79 Elm Street, Hartford, CT 06106-5127 

www.ct.gov/deep 

Affirmative Action/Equal Opportunity Employer

Connecticut Department of 

ENERGY & 

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 

Modification Issue Date: May 20, 2013 

Prior Permit Issue Date: April 6, 2010 

Expiration Date: None 

/s/ Anne Gobin fo May 20, 2013 

Daniel C. Esty Date 

Commissioner
Page 2 of 20 

PERMIT FOR FUEL BURNING EQUIPMENT

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 

BUREAU OF AIR MANAGEMENT

 

 

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 

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 @50% moisture. 2. Maximum firing rate: 65.2 tons/hr 
Page 3 of 20 

PERMIT FOR FUEL BURNING EQUIPMENT

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 

BUREAU OF AIR MANAGEMENT

 

 

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 

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 Types Description

Land Clearing debris Chipped trees, stumps, branches or brush as 

defined in RCSA 22a-208a-1 

Recycled wood or clean wood Recycled wood or clean wood means any 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 

wood. [CGS 22a-209a][RCSA 22a-208a-1]

Other Clean Wood Other types if properly sized, clean, 

uncontaminated wood materials, such as 

sawdust, chips, bark, tree trimmings or 

other 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/ft3

) ≤ 610,134 MMBtu 

Where, X = gallons of ULS distillate oil fired over any consecutive 12 

month period. 

 Y = ft3

 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) 
Page 4 of 20 

PERMIT FOR FUEL BURNING EQUIPMENT

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 

BUREAU OF AIR MANAGEMENT

 

 

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 

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. 
Page 5 of 20 

PERMIT FOR FUEL BURNING EQUIPMENT

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 

BUREAU OF AIR MANAGEMENT

 

 

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 

PART I. OPERATIONAL CONDITIONS, continued 

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. 

E. Expected Control Efficiency 

Type of control Overall control 

efficiency* Pollutants Controlled

Regenerative Selective 

Catalytic Reduction 

(RSCR) 

70% biomass

30% gas/oil 

NOx 

Low NOx burners 30% gas/oil NOx 

Electrostatic 

Precipitator (ESP) 

95% Filterable PM/PM-10/PM- 2.5 

Oxidation Catalyst 70% CO and VOC 

* 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): 350-6500F (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 
Page 6 of 20 

PERMIT FOR FUEL BURNING EQUIPMENT

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 

BUREAU OF AIR MANAGEMENT

 

 

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 

PART II. CONTROL EQUIPMENT, continued 

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 (%): 95 of filterable PM (99% with 

multicyclone) 

4. Oxidation Catalyst 

Make and Model: TBD 

Pressure Drop (inches H2O): 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 H2O): 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 include good operating and maintenance practices based on 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, preventative measures for the 

fugitive GHG emissions (CH4 from the natural gas pipeline 

components; SF6 emission from the insulated electrical equipment), 

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: 
Page 7 of 20 

PERMIT FOR FUEL BURNING EQUIPMENT

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 

BUREAU OF AIR MANAGEMENT

 

 

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 

PART II. CONTROL EQUIPMENT, continued 

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. 

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 or an acceptable alternative monitoring method 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%1 SOx 3 hour block 10.8 ppmvd @ 7% O2

 NOx 24 hour block 36.2 ppmvd @ 7% O2 

 CO 8 hour block 99.1 ppmvd @ 7% O2 

 CO2 1 hour ppmvd @ 7% O2 

 O2 1 hour block 

 Ammonia 24 hour block 18 ppmvd @ 7% O2

 Unit Load 4 hour block steam flow 

1 Opacity limit is applicable for all fuels during steady-state operation. 
Page 8 of 20 

PERMIT FOR FUEL BURNING EQUIPMENT

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 

BUREAU OF AIR MANAGEMENT

 

 

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 

PART III. CONTINUOUS EMISSION MONITORING REQUIREMENTS AND 

 ASSOCIATED EMISSION LIMITS, continued Applicable if -XChecked)

Pollutant/Operational Averaging Emission 

 Parameter Times Limit Units

 RSCR Temperature 1 hour block 

 Oxid. Cat. Temperature 1 hour block 

 T-R secondary voltage Hourly 

 Heat Input Hourly Btu 

 Gross Electrical Output 1 hour block MW 

 Biomass Feed Rate Hourly lbs 

The Permittee shall meet the performance and quality assurance 

specifications for the operation of CEM equipment pursuant to RCSA Section 

22a-174-4. 

