### Page 1 of 19 

## STATE OF CONNECTICUT

**DEPARTMENT OF ENVIRONMENTAL PROTECTION**

**BUREAU OF AIR MANAGEMENT**

**NEW SOURCE REVIEW PERMIT**

**TO CONSTRUCT AND OPERATE**

**A STATIONARY SOURCE**

Issued pursuant to Title 22a of the Connecticut General Statutes (CGS) and Section 22a-174-3a of the Regulations of Connecticut State Agencies (RCSA).

Owner/Operator: Montville Power LLC

Address: 74 Lathrop Road, Uncasville, CT 06382

Equipment Location: 74 Lathrop Road, Uncasville, CT 06382

Equipment Description: Unit 5: 42 MW (net) biomass stoker fired; 82 MW (net) tangentially fossil fuel fired utility boiler

Collateral Conditions: Part VII.B of this permit contains collateral conditions affecting the operation of two existing diesel generators, R107-0021 and R107-0022, Units

10 and 11.

Town-Permit Number: 107-0056

Premises Number: 5

Permit Issue Date: April 6, 2010

Expiration Date: None

/s/ Amey Marrella 4/6/10 Amey Marrella Date
CommissionerFIRM NAME: Montville Power LLC EQUIPMENT LOCATION: 74 Lathrop Road, Uncasville, CT 06382 EQUIPMENT DESCRIPTION (MODEL, I.D. #): 42 MW (net) biomass stoker fired; 82 net MW tangentially fired fossil fuel fired utility boiler

Town No: 107 Premises No: 5 Permit No: 0056 Stack No: 1 

### Page 2 of 19



## PERMIT FOR FUEL BURNING EQUIPMENT

**STATE OF CONNECTICUT, DEPARTMENT OF ENVIRONMENTAL PROTECTION**
**BUREAU OF AIR MANAGEMENT**

The conditions on all pages of this permit and attached appendices shall be verified at all times except those noted as design specifications. Design specifications need not be verified on a continuous basis; however, if requested by the commissioner, demonstration of compliance shall be shown.



### PART I. OPERATIONAL CONDITIONS

**A. General Process Description**

The 82 MW utility boiler, currently referred to as Unit 5, has been converted to combust biomass (clean wood) as a base load utility power plant with a net capacity of 42 MW. The boiler shall be able to transition to natural gas or distillate firing up to a net 82 MW for a period of time equivalent to an annual capacity factor of seven percent. The plant will utilize a stoker grate combustor (biomass firing) with regenerative selective catalytic reduction (RSCR) and Low NOx burners (fossil fuel firing) for NOx control, an electrostatic precipitator (ESP) and multi-cyclones for particulate matter control, an oxidation catalyst for CO, VOC and organic HAP control. The particulate emissions from electrically powered biomass fuel and ash handling systems were assessed and account for less than 3 tons/year. The ash and biomass handling is subject to management practices as described in this permit.

**B. Fuel Restrictions**

Natural gas and distillate oil will also be used for operations including but not limited to transient operation prior to the transition to biomass firing, biomass firing stabilization in the event of wet biomass, temperature control for the RSCR, and for shutdown of biomass firing. Natural gas and distillate oil firing shall not exceed an equivalent to a 7% annual capacity factor at maximum rated capacity for all modes of operation. All emissions associated with these fuels during transient operations shall be counted toward the annual emissions rates listed in Part V of this permit.

**Primary Fuel:**

**Biomass:** Allowable Biomass fuels are described in Table 1 of this permit. Any of these biomass fuels may be utilized 100% of any time of biomass operations.

Treated wood and regulated wood fuel as defined in the CGS 22a-209a(2) and CGS 22a-209a(4) shall not be combusted in this boiler.

1. Maximum wood biomass Consumption over any consecutive 12 month period: 521,000 tons/year based on a design higher heating value (HHV) of 4,600 Btu/lb
2. Maximum firing rate: 65.2 tons/hrFIRM NAME: Montville Power LLC EQUIPMENT LOCATION: 74 Lathrop Road, Uncasville, CT 06382 EQUIPMENT DESCRIPTION (MODEL, I.D. #): 42 MW (net) biomass stoker fired; 82 net MW tangentially fired fossil fuel fired utility boiler

Town No: 107 Premises No: 5 Permit No: 0056 Stack No: 1 

### Page 3 of 19



## PERMIT FOR FUEL BURNING EQUIPMENT

**STATE OF CONNECTICUT, DEPARTMENT OF ENVIRONMENTAL PROTECTION**
**BUREAU OF AIR MANAGEMENT**

**PART I. OPERATIONAL CONDITIONS, continued**

3. Maximum Heat Input (MMBtu/hr): 600 @ 50% moisture

4. Maximum Fuel Sulfur Content (% by weight, dry basis): 1 (biomass)

5. Nominal Electrical Generation (MW): 42 (net)

**TABLE 1.**

**Allowable Biomass Wood T yp**  **es D**  **escri p**  **tion** Land Clearing debris C hipped trees, stumps, branches or brush as

d efined in RCSA 22a

- 2 08a-1 Recycled wood or clean wood R ecycled wood or clean wood means a n y wood or wood fuel which is derived from such products or processes as pallets skids, spools, packaging materials, bulky wood waste or scraps from newly built wood products, provided such wood is not treated

w ood. [CGS 22a

- 2 09a][RCSA 22a-208a

- 1 ]

Other Clean Wood O ther types if properly sized, clean, uncontaminated wood materials, such as sawdust, chips, bark, tree trimmings or

o ther organic based materials

**Auxiliary Fuels:**

The boiler shall be limited to a combined maximum annual heat input of 610,134 MMBtu/yr (7% annual capacity factor) for natural gas and distillate firing. The following equation establishes the maximum fuel

usage.

