In accordance with 40 CFR 70.6(a)(3)(iii)(A), a summary report of monitoring and testing 

requirements shall be submitted every six months. Semi-annual reports shall be submitted 

no later than July 31 for the January through June report and no later than January 31 for 

the July through December report. All instances of deviations from permit requirements 

shall be clearly identified in such reports. All required reports shall be certified for 

accuracy by a responsible official consistent with 40 CFR 70.5(d). This certification and 

any other certification required under this part shall include the 

certification of accuracy statement included in Section XXIII.B. of this permit.. 

The report shall contain a summary of the following information: 

a. Monitoring and preventive maintenance results for control devices PC1 and PC2. 

Preventive maintenance and inspection results for EU1-Boiler, EU3-EG, and 

related stacks. 

c. All instances of deviations from permit requirements shall be clearly identified. 

7. Annual reporting and payment of emission based fees shall be conducted in accordance 
Page 21 

with Section XXV. of this Permit. 

An annual compliance certification as presented in Section XXIII. of this Permit shall be 

submitted to the DES and the USEPA by April 15 following each reporting year. 

Pursuant to40 CFR Part 70.6 (c)(1), all documents submitted to the DES and/or the EPA 

shall contain certification by the responsible official of truth, accuracy, and completeness as described in Section XXIII.B. of this permit. 

XI. Requirements Currently Not Applicable: 

Pinetree Bethlehem did not request that any non-applicable requirements be specifically listed in this 

permit. 

General Title V Operating Permit Conditions 

XII. Issuance of a Title V Operating Permit: 

This Permit is issued in accordance with the provisions of Part Env-A 609. In accordance with 40 

CFR 70.6(a)(2) this Permit shall expire on the date specified on the cover page of this Permit, 

which shall not be later than the date five (5) years after issuance of this Permit. 

Permit expiration terminates the Permittee's right to operate the Permittee's emission units, control 

equipment or associated equipment covered by this permit, unless a timely and complete renewal 

application is submitted at least 6 months before the expiration date. 

Pursuant to Env-A 609.02(b), this Permit shall be a state permit to operate as defined in RSA 125- 

C: 11, III. 

XIII. Title V Operating Permit Renewal Procedures: 

Pursuant to Env-A 609.06(b), an application for renewal of this Permit shall be considered timely if it is 

submitted to the Director at least six months prior to the designated expiration date of this Permit. 

XIV. Application Shield: 

Pursuant to Env-A 609.07, if an applicant submits a timely and complete application for the issuance or 

renewal of a Permit, the failure to have a Permit shall not be considered a violation of this part until the 

Director takes final action on the application. 

XV. Permit Shield: 

A. Pursuant to Env-A 609.08(a), a permit shield shall provide that: 

For any applicable requirement or any state requirement found in the New Hampshire 

Rules Governing the Control of Air Pollution specifically included in this Permit, 

compliance with the conditions of this Permit shall be deemed in compliance with said 

applicable requirement or said state requirement as of the date of permit issuance; and 
Page 22 

Bo 

Co 

Do 

Eo 

For any potential applicable requirement or any potential state requirement found in the 

New Hampshire Rules Governing the Control of Air Pollution specifically identified in this 

Title V Operating Permit as not applicable to the stationary source or area source, the 

Permittee need not comply with the specifically identified federal or state requirements. 

The permit shield identified in Section XV.A. of this Permit shall apply only to those conditions 

incorporated into this Permit in accordance with the provisions of Env-A 609.08(b). It shall not 

apply to certain conditions as specified in Env-A 609.08(c) that may be incorporated into this 

Permit following permit issuance by the DES. 

Ifa Title V Operating Permit and amendments thereto issued by the DES does not expressly 

include or exclude an applicable requirement or a state requirement found in the NH Rules 

Governing the Control of Air Pollution, that applicable requirement or state requirement shall not 

be covered by the permit shield and the Permittee shall comply with the provisions of said 

requirement to the extent that it applies to the Permittee. 

If the DES determines that this Title V Operating Permit was issuedbased upon inaccurate or 

incomplete information provided by the applicant or Permittee, any permit shield provisions in 

said Title V Operating Permit shall be void as to the portions of said Title V Operating Permit 

which are affected, directly or indirectly, by the inaccurate or incomplete information. 

