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

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 HemphillhaSbeen 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 DivisionDirector, 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 2222

XV. Permit Shield XVI. Reopening for Cause XVII,XVIII. Administrative Permit Amendments Operational Flexibility 22-23242424-25 XIX. Minor Permit Amendments 25-26 XX. Significant Permit Amendments 26 XXI. Title V Operating Permit Suspension, Revocation or Nullification 26 Inspection and Entry 26XXIII.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 27-282828-2929292929-3030Page 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 aDetroit

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. h:•pe•mits\current\titlev•amendments\tvhemph2.amd Revised4/IIIL

Bo Page 5 Si nificant Activities Identification and Stack Criteria continued 2. Based on facility operations, fuel fed to the EU1 Boiler shall consist of any of the following:Whole tree wood chips, mill residue and bark at approximately 55% moisture (approximately 7.65 mmBTU/ton). Clean processed wood fuel (approximately 7.65 mmBTU/ton to 13.5 mmBTU/ton). 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/natural gas at maximum 15 grains sulfur per 100 cubic feet. P.ropane/natural gas proposed for 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 wood fuel as specified in Section III.2.a-fat approximately 55% moisture (7.65 mmBTU/ton) consecutive twelve month period, during any 4. The emission units EU2-EG and EU3-Chipper shall be operated using diesel fuel. Operation of the EU2-EG shall be limited to 500 hours per calendar year. The operation of the EU3- Chipper shall be'limited to 8,760 hours during any consecutive 12-month period and shall not use more 274,200 gallons of diesel fuel during any consecutive 12-month period. 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 folio.wing criteria in accordance with the state-only air pollution dispersion modeling 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.

Revised4113/00III. 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 PartEnvA 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

h:•p ermits\eurrent\litlcv\amend s\tvhempl•2,amd Revised4/I 3/00Page 7 Operating Permit. 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 Electrostatic Precipitator (ESP) secondary particulate control for the EUI Boiler EU1 -Boiler

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. 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: Hemphill requested the alternative operating scenario of burning used oil in their Title V application. Hemphill proposed to burn up to 1,000 gallons of on-site generated specification used oil in

the EU 1-Boiler as an auxiliary fuel. The specification 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

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 mixed with approximately 20. tons (full truck load) of sawdust. Hemphill shall not use more than 1,000 gallons of specification used oil during any consecutive 365-day period. Hemphill shall only burn specification used oil generated at

the Hemphill thcilitv in the EU1-Boiler. Hemphill shall store and handle the specification used oil in accordance with all applicable state and federal regulations. Hemphill 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 •hcility in accordance with record keeping requirements described in Section X.C. of this permit. If

the facility-generated used oil is

transferred off-site for recycling or disposal, Hemphill shall comply with applicable DES rules regarding the storage/handling/transfer of used oil. h:•ermils•eurrent\till•v•amcndrnenls\tv•emph2.amd Revised4/] 3/00Page 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 Revised4113100VIII. 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 years from May 8, 1998 (May 8, 2001), shall comply with Env-A 1400. Env-A 1300 will no longer be in effect. 7. 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. 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 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 model/ng. Pursuant.to Waste Management Rules Env-Wm 807.02, specification used oil generated and burned at the facility shall m•et the criteria for specification used oil as described below. A. The oil shall not be mixed with hazardous waste; and B. 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.

ArsenicCadmiumChromium LeadPCBsTotal 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 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. 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 3/00Co 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 Revised4/l 3/00VIIL 60 minute period; or Page 11
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 fbr one period of 6

continuous minutes in any 60 minute period. A licable O erational and Emission Limitations continued 6. /n accordance with 40 CFR Part 522, the sulfur content of propane/natural gas shall not exceed 5

grains of sulfur per 100 cubic feet. 7. To avoid the requirements of the federal Prevention of Significant Deterioration (PSD) regulation 40 CFR 52.21(b)(1)(i)(b), the combined NO• emission rate for the facility fuel burning devices, including the EU1-Boiler, EU2-EG and the EU3-Chipper 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 NOx CEM data and estimated emission data,To avoid the requirements of the federal PSD regulation 40 CFR 52.21(b)(1)(i)(b), the combined carbon monoxide ((•O) emission rate for the facility fuel burning devices, including the EU1-Boiler, EU2-EG and the EU3-Chipper shall be limited to 57.0 lbs/hr average .for any consecutive 365-day period. In accordance with RSA 125-C:6, RSA 125-C: 11 and Env-A 606.04, the combined carbon monoxid• (CO) emission rate for the facility fuel burning devices, including the EU1-Boiler, EU2-EG and the EU3-Chipper shall be limited to •.5 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. 10.
11. In accordance with 40 CFR Part 60, Subpart Db, the PM emission rate for the EU1 Boiler shall be limited to 0.10 lb/rnmBTU heat input. Continuous Emission Monitoring (CEM) requirements are described in Section X.B. of

this permit. IX. .Emission Reductions Trading Requirements The Permittee did not request emissions reductions trading in the facility ooeratin• the time of this permit 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'A3000Reductions(the"EmissionS(orr•D•Reducti°ns Credits (or ERCs)aUth°rizedTradingunderprogram,,)theapplicableorEnv-A-3requirements100(t he "Discrete°feither" •,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. h:•P vrmi•s\current\titlev•am¢ naments\lvheraph2,amd Revised4/l 3/00Xo 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
h:•permits\¢u•ent\titlev•amendments\tvhemph2,amd Revised4/13/00Page 13 this equipment, on a

bi-hourly basis, facility personnel shall: i. Check the primary voltage reading on the PC2 ESP. The primary voltage shall be maintained between 25 and 250 volts. Voltage readings outside this range indicate a

malfunction with the PC2- ESP and the operator shall correct the malfunction immediately. _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 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, Hemphill personnel shall 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 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. Ifthis results in

a

permit limit exceedance, Hemphill personnel shall contact DES within 8

hours in accordance with Section XXX of this permit. 3. Stack Testing Requirements At such times as specified by the DES, Hemphill 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 maxmaum 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 h:•pcnnils\currcnl\lillevxamendments•tvhemph2.amd Revised4/I 3/00Page 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 Revised4/13/00Page 15 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.
.Compliance Demonstration Requirements (continued), 2. 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 NOx 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.6. of this permit. 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 inaVerageSsectionaSX.B.6.calculatedofthis°npermit.theplant CO CEM. Calculations shall be performed as specified 4. Carbon Dioxide (CO2) CEM The CO2 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 stacl• 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: 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 h:•pennits\eu•renl\lillev•a nls\lvhcmph2.a md Revised4/l 3/00Xo Page 16 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,

h:•p ermils\cu•xent\litlov•amendm s\tvhcmplt2, Revised4/l 3/00Page 17 quality control written procedure requirements for gaseous CEM monitors and record keepingrequirements. The specific record keeping and reporting requirements are described in Section X.C. and X.D. of this permit. Hemphill shall continuously monitor and record data from the gaseous CEM system during all periods of operation, including periods ofstartup, 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 flow rate. 9. Excess emissions indicated by the CEM system shall be considered violations of the .Compliance Demonstration Requirements (continued): applicable emission limit for purposes of this permit, except where Hemphill can adequately demonstrate to the DES that the recorded exceedance resulted from a