X*(0.140 MMBtu/gal) + Y*(0.001 MMBtu/ft 3 ) ≤ 610,134 MMBtu Where, X = gallons of ULS distillate oil fired over any consecutive 12 month period.

Y = ft 3 of natural gas fired over the same consecutive 12 month period.

**Natural Gas:**

1. Maximum natural gas consumption over any consecutive 12 month period: 610.134 MMscf/yr based on a HHV of 1000 Btu/scf
2. Maximum firing rate: 995,000 scf/hr

3. Maximum Heat Input (MMBtu/hr): 995

4. Nominal Electrical Generation (MW): 82 (net)FIRM NAME: Montville Power LLC EQUIPMENT LOCATION: 74 Lathrop Road, Uncasville, CT 06382 EQUIPMENT DESCRIPTION (MODEL, I.D. #): 42 MW (net) biomass stoker fired; 82 net MW tangentially fired fossil fuel fired utility boiler

Town No: 107 Premises No: 5 Permit No: 0056 Stack No: 1 

### Page 4 of 19



## PERMIT FOR FUEL BURNING EQUIPMENT

**STATE OF CONNECTICUT, DEPARTMENT OF ENVIRONMENTAL PROTECTION**
**BUREAU OF AIR MANAGEMENT**

**PART I. OPERATIONAL CONDITIONS, continued**

**Distillate Oil**

1. Maximum distillate oil consumption over any consecutive 12 month period: 4.3581 MMgal based on a HHV of 140 MBtu/gal 2. Maximum firing rate: 7,107 gal/hr 3. Maximum Heat Input (MMBtu/hr): 995 4. Nominal Electrical Generation (MW): 82 (net)

5. Maximum Fuel Sulfur Content (% by weight, dry basis):0.0015

**C. Stack Parameters**

1. Minimum Stack Height (ft): 258 2. Minimum Exhaust Gas Flow Rate at maximum load (acfm): 214,696 (biomass); 253,360 (gas); 249,404 (oil) 3. Stack Exit Temperature ( o F): 327 (biomass); 409 (gas); 373 (oil) 4. Minimum Distance from Stack to Property Line (ft): 213

**D. Definitions**

1. "Steady-state" operation shall be defined as operation of the boiler when the rate of change in load (i.e. lbs of steam), with respect to time, is less than 5 percent per hour; except for such operation that occurs during periods of start-up, shutdown, malfunction, fuel switching, and equipment cleaning. Additionally, steady-state operation shall include all modes of operation during which the

boiler load exceeds 50% of the manufacturer's specified maximum for the specific fuel.

2. "Transient" operation shall be defined as operation of the boiler when the rate of change in load, with respect to time, is greater than 5 percent per hour. Additionally, transient operation shall include and describe the operation of the boiler during all phases of start-up, shutdown, fuel switching, flame stabilization and equipment cleaning where the load is less than 50% of the manufacturer's specified maximum for the specific fuel.

3. "Malfunction" shall be defined as 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 manner. Failures that were caused in part by poor maintenance or careless operation are not malfunctions.FIRM NAME: Montville Power LLC EQUIPMENT LOCATION: 74 Lathrop Road, Uncasville, CT 06382 EQUIPMENT DESCRIPTION (MODEL, I.D. #): 42 MW (net) biomass stoker fired; 82 net MW tangentially fired fossil fuel fired utility boiler

Town No: 107 Premises No: 5 Permit No: 0056 Stack No: 1 

### Page 5 of 19



## PERMIT FOR FUEL BURNING EQUIPMENT

**STATE OF CONNECTICUT, DEPARTMENT OF ENVIRONMENTAL PROTECTION**
**BUREAU OF AIR MANAGEMENT**

**PART I. OPERATIONAL CONDITIONS, continued**

**E. Expected Control Efficiency** 

**Type of control Overall control efficienc**  **y** ***** **P ollutants Controlled** 

Regenerative Selective Catalytic Reduction (RSCR) 7 0% biomass 30% gas/oil N Ox

Low NOx burners 3 0% gas/oil N Ox Electrostatic Precipitator (ESP) 9 5% PM/PM

- 1 0/PM

- 2 .5 ( filterable) P M/PM-10/PM

- 2 .5 ( filterable) Oxidation Catalyst 7 0% C O and VOC

*** Note:** Overall control efficiency is calculated based on assumed uncontrolled emission rates and required controlled emission rates.