Pursuant to Env-A 609.08(f), nothing contained in Section XVI. of this Permit shall alter or affect 

the ability of the DES to reopen this Permit for cause in accordance with Env-A 609.18, or to 

exercise its summary abatement authority. 

Pursuant to Env-A 609.08(g), nothing contained in this section or in any Title V operating permit 

issued by the DES shall alter or affect the following: 

The ability of the DES to order abatement requiring immediate compliance with applicable 

requirements upon finding that there is an imminent and substantial endangerment to 

public health, welfare, or the environment; 

The state of New Hampshire's ability to bring an enforcement action pursuant to RSA 125- 

C: 15,II; 

The'provisions of Section 303 of the Act regarding emergency orders including the 

authority of the EPA Administrator under that section; 

The liability of an owner or operator of a source forany violation of applicable 

requirements prior to or at the time of permit issuance; 

The applicable requirements of the acid rain program, consistent with Section 408(a) of the 

Act; 

The ability of the DES or the EPA Administrator to obtain information about a stationary 

source, area source, or device from the owner or operator pursuant to Section 114 of the 

Act; or 

7. The ability of the DES or the EPA Administrator to enter, inspect, and/or monitor a 
Page 23 

stationary source, area source, or device. 

Reopening for Cause: 

The Director shall reopen and revise a Title V Operating Permit for cause if any of the circumstances 

contained in Eriv-A 609.18(a) exist. In all proceedings to reopen and reissue a Title V Operating Permit, 

the Director shall follow the provisions specified in Env-A 609.18(b) through (g). 

XVII. Administrative Permit Amendments: 

Pursuant to Env-A 6.12.01, the Permittee may implement the changes addressed in the request for 

an administrative permit amendment as defined in Part Env-A 100 immediately upon submittal of 

the request. 

Bo Pursuant to Env-A612.01, the Director shall take final action on a request for an administrative 

permit amendment in accordance with the provisions of Env-A 612.01 (b) and (c). 

XVIII. Operational Flexibility: 

Pursuant to Env-A 612.02(a), the Penriittee subject to and operating under this Title V Operating 

Permit may make changes involving trading of emissions under this existing Title V Operating 

Permit at the permitted stationary source or area source without filing a Title V Operating Permit 

application for and obtaining an amended Title V Operating Permit, provided that all the 

conditions are met as specified in Section XVIII.A. 1. through 7. of this permit and a notice is 

submitted to the DES and the EPA describing the intended changes. The DES has not included 

any permit terms authorizing intra- or inter-facility emissions trading in this permit. 

1. The change is not a modification under any provision of Title I of the Act; 

The change does not cause emissions to exceed the emissions allowable under the Title V 

operating permit, whether expressed therein as a rate of emissions or in terms of total 

emissions; 

3. The owner or operator has obtained any temporary permit required by Env-A 600; 

The owner or operator has provided written notification to the director and administrator at 

least 15 days prior to the proposed change and such written notification includes: 

a. The date on which each proposed change will occur; 

b. A description of each such change; 

Any change in emissions that will result and how this change in emissions will 

comply with the terms and conditions of the permit; 

d. A written request that the operational flexibility procedures be used; and 

e. The signature of the responsible official, consistent with Env-A 605.04(b); 
Page 24 

Bo 

The Title V operating permit issued to the stationary source or area source already contains 

terms and conditions including all terms and conditions which determine compliance 

required under 40 CFR 70.6(a) and (c) and which allow for the trading of emissions 

increases and decreases at the permitted stationary source or area source solely for the 

purpose of completing with a federally-enforceable emissions cap that is established in the 

permit independent of otherwise applicable requirements; 

The owner or operator has included in the application for the Title V operating permit 

proposed replicable procedures and proposed permit terms which ensure that the emissions 

trades are quantifiable and federally enforceable for changes to the Title V operating permit 

which qualify under a federally-enforceable emissions cap that is established in the Title V 

operating permit independent of the otherwise applicable requirements; and 

7. The proposed change complies with Env-A 612.02(e). 

Pursuant to Env-A 612.02(c), the Permittee subject to and operating under this Title V Operating 

Permit may make changes not addressed or prohibited by this existing Title V Operating Permit at 

the permitted stationary source or area source without filing a Title V Operating Permit 

application, provided that all the conditions specified in Env-A 612.02(c)(1) through (6) are met 

and a notice is submitted to the DES and the EPA describing the intended changes. 