CEM malfunction. 10. Hemphill 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, Hemphill may use a

steam flow rate monitoring 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 In accordance with 40 CFR Part 70.6(a)(3)(ii)(B), Hemphill 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), Hemphill 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:

a. 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; h:•permits\current\litlcv•mendmonts•tvhemph2.amd Revised4/[3/00Xo Page 18 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 performtesting 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;

h:•permits\current•tillev•mendtnenls\tvhempl•2.amd Rovised4/13/00bo Page 19 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 ozone season day 3,

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 4

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

D° 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. 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. Fuel Usage Reporting In accordance with Env-A 901.08(c), monthly fuel usage information, by device, fuel type, and sulfur content of liquid 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, h:•pcrmits\current\tillev•mendlllen(s•tvhemph2.atnd Revised4/13/00Page 20 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
h:•ermits\eurrent\litlev•amendments\tvhemph2.amd Revised4/l 3/009• Page 21 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 PC1 through PC2. b. Preventive maintenance and inspection results for EU1-Boiler and related stacks, EU2-EG and EU3-Chipper.

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)(l), 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.

hAponnits•currerit\litlev•amendmenls\lvhemph2.amd Revised4/l 3/00Page 22 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 3/00Page 23 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 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 Permit-tee 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(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. 8

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

h:•P ennils\currenl\title dmenls\lvhemph2.amd Revised4/13/00Page 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: 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 h:•pennils\cu•rent\titlev\amendments\tvhemph2.amd Revised4/13/00Page 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 mak• changes not addressed or prohibited by this existing Title V Operating Permit at the permitted stationary 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 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 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 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. .,Minor Permit Amendments. A. 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). 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). C. Pursuant to Env-A 612.04(g), the permit shield specified in Env-A 609.08 shall not apply to minor

Revised4113100Page 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.

h:•pennits\eurrent\titlev\amendments\tvhemph2.amdPage 27
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 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: 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 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 h:•ermits\eurrent\titlcv•amendmenls\tvhemph2.amd Revised4/13100Page 28 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. h:•permils\current\lillev•amendments\tvhemph2.amd Revised4/I 3/00Do Page 29 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 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 to 40 CFR 70.6 (a)(6)(iv), this Permit does not convey any property rights of any sort, or any exclusive privilege. 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. h:kperm 0s\eurrent\lillev•mendmcnts\ivhemph2.amd Revised4/13/00Page 30
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 3/00STATE OF NEW HAMPSHIRE Department of Environmental Services Air Resources DivisionTitle V Operating Permit Permit No: TV-OP-007 Date Issued: January 11, 1999, Amended November 15, 1999, April 12, 2000, June 26, 2001, & November 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 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 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: Douglas York Operations Manager (603) 837-9328 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 January 31, 2004. .SEE ATTACHED SHEETS FOR ADDITIONAL PERMIT CONDITIONS For the New Hampshire Department of Environmental Services, Air Resource DivisionDirector, 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 44-66

6-77-88-111111-20

21

21212121-2223 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 2525 Inspection and Entry Certifications 26-27Page 3

XXIV.XXV.XXVI.XXVII. Enforcement Emission Based Fee Requirements Duty to Provide Information Property Rights XXVIII,. • Clause
XXX. 2 Permit Malfunctions and Deviations 2727-282828Page 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 withDetroit Stoker Propane/Natural Gas Burner (Model DB-21-SS-0 l-G) CumminsEmergency Diesel Generator Stack #1

Stack #2 EU2 EG 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 Revised4/12/00Page 5 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 1458.5 Maxiinum Stack Diameter( 6.50.666 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 Revised4112100Page 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 Revised4/12/00Page 7
• 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 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 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.

ArsenicCadmium Chromium 5.0 ppm maximum 2.0 ppm maximum 10 ppm maximum 100 ppm maximum LeadPCBs 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 Revised4/12/00Page 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 2/00Page 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 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

:p ennlls•urrent•title v•amendmnt \lvwhilo2. Revised4/lPage 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 Revised4/12/00Page 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) 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 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 2/00Page 12

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 Revised4/12/00Page 13 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 2/00Page 14
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.amdPage 15 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.
h:petmils•eurrenl\titlewamendmnt\tvwhite2.amd Revised4/12100No Page 16 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
h:pennits•eurrent\tillev•amendmnt\tvwhile2.amd Revised4/l 2/00Page 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 may use a

steam flow rate Compliance 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;

h:pennils\eurrent\fiflov•amendmnt\tvwhite2.amd Revised4/12/O0Xo 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

Revised4/12/00ii. 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 type, and sulfur content of liquid fuel 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.
Typical ozone season day is

defined any day between May and October.

h:permits•cuIrent\titlev•amendmnt\tvwhile2.amd Revised4/12100Page 20 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 Revised4/12100Page 21 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 Revised4112/O0XIV. 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 Revised4/12/00Page 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; orThe ability of the DES or the EPA Administrator to enter, inspect, and/or monitor a stationary source, area source, or device.