### PART II. CONTROL EQUIPMENT

A. Control Equipment Design Specifications:

1. Regenerative Selective Catalytic Reduction:

Ammonia –or- Urea

Make and Model: TBD Injection Rate at Maximum Rated Capacity (TBD): TBD Operating Temperature Range ( o F): 350-650 0 F (typical) Minimum Gas Flow Rate at Maximum Rated Capacity (acfm): TBD Design Removal Efficiency (%): 70% (max)

2. Low NOx Burner

Make and Model: Riley Custom Burner Modifications Design NOx Emission Rate (lb/MM BTU): 0.02

3. Electrostatic Precipitator (ESP)

Make and Model: TBD
Number of Fields: TBD Minimum Gas Flow Rate at Maximum Rated Capacity (acfm): 139,000 Design Outlet Grain Loading (gr/dscf): TBD Expected Design Removal Efficiency (%): 90 (99% with multicyclone)FIRM NAME: Montville Power LLC EQUIPMENT LOCATION: 74 Lathrop Road, Uncasville, CT 06382 EQUIPMENT DESCRIPTION (MODEL, I.D. #): 42 MW (net) biomass stoker fired; 82 net MW tangentially fired fossil fuel fired utility boiler

Town No: 107 Premises No: 5 Permit No: 0056 Stack No: 1 

### Page 6 of 19



## PERMIT FOR FUEL BURNING EQUIPMENT

**STATE OF CONNECTICUT, DEPARTMENT OF ENVIRONMENTAL PROTECTION**
**BUREAU OF AIR MANAGEMENT**

**PART II. CONTROL EQUIPMENT, continued**

4. Oxidation Catalyst

Make and Model: TBD Pressure Drop (inches H 2 O): TBD Minimum Gas Flow Rate at Maximum Rated Capacity (acfm): TBD Expected Design Removal Efficiency (%): 70%

5. Multicyclone

Make and Model: TBD Pressure Drop (inches H 2 O): TBD Minimum Gas Flow Rate at Maximum Rated Capacity (acfm): TBD

B. Control Equipment Operational Conditions:

1. The Permittee shall develop an operating and maintenance plan (O&M) to implement the manufacturer’s specifications and written recommendations. Appropriate records shall be made to verify that there is proper operation, monitoring and maintenance of all pollution control devices including those associated with the fuel and ash handling systems. The fuel and ash handling system shall have sufficient enclosures, fabric filters as to minimize particulate emissions from these point sources. The plan shall detail the procedures for operation, inspection, maintenance and corrective measures for all components of the combustor, including all associated pollution control equipment. The O&M plan must also include a corrective measures plan that specifies the procedures to be followed in the case of a malfunction to the pollution control devices. The corrective measures plan must include, at a minimum, the procedures used to determine and record the time and cause of

the alarm as well as the corrective measures taken to correct the control device malfunction or minimize emissions as specified below:

i. the applicant must initiate the procedures used to determine

the cause of the alarm within 30 minutes of the time the alarm

first sounds; and

ii. must alleviate the cause of the alarm by taking the necessary corrective measure(s) which may include, but are not to be limited to, inspecting the device for any malfunctions that may cause an increase in emissions or shutting down the

combustor.FIRM NAME: Montville Power LLC EQUIPMENT LOCATION: 74 Lathrop Road, Uncasville, CT 06382 EQUIPMENT DESCRIPTION (MODEL, I.D. #): 42 MW (net) biomass stoker fired; 82 net MW tangentially fired fossil fuel fired utility boiler

Town No: 107 Premises No: 5 Permit No: 0056 Stack No: 1 

### Page 7 of 19



## PERMIT FOR FUEL BURNING EQUIPMENT

**STATE OF CONNECTICUT, DEPARTMENT OF ENVIRONMENTAL PROTECTION**
**BUREAU OF AIR MANAGEMENT**

**PART II. CONTROL EQUIPMENT, continued**

2. The Permittee shall operate and maintain pollution control devices in accordance with the manufacturer’s specifications and written recommendations at all times that the unit is emitting air pollutants. During such times of transient operation pollution control devices shall be operated according to the manufacturer’s specifications and written recommendations. During start-up only fossil fuels will be used. The boiler can be operated without RSCR urea or ammonia injection during a start-up/shut-down when the RSCR is not within the manufacturer’s specified operating temperature range. During boiler shutdown the Permittee shall not shut down the ESP particulate control while there is biomass fuel on the stoker

grate.



### PART III. CONTINUOUS EMISSION MONITORING REQUIREMENTS AND
**ASSOCIATED EMISSION LIMITS** (Applicable if -X- Checked)

The Permittee shall comply with the CEM requirements as set forth in RCSA Section 22a-174-4. CEM shall be required for the following pollutant/operational parameters and enforced on the following basis firing biomass and fossil fuels – except that emissions limits for fossil fuels are as listed in Part V of this permit. CEM is required at all times that the boiler is emitting air pollutants.

Pollutant/Operational Averaging Emission

Parameter Times Limit Units

Opacity six-minute block 10% **3**
SOx 3 hour block 10.8 ppmvd @ 7% O 2 NOx 24 hour block 36.2 ppmvd @ 7% O 2 CO 8 hour block 99.1 ppmvd @ 7% O 2 O 2 1 hour block Ammonia 24 hour block 18 ppmvd @ 7% O 2 Unit Load 4 hour block steam flow RSCR Temperature 1 hour block Oxid. Cat. Temperature 1 hour block T-R secondary voltage Hourly

**Note 3: Opacity limit is applicable for all fuels during steady-state operation.**

The Permittee shall meet the performance and quality assurance specifications for the operation of CEM equipment pursuant to RCSA Section