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. 
Page 9 of 20 

PERMIT FOR FUEL BURNING EQUIPMENT

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 

BUREAU OF AIR MANAGEMENT

 

 

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 

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

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. 

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. 
Page 10 of 20 

PERMIT FOR FUEL BURNING EQUIPMENT

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 

BUREAU OF AIR MANAGEMENT

 

 

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 

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

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 make and keep records of estimated fugitive GHG 

emissions for CH4 (natural gas pipeline components) and SF6

(insulated electrical equipment). Records shall be sufficient to 

show methodology used to determine emission values. 

16. 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 shall 

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. 
Page 11 of 20 

PERMIT FOR FUEL BURNING EQUIPMENT

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 

BUREAU OF AIR MANAGEMENT

 

 

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 

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

2. The Permittee shall submit sufficient documentation to the Department at 

least 60-days prior to commencement of commercial operation that the 

energy efficiency measures found in Part VII.D.1 of this permit have 

been incorporated into the unit. 

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, whichever 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. 

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% O2)2 

PM-10/2.5 (total)3 15.6 0.026 

SOx 15 10.8 

NOx 36 36.2 

VOC 6.0 0.01 

CO 60.0 99.1 

Pb 2.88E-2 4.8E-5 
Page 12 of 20 

PERMIT FOR FUEL BURNING EQUIPMENT

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 

BUREAU OF AIR MANAGEMENT

 

 

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 

Auxiliary Fuel 

Distillate Oil: lb/hr lbs/MMBtu

Pollutants monitored by CEMS

(ppmvd @3% O2)

PM-10/2.5 (total)3 23.4 0.024 

SOx 1.7 1.0 

NOx 59.7 46.9 

VOC 1.4 0.0014 

CO 35.5 46.2 

Auxiliary Fuel 

Natural Gas: lbs/MMBtu

Pollutants monitored by CEMS

(ppmvd @3% O2)

PM-10/2.5 (total)3 7.6 0.0076 

SOx 0.6 0.4 

NOx 59.7 49.4 

VOC 5.5 0.0055 

CO 83.6 113.7 

Other Pollutants 

Ammonia (all fuels) 18 

2 Equivalent mass emission rate based on wood F-factor of 9,240 dscf/MMBtu. [40CFR 

Part 60, Appendix A, Table 19-2] 

3

 PM-10/2.5 (total) is the sum of the filterable and condensable fractions 

of particulate matter. 

C. Annual Emission Limits: 

The Permittee shall not cause or allow this equipment to exceed the annual 

emission limits stated herein at any time. 

Criteria 

Pollutants tpy 

PM-10/2.5 (total) 69.4 

SOx 60.4 

NOx 161.9 

VOC 25.6 

CO 265.0 
Page 13 of 20 

PERMIT FOR FUEL BURNING EQUIPMENT

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 

BUREAU OF AIR MANAGEMENT

 

 

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 

PART V. ALLOWABLE EMISSION LIMITS, continued 

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. 

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/deep/lib/deep/air/compliance_monitoring/emission_test/

emission_test_guidelines.pdf

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; NH3
Page 14 of 20 

PERMIT FOR FUEL BURNING EQUIPMENT

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 

BUREAU OF AIR MANAGEMENT

 

 

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 

PART VI. STACK EMISSION TEST REQUIREMENTS, continued

 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 along with a determination of the methodology to be 

used to monitor heat input to the unit while firing biomass. 

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: 

1. After the initial stack test, stack testing may not be required for 

pollutants requiring CEMs/COMS (NOx, SOx, CO, Opacity, and NH3). The 

commissioner retains the right to require stack testing of any 

pollutant at any time to demonstrate compliance. 

