Vermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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Air Pollution Control Division

March 29, 2013 Page 1 of 28 

### Response t o Commen t s

Draft Air Pollution Control Permit to Construct for North Springfield
Sustainable Energy Project

, LLC (NSSEP) issued August 9, 2012

On August 9, 2012 the Verm o nt Agency of Natural Resources, De p artment of

Environme n tal Conservation, Air Pollution Cont r ol Division ( Agency) issued a D raft Air

Pollution Control Permit to Construct to North Springfield Sustainable Energy Project,

LLC (NSSEP)

. The Agency then held a public meeting on August 29, 2012 to accept oral

and written comments regarding the draft air permit. In addition, the Agency accepted

written comments on t h e Draft Air Pollution Con t rol Permit to Construct until September

10, 2012.

The Agency has summarized herein all the oral and writt e n comments submitted

regarding the draft Air Permit and is providing the Agency’s res p onses to th o s e

comments below. Similar comments and concerns have been grouped together into

a single response where appropriate

. A list of all commenters is provided at the end

of this document.

During the comment period, t he Agency received a number of comments that fall

outside the scope of the Agency’s air permitting authority, and in many cases beyond

the Agency’s area of expertise with respect to air pollution . The Agency’s air permitting

process is governed by 10 VSA Chap. 23. The statutory provisions contained therein

delegate to the Agency the authority to grant permits to contro l sources of air pollution.

To implement this permitting authority, the Agency promulgated the Vermont Air

Pollution Control Regulations to establish the requirements that permit applicants must

follow when applying for an air permit. Under 10 VSA §556(c ), the Agency is required

to issue an air pollution permit to construct if “the secretary determines that the

proposed construction or installation of an air contaminant source will be in compliance

with all requirements of this chapter and the rules adopt ed under this chapter.” On the

other hand, 10 VSA §556(c) requires the secretary to deny the permit if the Agency

“determines that the proposed construction or installation of an air contaminant source

will not be in compliance with all requirements of th is chapter and the rules adopted

under this chapter.” Thus, the scope of the Agency’s permitting authority is limited to

determining whether a permit application has complied with the requirements in 10 VSA

Chap. 23 and Vermont’s Air Pollution Control Reg ulations. Thus, with respect to

comments that exceed the Agency’s jurisdiction under 10 VSA Chap. 23 , the Agency’sVermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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Air Pollution Control Division

March 29, 2013 Page 2 of 28 response simply notes that the issue(s) raised by the comment fall outside the scope of

the Agency’s permitting authority.

The Vermont Agen cy of Natural Resourc es, Department of Environmental

Conservation, Air Pollution Control Division (Agency) has summarized herein all the

written comments submitted and is providing the Agency’s responses to those

comments below.



### Comments related to the size of the project:

Comment #1: T h e f a c i l i t y r a t i n g in M We d o e s n o t m a t c h w h at h as b ee n f i l e d at t h e

P S B ( Commenters 3, 9, 26)

T h e draft p e r mi t s tat e s ( p. 2) “ T he high p r e s s u r e s te a m is di r ec t e d to a mult i

- s ta g e

c on d e n s ing s t e am t u r bi

n e

- g e n e r ato r

, w i t

h a ma x i mum g r o s s e l e c t r i c al out p ut o f

a

p

p r o

x

i mat e l

y 42

. 5 M W e . Due to in t e r nal e n e r gy d e ma n d s , the F a c i l i t

y is d e s ig n e d to

p r od u c e an a ve r a g e of a pp r o

x

ima t e ly 37 M W e ( n e t) f or s al e ”

T h i s do e s n ot m a tch s ta t e m e n ts m a de to t h e PS B w h e r e t h e a pp li ca n t h a s r e p ea t e d l y

s ta t e d t h a t t h e f ac i l i t y w i ll be b e t w e e n 25 a n d 35 M W i n ca p a c i t y

. W ood u s e by t h e

f ac i l i ty h a s b e e n e s t i m a ted b a s e d on a to t a l ca p ac i ty of 35 M W

. T h e d i f f e r e n c e i n

wood u s e b e t w ee n a 4 2

. 5 M W p l a n t a n d a 35 M W p l a n t i s s u b s t a n t i a l

. T h i s po in t

n ee ds to be c l a r i f i e d a n d t h e w o o d u s e n u m b e r s c o rr e c t e d i f th i s p l a n t i s r ea l ly g o i ng to

be t hi s l a r g e

.

Response: On 12/22/2011 H. Dana Smith, of Waldron Engineering and Construction
Incorporated, provided testimony on behalf of the NSSEP to the Vermont Public
Service Board. On page 3 of this testimony Mr. Smith indicated ”when at full load, the
facility will consume approximately 50 tons per hour of natural biomass wood fuel and it
will generate 35,000 kW of power at 46,000 kV, deli vered to CVPS Fellows Gear

Substation.”

The Air Pollution Control Permit application was submitted for a 35 MW (35,000 kW)
net electric capacity. This electric output is consistent with the testimony noted above.
Additionally the fuel usage value provi ded by Mr. Smith is similar to the Agency’s
estimated hourly fuel usage rate of 51.5 tons/yr. During the development of the draft
permit, NSSEP refined their system design and increase d the proposed plant’s overall
energy efficiency so they could achieve a net electrical output of 37 MW without
increasing the energy input (wood fuel usage) to the boiler. Thus

, the Agency has
estimated emissions and wood fuel consumption based on the full 42.5 MW gross and
37 MW net electric power generation.Vermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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Air Pollution Control Division

March 29, 2013 Page 3 of 28

Comment #2 : The proposed large scale biomass electric project is not in

- line with Governor Shumlin’s goals for reducing CO 2 emissions and/or for renewable energy
development. ( Commenters 4, 9, 24, 27)

Response: The issue raised by this comment is outside the scope of the Agency’s

air permitting authority under 10 VSA Chap. 23, and therefore the Agency is not
considering it in the final decision for this permit.