22a-174-4.FIRM NAME: Montville Power LLC EQUIPMENT LOCATION: 74 Lathrop Road, Uncasville, CT 06382 EQUIPMENT DESCRIPTION (MODEL, I.D. #): 42 MW (net) biomass stoker fired; 82 net MW tangentially fired fossil fuel fired utility boiler

Town No: 107 Premises No: 5 Permit No: 0056 Stack No: 1 

### Page 8 of 19



## PERMIT FOR FUEL BURNING EQUIPMENT

**STATE OF CONNECTICUT, DEPARTMENT OF ENVIRONMENTAL PROTECTION**
**BUREAU OF AIR MANAGEMENT**

**PART IV. MONITORING, RECORD KEEPING AND REPORTING REQUIREMENTS**

**A. Monitoring and Record Keeping**

1. The Permittee shall use a non-resettable totalizing fuel metering device to continuously monitor natural gas and distillate fuel feed to this permitted source.

2. The Permittee shall monitor the ESP Transformer-Rectifier (TR) Set secondary voltage. The Permittee shall maintain these parameters within the ranges recommended by the manufacturer and/or determined by the performance test required in Part VI of this permit to achieve compliance with the particulate emission limits in this permit.

3. The Permittee shall keep records of daily and annual fuel consumption for all fuels. Annual fuel consumption shall be based on any consecutive 12 month time period and shall be determined by adding (for each fuel) the current month’s fuel usage to that of the previous 11 months. The record keeping requirements for fossil fuel consumption shall also be sufficient to show compliance with the annual capacity factor limitation using the equation in Part I.B of this permit. The Permittee shall make these calculations within 30 days of the end of the previous month.

4. The Permittee shall keep records of the fuel certification for each delivery of fuel oil from the fuel supplier or a copy of the current contract with the fuel supplier supplying the fuel used by the equipment. The shipping receipt or contract shall include the date of delivery, the name of the fuel supplier and type of fuel

delivered.

5. The Permittee shall keep records of the biomass fuel certification for each delivery of biomass fuel from the fuel supplier or a copy of the current contract with the fuel supplier supplying the biomass fuel used by the equipment. The Permittee shall keep records of each delivery of the biomass fuel and the weight of each delivery. These records, at a minimum, shall show that the allowable biomass fuel meets the specifications in Part I.B Table 1 of this permit.FIRM NAME: Montville Power LLC EQUIPMENT LOCATION: 74 Lathrop Road, Uncasville, CT 06382 EQUIPMENT DESCRIPTION (MODEL, I.D. #): 42 MW (net) biomass stoker fired; 82 net MW tangentially fired fossil fuel fired utility boiler

Town No: 107 Premises No: 5 Permit No: 0056 Stack No: 1 

### Page 9 of 19



## PERMIT FOR FUEL BURNING EQUIPMENT

**STATE OF CONNECTICUT, DEPARTMENT OF ENVIRONMENTAL PROTECTION**
**BUREAU OF AIR MANAGEMENT**

**PART IV. MONITORING, RECORD KEEPING AND REPORTING REQUIREMENTS, cont.**

6. The Permittee shall keep records of all performance tests conducted to determine compliance with the emissions limits in Part V of this permit.

7. The Permittee shall develop pollution control inspection procedures pursuant to the manufacturer’s recommendations. The Permittee shall keep records of all inspections to pollution control devices. These records shall include the date of inspection, any findings of pollution control failures and the time period for corrective

action.

8. The Permittee shall keep records of hours of operation of all biomass fuel handling equipment.

9. The Permittee shall develop a written startup, shutdown, and malfunction plan and make this plan available at the Commissioner’s

request.

10. The Permittee shall keep records of the duration of all transient operation and malfunction events.

11. The Permittee shall keep records of all tune-ups, repairs, replacement of parts and other maintenance.

12. The Permittee shall keep records for the pollutions control systems consisting of the date, time and duration of each alarm/warning, the time corrective action was initiated and completed, a brief description of the cause of the alarm, and the corrective action

taken.

13. The Permittee shall measure and record the electrical output (MW) of this unit during all operating modes, such measurement shall be as required by ISO-NE Operating Procedure No. 18,as may be amended, “Metering and Telemetering Criteria”.

14. The Permittee shall keep records to show that the unit will not emit more than 10 tons of any individual HAP or 25 tons of any combination of HAP, on an annual basis, listed in Section 112(b) of the Clean Air Act Amendments of 1990 at this premises

15. The Permittee shall record each exceedance of an emission limit or operating parameter contained in this permit. Such records shall include the date and time of the exceedance, a description of the exceedance, and the duration of the exceedance. Such report shallFIRM NAME: Montville Power LLC EQUIPMENT LOCATION: 74 Lathrop Road, Uncasville, CT 06382 EQUIPMENT DESCRIPTION (MODEL, I.D. #): 42 MW (net) biomass stoker fired; 82 net MW tangentially fired fossil fuel fired utility boiler

Town No: 107 Premises No: 5 Permit No: 0056 Stack No: 1 

### Page 10 of 19



## PERMIT FOR FUEL BURNING EQUIPMENT

**STATE OF CONNECTICUT, DEPARTMENT OF ENVIRONMENTAL PROTECTION**
**BUREAU OF AIR MANAGEMENT**

**PART IV. MONITORING, RECORD KEEPING AND REPORTING REQUIREMENTS, cont.**

contain copies of the exceedance records for the month, an explanation of the likely causes of the exceedances, and an explanation of remedial actions taken to correct the exceedance.