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. 

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. 
Page 15 of 20 

PERMIT FOR FUEL BURNING EQUIPMENT

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 

BUREAU OF AIR MANAGEMENT

 

 

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 

PART VI. STACK EMISSION TEST REQUIREMENTS, continued

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. 

C. For 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. 
Page 16 of 20 

PERMIT FOR FUEL BURNING EQUIPMENT

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 

BUREAU OF AIR MANAGEMENT

 

 

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 

PART VII. SPECIAL REQUIREMENTS, continued

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. Greenhouse Gas Requirements: 

1. The Permittee shall incorporate the following energy efficiency 

measures: 

i. Replacement of the existing continuous fin economizer with a 

bare-tube in-line economizer. 

ii. Removal of a portion of the existing low temperature superheater 

(LTSH). 

iii. Conversion of the existing air soot blower system to a steam 

soot blowing system, and; 

iv. Replacement of the air heater baskets with units designed for 

biomass firing. 

2. The Permittee shall not exceed a maximum allowable heat rate for the 

unit while firing biomass of 15,564 Btu/kW-hr (gross) with a rolling 

12-month averaging period. 

i. The Permittee shall determine an appropriate methodology to 

monitor heat input to the unit while firing biomass during the 

initial stack test and submit a report of the findings within 30 

days after completion of the initial stack test. 
Page 17 of 20 

PERMIT FOR FUEL BURNING EQUIPMENT

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 

BUREAU OF AIR MANAGEMENT

 

 

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 

PART VII. SPECIAL REQUIREMENTS, continued

ii. The Permittee shall monitor and record heat input to the unit 

while firing biomass as determined by the initial stack test. 

iii. Gross electrical output will be the sum of the hourly data as 

metered by the station. 

3. The Permittee shall calculate the total allowable heat rate to 

determine plant efficiency by the following equation: 

η = [(percent biomass heat input) x (15,564 btu/kW-hr (gross))] + [(percent 

natural gas input) x (12,448 Btu/kW-hr)(gross)] + [(percent ULSD heat 

input) x 12,304 Btu/kW-hr (gross)] 

Note: The heat rates for each fuel represent an actual measure of 

plant efficiency for that mode of operation and are to be considered 

an enforceable permit condition. 

4. The Permittee shall not exceed an annual CO2e emission limit of 

590,109 tons/year from the following: 

i. CO2 emissions from fuel combustion shall be determined by CEMS 

data. 

ii. CH4 and N2O emission from fuel combustion shall be determined 

using the default emissions factors found in 40 CFR Part 98. 

iii. Estimated Fugitive Emissions of SF6 from the insulated 

electrical equipment. 

iv. Estimated fugitive emissions of CH4 from the natural gas 

pipeline and components for this unit. 

5. The Permittee shall track and evaluate the heat rate, overall 

efficiency and CO2e emissions over the first year of commercial 

operation for all modes of operation and evaluate the need to revise 

the operating limits, design/operational variables and averaging 

periods at that time. The Permittee shall submit a written report 

to the Commissioner of this analysis within 60-days after the first 

year of commercial operation. 
Page 18 of 20 

PERMIT FOR FUEL BURNING EQUIPMENT

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 

BUREAU OF AIR MANAGEMENT

 

 

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 

PART VII. SPECIAL REQUIREMENTS, continued

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. 

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 DEEP may enter the Permittee's site in 
Page 19 of 20 

PERMIT FOR FUEL BURNING EQUIPMENT

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 

BUREAU OF AIR MANAGEMENT

 

 

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 

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. 