### Comments related to emission calculations and BACT /MSER:

Comment # 3 : Potential to emit has been calculated incorrectly ( Commenter 26)

Page 5 of the draft technical support document states: the Permittee has not proposed
any operating limits for the Boiler. However, the annual potential to emit calculations are based on an average heat input of 464 MMBtu/hr (vs. the maximum design heat
input of 502 MMBtu/h r), for 365 days per year, so the permit will have an annual heat
input limit of 4,064,640 MMBtu/yr. Assuming 4,500 Btus per pound of 45% moisture
wood, this equates to approximately 451,627 tons/yr of wet wood fuel.

Page 6 of the draft technical support document states: for the Boiler, the calculated

a llowable annual emissions of SO 2 , NOx, PM, CO and VOCs are based on the
established emission limits expressed in lbs/MMBtu and an annual average maximum
heat input of 464 MMBtu/hr.

This is not the correct way to calculate the potential to emit (PTE). The PTE is correctly
calculated by multiplying the maximum heat input capacity of the boiler (502 mmbtu) by
the maximum hours of operation (8760) by the emission rate of the pollutant.

The avoidance of correctly estimating PTE is explained on page 20 of the permit, which
states that the heat input of the facility will be limited to 4,064,640 mmbtu per 12 month
period. However, there is little evidence that this limit can be enforced.

Respon s e: The rev iew of this permit appli c at ion follow e d the guid a nce in the U.S. EPA

‘New Sour c e Review Workshop Manual ( D raft October 1990). In this guidan c e

docu m ent, the potential to emit (PTE) m ay inc l ude limitations such as restrictions
on design ca p acity utiliz a tions, restr i ctions on hours of operation and restrictions
on the types or amount of material processed. The heat input limit of 4,064,640
MMBtu/hr per 12 month period is a permitted limit and is used to limit the PTE.Vermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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Air Pollution Control Division

March 29, 2013 Page 4 of 28

The heat input limit is enforce able since the heat input to the boiler will be

calculated and recorded on an hourly basis and can be averaged over the course
of a full year.

The Equipment Specifications table on page 3 of the draft permit will be changed
to reflect that 464 MMBtu/hr ( with 45% moisture content fuel) is the annual
average ‘maximum’ heat input to the boiler, while 505 MMBtu/hr is the short term
maximum heat input. The purpose of identifying a higher short term heat input, is
to recognize that during periods of time when firing very wet fuel, the pollutant
emission rate will be higher, and the short term ( ≤ 24 hour standards) NAAQS
review must be conducted with these higher pollutant emission rates. Conversely,
compliance with the annual NAAQS was based on the annual aver age heat input

limit.

Comment # 4 : T h e emission rate of pollutants from this project will be greater than
coal plants: wood is dirtier than coal (4, 14, 23, 24, 25, 27, 29)

Response: Some of the comparisons for pollutant emission rates from NSSEP and the
Mount Tom Coal Plant have shown the reported actual emission rates from Mt. Tom
and comparing them to the proposed permit limits for NSSEP. A more appropriate

comparison would be to c ompare the permitted emission limits for Mt. Tom and the
proposed emission limits for NSSEP. Most of the limits in the draft NSSEP permit are
in terms of heat input, for comparison purposes, these limits have been converted to
electrical output assuming a heat rate of 12,541 Btu/kWh and are shown in the
following table. It should be noted that the Mt. Tom coal plant has been upgraded and
has modern emission control equipment installed and operating: it is much cleaner
than a typical 52

- year old coal plan t.

Permitted Emissions (lb/MWh)

Pollutant Mt. Tom Coal Plant NSSEP

SO2 2 0.25

NOx 1.5 0.38

PM 0.25 0.24

VOC 0.024 0.063

CO 1.66 0.94

CO2 1800 2675

NH3 0.03 0.075Vermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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March 29, 2013 Page 5 of 28

Comment #5: M S E R f o r CO i s n o t re al l y t h e m o s t s t r i n g e n t e m i s s i o n r a t e (Commenter

#26)

P a g e 6 of t h e draft p e r mi t s tat e s t h a t M S E R f or C O i s 0

. 0 75 l b / m m b t u

. T h i s i s n ot t h e

m o s t s t r in g e n t e mi ss i o n r a te. T h e a i r p e r mi t f or t h e P a l m e r Re n e w a bl e E n e r gy f ac i l i t y

,

w h i c h a l s o i n c l u d e s a Ba b c o c k a n d W il c ox bo il e r

, h a s a 1 2 m o n t h C O e m i ss i o n r a te of

0

. 0 3 65 l b/ m m b t u

, ac hi e v e d w i th u s e of a n o x i d a t i on ca ta ly s t. C o n s i d e r i ng t h e l o ca t i on o f

t h e No r th S p r i ng f i e l d f ac i l i t y

, in c l o s e p r o x i m i t y to ot h e r b u s in e ss e s

, e t c

, t h e A NR s h o ul d

r e qu i r e t h e M S E R r a t e to a c t u al l y be t h e “ m o s t s t r i n g e n t”. T hi s wo u l d r e q u i r e u s e of a n

o xi d a t i on ca ta ly s t.