The Permittee shall keep all records required by this permit on site for a period of no less than five years and shall submit such records to the commissioner upon request. An electronic version of any of the required records is acceptable provided it is made readable to the commissioner.

**C. Reporting** 

1. The Permittee shall notify the commissioner in writing each calendar quarter of any malfunction of the boiler or the air pollution control system that resulted in an exceedance of any of the specified emission limits. Reporting of malfunctions for the CEM system shall be in

accordance with RCSA 22a-174-4. The Permittee shall submit such notification within thirty days following the end of each calendar quarter. The notification shall include the following:

i. Description of the malfunction, date and time, the duration and a description of the circumstances surrounding the cause or likely cause of such malfunction and; ii. Description of all corrective actions and preventative measures taken and/or planned with respect to such

malfunction.



### PART V. ALLOWABLE EMISSION LIMITS

A. Start-up, Shut-down and Malfunction

1. The Permittee shall develop start-up and shut-down emission rates for each specific fuel as required in Part VII.C of this permit over the first calendar year of commercial operation or 1,000 hours of operations, which ever occurs later. Until such time, the steady state (lb/hr) emission limits listed in Part V of this permit shall be used for permit compliance demonstration during start-up (SU) and shut-down (SD) operation of the boiler. During all SU/SD operation of the boiler the (lb/MMBtu) and (ppm) limits shall not apply.

2. Start-up, shut-down and malfunction shall not exceed 4 hours for

each occurrence.FIRM NAME: Montville Power LLC EQUIPMENT LOCATION: 74 Lathrop Road, Uncasville, CT 06382 EQUIPMENT DESCRIPTION (MODEL, I.D. #): 42 MW (net) biomass stoker fired; 82 net MW tangentially fired fossil fuel fired utility boiler

Town No: 107 Premises No: 5 Permit No: 0056 Stack No: 1 

### Page 11 of 19



## PERMIT FOR FUEL BURNING EQUIPMENT

**STATE OF CONNECTICUT, DEPARTMENT OF ENVIRONMENTAL PROTECTION**
**BUREAU OF AIR MANAGEMENT**

**PART V. ALLOWABLE EMISSION LIMITS, continued**

B. The Permittee shall not cause or allow the emissions from this stationary source to exceed the emissions limits stated herein at steady state operation.

**Primary Fuel : Biomass** 

**Criteria**

**Pollutants lb/hr lbs/MMBtu Pollutants monitored by CEMS** 
**(ppmvd @7% O 2**  **) 4** 

PM-10/2.5 (filterable) **5** 7.2 0.012

PM-2.5 (condensable) **6** 8.4 0.014

PM-10/2.5 (total) **6** 15.6 0.026

SOx 15 0.025 10.8

NOx 36 0.06 36.2

VOC 6.0 0.01

CO 60.0 0.1 99.1

Pb 2.88E-2 4.8E-5
**Auxiliary Fuel**

**Distillate Oil: Pollutants monitored by CEMS** 
**(ppmvd @3% O 2**  **)**

PM-10/2.5 (filterable) **5** 14.2 0.014

PM-2.5 (condensable) **6** 9.2 0.009

PM-10/2.5 (total) **6** 23.4 0.024

SOx 1.7 0.0017 1.0

NOx 59.7 0.06 46.9

VOC 1.4 0.0014

CO 35.5 0.036 46.2FIRM NAME: Montville Power LLC EQUIPMENT LOCATION: 74 Lathrop Road, Uncasville, CT 06382 EQUIPMENT DESCRIPTION (MODEL, I.D. #): 42 MW (net) biomass stoker fired; 82 net MW tangentially fired fossil fuel fired utility boiler

Town No: 107 Premises No: 5 Permit No: 0056 Stack No: 1 

### Page 12 of 19



## PERMIT FOR FUEL BURNING EQUIPMENT

**STATE OF CONNECTICUT, DEPARTMENT OF ENVIRONMENTAL PROTECTION**
**BUREAU OF AIR MANAGEMENT**

**PART V. ALLOWABLE EMISSION LIMITS, continued**

**Auxiliary Fuel**

**Natural Gas: lbs/MMBtu**  **Pollutants monitored by CEMS**
**(ppmvd @3% O 2**  **)**

PM-10/2.5 (filterable) 5 1.9 0.0019

PM-2.5 (condensable) 6 5.7 0.0057
PM-10/2.5 (total) 6 7.6 0.0076

SOx 0.6 0.0006 0.4

NOx 59.7 0.06 49.4

VOC 5.5 0.0055

CO 83.6 0.084 113.7

**Other Pollutants** Ammonia (all fuels) 18

**Note 4: Equivalent mass emission rate based on wood F-factor of 9,240 dscf/MMBtu. [40CFR Part 60, Appendix A, Table 19-2]** 

**Note 5: Filterable particulate matter (PM-10 and PM-2.5) as measured by EPA**

**Reference Method 5 or 17.**

**Note 6: Condensable PM-2.5 and total PM-2.5, including condensables, are**

**estimated based on EPA AP-42 emission factor for condensable PM from wood residue, Table 1.6-1, Fifth Edition, September 2003. Initially, testing**  **for filterable PM-2.5 shall be required. Within one year following the US EPA’s promulgation of a condensable PM-2.5 reference test method, the** 