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 submitted 

information 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. 
Page 20 of 20 

PERMIT FOR FUEL BURNING EQUIPMENT

DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION 

BUREAU OF AIR MANAGEMENT

 

 

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 

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 Energy and Environmental 

Protection; 79 Elm Street, 5th Floor; Hartford, Connecticut 06106-5127. 
NSR Engineering Evaluation

CT Department of Energy and Environmental Protection 

Bureau of Air Management 

 

Administrative Information 

Date Application Received: 12/3/2012 

SIMS No: 201207376 

Applicant Information 

Company Name: Montville Power LLC 

Equipment Location: 74 Lathrop Road, 

Montville, CT 06382 

Mailing Address: P.O. Box 1001, Middletown, 

CT 06106 

Contact Person: Ms. Cynthia Karlic 

Contact Title: Regional Environmental Director 

Contact Phone Number: 860-343-6962 

Contact E-mail: cynthia.karlic@nrgenergy.com 

Evaluation Information 

Date Prepared: 1/30/2013

Prepared By: Mr. James Grillo, jag

Permit Information 

Permit No: 107-0056 

Equipment Description: 42 MW biomass; 82 

MW fossil fuel fired boiler 

Choose a Permit Type: 

Single Unit Multiple Units Multiple Units

NNew NSR at a Ma ew NSR at a Major jor 

Source Source

NNew NSR at a Minor ew NSR at a Minor 

Source Source

Non-Minor 

Modification at a 

Major Source

NNon-Minor on-Minor 

Modification at a Modification at a 

Minor Source Minor Source

Minor Modification Minor Modification 

(prepaid in full) (prepaid in full)

Minor Modification Minor Modification 

(app fee paid only) (app fee paid only)

Revision at a Major Revision at a Major 

Source Source

Revision at a Minor Revision at a Minor 

Source Source

Update Fields

Part I. – Annual Emission Review: Tons Per Year 

Pollutant Premises PTE Permit PTE New Premises PTE 

CO2e N/A 590,103 N/A 

Note: There are no emissions increases for any pollutants due to this non-minor 

modification. 

Part II. – Emissions Summary (TPY) for Major Modification Determination 

(Attachment C) 

Pollutant 

Actual 

Emissions 

(2 yr avg) 

PTE as 

limited by 

permit 

Actual 

Emissions 

Increase/ 

Decrease 

Net 

Emissions 

Change 

Significance 

Levels (Table 

3a(k)-1 

Increase Equal 

or greater than 

Table 3a(k)-1? 

CO2e >100,000 100,000 Yes 
Montville Power LLC Page 2 of 6 

Part III. – Emissions Standards Review and Regulatory Authority 

a. 

Regulatory Standard Allowable Rate(s) Basis 

CO2e: 

RCSA §22a-174-31 

590,103 tpy 

15,564 Btu/kWh CEM and 40 CFR Part 98 

b. Source subject to: NSPS – 40 CFR Part 60 Subpart A and Db 

 NESHAP – 40 CFR Part 61 Subpart 

 NESHAP – 40 CFR Part 63 Subpart 

 None 

 

 Note: Any source subject to NESHAP Part 63 will be subject, in part, to Part 59 General Provisions 

as well. 

c. Hazardous Air Pollutant Compliance (RCSA §22a-174-29) (Attachment A): N/A 

Part IV. – Ambient Impact Analysis: 

Note Additional Ambient Impact Analysis is not required for this non-minor modification. The 

original analysis was reviewed and approved on December 4, 2009. 

Part V. – PSD Review 

Source is subject to PSD Review: Yes 

Source netted out of PSD Review (Attachment C1) : No 

Note: Source is subject to additional PSD review pursuant to RCSA 22a-174-3a(k)(2)(C). There are 

no additional PSD pre-construction analysis required for CO2e. 

Part VI. – Non-attainment Review: N/A 

Part VII. – Control Technology Analysis: 

a. BACT/MACT Compliance: Yes 

b. BACT/MACT Utilized (Attachment C): 

 

 Pollutant BACT/MACT

 CO2e Energy Efficiency measures 

 Enforceable limit on heat rate 

 Annual limit on CO2e emissions 

Part VIII. Emission Testing Requirements: 

No additional stack testing is required due to this modification. 
Montville Power LLC Page 3 of 6 

Part IX. – Administrative Criteria Review: 

a. Air Quality Status: 