Respon s e: The 0.075 lb/mmbtu emission rate is the same emission rate the Agency
established for the similar Beaver Wood Energy Fair Haven permit. Beaver Wood
Energy had proposed the use of an advanced stoker design boiler and an oxidation
catalyst to achieve this e mission rate. NSSEP has designed their boiler to achieve this
emission rate without the need of an oxidation catalyst. In response to this comment regarding CO BACT, the Agency instructed the Permittee to conduct additional analysis

to determine the cost effectiveness of using a an oxidation catalyst for their boiler to

achieve 0.0365 lb/MMBtu. The addition of an oxidative catalyst to achieve a reduction
in CO from 0.075 lb/MMBtu to 0.0365 lb/MMBtu would result in a potential reduction in
annual CO emissions of 74 tons. The estimated cost to add a CO catalyst is
$16,800 /ton of CO controlled (inc ludes cost to install and an estimated catalyst life of 3
years, which requires an estimated cost of $ 1,200,000 to replace the catalyst). Based on these costs, which can be considered in an MSER determination, the Agency

determined that 0.075 lb/mmbtu sti ll constitutes MSER for CO.



### Comments related to Hazardous Air Pollutants (HAPS) and Hazardous

Air Contaminants (HACs):

Comment # 6 : T h e fa cili t y sh o u l d b e c o ns i d ere d a m a j o r s o u rc e f o r H A P s (Commenter
#26)

T h e HA P s e mi ss i o n s l i mi t o f 25 to n s a pp e a r s t o b e un e n f o r cea b l e

, b oth b e ca u s e

H C l e m i ss i o n s w i ll l i k e ly e x cee d 1 0 to n s ( d i s c u s s e d b e l ow) a n d b e ca u s e o r g a ni c

HA P s e mi ss i o n s h a v e l i k e ly b ee n u n d e r e s t i m a ted s i gni f i ca n t ly

.

T he ab s e n c e of a c i d gas c on t r o l s m a ke s s t a yi ng b el ow 10 t ons of H Cl h i gh l y un l i ke l y

- T h e p e r mi t s tat e s

, ( p . 3) “ A c id ga s e s ( SO 2 , H 2 S O 4 , a nd H C l) a r e l i mited b y i nh e r e nt l y

v e r y l ow s ul f u r and c h l o r ine l eve l s in the w ood fuel, a nd f u r t h e r r e du c t i o n s in t h e boi l e r

and f a b r i c f i l t e r f r o m n at u r al al k al i ni t y i n t h e w ood a s h

. ”Vermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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Air Pollution Control Division

March 29, 2013 Page 6 of 28

B oth t h e b i o m a s s p l a n ts c i ted by t h e a pp li ca n t a r e u s in g s o r b e n t s y s t e m s f or ac i d

c o n t r o l

. T h e r e f o r e

, i t i s n ot r ea s o n a b l e f or NS S E P

, w h i c h i s n ot u s i ng a s o r b e n t

s y s te m

, to c i te t h e s e r a t e s a s a c hi e v a b l e

. F u r t h e r

, i n o u r own d a t a b a s e of o v e r 70

r e c e n t l y i ss u e d a i r p e r mi ts f or b i o m a s s f ac i l i t i e s a r o un d t h e c o u n t r y

, we f o un d t h a t

s o r b e n t in je c t i on i s m o r e c o m m o n t h a n n ot. I n f ac t, a n u m b e r of f ac i l i t i e s w i th boi l e r s

on e h a lf or l e s s t h e ca p ac i ty of t h e NS S EP b o il e r p r opo s e t o u s e s o r b e n t s y s te m s f or

ac i d g a s c o n t r o l

. T h e r e i s n oth i n g s p ec i a l a bo u t t h e NS S E P f ac i l i t y ot h e r t h a n t h e

in e xp e r i e n c e of t h e d e v e l op e r

. A c i d g a s c o n t r ol s y s te m s a r e n ow s ta n d a r d i n t h e

i n d u s t r y

. W h y i s A NR n ot r e q u i r i ng o n e ?

Response: NSSEP HCl emission rate is based on the emission limit in the Palmer Renewable Energy permit and the Burgess Biopower permit: 8.34 x 10 - 4 lb/MMBtu. While Burgess Biopower’s design includes a dry sorbent injection system to control the

emission of SO 2 and H 2 SO 4 , this system is only required to be operated ‘as needed’ to

achieve the SO 2 and H 2 SO 4 emission limits. The Palmer Renewable Energy design included a dry circulating fluid bed scrubber to control acid gases from the use of

construction and demolition ( C&D ) fuel. When the Palmer project was re

- proposed to use just unadulterated wood for fuel (no C&D), they did not seek approval to remove the use of the acid gas scrubber.

The Agency concluded that the proposed emission rate is achievable without an acid

gas scrubber based on testing results of similar facilities. In the past

, the Agency has reviewed potential HCl emissions by using the average of the stack tests from these

four boilers, none of which use an acid gas control device: McNeil (1.1 x 10 - 4

lb/MMB tu), Ryegate (2.3 x 10 - 4 lb/MMBtu), Schiller Station (1.39 x 10 - 4 lb/MMBtu) and Bridgewater Power (8.7 x 10 - 4 lb/MMBtu). Average of these four facilities = 3.4 x 10 - 4

lb/MMBtu. With the exception of Bridgewater Power, which was within 5% of the 8.34

x10 - 4 lb/MMBtu emission rate, all of these boilers, without an HCl control device would have met the limit. The Agency anticipates that other biomass boilers, including NSSEP, in this region burning unadulterated wood will also have low emission rates of

HCl

.

The Agency will modify the NSSEP permit to include an emission limit of 8.34 x 10 - 4

lb/MMBtu for HCl. I f the HCl stack test demonstrates that the emission of HCl is greater

than 8.34 x 10 - 4 lb/MMBtu, t hen the Permittee must take corrective action to red uce the

emissions of HCl and demonstrate that it can achieve an HCl emission rate that is less

than 8.34 x 10 - 4 lb/MMBtu.