Pursuant to Env-A 612.02(d), the Permittee, Operator, Director, and Administrator shall attach 

each notice of an off-permit change completed in accordance with Section XVIII.B. of this Title V 

Operating Permit to their copy of the current Title V Operating Permit. 

Pursuant to Env-A 612.02(e), any change under Section XVIII. shall not exceed any emissions 

limitations established under the New Hampshire Rules Goverriing the Control of Air Pollution, or 

resUlt in an increase in emissions, or result in new emissions, Of any toxic air pollutant or 

hazardous air pollutant other than those listed in the existing Permit. 

Pursuant to Env-A 612.02(f), the off-permit change shall not qualify for.the permit shield under 

Env-A 609.08. 

Minor Permit Amendments: 

Do 

Pursuant to Env-A 612.04 prior to implementing a minor permit modification, the Permittee shall 

submit a written request to the Director in accordance with the requirements of Env-A 612.04(b). 

The Director shall take final action on the minor permit amendment request in accordance with the 

provisions of Env-A 612.04(c) through (g). 

Pursuant to Env-A 612.04(g), the permit shield specified in Env-A 609.08 shall not apply to minor 

permit amendments under Section XIX. of this Permit. 

Pursuant to Env-A 612.04(i), the Permittee shall be subject to the provisions of Part Env-A 614 

and Part Env-A 615 if the change is made prior.to the filing with the Director a request for a minor 

permit amendment. 
Page 25 

XX. Significant Permit Amendments: 

Ao Pursuant to Env-A 612.05, a change at the facility shall qualify as a significant permit amendment 

if it meets the criteria specified in Env-A 612.05(a)(1) through (7). 

Bo Prior to implementing the significant permit amendment, the Permittee shall submit a written 

request to the Director and to the EPA which includes all the information as referenced in Env-A 

612.05(b) and (c), and shall be issued an amended Title V Operating Permit from the DES. The 

Permit-tee shall be subject to the provisions of Env-A 614 and Env-A 615 ifa request for a 

significant permit amendment is not filed with the Director and/or the change is made prior to the 

issuance of an amended Title V Operating Permit. 

Co The Director shall take final action on the significant permit amendment in accordance with the 

procedures specified in Env-A 612.05(d), (e), and (f). 

XXI. Title V Operating Permit Suspension• Revocation• or Nullification: 

Pursuant to RSA 125-C: 13, the Director may suspend or revoke any final permit issued hereunder 

if, following a hearing, the Director determines that: 

The Permittee has committed a violation of any applicable statute or state requirement 

found in the New Hampshire Rules Governing the Control of Air Pollution, order, or 

permit condition in force and applicable to it; or 

That the emissions from any device to which this Permit applies, alone or in conjunction 

with other sources of the same pollutants, present an immediate danger to the public health. 

The Director shall nullify any Permit, if following a hearing in accordance with RSA 541-A:30, II, 

a finding is made that the Permit was issued in whole or in part based upon any information 

proven to be intentionally false or misleading. 

XXII. Inspection and Entry: 

Pursuant to Env-A 614.01, EPA and DES personnel shall be granted access to the facility covered by this 

Permit, in accordance with RSA 125-C:6, VII for the purposes of: inspecting the proposed or permitted 

site; investigating a complaint; and assuring compliance with any applicable requirement or state 

requirement found in the New Hampshire Rules Governing the Control of Air Pollution and/or conditions 

of any Permit issued pursuant to Chapter Env-A 600. 

XXIII. Certifications: 

A. Compliance Certification Report 

In accordance with 40 CFR 70.6(c) the Responsible Official shall certify, annually from the date of 

issuance, that the facility is in compliance with the requirements of this permit. The report shall be 

submitted tothe DES and to the Regional Administrator, U.S. Environmental Protection Agency 

New England Region. The report shall be submitted in compliance with the submission 

requirements below. 
Page 26 

In accordance with 40 CFR 70.6(c)(5)(B), the report shall describe: 

1. The terms and conditions of the Permit that are the basis of the certification; 

The current compliance status of the source with respect to the terms and conditions of this 

Permit, and whether the method was continuous or intermittent during the reporting 

period; 

The methods used for determining compliance, including a description of the monitoring, 

record keeping and reporting requirements, and test methods; and 

Any additional information required by the DES to determine the compliance status of the 

source. 