**Permittee shall test for both filterable and condensable PM-2.5.**FIRM NAME: Montville Power LLC EQUIPMENT LOCATION: 74 Lathrop Road, Uncasville, CT 06382 EQUIPMENT DESCRIPTION (MODEL, I.D. #): 42 MW (net) biomass stoker fired; 82 net MW tangentially fired fossil fuel fired utility boiler

Town No: 107 Premises No: 5 Permit No: 0056 Stack No: 1 

### Page 13 of 19



## PERMIT FOR FUEL BURNING EQUIPMENT

**STATE OF CONNECTICUT, DEPARTMENT OF ENVIRONMENTAL PROTECTION**
**BUREAU OF AIR MANAGEMENT**

**PART V. ALLOWABLE EMISSION LIMITS, continued**

**C. Annual Emission Limits:** 

The Permittee shall not cause or allow this equipment to exceed the emission limits stated herein at any time.

**Criteria**
**Pollutants tpy** PM-10/2.5 (filterable) 33.1
PM-2.5 (condensable) 36.3
PM-10/2.5 (total) 69.4

SOx 60.4

NOx 161.9

VOC 25.6

CO 265.0

**D. Hazardous Air Pollutants (HAPs)**

The Permittee shall not cause or allow emission from this equipment to exceed the maximum allowable stack concentration (MASC) for any pollutant listed in RCSA §22a-174-29.

**E. OPACITY**

Opacity during steady state operating modes shall not exceed 10% for any six-minute block average.

**F. DEMONSTRATION OF COMPLIANCE**

Demonstration of compliance with the above emission limits shall be met by calculating the emission rates using emission factors from the following sources:

1. CEM/COMS data for SOx, NOx, CO, Opacity and ammonia 2. Predictive emissions monitoring for VOC as defined in Part VI.D of this permit. 3. Initial and recurring stack testing for all other pollutants

The above statement shall not preclude the commissioner from requiring other means (e.g. stack testing) to demonstrate compliance with the above emission limits, as allowed by state or federal statute, law or regulation.FIRM NAME: Montville Power LLC EQUIPMENT LOCATION: 74 Lathrop Road, Uncasville, CT 06382 EQUIPMENT DESCRIPTION (MODEL, I.D. #): 42 MW (net) biomass stoker fired; 82 net MW tangentially fired fossil fuel fired utility boiler

Town No: 107 Premises No: 5 Permit No: 0056 Stack No: 1 

### Page 14 of 19



## PERMIT FOR FUEL BURNING EQUIPMENT

**STATE OF CONNECTICUT, DEPARTMENT OF ENVIRONMENTAL PROTECTION**
**BUREAU OF AIR MANAGEMENT**

**PART VI. STACK EMISSION TEST REQUIREMENTS** (Applicable if -X- Checked)

**A.** Stack testing shall be performed in accordance with the latest Emission

Test Guidelines available on the DEP website:

http://www.ct.gov/dep/cwp/view.asp?a=2684&q=322076&depNav_GID=1619

Stack emission testing shall be required for the following pollutants for biomass firing:

PM 10/PM 2.5 SOx NOx CO VOC

Hazardous Air Pollutants: Hydrogen Chloride; NH 3

Initial Performance testing shall include the baseline operating

parameters (i.e. flow rate, pressure drop, temperature and listed as TBD, subject to modification) of all control equipment listed in Part II of this permit.

**B.** The Permittee shall conduct initial stack testing within 180 days of the commencement of commercial operations. Test results must be submitted within 45 days after testing.

Testing being conducted pursuant to 40 CFR Part 60, the test report is to be submitted within 180 days after the initial startup date or within 60 days after reaching maximum production rate. [40 CFR §60.8(a)]

**C.** After the initial compliance stack test required in Part VI.A of this permit, testing shall be performed at least once every five years from the date of the initial compliance stack test required in Part VI.A of this permit for all pollutants listed in Part V.A with the following exceptions:

• After the initial stack test, stack testing may not be required for pollutants requiring CEMs/COMS (NO

x , SO

x , CO, Opacity, and NH 3 ). The commissioner retains the right to require stack testing of any pollutant at any time to demonstrate compliance.

• The Permittee shall conduct a one-time stack test for the condensable fraction of PM 2.5, once EPA promulgates a reference test method, for

all fuels.

**D.** Compliance with Volatile Organic Compounds (VOC) emission limits in Part V shall be determined by correlating the VOC emissions to the Carbon Monoxide (CO) emissions using the results of a diagnostic stack test and tracked using the CO CEMS.FIRM NAME: Montville Power LLC EQUIPMENT LOCATION: 74 Lathrop Road, Uncasville, CT 06382 EQUIPMENT DESCRIPTION (MODEL, I.D. #): 42 MW (net) biomass stoker fired; 82 net MW tangentially fired fossil fuel fired utility boiler