Comment # 7 : T he app lic ant has c on s i s t e n t l y und e r e s ti m a te d H AP s e m i ss i ons (Commenter #26)

W e h a v e r e vi e w e d t h e ac t u a l d a t a t h a t li e s b e h i n d t h e A P

- 42 e s t i m a tes of HA P s

, a n d

w e h a v e r e vi e w e d h un d r e ds of t e s t r e s ul ts f or bo il e r s b u r ni n g u n a du l te r a ted wo o d i n

E P A ’ s D e c e m b e r 20 1 1 bo il e r d a t a b a s e u n d e r p i nning t h e n e w M A C T r ul e s

. S i m i l a r l y

,Vermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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March 29, 2013 Page 7 of 28

we h a v e r e vi e w e d t h e d a t a t h a t li e s b e hi nd t h e N C A S I e mi ss i on f ac to r s ( m u c h of

w h i c h i s t h e s a m e a s t h e A P

- 42 d a t a s e t )

. T h e a pp li ca n t h a s i n s o m e c a s e s c h e rr y

p i c k e d d a t a to e l i m i n a te d a ta p o in ts t h a t t h e y do n ’ t li ke a n d t h a t t h e y i d e n t if y a s

“ o u t l i e r s ”

, e v e n t h o u gh t h e y u s e d n o s t a t i s t i ca l te s t to i d e n t i f y t h e m a s s u c h

, a n d h a s

i n v e n ted n e w e m i ss i o n s f ac to r s

. F or n ea r ly e v e r y HA P e mi t t e d i n a n y s ign if i ca n t

a m o un t, t h e a pp li ca n t h a s c h o s e n or i n v e n ted a n e mi ss i on f ac tor t h a t i s s i gni f i ca n t l y

l ow e r t h a n t h e A P

- 42 f ac to r

.

Respon s e: The EPA AP

- 42 emission factors for wood combustion in boilers are based on emission testing at facilities that are wide ranging in size that burn wood residue in the form of hogged wood, bark, sawdust, shavings, chips, mill rejects,
sander dust, or wood trim. For some of the facilities included in the AP

- 42 database, the wood fuel included waste plywood/particle board, wood contaminated with up to 15% urea formaldehyde resins, laminated wood, paper mill sludge, or wood finishing

waste. The emissions from the combustion of these contaminated wood fuel types, often in older boilers, is not considered to be representative of the combustion of
unadulterated, natural wood that is the allowable wood fuel for NSSEP with more

modern combustion controls. The NCASI data from Tech nical Bulletin No. 858 was based primarily on the emission data set used for AP

- 42, but NCASI used only the test data for the combustion of unadulterated natural wood, mostly from larger boilers. The Agency believes that the NCASI data is more representat ive of the HAP emissions from the combustion of natural wood from larger boilers compared to the AP

- 42 EFs.

The evaluation of the potential emissions of hazardous air pollutants (HAPs) and Hazardous Air Contaminants (HACs) for NSSEP is based on a combinat ion of (1) emission data from the National Council for Air and Stream Improvements (NCASI), (2)

emission factors from the EPA’s AP

- 42 emission factors, and (3) AP

- 42 emission factors adjusted for outlier data. In general

, the Permittee selected the higher emission factor (NCASI or AP

- 42), but in some cases they selected a less conservative emission factor. This was done for the following pollutants: acrolein, benzene, carbon tetrachloride, formaldehyde, HCl, propionaldehyde, styrene, toluene, arsenic, and

manganese.

The Agency will ensure that the permit requires testing of all HAPs that represent a significant portion of the total HAP emissions. Many HAPs will not be required to be tested for since they are predicted to be very low emissions and are unlikely to influence whether the facility exceeds the EPA HAP Major Source thresholds of 10

tons /yr for a single HAP or 25 ton s/yr for total HAPs

.

What const itutes a ‘significant portion’? The following table shows the HAPs with the highest estimated emissions from NSSEP. The HAPs in the right column will be specified for compliance stack testing at NSSEP once it is operational:Vermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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March 29, 2013 Page 8 of 28 Top HAPs, based only on AP

- 42, that

account for >85% of total estimated

HAP emissions. Top HAPs from NSSEP Application that

account for >85% of total estimated HAP

emissions.
Hydrogen Chloride Formaldehyde

Formaldehyde Benzene

Benzene Hydrogen Chloride

Acrolein Methanol
Styrene Chlorine
Styrene
Dichloromethane (methylene chloride)

Hexane

Acrolein

Acetaldehyde

Comment # 8 : Commenters expressed concerns about the emission of air toxics
(a.k.a. hazardous air pollutants and hazardous air contaminants):

“ The plant will be a major source of toxic pollutants according to all available

information and data. ” (Commenter 19)

“ As you know well scientific evidence indicates that carbon monoxide and a variety of
"noxins," as well as a broad range of particulate matter c omes from biomass burning ”
(Commenter 27)
“A number of reports indicate that expansion of biomass energy would undermine
Vermont’s stated goals of reducing greenhouse gas emissions and will send hazardous
air pollutants (HAPs) into our environment” (Commen ter 9).

Response: As stated in the response to Comment #7 the facility is not considered to
be a Major Source of HAPs. However, the plant will emit pollutants that are
categorized as toxic. The proposed plant is designed to minimize the formation and

e mission of these toxic air pollutants. As noted in the response to Comment #8, t he
Agency will ensure that NSSEP will conduct stack testing of al l of the HAPs that
represent a significant portion of the total HAP emissions.



### Comments related to air dispersion modeling and analysis:

Comment # 9 : Stack height is inadequate (Commenters 8, 19, 25, 26)

Good engineering practice for the stack height at NSSEP would be 290 feet, according

to page 5

- 8 of the air permit application. However, according to testimony submitted by NSSEP to the PSB, the FAA has placed restrictions on the stack height of the

facil ity. Page 19 states that the stack will be 140 feet in height. This facility is going toVermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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March 29, 2013 Page 9 of 28

be located in a densely populated area. If the stack height can’t be made maximally
protective to disperse pollutants, then the facility should not be built in this ar ea.