Revised4/12100Page 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
h:pormils\eurrent•titlov•amendmnt\tvwhite2.amd Revise, d4/I

2/00Page 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). h:permits\eurrent\lillev•amendmnt\tvwhile2.amd Revised4112/O0Page 26
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 Revised4/12/00any 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 h:permltsXeurrent\titlovXamendmnt\tvwhite2.amd Revised4/l 2/00Page 28 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.auldPage 29
FEE E

*

DPT *

CPIm *

ISF Where:FEEE= 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 to 40 CFR 70.6 (a)(6)(iv), this Permit does not convey any property rights of any sort, or any exclusive privilege. h:pennits\eurrent\litlcv•amendmnt•h, whi{e2.amd Revised4/12100Page 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.

h:permits•currenfitillvv•amendmnt\tvwhil•'2.amd Revised4/12/00Page 31 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.

h:permils•eurrent\litlev•amendmnt\tvwhile2.amd Revised4/12/00STATE OF NEW HAMPSHIRE Department of Environmental Services Air Resources DivisionTitle 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 DivisionTABLE 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. 20-22 Requirements Not'Currently Applicable Table 4

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 23232323-2424-25

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 27272727-29XXIV.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 303030-3131Facility 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): h:\pennits\eurrent\titlev\amend mnts\tvbiQen5.amd Revisedl 1/15/99Page 5

Bo 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 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 #1 157.5 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 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\eurrent\titlevXarnendmnts\tvbioen5,amd Revised 1/15/99VI. 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:

h:\permits\eurren t\titlev•amendronts\tvbioen5,amd Revised 1/15/99VIII. 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): h:\permtts\current\titlev\amendmnts\tvbioenS.amd Revisedl 1/15/99VIII. Page 8 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): h:\permits\eurrent\titlev•mendmnts\tvbioen5.amd Revised 1/15/99Page 9 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: h:\permits\eurrent\/itlev\amendmnls\tvbioen5.amd Revisedl 1/15/99Page 10 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):

h:\permits\current\titlev\amendmnts\IvbioenS.amd Revisedl 1/15/99Page 11 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). h:\permits\eurrent\fitlev•amendmnts\tvbiocn5.amd Revised 11/15/99Bo 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): h:\permits\eurrent\titlev\amendmnts\tvbioen5.amd Revised 1/I

5/99Page 13 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)"
h:\permits\eurrent\tltlev\amendmnts\tvbioen5.amd Revisedl 1/15/99Xo Page 1-4 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): h:\permits\eurrent\titlev•amendmnts\tvbioen5 ,amd RevisedI 1/15/9910. 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).
h:\permits\eurren t\titlev\amendmn ls\tvbioen5.amd Revised l/15/99Do Page 16 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):

h:\pennits\curfent\fiflev\amendmnts\tvbioen5 .amd Revisedl 1/15/99Page 17 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): h:\permits\eurrent\t ev\amendmnts•tvbioen5.amd Revised 1/15/99Xo 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): h:\petmits\eurrent\titlev•mendmnts\tvbioen 5.amd Revised 1/15/99Malfunction Reporting 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): h:\permits\eurrent\titlev\amendmnrs•tvbioen 5.•md Revisedl 1/15/99XIo Page 20 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. h:\permils\eurrent\titlev\amendmnts\tvbioen5.amd Revisedl 1/15/99Page 21

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 x, TRS, O2 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.

h:\permits\eurrent\titlev•mendmnls\lvbioen5.amd Revised 11/15/99Page 22

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.

h:\permits\eurrent\litlev\atnendmnts\tvbioen5.amd Revised 1/15/99Page 23 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.
h:\permits\cur•ent\titlev•mendmnts\tvbioen5.amd Revised 1/15/99XIV. 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; orThe 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).

h:\permits\eurrent\titlev\amendmnts\tvbioen5.amd Revised 1/15/99Page 25 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 h:\pennits\current\titlev\amendmnts\lvbioen5.amd Revisedl 1/!

5/99XVII. 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.

h:\permils\eurrent\titlev•anendmnts\tvbioenS.amd Revised 1/15/99Page 27 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 h:\permils\eurrent\titlev\amendmnts•tvbioen5.amd Revised 15/99Page 28 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 h:\permits\eurrent\titlev\amendmnts\tvbioen5.amd Revised 1/15/99XXIII. Page 29 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:FEEE=DPTCPIm=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. h:\permits\eurren t\titlev•amendmnts\tvbioen5.arad Revised 1/15/99Page 30 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. Theemissionbased 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.

15/99Page 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 1/15/99STATE OF NEW HAMPSHIRE Department of Environmental Services Air Resources DivisionTitle 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 DivisionTABLE 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 15-16161616-17171717-191919XIX.XX.XXI.XXILXXlll.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 19-202020-212121-222222222323Page 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) emissionsPage 5 Stack Criteria:

Stack #1 (EU1 &

EU2 combined) 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:

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 ActivitiesIdentificationAll 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 EquipmentIdentificationVII. The devices and/or processes identified in Table 1

do not operate with any pollution control equipment. Alternative OperatingScenariosNo 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-A2003.06(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/mmBtuPage 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_• RequirementsPage 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 CFR70.6(a)(3)Federally Enforceable

Env-A1211.05(b)(1) Federally Enforceable

Env-A 809Federally Enforceable

As needed Env-A 810.03 Federally EnforceableVIII. 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

thispermit

Daily, monthly, & annual total of fuel consumption

Daily,

monthly, and annually Facility wide
Facility wide 40 CFR70.6(a)(3)(ii)(B) Federally Enforceable 40 CFR70.6(a)(3)(iii)(A)Federally Enforceable
EU1 &

EU2 E•v-A1211.05(b)(2 )

& 40 CFR70.6(a)(3)(iii) Federally Enforceable

EU1 &

EU2 Env-A 901.03 and 40 CFR 70.6 (a)(3)(i)(B)Federally Enforceable

FacilityWide Env-A 901.04 Federally EnforceablePage 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; and3. 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 EnforceableVOC 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 eachVOCemitting 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, andannually FacilityWide Page 13

Env-A901.06(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-A901.07(b)Federally Enforceable

EU1 &

EU2 Env-A901.09(b)(1) Federally Enforceable

EU1 &

EU2 40 CFR 70.6 (a)(1) Federally Enforceable
EU3 40 CFR70.6(a)(1)Federally EnforceablePage 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. Promptreporting(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 CFR70.6(a)(3)(iii) Federally Enforceable 40 CFR70.6(a)(3)(iii)(A)Federally Enforceable

As specified Facility wide

As specified in Facility wide Section XXIII. April 15th Facility wide 40 CFR70.6(c)(1)Federally Enforceable Env-A 704.03
40 CFR70.6(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; orThe 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 andBo 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 underEnvA 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 foundXXj 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 NHPage 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:FEEE=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 CPImISF 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 theannual 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 ConditionsPage 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 02-17-99Page 24STATE OF NEW HAMPSHIRE Department of Environmental Services Air Resources DivisionTitle 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 DivisionPage 2