Town No: 107 Premises No: 5 Permit No: 0056 Stack No: 1 

### Page 15 of 19



## PERMIT FOR FUEL BURNING EQUIPMENT

**STATE OF CONNECTICUT, DEPARTMENT OF ENVIRONMENTAL PROTECTION**
**BUREAU OF AIR MANAGEMENT**

**PART VI. STACK EMISSION TEST REQUIREMENTS, continued**

**E.** The Permittee shall test the boiler during transient loads to show compliance with Part VII.C of this permit.

**NOTE: Stack testing shall be conducted at or above ninety percent (90%) of maximum rated capacity for the specific fuel. If the source does not achieve ninety percent**  **maximum rated capacity during the stack test, the Permittee shall apply for a minor modification of this permit to address the actual maximum rated capacity achieved in**  **practice. The Commissioner may require stack testing for natural gas and distillate firing at any time to demonstrate compliance with the above emission limits.**  **The Commissioner may require the Permittee to stack test at typical operating loads for**  **recurring tests if necessary.**

All stack emissions tests shall be conducted in accordance with the requirements of Section 22a-174-5 of the RCSA. The Commissioner may attach additional requirements to the requirements of Section 22a-174-5 in order to demonstrate continual compliance with the requirements of this permit.



### PART VII. SPECIAL REQUIREMENTS

**A.** The Permittee shall possess, at least, 195 tons of emissions reductions of NOx to offset the quantity of NOx emitted from this source to comply with RCSA Subsection 22a-174-3a(l). Such a quantity is sufficient to

offset the emissions from the source listed at a ratio of 1.2 tons of reduction for every 1 ton of NOx emissions allowed under this permit. There are 24.2 tons of internal emissions reductions (offsets) allowed from the actual NOx emissions from this boiler prior to the modification based on calendar years 2007 and 2008. After the internal offsets are considered, **the Permittee shall possess 171 tons of external emissions**

**reduction credits.** Such offsets have been obtained from the following source: Devon Power LLC (Serial # CTNOx0304-105-14-171). The offsets were approved by the Department on March 30, 2010. The Permittee shall maintain sole ownership and possession of these external emission reduction credits for the duration of this permit and any subsequent changes to the permit.

**B.** The Permittee shall not operate the existing 2.5 MW diesel generators, R107-0021 and R107-0022, for more than 30 hours/day combined when firing Unit 5 on biomass. The Permittee shall make and keep records sufficient to demonstrate compliance with this operating limitation.FIRM NAME: Montville Power LLC EQUIPMENT LOCATION: 74 Lathrop Road, Uncasville, CT 06382 EQUIPMENT DESCRIPTION (MODEL, I.D. #): 42 MW (net) biomass stoker fired; 82 net MW tangentially fired fossil fuel fired utility boiler

Town No: 107 Premises No: 5 Permit No: 0056 Stack No: 1 

### Page 16 of 19



## PERMIT FOR FUEL BURNING EQUIPMENT

**STATE OF CONNECTICUT, DEPARTMENT OF ENVIRONMENTAL PROTECTION**
**BUREAU OF AIR MANAGEMENT**

C . F or one calendar year from the date of commencement of commercial operation, the Permittee shall track steady state and transient emissions of CO, Opacity, SOx, NOx, VOC and PM-2.5/10 during operation of the boiler. Emissions of SOx, NOx, Opacity and CO shall be tracked by means of the required continuous emissions monitoring systems, in

accordance with 40 CFR Part 75. Emissions of VOC and PM-10 shall be correlated to fuel flow, boiler output or the combination thereof during the initial stack tests performed in accordance with Part VI of this permit.

Within sixty (60) days of the end of one (1) calendar year or 1,000 hours of commercial operations of the boiler, whichever occurs later, the Permittee shall submit a report of observed steady state and transient emissions and of any operating parameters observed in order to estimate transient emissions. Together with submission of the report, the permittee shall apply for a permit modification to incorporate a table of emission limits for transient operation along with the TBD parameters listed in Part II.A of this permit. Transient emission limits will be established and incorporated into the permit for any pollutant for which transient operation shows a deviation from the steady state emission limits in Part V of this permit.

The Permittee may be required to obtain additional NOx offsets and complete additional ambient air quality analysis to show that the NAAQS

and PSD increments have not been violated. All transient emissions

shall be counted toward the annual emissions limits in Part V of this permit.

**D.** Noise

The Permittee shall operate this facility at all times in a manner so as not to violate or contribute significantly to the violation of any applicable state noise control regulations, as set forth in RCSA Sections 22a-69-1 through 22a-69-7.4.

**E.** The Permittee shall comply with all applicable sections of the following New Source Performance Standard(s) at all times.

40 CFR Part 60, Subparts: A and Db

Copies of the Code of Federal Regulations (CFR) are available online at the U.S. Government Printing Office website.FIRM NAME: Montville Power LLC EQUIPMENT LOCATION: 74 Lathrop Road, Uncasville, CT 06382 EQUIPMENT DESCRIPTION (MODEL, I.D. #): 42 MW (net) biomass stoker fired; 82 net MW tangentially fired fossil fuel fired utility boiler

Town No: 107 Premises No: 5 Permit No: 0056 Stack No: 1 

### Page 17 of 19



## PERMIT FOR FUEL BURNING EQUIPMENT

**STATE OF CONNECTICUT, DEPARTMENT OF ENVIRONMENTAL PROTECTION**
**BUREAU OF AIR MANAGEMENT**

**PART VII. SPECIAL REQUIREMENTS, continued**

**F.** The Permittee shall comply with all applicable requirements of the Federal Acid Rain Program codified in Title 40 CFR Parts 72-78, inclusive, by the deadlines set forth within the aforementioned regulation.