Respon s e: The basis for a “good engineering practice” (GEP) stack goes back to the
development of air dispersion models for stationary sources of air pollution. The original intent of the GEP stack height was to disallow the use of stack heights above
this level to demonstrate compliance with ambient standards.

The EPA wanted large facilities to utilize better control equipment to reduce emissions
rather than constructing taller and taller stacks to disperse the pollutants into the upper
atmosphe re, and then downwind for hundreds of miles. There is no requirement for a
facility to construct a GEP stack. A facility is allowed to make a demonstration of
compliance with ambient standards at any stack height they wish so long as it is not
greater th an GEP , although lower stacks are progressively more difficult to show
compliance. NSSEP has demonstrated compliance with all applicable ambient
standards at a stack height of 140 feet.

Comment # 10: S I L a n d S I A m o d e l i n g r e s u l t s a r e o b f u s c a t e d a n d a p p e a r t o h ave b e e n

m i s r e p re s e n t e d (Commenter #26)

T h e A NR s h o ul d c o n s i d e r r e w r i t i ng a n d e x p l a in i ng t h e f o l l owi n g s ec t i on s o t h a t i t

a c t u a l l y s a y s w h a t i t i s s u ppo s e d to s a y . On p a g e 7 of t h e draft p e r mi t, i t s ta t e s :

T

he fo l l o w ing p o l l utan t s

/

a v e r ag i ng t i m e s w e r e had ( s i

c

) p r e d i c t

e d c o n ce n t r at i ons

t h at w e r e g r e a t e r th a n their r e s p e c t i v

e S IL : PM 10 2 4

- h r

, PM 2.5 24

- h r

, PM 2.5 a n nua l

, SO 2 1

- h r

, SO 2 2 4

- h r a n d NO 2 1

- h r

. T he in t e r a c t i v

e s o u r c e mo d e l

i ng includ e d t he

f ol

l o w ing t w o s o u r ce s : A P C P ap e r in C l a r e mon t

, N H ( SO 2 & NO 2 ) a nd W h e e la b r at o r C l a r e mont in C l a r e mon t

, N H ( SO 2 & NO 2 )

. N o n e a r by s o u r c e s w i t

h s i gni f i c

ant

e m i ss i o n r a t e s of PM 10 o r PM 2.5 w e r e i d

e n t i f i e d.

B u t t h e n on p a g e 8, w e a r e to l d: F or t h e 1

- h r NO 2 a nd SO 2 s t a nd a r d

s it w as

n e c e s s a r y to i d

e n t i f y t he F a c i l i t

y ’

s c ont r i b ut i on to impa c ts at the r e ce p t o r s that had a

to t al i m

p a c t t hat is g r e a t e r t h an the N AA Q S

. T h i

s a n aly s i

s w as d o ne and it w as

d

e t e r mi n e d that t h e p r e dic t e d i m

pa c t s f r

o m th i s p r o

p o s e d p r o

j

ec t at th o s e r ec e pto r s

w

e r e w e ll b e low t h e s igni f ica n t i m

pa c t le v e l

. T his r e v iew c o n c lu d e d that t h e F a c i l i t

y

d

o e s n ot c o nt r ibu t e to t h e s e p r e dic t e d v io l at i o n s of t h e N AA Q S.

S o w h i c h i s i t? W e a r e to l d on p a g e 7 t h a t s e v e r a l po l l u ta n t m ea s u r e s h a v e

“ p r e d i c t e d c o n ce n t r a t i o n s t h a t w e r e g r ea ter t h a n t h e i r r e s p ec t i v e SI L ”

, t h e n on

p a g e 8 w e a r e to l d t h a t t h e p r e d i c ted im p ac t s a r e “ w e l l b e l ow” t h e s i gni f i ca n t

i m p ac t l e v e l

. T h e n we a r e to l d i n t h e tab l e on p a g e 9 t h a t f o r t h e po l l u ta n ts

r e q u i r ing c u m u l a t iv e s o u r c e m od e l i n g

, e v e n t h ough t h e N AA QS a r e a l r ea dyVermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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Air Pollution Control Division

March 29, 2013 Page 10 of 28

e x c e e d e d f o r t h e 1

- h o u r NO 2 a n d SO 2 s ta n d a r d s

, n ot to wo rr y

, t h e c o n t r i b u t i on of

NS S E P i s s o s m a ll

, i t do e s “ n ot c o n t r i b u te” to t h e vi o l a t i o n s

.

T h e p u bl i c s h o ul d n ot h a v e to wo r k t hi s h a r d to in te r p r e t a n a i r p e r mi t. T h i s te x t i s

i m p e n e t r a b l e

, a n d t h e p r e s e n tat i on of i n f o r m a t i on c o nv e y s t h e i m p r e s s i on t h a t t h e r e i s

a p r ob l e m w i t h th i s f ac i l i t y ’ s e mi ss i o n s

, b u t t h e y a r e hi ding i t. W o r s e y e t, A NR s ig ning

o f f on a p e r mi t c o n taini n g s u c h c on f u s i n g v e r b i a g e m a k e s i t l ook l i ke A NR i s n ’ t

min d ing t h e s to r e

. T hi s p e r m it n ee ds wo r k

, a n d i f A NR h a s t h e s l i gh te s t do u bt a bo u t

t h e m od e l i ng r e s ul ts f r o m t h e f ac i l i t y

, t h e y s h o ul d r e q ui r e t h e m od e l i ng to be r e p ea t e d

,

w i th t h e A g e n c y s u p e r vi s i ng c l o s e ly

.