TABLE OF CONTENTS

I. Facility Description of Operations 4 II. 44-6

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. 7-910-121313-1617-2122-242525-26

27272727-282828-2929-30Page 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 3131-323232-3333 XXV. Property Rights 34 XXVI. Severability Clause 34 XXVII. Emergency Conditions 34 XXVIII. Permit Deviations 34-35 List of Emergency Generators Appendix A 36-37Page 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 withonsite generatedonspecification (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 withonsite 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 2.330.5 No. 98

EU6 (Emerg. Generator) 15.0
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 CFR70.6(a)(3)(i)(B)

Env-Wm 807.03(b)

40 CFR 70.6(c)(1)

Env-A 1204.10(c)

Env-A1211.02(j)(1)&(2) EU6EU1

&

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) ArsenicCadmium Chromium LeadTotal Halogens PCBsFlash 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 CFR70.6(a)(3)Federally Enforceable

Annually, Env-A before April 1211.05(b)(l) 1st

Federally Enforceable

For eachdelivery

During annual efficiency

test Env-A 809State-only Enforceable & 40 CFR70.6(a)(3)Federally Enforceable

Env-A 810.03 Federally EnforceablePage 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 CFR70.6(a)(1)Federally EnforceableEU3,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 CiteEnvA 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 anexistingcoating is reformulated or there is

a change in supplier of

a componentcontaining VOCs. Page 15

Env-A 803.03 Federally EnforceablePage 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 andannually FacilityWide 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 eachVOCemitting 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 eachVOCemitting 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 andannually FacilityWide Page 19

Env-A901.06(a), (b), (c), &

(d)Federally EnforceablePage 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 andannually EU3, EU4, & EU5 Env-A90k06(a), (b), (c), &

(d)Federally EnforceablePage 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; and3. 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 andannually

Maintain on a continuous basis
as specified in Table 5

of

this permit Facility Env-A 901.08 Wide Federally Enforceable

EU1 &

EU2 Env-A1211.05(b)(2) & 40 CFR70.6(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 DESAnnually (•o Facility Wide later than April 15th of

the following year) to DESAnnually (no Facility Wide later than April 15th of

the following year) to DES 40 CFR70.6(a)(3)(iii)(•)Federally Enforceable
40 CFR 70.6(a)(1)Federally Enforceable
40 CFR70.6(a)(1)Federally EnforceablePage 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 CFR70.6(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 CFR70.6(c)(1)Federally

40 CFR70.6(c)(1)Federally Enforceable Env-A 704.03 Federally Enforceable EnforceableVIII.

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 withEnvA 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 RulesPage 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; orThe 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 forXVI. 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 operatingPage 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

writtenCo 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:FEEE=

DPTCPIm=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,

2001Page 36 Appendix APage 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 105108113 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 emissionsSTATE OF NEW HAMPSHIRE Department of Environmental Services Air Resources DivisionTitle 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 DivisionTABLE 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

7-88-101011-12

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 17171717-18181919-2020Page 3

XVIII.IXX.XX.XXI.XXII.XXIII.XXIV.XXVXXVIXXVIIXXVIII 21 Inspection and Entry 21 Certifications Enforcement Emission-Based Fees Duty to Provide Information Property Rights Severability Clause Emergency Conditions Permit Deviations 21-22.2223-2424242424-2525Facility 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

EU9EUi0

EU11

EU12

EU13 HeatingPlant Emergency GeneratorCaterpillar Morse Hall Emergency GeneratorCaterpillar N.E. Center Emergency GeneratorCaterpillar WaterTreatment Plant Emergency Generator KohlerGablesEmergency GeneratorCaterpillar New Ice Arena Emergency GeneratorCaterpillar Biosciences Emergency GeneratorCaterpillar 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 EUIEU2 205 8.5 EU3EU4

Stack #2 EU5 Stack #3 EU6 35 3IV.

VI.

VII. Page 6
Stack #4 EU7EU8 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 0.50.50.50.50.5
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-A1604.01(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:

FacilityStacksandEUs1-13

Alldevicesusingliquidfuels

Alldevicesusinggaseousfuels Allows foradequatedispersion of HAPsand

otherregulatedpollutantsSulfur content inliquid fuels

Sulfur content

in gaseousfuels 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

thefacility Env-A806.01(4)and40

CFR70.6(a)(3)Federally Enforceable Env-A 809.01

Upon written request by EPA or DES Env-A 809.02Page 12

EUs I-6 Boilerefficiency 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 EnforceablePage 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. FacilityWide 40 CFR70.6(a)(3)(iii)(A)Federally Enforceable

EU1 through EU13 Env-A 901.03 Federally EnforceablePage 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.ActualNOXemissi
onsfor
eachfuel

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 CFR70.6(a)(3)Federally Enforceable

40 CFR70.6(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 EnforceablePag• 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 CFR70.6(c)(1)Federally Enforceable Env-A 704.03 Federally Enforceable
40 CFR70.6(c)(1)Federally EnforceablePage 17
IX. Requirements Currently. NotApplicableThe 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 PermitXIV. 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; orThe 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 underEnvA 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 shallCo 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:FEEE=DPTCPIm=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\tvunhfnlSTATE OF NEW HAMPSHIRE Department of Environmental Services Air Resources DivisionTitle 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 DivisionTABLE 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 21212121-222222-2323

-2424242525 Certifications 25-26Page 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 26-272727282828-29Page 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 •pmPage 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 thePage 8 transition period ending three years from May 8, 1998 (May 8, 2001) shall comply withEnvA 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 shallP•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 thePage 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 byPage 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 (uponPage 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 saidXVI.

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;
orThe 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 underEnvA 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• orNullificationAo 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 StatementPage 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.

DPTCPImISF 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 annualemissxonbased 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,

2001STATE 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 DivisionTABLE 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 4Federally 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.

XoXI.XII.XIII.XIV.XV.XVI. 6-7

8-318-11
12-13
1415-2526-2829-3132

323232-333434 Operational Flexibility 34-35Page 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 ̧

36-3737-383838-393939394o4OPage 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 500Page 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; orSpecification 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 thestateonly air pollution dispersion modeling requirements specified in Env-A 606.