 Ozone: serious non-attainment 

 PM2.5: attainment 

b. Premises size: <15TPY ≥15, <100 TPY ≥100 TPY 

c. Source size: <15TPY ≥15, <100 TPY ≥100 TPY 

d. The source is a new fossil fuel fired unit that serves a generator with a nameplate capacity of 15 

MW or greater or is a new fossil fuel fired boiler or indirect heat exchanger with a maximum heat 

input capacity of 250 MMBTU or more.: Yes; This unit is already identified as a NOx Budget 

Program Source. 

e. Fee (Attachment D): $5,000.00 

f. Signatory responsibilities authorized (Attachment E): Yes 

g. Source entered in SIMS P&E Tracking system: Yes 

h. Source entered in EMIT Permit Tracking System: Yes 

i. Source is in the Coastal Boundary: Yes 

 Source is in the Coastal Area: Yes 

j. Source is on federally recognized Indian lands: No 

k. Source is in a Natural Diversity DataBase Area: No 

l. Source is Subject to conservation/preservation restrictions: No 

m. The source to be permitted combusts coal, waste oil, tires, recycled materials, 

construction/demolition debris, wood products, biological waste or any other non-fossil fuel that 

may contain or emit toxic air pollutants: Yes 

n. The source to be permitted is major for federal HAPs: Yes 

o. The source to be permitted is subject to RCSA §22a-174-22: Yes 

Note: Parts IX.d through (o), except for (e), above were addressed in the initial permitting of 

this source and no changes to the project will affect the determination of above requirements 

Part X. – Maps 

Not Applicable, see note above. 
Montville Power LLC Page 4 of 6 

Part XI. – CGS 22a-6 and 22a-186a Compliance: 

-6g - Certified Notice of Application: Yes 

-6p - Posting of Notice Certification: N/A 

-6m - Compliance Information (Attachment F): Yes 

Part XII. – Summary: 

Montville Power LLC submitted a non-minor modification to NSR permit 107-0056 on December 3, 

2012. The NSR permit that was issued on April 6, 2010 contained a requirement to submit an updated 

Best Available Control Technology (BACT) review if construction did not commence within eighteen 

(18) months from the date of permit issuance. In January 2011 the Department finalized new regulations 

that require Prevention of Significant Deterioration (PSD) review and incorporation of greenhouse gas 

(GHG) BACT limitations for sources that have greater than 100,000 tons/yr of CO2e emission. 

On August 30, 2011 Montville Power submitted a timely updated BACT analysis for the applicable 

criteria pollutants and a new greenhouse gas PSD/BACT review since construction had not been started 

before October 2011. 

In a letter dated October 9, 2012, the Department informed Montville Power that the criteria pollutant 

BACT review was acceptable and that no further action was required by Montville Power concerning the 

BACT for the criteria pollutants. The letter also stated that Montville Power’s proposed limits and energy 

efficiency improvements were BACT for CO2e. (see technical analysis memo and notification letter 

dated 10/05/12 & 10/09/12, respectively) 

A review of the RACT/BACT/LAER Clearinghouse, which included the United States, Canada and 

Mexico, has not found any additional BACT reviews that have been issued since October 2012 . 

Based on the review and approval of the BACT analysis submitted by Montville Power on August 30, 

2011 the following changes have been added to the permit: 

 A requirement to submit documentation at least 60-days prior to commencement of commercial 

operation that the approved energy efficiency methods have been incorporated into the plant 

processes. 

 An enforceable heat rate of 15,564 Btu/kWhr (gross) with a 12-month rolling averaging period. 

Heat input will be monitored by CEMS and the methodology to be used shall be determined during 

the initial performance test. The methodology shall be acceptable to the Department and the 

permittee. 

 An enforceable annual CO2e limit of 590,104 tons/yr. 

 Require the intallation of a CO2 CEMS to measure actual annual emissions. The default emission 

factors found in 40 CFR Part 98 will be used to calculate CH4 and N2O emissions from the 

combustion process and then added to the CEMS data to calculate the total annual CO2e emissions. 
Montville Power LLC Page 5 of 6 

 Included a requirement to estimate fugitive GHG emissions of SF6 from the insulated electrical 

equipment and CH4 emissions from the natural gas pipeline component on site. 