Respon s e: To determine the size of the significant impact area (SIA), just the
emissions from the proposed source are modeled to identify the maximum distance
from the source where modeled impacts equal or exceed the significant impact limit (SIL). The nature of modeling is that the impact s will be distributed unevenly due to

the variability in the meteorological data such as mixing height, stability and wind
speed as well as the topography of the land . The furthest away receptor with a
predicted impact at or above the SIL will establish the radius of the SIA, and the SIA,
a circle in shape, will cover large areas where the predicted impacts were below the

SIL. This is a conservative approach for identifying other nearby sources that may have an overlapping impact area with NSSEP. To use the actual individual points of
sign ificant impact to identify such sources would be more difficult and prone to
missing potentially applicable nearby sources.

The shaded areas on the attached map (Figure 1) show where there are modeled
impacts from NSSEP for SO 2 at or above the SIL. Thi s map also has a circle representing the SIA. There are many receptors within the SIA that are below the SIL
(represented by the white area), including the area around Claremont, NH. Since the
radius of the SIA was great enough that it included the two ai r pollution sources in Claremont, these two existing sources were included in the ‘interactive modeling.’
Interactive modeling is conducted to make sure that new projects do not combine with
existing significant source of air pollution and result in excee dances of the NAAQS.

As noted in the draft permit and technical support document, t he interactive modeling
identified potential exceedances of the 1

- hr SO 2 NAAQS at 263 receptors near
Claremont. The highest modeled contribution from NSSEP at these rec eptors was 0.11 μg/m 3 which is well below the SIL of 7.8 μg/m 3 . Based on this data, the Agency

determined that the NSSEP does not cause or contribute to these predicted violations

of the 1

- hr SO 2 NAAQS.Vermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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Air Pollution Control Division

March 29, 2013 Page 11 of 28 Figure 1: Significant Impact Area

– 1

- hr SO 2

Claremont, NHVermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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Air Pollution Control Division

March 29, 2013 Page 12 of 28

For NO 2 , the radius of the SIA was also great enough that it also included the two air
pollution sources in Claremont, NH. The interactive modeling identified potential

exceedances of the 1

- hr NO 2 at 12 receptors near Claremont. The modeling analysis
reviewed the 4 operating scenarios and found the highest predicted impact from the

NSSEP occurred with the “75% boiler load/45% wood moisture content” scenario.

The attached map (Figure 2) shows the locations of 12 receptors where th ere are predicted exceedances of the 1

- hr N O 2 NAAQS . T he contribution from for the NSSEP

75%/45% scenario is also marked on the map: the highest contribution from the NSSEP is 4.06 μg/m 3 which is below the SIL of 7.5 μg/m 3

.Vermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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Air Pollution Control Division

March 29, 2013 Page 13 of 28 Figure 2: Significant Impact Area: 1

- hr NO2:

Comment #11 : R eferring to the review of the potential Class 1 Area visibility
impairment, a commenter asked the following; “Was this level 1 Screening procedure
documented and does the ANR have a copy? The question of adverse Impact from
the facility’s plume visibility . . . was that based on a 360 degree viewing area? SinceVermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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Air Pollution Control Division

March 29, 2013 Page 14 of 28

we have yet to see a clear, concise diagram, or picture or architectural rendering of the
building, the stacks, or precisely how the project appears on the piece of property in

relation to all the other buildings and landscapes, I question that statement with what
will be seen coming from the 140 ft stack and the 6

- 65 ft cooling areas?” ( Commenter
3)

Response: The EPA’s VISCREEN model is used to evaluate the potential visibility
impacts at federa lly listed Class 1 Areas due to the emission plume . In the case of
NSSEP, the evaluation was for the Lye Brook Wilderness Area. This visibility
assessment was not intended to determine if the buildings and stacks of NSSEP are

visible in the immediate sur rounding area. This screening procedure is documented
and the Agency has a copy that is available upon request

.

Comment #12 : There are many comments and concerns regarding the dispersion of the pollutants from NSSEP. Many of these concerns had to do with the topography

around the plant and inversions. “North Springfield Industrial Park is situated in a hollow of the Black Rive r Valley and up the prevailing wind from much of Springfield.” ( Commenter 6)
“The draft permit documents do not appear to consider: local terrain, local lower level

wind condition, concentration effect on emissions of terrain and wind. . .What state or
federal standards apply to such situations? How can a project go forward wit hout such
analysis? ( Commenter 8)
“The town of North Springfield is a valley and there are many days in the winter when
the entire area is immersed in a smoky haze created by a relatively small number of
home heating wood stoves used in the area. This is p articularly bad when we
experience a temperature inversion. These conditions sometimes persist all day.”
( Commenter 24)
“I ask that the Agency of Natural Resources carefully considers the impact of the emissions on North Springfield residential areas give n the poor site, prevailing winds, and lower stack height.” ( Commenter 19)

Response: The proposed project has been thoroughly reviewed to determine how the
pollutants from the main stack will disperse into the surrounding area. This process is

referred to as an Ambient Air Quality Modeling Analysis. NSSEP was obligated to use
the USEPA approved American Meteorological Society/ EPA Regulatory Model
(AERMOD) for their air quality computer dispersion modeling analysis. According to
the EPA, AERMOD employs best state

- of

- practice parameterizations for characterizing the meteorological influences and dispersion. The AERMOD atmospheric dispersion
modeling system incorporates air dispersion based on planetary boundary layer
turbulence structure and scaling con cepts, including treatment of both surface and
elevated sources, and both simple and complex terrain. It is an integrated system that

includes three modules:Vermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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Air Pollution Control Division

March 29, 2013 Page 15 of 28 1. A steady

- state dispersion model designed for short

- range (up to 50 kilometers)
dispersion of air pollutant emissions from stationary industrial sources.
2. A meteorological data preprocessor (AERMET) that accepts surface
meteorological data and upper air soundings. It then calculates atmospheric
parameters needed by the dispersion model, such as atmospheric turbulence
characteristics, mixing heights, friction velocity, and surface heat flux. The
surface meteorological data is from the Hartness Airport, located a mile from the NSSEP. The upper air soundings are from Albany, NY which

, while not ve ry close to North Springfield, is still considered to be representati ve of the upper air
conditions for the purpose of air dispersion modeling.
3. A terrain preprocessor (AERMAP) whose main purpose is to provide a physical
relationship between terrain fea tures and the behavior of air pollution plumes. It
generates location and height data for each receptor location. It also provides
information that allows the dispersion model to simulate the effects of air flowing
over hills or splitting to flow around h ills.