Stack #1 EUl-(Boiler) 150 Stack #2 EU3-Emergenc• 9 5.00.3

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 fuelPage 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 overPage 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 foremissionbased 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 11Page 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

maximumTable 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-A1211.020)(1 )

& Env-A1211.020)(2) 5. Env-A 1211.04(d) & Env-A1211.05(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 CFR52.21 (b)(1)(i)(b)

9. 40 CFR52.21(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 (1) As a

condition of this pe•it, Indeck Energy shall InitialPerformance 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

determinenonmethane 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 maximumproduction 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 EnforceablePage 16

Boiler InitialPerformance 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 maximumproduction 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. PeriodicMonitoring (TotalSuspended 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 and40 CFR70.6(a)(3)Federally EnforceablePage 18

PC2-ESP PeriodicMonitoring (TotalSuspended 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-A806.01(4) and40 CFR70.6(a)(3)Federally EnforceablePage 19

6o Boiler

Boiler CEMRequirements

CEMRequirements (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)FederallyEnforceable

Env-A 805.02 &40 CFR Part 70.6(a)(3)FederallyPage 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.
CEMRequirements (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) FederallyPage 21

Boiler CEMRequirements (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 EnforceablePage 22

Boiler PeriodicMonitoring Chip Testing

Boiler PeriodicMonitoring 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 Weeklycompositechip samples from eachsupplierMonthlycompositechip samples from eachsupplier Env-A806.01(4) &40 CFR Part 70.6(a)(3)Federally Enforceable Env-A806.01(4) &40 CFR Part 70.6(a)(3)Federally EnforceablePage 23

FacilityWide. Fuel Sulfur ContentVerification (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 eachdelivery Env-A 809 Federally EnforceableVIII. 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 Results of

weekly and monthly Chip testing required. (H)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•sMaintain 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 FacilityWide

Boiler 40 CFR70.6(a)(3)(iii) (A)Federally Enforceable

40 CFR70.6(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 oilconsumption Daily,

monthly, Boiler Env-A 901.03 Env-A 901.03 Federally EnforceablePage 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 BoilerEmergency Generator

FacilityWideEnv-A 901.03 Federally Enforceable Env-A 901.03 Federally Enforceable

Env-A 901.08 Federally Enforceable Federally Enforceable1. 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- ) EnforceablePage 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) Promptreporting (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 GeneratorFacility Wide

Facility Wide

Boiler 40 CFR 70.6 (a)(1)Federally Enforceable 40 CFR70.6(a)(3)(iii) (B)Federally Enforceable
40 CFR70.6(a)(3)(iii) (A)Federally Enforceable

Env-A 805 Federally EnforceablePage 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 CFR70.6(c)(1)Federally Enforceable Env-A 704.03 Federally Enforceable 40 CFR70.6(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 completeXI. 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; orThe 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; andPage 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 byPage 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 DivisionTitle 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 DivisionTABLE 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 2929 Inspection and Entry Certifications 25252525-26272727-2828-29

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 RequirementsPage 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 33Facility 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:

h:\permils\current\titlev•amendmnt\tvbridg2.amd Revised 11/15/98IIl. 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 1/15/98IlL 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 thestateonly 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.

h:\pemfils\current\titlev•amendmnt\tvbridg2.amd Revised 11/15/98VI. 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 #1Stack #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 11115/98VIII.

VIII. Page 8

Arsenic 5.0 ppm maximum Cadmium 2.0 ppm maximum ChromiumLead 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 Revised 11/15/98Page 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):

h:\pennits\eurrenfltitlev\amendmnt\tvbridg2.amd Revised 1/I

5/98Page 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. h:\permits\eurrent\titlev\amendmnt\ivbridg2.amd Revised 11/15/98Page 11 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 11/15/98Page 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.

h:\pcrmits\current\fitlev•amendmnt\tvbridg2.amd Revised 11/15/98XQ 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,

h:\permits\eurrent\titlev•amendmnt\tvbridg2.amd Revised I/15/98Xe Page 14 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.

h:\permits\eurrent\fiflev\amendmnfilvbridg2.amd Revised 11/15/98Xo 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.

h:\permits\currenftiflev•mendnmt\tvbridg2.amd Revised 11/|5/98Page 16 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.

h:\permits\eurrent\litlev\amendmnt\tvbridg2.amd Revised |/15/98Page 17 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);

h:\permits\eurrent\titlev•ameudmnt\tvbridg2.amd Revised 11/15/98Xt Page 18 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 h:\permits\current\titlev\amendnmt\•bridg2.amd Revised 11/15/98Page 19

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

h;\permits\current\fitlev\amendmnt\tvbridg2.amd Revised 11/15/98Xe 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.

h:\pennits\eurrent\tit lev•amendmnfitvbridg2.amd Revised 11/15/98Xo 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. h:\pennits\current\titlev•amendmnt\tvbridg2.arad Revised 11/15/98XJ Page 22 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 11/15/98Compliance 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): h:\permits\eurrent\titlev\amcndmnt\lvbriag2.amd Revised I/I

5/98Page 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.

h:\permits\eutrent\fitlev•nmendmnt\tvbridg2.amd Revised 11/15/98Page 25

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 h:\permits\current\titlev•amendmnt\tvbridg2.amd Revised 11/15/98Co 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; orThe ability of the DES or the EPA Administrator to enter, inspect, and/or monitor a stationary source, area source, or device.

h:\permits\eu rrent\liflev•mendmnt\tvbridg2.amd Revised 1/15/98XIV.

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); h:Xpermits\currenrtitlev•amendmnt\tvbridg2.amd Revised 11/15/98Page 28 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

5/98Page 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 11/15/98XXI. 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/15/98XXIII. 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:FEEE 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 11/15/98Page 32 DPTCPIm=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. Theemissionbased 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 11/15/98Page 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 11/15/98STATE OF NEW HAMPSHIRE Department of Environmental Services Air Resources DivisionTITLE 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 DivisionTABLE 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

T:\Trans fer\TVWEBPAG\TV Website\eoncordsteamtv fl

2-13-00,doe Final Issued 12/13/2000ABBREVIATIONS Page 3

of 34

AALAP-42ARDASTMBACTBHPBTUCAACAMCASCEMSCFRCNGCOCO2COMSDEREnv-AEnv-Wm ECSERCFRHAPHCIHrkGalLAERLb/hrLNBLNGLPGMACTmg/LMMBTU MMCFNAAQSNCCEM 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 Hour1,000 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 T:\Trans fe

r•TVWE B PAG\TV Website\eoneordsteamtvfl 2-13-00.doe Final Issued 1211312000Page 4

of 34 ABBREVIATIONS (CONT.) NHDES (or DES) NOxNSPSNSRPCBPEPMPM•0ppmppmvppmdvPSDPSIPTERACTRTAPSIPSO2T-12MTAPTSPTPYUSEPAVOC 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

T:\Trans fer\TVWEBPAG\TV Websile\eoneordsteamtvfl 2-13-00.doe Fhlal Issued 12/[3/2000Page 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. T:Wrans fer\TVWEBPAG\TV Website\concordsteamtvfl2-13-00.doe Final Issued 12/13/2000Page 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.