 Require preventative measures for fugitive GHG emissions be included in the O&M plan. 

 Require the permittee to track and evaluate the heat rate of the unit, overall efficiency and CO2e 

emissions over the first year of operation for all modes of operationand evaluate the need to revise 

the operating limits, design/operational variables and averaging periods at that time. A 

requirement to submit a report of the above information. 

The compliance record was reviewed in accordance with the Environmental Compliance History Policy. 

The applicant’s submitted compliance information form was reviewed along with agency records, 

including the SIMS Enforcement database, for information to evaluate the applicant’s compliance history 

and the relevance of such history to the activity for which authorization is being sought. Additionally, a 

review of air program compliance was requested from the Enforcement Section and that response forms a 

part of this record. 

Based on the information submitted by the applicant, this engineering evaluation and the compliance 

history review, the granting of a permit is recommended for Montville Power LLC. 

/s/ James Grillo 2/28/13 

James Grillo, APCE Date 

Approvals: 

/s/ Kiernan Wholean 3/1/13 

Supervisor’s Name 

Supervising APCE 

/s/ Richard Pirolli 3/19/13 

Richard A. Pirolli 

Assistant Director 

 
M E M O R A N D U M 

TO: Richard A. Pirolli, Assistant Director SIMS No.: 201207376 

Date Rec'd: 12/03/2012 

 FROM: James Grillo, APCE 

Kiernan J. Wholean, SAPCE 

SUBJECT: Final Permit to Construct and Operate 42 MW Biomass Utility Boiler for permit 

107-0056 

 

DISCUSSION:

On March 19, 2013, a tentative determination was made to issue a non-minor permit modification to 

construct and operate a 42 MW biomass utility boiler located in Montville, CT to Montville Power 

LLC. The Notice of Tentative determination was published in The Day on March 20, 2013. The 45-

day comment period expired on May 3, 2013. The permit fee and publication fee have been paid in 

full. 

 There were no comments from the public. 

 On April 16, 2013 the applicant submitted one minor comment to the draft permit (see attached 

letter). The applicant commented that the heat rate for natural gas firing was listed incorrectly 

in the draft permit and that it should be consistent with the value that was submitted in the 

permit application. 

 No comments were received from EPA. 

The following changes have been made to the draft permit: 

 Changed the heat rate for natural gas in the Part VII.D.3 equation from 11,963 Btu/kW-hr to 

12,448 Btu/kW-hr. 

 Based on recent conversations with the stack test group the permit was changed from having 

separate emissions rates for the filterable and condensable fractions for particulate matter to 

one “PM-10/2.5 (total)” emissions rate for all fuels. The following note was added after the 

emissions table to clarify that total emissions include both the filterable and condensable 

fractions PM-10/2.5: 

“PM-10/2.5 (total) is the sum of the filterable and condensable fractions of particulate matter. 

The reason for this change is that during the performance test the source could fail either the 

filterable or condensable emissions limit but still comply with the total emissions limit and still 

be issued a Notice of Violation (NOV). The refined modeling analysis that was completed 

during the initial permitting was based on a total emissions rate and the permittee should not be 

penalized for exceeding the fractional PM emissions rates if the total emissions are not 

exceeded. 

 The lb/MMBtu emissions limits for the CEM (NOx, SOx, and CO) monitored pollutants have 

also been removed from the permit. There is no reason to have three emissions limits for these 

pollutants in the permit. The refined modeling that was completed was based on a (lb/hr) 

emissions rate and there is no reason to have an additional rate to show compliance with during 

the performance testing. 

-2- 
Montville Power LLC 

RECOMMENDATION:

It is recommended to issue the non-minor modification for permit 107-0056 to Montville Power LLC, 

Montville, CT. 

/s/ James Grillo 5/14/13 

James Grillo, APCE Date 

REVIEW: 

/s/ Kiernan Wholean 5/14/13 

Kiernan J. Wholean, Supervising APCE