AERMOD also includes PRIME (Plume Rise Model Enhancements) which is an
algorithm for modeling the effects of downwash created by the pollution plume flowing
over nearby buildings.

This modeling process takes into account all winds (including the prevailing winds),
inversions, the elevation of the ground, as well as the affect of temperature, and
calculates hourly pollutant concentrations at the worst case (highest) pollutant
concentrations over a 5 year period (meteorological data from 2006

– 2010 ).

After reviewing the air dispersion modeling for NSSEP, the Agency has concluded that
the proposed project will not cause or contribute to violations of the National Ambient Air Quality Standards (NAAQS), will not exceed Vermont’s Prevention of Signifi cant Deterioration (PSD) increments, will not significantly impact any Class I areas, nor will
it significantly deteriorate existing air quality.

Comment #13 : My home sits on land 700 feet above sea level, putting my home at
precisely the same elevation as the top of the stack. What will be the concentration of
pollutants and odors at my home when the wind is blowing from the northwest at
various velocities? . . .” ( Commenter 8)

Response: Based on the location of the home on French Meadow Road, the output from the AERMOD analysis indicates an increase in the annual average concentration

of PM 2.5 of 0.15 μg/m 3 . This is an increase of approximately 2% over the current background level of 7.8 μg/m 3 for PM 2.5 . For the 24

- hr PM 2.5 concentration, the

AE RMOD analysis indicates an increase of 1.5 μg/m 3 ; this is an increase of approximately 8% over the current background level of 19.1 μg/m 3 for PM 2.5

. When
these potential increases in PM 2.5 are added to the PM 2.5 background concentration,Vermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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Air Pollution Control Division

March 29, 2013 Page 16 of 28

the total is still well below the NAAQS for PM 2.5

. Note that the air dispersion modeling

does not estimate odors.

Comment #14 : “I formally request that a thorough analysis of nearby (within a 2 mile
radius) emission distribution and concentration effects of the interactio n of wind and
terrain be made, provided to the public and reviewed before a permit is issued.
( Commenter 8)”

Response: The air dispersion modeling described above in response to comment 12
included using a receptor grid spacing of 100 meters out to a distance of 3 kilometers
from the source (approximately 3600 individual receptors). The 100 meter receptor
grid spacing covers an area similar to the requested 2 mile radius. The receptor gri d
continues out to a distance of 40 km, with receptor spacings greater than 100 meters;
there are a total of 11,602 receptors. As noted above this modeling includes the

effects of the interaction of wind and terrain. Moreover, this modeling was carefully
reviewed by the Agency and is available to the public upon request.

Comment #15 : “Was particulate matter concentrations and air impacts related to the plant’s fire pump and the standby/auxiliary generator (sized at 3,000 kW) is included as
part of the air permit? It looks like in the technical support summary the genera tor and
fire pump are noted as tier 3 units but should they not be part of the totals? Or are
they?” ( Commenter 9)

Response: The emissions estimates for the diesel engine fire pump and the diesel
engine generator were included in the facilities total allowable emissions. This

information is available in Table 3

- 4 of page 8 of the draft Technical Support
Document. These engines are only permitted to operate up to 65 hours/year for testing
and maintenance and will result in negligible PM emissions, so they were not included
in the air dispersion modeling analysis. Note that only the fire pump’s engine is to be a

Tier 3 certified engine. The 3,000 kW generator is anticipated to be a Tier 2 certified
engine

.



### Comments related to particulate matter (PM ) emissions and impacts:

Comment #16 : There were numerous comments and concerns regarding the emission
of particulate matter from this proposed facility. Many concerns have been raised
regarding the possibility that the emissions from the plant will exacerbate existing

health conditions of ne arby residents and that the regulations do not protect those with
fragile health. ( Commenters 6, 11, 13, 17, 19, 20, 22, 23, 27, 2 9 )

Response: Any criteria pollutant emissions that are emitted from the plant must
comply with the applicable National Ambient Air Quality Standards (NAAQS) as set byVermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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March 29, 2013 Page 17 of 28

the US EPA. The NAAQS are developed for the purpose of protecting the most

sensitive persons in the population, including people with diseases (e.g. asthma,
cardiovascular disease, etc.), children and the elderly, with an adequate margin of
safety as stated in the Clean Air Act (CAA). The development and ongoing review
process for the NAAQS includes seve ral key elements which are planning, science assessment, risk/exposure assessment, policy assessment

, and notice and comment rulemaking. The Clean Air Scientific Advisory Committee (CASAC) is involved
throughout the NAAQS review process in providing revie w and advice on the air quality
criteria (AQC) and the standards. The CASAC is composed of seven members that
include at least one member of the National Academy of Sciences (NAS), one
physician, and one person representing State air pollution control age ncies. Under the CAA, each NAAQS must be reviewed by the CASAC periodically and revised as

appropriate.

In the case of NSSEP, it has been demonstrated that the plant will neither cause nor
contribute to a violation of the NAAQS in terrain surrounding t he site. Therefore, the
plant will not have an adverse effect on public health or welfare in the area.