T:\Tr fe

r\TV WEBPAG\TV Website\concordsteamtv fl

2-1

]-00.doe Finnl Issued 12/13/2000IV. 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 PartEnvA 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. T:\Transfer\TVWEBPAG\TV Websile\eoncordsteamtvfl 2-13-00.doe Final Issued 12/13/2000Page 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-A1305.01(a)

Env-A1305.02

Env-A1403.01.Env-A1403.02(a)

Env-A.1403.02(b)

Env-A1404.01(d)

T:\Trans fe

r•TVWEBPAG\TV Website\eoncordsteamlvfl 2-13-00,do¢ Final Issued 12/13/2000The 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-A1405.02

Env-A1405.03

Env-A1406.01

T:\Transfer•TVWEBPAG\TV Website\concordsteamtvfl 2-13-00.doe Final Issued 12/13/2000Page 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: ArsenicCadmium Chromium LeadHalogens as HC1 PCBsFlash 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-A1406.01

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. T:\Tra fer\TVWEB P AG\TV Website\eoneordsteamtvfl 2-13-00.doe Final Issued 12/13/2000Page 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 andEnvA 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-A606.04Facility Permi No. FP-S-0111 Env-A1604.01(a) Env-A1604.01(c)(2) Facility Wide Env-A1604.01(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. T:\Transfer\TVWEBPAG\TV Websi/e\concordsteamtvfl 2-13-00.doe Final Issued 12/13/2000Page 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 fueloilspecification 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-A1211.02(n)

Env-A1211.05(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. T:\Tmns fefiTVWEBPAG\TV Website\eoncordst¢•mtvfl 2-13-00.doe Final Issued 12/13/2000Page 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 68Federally 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. T:\Trausfer\TVWEBPAG\TV Website\eoneordsteamhefl 2-13-00.doe Final Issued 1211312000A 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 regulatedpollutants :•:•,!,•::•: •?:•,•: :•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 12113/2000Sulfur 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 eachdelivery of fuel oil to the facility

Upon

written request by EPA or DES

For eachdelivery of specification used oil to the facility

As requiredby

the manufacturer FacilityWide

FacilityWide

FacilityWide

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

CFR70.6(a)(3) & Env-A806.01(4)Federally Enforceable

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6. Continuous EmissionMonitoring

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 requiredby

thisPermit NCCEM Env-A 805, System 40 CFR 60, & 40 CFR 51Federally Enforceable

NCCEMSystem Env-A 805 & RSA 125-CFederally 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. T:Vrrans fer•'lN WE

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9. VolumetricFlowMonitoring

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. VolumetricFlowMonitoring
VolumetricFlowMonitoring

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-A805.03(h)Federally Enforceable

Daily

13. ContinuousOpacityMonitoring 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 NCCEMSystem Env-A 805 & 40 CFR 51Federally Enforceable NCCEMSystem Env-A 805.03 & 40 CFR 51 Federally Enforceable

Continuous NCCEMSystem 40 CFR 51Federally 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. COMSSystem

NCCEMandCOMSsystem 40 CFR Part 60 Appendix B, & Env-A 805Federally Enforceable Env-A 805Federally Enforceable

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2-13-00.doe Final Issued 12/13/2000Page 18 of 34

16.

17.

18.

19. Continuous Emissions Monitoring
PeriodicMonitoring

PeriodicMonitoring

Continuous Emissions Monitoring

PeriodicMonitoring 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 requiresrecertification, 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 requiredby

the manufacturer NCCEMandCOMSSystemEU01,EU02,EU03 &EU04 Env-A 805 & 40 CFR 70;6 Federally Enforceable 40 CFR 70.6 (a)(3)(i)(B) & Env-A 806Federally Enforceable Daily

On acontinuousbasis EU01,EU02,EU03,EU04 &EU05 40 CFR 70.6 (a)(3)(i)(B) & Env-A 806Federally Enforceable EU01, Env-A 1211.21 EU02, Federally EU03, Enforceable EU04 &EU05 Annually (before April l•t of eachyear) EUO1 Env-A1211.05(b)Federally Enforceable

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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 CFR70.6(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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2-13-00.doe Final Issued.: 12/I

3/2000Page 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

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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 continuousbasis FacilityWide 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 continuousbasis

Maintain on a continuousbasis EU01

FacilityWide Env-A 1211.05 Federally Enforceable

40 CFR 70.6(a)(3)

&EnvA 1604.01Federally Enforceable

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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 continuousbasis FacilityWide Env-A 1604.01 & Env-Wm 807.02 State-Only Enforceable

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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

Significantandinsignificant activities Env-A 901.04 Federally Enforceable

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2-13 -00,doe Final Issued 12/13/2000Page 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 acontinuousbasis •!•!•cal•lc
Facili•Wide Env-A 901.08 Federally Enforceable

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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 CFR70.6(a)(3)(iii) (A) Federally Enforceable Env-A901.09Federally Enforceable

Env-A901.09Federally Enforceable

901.09Federally Enforceable

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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 CFR70.6(c)(1)Federally Enforceable Facility Wide Env-A704.03Federally Enforceable Facility Wide 40 CFR70.6(c)(1)Federally Enforceable
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2-13-00.doe Final Issued 12113/2000IX. 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. T:\Tr fer\TVWEB PAG\TV Website\•oncordsteamtvfl 2-13-00.doe Final Issued 12/13/2000Page 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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2-13 -00.doe Final Issued 12/13/2000Page 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 underEnvA 609.08.

T:\Tr fer\TVWEBPAG\TV Website\eoncordsleamtvfl 2-13 -00.doe Final Issued 12/13/2000XVII. 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.