Certification of Accuracy Statement 

All documents submitted to the DES shall contain a certification of accuracy statement by the 

responsible official of truth, accuracy, and completeness. Such certification shall be in accordance 

with the requirements of 40 CFR 70.5(d) and contain the following language: 

"I am authorized to make this submission on behalf of the facility for which 

the submission is made. Based on information and belief formed after 

reasonable inquiry, I certify that the statements and information in the 

enclosed documents are to the best of my knowledge and belief true, 

accurate and complete, I am aware that there are significant penalties for 

submitting false statements and information or. omitting required statements 

and information, including the possibility of fine or imprisonment." 

All reports submitted to the DES (except those submitted as emission based fees as outlined in 

Section XXV. of this permit) shall be submitted to the following address: 

New Hampshire Department of Environmental Services 

Air Resources Division 

64 North Main Street 

P.O. Box 2033 

Concord, NH 03302-2033 

Attn: Compliance Bureau 

XXlV. Enforcement: 

Any noncompliance with a permit condition constitutes a violation of RSA 125-C: 15, and, as to the 

conditions in this permit which are federally enforceable, a violation of the Clean Air Act, 42 U.S.C. 

Section 7401 et seq., and is grounds for enforcement action, for permit termination or revocation, or for 

denial of an operating permit renewal application by the DES and/or EPA. Noncompliance may also be 

grounds for assessment of administrative, civil, or criminal penalties in accordance with RSA 125-C: 15 

and/or the Clean Air Act. This Permit does not relieve the Permittee from the obligation to comply with 

any other provisions of RSA 125-C, the New Hampshire Rules Goveming the Control of Air Pollution, or 
Page 27 

the Clean Air Act, or to obtain any other necessary authorizations from other governmental agencies, or to 

comply with all other applicable Federal, State, or Local rules and regulations not addressed in this 

Permit. 

In accordance with 40 CFR 70.6 (a)(6)(ii) a Permittee shall not claim as a defense in an enforcement 

action that it would have been necessary to halt or reduce the permitted activity in order to maintain 

compliance with the conditions of this Permit. 

XXV. Emission-Based Fee Requirements: 

The Permittee shall pay an emission-based fee annually for this facility as calculated each calendar 

year pursuant to Env-A 704.03, 

The Permit-tee shall determine the .total actual annual emissions from the facility to be included in 

the emission-based multiplier specified in Env-A 704.03(a) for each calendar year in accordance 

with the methods specified in Env-A 620. 

Co The Permittee shall calculate the annual emission-based fee for each calendar year in accordance 

with the procedures specified in Env-A 704.03 and the following equation: 

FEE E * DPT * CPIm * ISF 

FEE The annual emission-based fee for each calendar year as specified in Env-A 704. 

E The emission-based multiplier is based on the calculation of total annual emissions 

as specified in Env-A 704.02 and the provisions specified in Env-A 704.03(a). 

DPT The dollar per ton fee the DES has specified in Env-A 704.03(b). 

CPIm--The Consumer Price Index Multiplier as calculated in Env-A 704.03(c). 

ISF The Inventory Stabilization Factor as specified in Env-A 704.03(d). 

The Permittee shall contact the DES each calendar year for the value of the Inventory Stabilization 

Factor. 

The Permittee shall contact the DES each calendar year for the value of the Consumer Price Index 

Multiplier. 

The Permittee shall submit, to the DES, payment of the emission-based fee and a summary of the 

calculations referenced in Sections XXV.B. and C. of this Permit for each calendar year by 

October 15 th of the following calendar year in accordance with Env-A 704.04. 

The emission-based fee and summary of the calculations shall be submitted to the following 

address: 

New Hampshire Department of Environmental Services 
Page 28 

Air Resources Division 

64 North Main Street 

P.O. Box 2033 

Concord, NH 03302-2033 

ATTN: Emissions Inventory 

Gt The DES shall notify the Permittee of any under payments or over payments of the annual 

emission-based fee in accordance with Env-A 704.05. 

