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 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 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

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)**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 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% F ilterable P M/PM

- 1 0/PM

- 2 .5 Oxidation Catalyst 7 0% C O 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): 350-650 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**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 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 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 (CH 4 from the natural gas pipeline
components; SF 6 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% O 2 NOx 24 hour block 36.2 ppmvd @ 7% O 2 CO 8 hour block 99.1 ppmvd @ 7% O 2 CO 2 1 hour 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

**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 CH 4 (natural gas pipeline components) and SF 6 (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% O 2**  **) 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% O 2**  **)**
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% O 2**  **)**
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; NH 3**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 (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.

**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 . 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.**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 CO 2 e emission limit of 590,109 tons/year from the following:

i. CO 2 emissions from fuel combustion shall be determined by CEMS

data.

ii. CH 4 and N 2 O emission from fuel combustion shall be determined using the default emissions factors found in 40 CFR Part 98.

iii. Estimated Fugitive Emissions of SF 6 from the insulated electrical equipment.

iv. Estimated fugitive emissions of CH 4 from the natural gas pipeline and components for this unit.

5. The Permittee shall track and evaluate the heat rate, overall efficiency and CO 2 e 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 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.**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 Multi p le Units Multiple Units

New NSR at a Ma j or N ew NSR at a Major

Source Source New NSR at a Minor N ew NSR at a Minor

Source Source

N on-Minor

Modification at a Major Source Non-Minor N on-Minor

Modification at a Modification at a

Minor Source Minor Source

Minor Modification Minor Modification (p re p aid in full ) (prepaid in full) Minor Modification Minor Modification ( a pp fee p aid onl y) (app fee paid only)

Revision at a Ma j or 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

CO 2 e N/A 590,103 N/A



### Note: There are no emissions increases fo r 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?

CO 2 e >100,000 100,000 YesMontville Power LLC Page 2 of 6



### Part III. – Emissions Standards Re view and Regulatory Authority

a. Regulatory Standard Allowable Rate(s) Basis

CO 2 e: 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 no t required for this non-minor modification. The original analysis was reviewed a nd 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 rev iew pursuant to RCSA 22a-174-3a(k)(2)(C). There are no additional PSD pre-construction analysis required for CO 2 e.



### 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

CO 2 e Energy Efficiency measures

Enforceable limit on heat rate

Annual limit on CO 2 e 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), ab ove were addressed in the initial permitting of this source and no changes to the project will affect the determinatio n 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 modifi cation 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 Ja nuary 2011 the Department finalized new regulations that require Prevention of Significant Deteriorati on (PSD) review and incorporation of greenhouse gas (GHG) BACT limitations for sources that have greater than 100,000 tons/yr of CO 2 e emission.

On August 30, 2011 Montville Power submitted a time ly 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 in formed Montville Power that the criteria pollutant BACT review was acceptable and that no further act ion was required by Montville Power concerning the BACT for the criteria pollutants. The letter also stat ed that Montville Power’s proposed limits and energy efficiency improvements were BACT for CO 2 e. (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 an alysis 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 (g ross) with a 12-month rolling averaging period. Heat input will be monitored by CEMS and the me thodology to be used shall be determined during the initial performance test. The methodology sh all be acceptable to the Department and the permittee.

 An enforceable annual CO 2 e limit of 590,104 tons/yr.

 Require the intallation of a CO 2 CEMS to measure actual annual emissions. The default emission

factors found in 40 CFR Part 98 will be used to calculate CH 4 and N 2 O emissions from the combustion process and then added to the CEMS data to calculate the total annual CO 2 e emissions.Montville Power LLC Page 5 of 6

 Included a requirement to estimate fugitive GHG emissions of SF 6 from the insulated electrical equipment and CH 4 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 h eat rate of the unit, overall efficiency and CO 2 e emissions over the first year of operation for a ll 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 Environmen tal Compliance History Policy. The applicant’s submitted compliance information fo rm was reviewed along with agency records, including the SIMS Enforcement database, for informa tion 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