TATransfer\TVWEBPAG\TV Website\concords/eamtvfl 2-13-00.doc Final Issued 12/13/2000XXIo 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 T:\Transfer\TVWEBPAG\TV Website\coneordsteamN fl

2-13-00.doe Final Issued 12/13/2000Page 32 of 34 XXII. EnforcementAny 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:FEEEDPTCPImISF 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:

T:\Tra•m fer\TV WEB PAG\TV Website\concordsleamtvfl 2-13-00.doe Final Issued 12/13/2000Page 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 annualemissionbased 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 12/13/2000XXVIII. 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 12/13/2000STATE OF NEW HAMPSHIRE Department of Environmental Services Air Resources DivisionTitle 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 DivisionPage 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
66

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. 15-16 Reporting Requirements Table 8. Requirements Not Currently Applicable IX. 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 19Page 3

XVI.XVII.XVIII.IXX.XX.XXI.XXII.XXIII.XXIV.XXVXXVIXXVIIXXVIII 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 19-202020-21212121-22222324242424-2525 Property Rights Severability Clause Emergency Conditions Permit DeviationsPage 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 thestateonly 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 40.049.7549.7549.7549.7549.7549.7549.7549.755.555.555.'5 48303030303030303025x2925x2925x2925x29 55.554 40x24 54 40x24 54 25x29 54 25x2948 545454545454

4848484848 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 "DESIV.

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.

Baghouses and Filter Bags-(2 baghouses total) PCE1 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-A2103.02(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 andEnv-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:

FacilityStacksand EU1

Baghouseunits

andfilterbags(PCE#1)

Baghouseunits andfilterbags(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 Totalsuspendedparticulate 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. Totalsuspendedparticulate 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 inliquid 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

thefacility Env-A806.01(4)and40 CFR Part 70.6(a)(3)Federally Enforceable

Env-A806.01(4)and40 CFR Part 70.6(a)(3)Federally Enforceable Env-A809.01Page 12

EUI Annual Boilerefficiency 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-A1211.05(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 EnforceablePage 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 ActualNOXemissi
onsfor
eachfuel

burningdevice. On a

continuous basis. Facility wide Env-A 901.08 Federally EnforceablePage 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. Significantandinsignificant activities Facility wide 40 CFR70.6(a)(3)Federally Enforceable

Env-A

901.04 Federally Enforceable

Env-A 1300 and Env-A 1400State-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 CFR70.6(a)(3)(iii) Federally EnforceablePage 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-A901.08(c)(4) Federally Enforceable

40 CFR70.6(c)(1)Federally Enforceable Env-A 704.03 Federally Enforceable
40 CFR70.6(c)(1)Federally EnforceablePage 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 PermitPage 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; orThe 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 DivisionTitle 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 DivisionPage 2 TABLE OF CONTENTS

WoWI.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.

XoXI.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 4-101010101011-3711-1213-242425-2829-3334-3737

37373737-39393939-4040-4141Page 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 414142-434343 -44444444454546-5253-55Page 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 PermitTPB-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 NA NA Tank #2 125,000 gallon No.6 Fuel Oil (AST), 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

NANANANA NA

NANANANA 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 thestateonly 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 ofEnvA 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

particularCARBcertified 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

particularCARBcertified 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 EU8GasolineDispensingFacility

EU8GasolineDispensingFacility 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.) EU8GasolineDispensingFacility

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 #4Facility 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-A2003.08(c)(2) Env-A 2003.06(2)

Env-A2003.08(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 MaineMassachusetts 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 GSignificant 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 NitrogenOxides

5. Boiler # NitrogenOxides 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 EnforceablePage 25

6. Boiler #1

7. Boiler #2

8. Boiler #3 Continuous Monitors

PeriodicMonitoring (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 April1st

Continuous 40 CFR 60 Subpart Db § 60.48b(e)Federally Enforceable

Env-A1211.05(b)Federally Enforceable

40

CFR 60 Subpart De§ 60.47cFederally EnforceablePage 26

Boilers #3& #4 NOx RACT ComplianceTesting 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-A1211.21(b),(d) Federally EnforceablePage 27

10. Boilers Steam Flow #1, #2, Rate #3, &

#4

11.

12. Boilers Periodic #1, #2, Monitoring #3, &

#4Facility 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 806Federally Enforceable

Daily

For eachdelivery Env-A 806 & 40 CFR 70.6 (a)(3)(i)(B)Federally Enforceable Env-A 809Federally EnforceablePage 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 wideFacilitywide

Boiler #3 70.6(a)(3)(ii)(B) Federally Enforceable 40 CFR70.6(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 EnforceablePage 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 CFR70.06(a)(3)Federally EnforceablePage 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 ofoperation

Monthly

& calendar year totals Boiler #2

EU6 &

EU7 (No. 6

Fuel Oil Storage Tanks #1 )Boilers #1, #2, #3, &

#4

Boiler #2

AllEmergency 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 ofoperation Env-A 1211 ;05(b)(2) & 40 CFR70.6(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 EnforceablePage 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

FacilityWide Env-A901.03 Federally Enforceable

Env-A901.08• Federally EnforceablePage 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 GasolineDispensingFacility Env-A 1205.10 Federally EnforceableVIII. 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 EnforceablePage 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 thesubsequentreportingperiod

Postmarked by the 30th day after thesubsequentreportingperiod
Postmarked by the 30th day after thesubsequentreportingperiod 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 EnforceablePage 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 thesubsequent calendarquarter

Within 30 days of stack testing Annually

(no later than April 15th of the following year)

Promptreporting (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 Facility Wide

Facility Wide

Facility wide 40 CFR 60 Subpart De § 60.48c(d),(e) Federally Enforceable

Env-A1211.21(c) 40CFR70.6(a)(1)Federally Enforceable

Env-A 902.02&40 CFR70.6(a)(3)(iii)(B)Federally Enforceable 40 CFR70.6(a)(3)(iii)(A)Federally EnforceablePage 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 CFR70.6(c)(1)Federally Enfbrceable Env-A

704.03 Federally Enforceable 40 CFR70.6(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 RulesBo 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; orThe 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 underEnvA 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 BureauPage 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:FEEE=DPTCPIm 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 annualemissionbased 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 APage 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 LodgeLodge29 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)0.840.320.210.080.210.08 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 '0.080.230.080.320.080.180.080.040.080.180.180.210.080.150.080.210.080.370.080.42Page 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 0.120.370.120.320.120.46 11 East Wheelock No. 2

Fuel Oil 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 RemsenVailRiver Crest FletcherChandler DresdonBridgeman BurtonMasacoma Street Masacoma Street 6 No. 2

Fuel Oil 6 No. 2

Fuel Oil

614 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 2913 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 0.080.080.120.140.080.120.080.141.681.680.080.120.120.140.140.120.180.080.180.140.490.080.230.42Page 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 0.420.320.370.110210.110.210.110.230.080.320.110.320.21 No. 2