**G.** Unless directed otherwise by the Commissioner, if construction does not commence within eighteen (18) months from the date of issuance of this permit, the Permittee shall submit a written updated review of all prior

BACT determinations for this unit. The Permittee shall submit this review to the Commissioner within 30 days of the end of such 18 month period.

**H.** The Permittee shall notify the commissioner, in writing, of the commencement of construction, any lapse in construction lasting for more than eighteen (18) months after actual construction has begun, completion of construction and commencement of commercial operation of

this source. Such written notifications shall be submitted no later than 30 days after the subject event. Commencement of commercial operations shall mean the date when the unit is released to ISO-New England for dispatch.



### PART VIII. ADDITIONAL TERMS AND CONDITIONS

**A.** This permit does not relieve the Permittee of the responsibility to conduct, maintain and operate the regulated activity in compliance with all applicable requirements of any federal, municipal or other state agency. Nothing in this permit shall relieve the Permittee of other obligations under applicable federal, state and local law.

**B.** Any representative of the DEP may enter the Permittee's site in

accordance with constitutional limitations at all reasonable times without prior notice, for the purposes of inspecting, monitoring and enforcing the terms and conditions of this permit and applicable state

law.

**C.** This permit may be revoked, suspended, modified or transferred in accordance with applicable law.FIRM NAME: Montville Power LLC EQUIPMENT LOCATION: 74 Lathrop Road, Uncasville, CT 06382 EQUIPMENT DESCRIPTION (MODEL, I.D. #): 42 MW (net) biomass stoker fired; 82 net MW tangentially fired fossil fuel fired utility boiler

Town No: 107 Premises No: 5 Permit No: 0056 Stack No: 1 

### Page 18 of 19



## PERMIT FOR FUEL BURNING EQUIPMENT

**STATE OF CONNECTICUT, DEPARTMENT OF ENVIRONMENTAL PROTECTION**
**BUREAU OF AIR MANAGEMENT**

**PART VIII. ADDITIONAL TERMS AND CONDITIONS, continued**

**D.** This permit is subject to and in no way derogates from any present or future property rights or other rights or powers of the State of Connecticut and conveys no property rights in real estate or material, nor any exclusive privileges, and is further subject to any and all public and private rights and to any federal, state or local laws or regulations pertinent to the facility or regulated activity affected thereby. This permit shall neither create nor affect any rights of persons or municipalities who are not parties to this permit.

**E.** Any document, including any notice, which is required to be submitted to the commissioner under this permit shall be signed by a duly authorized representative of the Permittee and by the person who is responsible for actually preparing such document, each of whom shall certify in writing

as follows:

“I have personally examined and am familiar with the information submitted in this document and all attachments thereto, and I certify that based on reasonable investigation, including my inquiry of those individuals responsible for obtaining the information, the submitted information is true, accurate and complete to the best of my knowledge and belief. I understand that any false statement made in the submittedinformation may be punishable as a criminal offense under section 22a175 of the Connecticut General Statutes, under section 53a-157b of the Connecticut General Statutes, and in accordance with any applicable

statute.”

**F.** Nothing in this permit shall affect the commissioner's authority to institute any proceeding or take any other action to prevent or abate violations of law, prevent or abate pollution, recover costs and natural resource damages, and to impose penalties for violations of law, including but not limited to violations of this or any other permit issued to the Permittee by the commissioner.

**G.** Within 15 days of the date the Permittee becomes aware of a change in any information submitted to the commissioner under this permit, or that any such information was inaccurate or misleading or that any relevant information was omitted, the Permittee shall submit the correct or

omitted information to the commissioner.FIRM NAME: Montville Power LLC EQUIPMENT LOCATION: 74 Lathrop Road, Uncasville, CT 06382 EQUIPMENT DESCRIPTION (MODEL, I.D. #): 42 MW (net) biomass stoker fired; 82 net MW tangentially fired fossil fuel fired utility boiler

Town No: 107 Premises No: 5 Permit No: 0056 Stack No: 1 

### Page 19 of 19



## PERMIT FOR FUEL BURNING EQUIPMENT

**STATE OF CONNECTICUT, DEPARTMENT OF ENVIRONMENTAL PROTECTION**
**BUREAU OF AIR MANAGEMENT**

**PART VIII. ADDITIONAL TERMS AND CONDITIONS, continued**

**H.** The date of submission to the commissioner of any document required by this permit shall be the date such document is received by the commissioner. The date of any notice by the commissioner under this permit, including but not limited to notice of approval or disapproval of any document or other action, shall be the date such notice is personally delivered or the date three days after it is mailed by the commissioner, whichever is earlier. Except as otherwise specified in this permit, the word "day" means calendar day. Any document or action which is required by this permit to be submitted or performed by a date which falls on a Saturday, Sunday or legal holiday shall be submitted or performed by the next business day thereafter.

**I.** Any document required to be submitted to the commissioner under this permit shall, unless otherwise specified in writing by the commissioner, be directed to: Office of Director; Engineering & Enforcement Division; Bureau of Air Management; Department of Environmental Protection; 79 Elm Street, 5th Floor; Hartford, Connecticut 06106-5127.