XXVI. Duty To Provide Information: 

In accordance with 40 CFR 70.6 (a)(6)(v), upon the DES's written request, the Permittee shall furnish, 

within a reasonable time, any information necessary for determining whether cause exists for modifying, revoking and reissuing, or terminating the Permit, or to determine compliance with the Permit. Upon 

request, the Permittee shall furnish to the DES copies of records that the Permittee is required to retain 

by this Permit. The Permittee may make a claim of confidentiality as to any information submitted 

pursuant to this condition in accordance with Part Env-A 103 at the time such information is submitted to 

DES. The DES shall evaluate such requests in accordance with the provisions of Part Env-A 103. 

XXVII. Property Rights: 

Pursuant to 40 CFR 70.6 (a)(6)(iv), this Permit does not convey any property rights of any sort, or any 

exclusive privilege. 

XXVIII. Severability Clause: 

Pursuant to 40 CFR 70.6 (a)(5), the provisions of this Permit are severable, and if any provision of this 

Permit, or the application of any provision of this Permit to any circumstances is held invalid, the 

application of such provision to other circumstances, and the remainder of this Permit, shall not be 

affected thereby. 

XXIX. Emergency Conditions: 

Pursuant to 40 CFR 70.6 (g), the Permittee shall be shielded from enforcement action brought for 

noncompliance with technology based s emission limitations specified in this Permit as a result of an 

emergency •. In order touse emergency as an affirmative defense to an action brought for noncompliance, 

the Permittee shall demonstrate the affirmative defense through properly signed, contemporaneous 

operating logs, or other relevant evidence that: 

Technology based emission limits are those established on the basis of emission reductions achievable with various 

control measures or process changes (e.g., a new source performance standard) rather than.those established to attain 

health based air quality standards. 

An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of 

the source, including acts of God, which situation would require immediate corrective action to restore normal operation, 

and that causes the source to exceed a technology based limitation under the permit, due to unavoidable increases in 

emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by 

improperly designed equipment, lack of preventive maintenance, careless or improper operations, operator error, or 

decision to keep operating despite knowledge of any of these things. 
Page 29 

A. An emergency occurred and that the Permittee can identify the cause(s) of the emergency; 

B. The permitted facility was at the time being properly operated; 

Co During the period of the emergency, the Permittee took all reasonable steps as expeditiously as 

possible, to minimize levels of emissions that exceeded the emissions standards, or other 

requirements in this Permit; and 

The Permittee submitted notice of the emergency to the DES within two (2) business days of the 

time when emission limitations were exceeded due to the emergency. This notice must contain a 

description of the emergency, any steps taken to mitigate emission, and corrective actions taken. 

XXX. Permit Deviations: 

In accordance with 40 CFR 70.6(a)(3)(iii)(B), the Permittee shall 

report to the DES all instances of deviations from Permit 

requirements, by telephone, fax or e-mail 

(pdeviations @ des.state.nh.us), within 24 hours of discovery of such 

deviation. This report shall include the deviation itself, including those attributable to upset conditions as defined in the Permit, the 

probable cause of such deviations, and any corrective actions or 

preventative measures taken. Within 15 days of discovery of the 

permit deviation, the Permittee shall submit a written report including th6 above information as well as the following: preventive measures taken to prevent future occurrences; date and 

time the permitted device returned to normal operation; specific device, process or air pollution control equipment that contributed to 

the permit deviation; type and quantity of excess emissions emitted 

to the atmosphere due to permit deviation; and an explanation of the 

calculation or estimation used to quantify excess emissions. Said 

Permit deviation shall also be submitted in writing to the DES in the 

semi-annual report of monitoring and testing requirements due July 

3 ls' and January 31st of each calendar year. Deviations are instances 

where any Permit condition is violated and has not already been 

reported as an emergency pursuant to Section XXVII of this. Permit. 

Reporting a Permit deviationis not an affirmative defense for action brought for noncompliance. 

H:•3ARU•PINETR~I \SIGNIF~I \SIGMOD.FNL 

Signifaent Modification dated -September 7, 2001