Fuel Oil 0.11 No. 2

Fuel Oil 0.080.56 No. 2

Fuel Oil 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 0.080.080.180.250.210.110.230.21Page 49 List of Insignificant Activities at Dartmouth College Furnaces/Small Boilers 4 DanaHillcrest 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 0.080.560.560.370.080.14 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 0.110.230.110.18

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 0.080.140.180.11

0.210.140.08 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 0.080.210.350.!11.68Page 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 1,11,1 No. 2

Fuel Oil No. 2

Fuel Oil No. 2

Fuel OilPropar/e

No. 2

Fuel Oil 0.230.420.110.16
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 Skiway, Caterpillar Shed Fuel Storage Tank Fuel Storage Tank Grounds, Labor Garage Fuel Storage Tank Hopkins Center Medical School Fuel Storage Tank 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 VOCPage 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, AshlandSachem 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 ParkingBoat House Skiway Caterpillar Shed, Lyme, NH Hanover Country Club, 5

Hilton Field LaneHCC 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 VOCPage 52

APPENDIX BAttachment 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 ByrneA & B Ward Sudikoff BrownRussell

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 11 Berry 1 McLain I Maxwell 1111

Topliff 1 Fayer Weather 1 Storehouse 1 Rated Generator Power Output (kW)800668166100300125•2233877.51516451515151512.57.5151515157.51515.6 Type of Fuel
No.

2

Fuel Oil DieselDieselLP GasLP GasLP Gas No. 2

Fuel Oil No. 2

Fuel Oil DieselDieselDieselDieselDieselLP GasLP GasLP GasLP GasLP GasLP GasLP GasLP GasLP GasLP GasLP GasLP GasLP GasPage 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 PropaneSTATE OF NEW HAMPSHIRE Department of Environmental Services Air Resources DivisionTitle 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 DivisionPage 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

6-77-91010

11-13 Recordkeeping Requirements Table 6. Reporting Requirements Table 7. 13-1415

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 15151515-161617Page3

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 1818-19191919-2020-2121-2222 XXV Property Rights, 22 XXVI Severability Clause 22 XXVII Emergency Conditions 22-2324Page 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, UnionIronworks BoilerBoiler #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 generatorPage 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 EU1EU2EU3 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 thePage 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

orPage 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 andEnv-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 and EPA 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 11Page 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]

BGBOMMCFkGal 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. FacilityStacksand EUs 1-5

Alldevicesusingliquidfuels

AlldevicesusinggaseousfuelsEUs

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

Boilerefficiency 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 CFR70.6(a)(3)(i)(B) FederallyEnforceablePage 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, andannually Facility Env-A 901.08 Wide Federally EnforceablePage 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 CFR70.6(a)(3)Federally Enforceable

40 CFR70.6(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 CFRrates 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

Promptreporting(ie;

within 8 hours of

an occurrence): Facility wide :.:t•egt•Jot0rY C•te,

40 CFR70.6(a)(3)(iii) (A)Federally Bnforceable

Env-A 902.02 &40 CFR70.6(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 CFRPage 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

thefollowing

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 CFR70.6(c)(1)Federally EnforceablePage 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 PermitPage 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;
orThe 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 isPage 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 underEnvA 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 CleanPage 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 annualemissionbased 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

keepPage 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 01-19-00STATE OF NEW HAh•PSHIRE Department of Environmental Services Air Resources DivisionTITLE 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 DivisionTABLE 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 05/25/2000TABLE 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 05/25/2000Facility 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 05125/2000EU7 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 EU5EU6EU71
EU83

EU9 -14.014.0 Heights vary reference .Drawing No Roof 1,

dated 11/29/95 Heights vary reference Drawing No Roof 1,

dated 11/29/9527.0 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 0.6650.665 Diameters vary reference Drawing No Roof 1,

dated 11/29/95 Diameters vmT reference Drawing No Roof 1,

dated 11/29/953.0

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 05/25/2000IV. 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 05/25/2000VII. 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-A1403.02(a) Facility Wide Env-A1403.02(b) Facility Wide Env-A1404.01(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 05/25/2000Page 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-A2003.04(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 05/25/2000Page 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-A2103.02(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 05/25/2000Page 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 05/25/2000Page 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: BWBOActual 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#5EU#6IA 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 05/25/2000Page 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 foradequatedispersion

of HAPs andotherregulatedpollutants
Sulfur content

of liquid fuels

3. Particulate Matter

4.

PeriodicMonitoring

5. PeriodicMonitoring 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-A806.01(4) and 40 CFR70.6(a)(3)Federally Enforceable

Env-A

809.01 Federally Enforceable

Env-A806.01(4) and 40 CFR70.6(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 05/25/2000Page 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 FacilityWideFacilityWide 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 05125/2000Page 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 05/25f20006. 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

FacilityWide 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 05/25/2000Page 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 eachVOCemitting 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 Significantandinsignificant activitiesFacilityWide Env-A 704.03 Federally Enforceable
Env-A 901.06 Federally Enforceable

T:\Transfcr•Tvwebpag•Tillolson_Dixville.doe Final Issued 05/25/2000e 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 toEnvA 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 eachfuelburning 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 05/25/2000Page 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 & EU4EU5, & EU6

Facility Wide 4. 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 05125/2000Page 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 CFR70.6(c)(1)Federally Enforceable Env-A

704.03 Federally Enforceable Facility Wide 40 CFR70.6(c)(1)Federally Enforceable

T:\Transfer\Tvwebpag\Tillolson_Dixville.doe Final Issued 05/25/2000Page 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 05/25f2000General 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 05/25/2000XIV.

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 05/25t2000XVI. 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 05/25/2000Page 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 underEnvA 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 05/25/2000XXo

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 05/25/2000Page 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 05/25/2000DPTCPImISF 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 annualemissionbased 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 05/25/2000XXVII. 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 05/25/2000STATE 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 DivisionII.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 44

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 67-10

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 222323-24 XIX. 24 XX. Significant Permit Amendments 24-25 XXI. Title.V Operating Permit Suspension, Revocation, or 25 NullificationPage 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 2525-26262728282828-2929Page 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 #1Cooling

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

dieselBo 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 PlanPage 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 whichPage 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 TDSPage 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 ticketPage 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

bo

CoPage 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 accordancePage 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; andPage 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 aPage 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, orPage 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 ServicesPage 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