Comment #17 : Several comments questioned the adequacy of the current NAAQS for

PM: “The EPA has announced that the National Ambient Air Quality Standar ds (NAAQS) are not stringent enough to protect people or the environment and stronger
rules are in the works. I would respectfully request that the Agency of Natural
Resources institute a moratorium on the permitting of additional biomass plants
pending new rulings from the EPA. ( Commenter 15)”
“This new evidence reinforces past research studies and supports the conclusion that
particulate matter harms human health at exposure levels far below the current
standards. This conclusion demands prompt action to protect human health and the EPA is considering stronger standards. ( Commenter 20)”
“As you are aware the National Ambient Air Quality Standards are being revised for
fine particle pollution, also known as fine particulate matter (PM 2.5). . . Our q uestion

- has the Vermont Air Pollution Control Division addresses these stronger emission
standards in the draft permit? If not, why? Please explain. If the existing National Ambient Air Quality Standards regulations will be the benchmark, we question if the Air Pollution Control Division is protecting the health, safety and welfare from the effects of
these emissions if these new standards are not followed, these pending standards are
being strengthened to be the new benchmark. ( Commenter 9)”

Response: Section 109 of the Clean Air Act requires EPA to review the NAAQS at 5

- year intervals, and to make such revisions in the NAAQS and promulgate such new
NAAQS as may be appropriate. Considering this requirement it is conceivable that
there will always be p ending rules from the EPA with regards to the NAAQS. With
regards to PM 2.5 , the EPA has yet to propose any new standards lower than the currentVermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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Air Pollution Control Division

March 29, 2013 Page 18 of 28

35 μg/m 3 24

- hr PM 2.5 NAAQS. On June 29, 2012 the EPA issued a proposed rule to
lower the primary PM 2.5 annual standard from 15 μg/m 3 down to 12 or 13 μg/m 3 and
introduce a secondary PM 2.5 visibility standard. On January 13, 2013 EPA finalized the
primary PM2.5 annual standard at 12 ug/m3. While this revised standard is not yet in

effect in Vermont, NSSEP has dem onstrated that they will comply with this new lower

standard.

Comment #18 : There were many comments concerning the potential affects from the air pollutants emitted from NSSEP on the local population including the young, elderly
and those who already suffer from respiratory issues such as asthma. “While some people would suffer only headaches, North Springfield also houses
Brookwood Estates, an assisted living community for senior citizens; many of the
elderly living there already suffer from respirato ry illnesses. Also, there are many children and adults suffering from asthma in the area. ( Commenter 25)”
“Families in homes in North Springfield that line the two potential access roads to the
site will be on the front lines. According to an earlier cens us, among the approximately 700 residents of North Springfield 17% are children and 35% are elderly. These two

are the most at

- risk groups as studies show.” ( Commenter 27)

Response : See response to Comment 16

.

Comment # 19 : There were comment s and concerns about the amount of air pollution

that is estimated to be emitted from NSSEP.
“The pollution from biomass causes respiratory problems in children and adults

. ”
(Commenter 4 )
“According to petitioner

– significant emitter of several important p ollutants

. ”
(Commenter 6 )

Response: See response to Comment 16

.



### Comments related to Greenhouse Gases:

Comment #19 : T h e d i s c u ss i o n o f B A C T f o r g r e e n h o u s e g a s e s is i n a d e q u a t e (Commenter #26)

A N R ’ s d i s c u s s i on of why t h e u s e of wood i s “ in te g r a l ” to a p o w e r g e n e r a t i on p r oje c t i s

s o w e a k

, i t r e f l ec ts p a r t i c u l a r ly poo r ly on t h e A g e n c y

. I n i ts r e vi e w of t h e B ea v e r F a i r

H a v e n p l a n t, A NR j u s t i f i e d wood a s “ in te g r a l ” to p o w e r g e n e r a t i on a t t h e f ac i li t y

b e ca u s e t h e f ac i l i t y wou l d, a s a p e ll e t p l a n t, g e n e r a te w o od w a s te t h a t wo u l d

c o n s t i t u te s o m e of t h e f u e l s u pp l y a t t h e po w e r p l a n t

. H ow e v e r , t h a t a r gu m e n t do e s

n ot p e r ta i n to t h e NS S E P f ac i l i t y a n d t h e A g e n c y ’ s a r g u m e n t f or w h y wood i s “ in te g r a l ”

to t h e N S S E P f ac i l i t y

. A N R ’ s r e m a in i n g j u s t if i ca t i o n s f or why w o od i s “ in te g r a l ” to t h eVermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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Air Pollution Control Division

March 29, 2013 Page 19 of 28

NS S E P f ac i l i t y a r e n ot mu c h m o r e t h a n a ta c i t a d m i ss i o n t h a t t h e s o l e p u r po s e of t h e

f ac i l i t y i s to m op u p s u b s i d i e s f or “ r e n e w a b l e ” p o w e r g e n e r a t i o n

, s o m e th i ng t h a t t h e y

wo u l d n ot be a b l e t o d o i f t h e y w e r e b u r n i ng n a t u r a l g a s

, f or in s ta n ce

.

A NR a r gu e s t h a t t h e G H G a n a ly s i s a n d d i s c u ss i on of B A C T s h o ul d n ot r e q ui r e t h e

f ac i l i t y to c o n s i d e r ot h e r f u e l s a n d te c hn o l og i e s

, b e c a u s e t hi s wo u l d c o n s t i t u te

“ r e d e f in i ng t h e s o u r c e ”

. T h e s e a r g u m e n ts a r e s h a l l ow.

1. T h e NS S E P t ec hni ca l s u ppo r t do c u m e n t c o n tai n s e l e m e n ts of t h e BA C T

a n a ly s i s f or g r ee nh o u s e g a s e s

, s u c h a s i t i s

. T h e f o ll o w i ng s tat e m e n t i s f ou n d

on p a g e 32: “ 4. T y

pe o f f u e l

. D ue t o t h ei r c h e m ic al m a k e up, s o m e f u e l s

g e n e r a t e le s s CO 2 p e r un i t of e n e r gy wh e n t h e y a r e c o m bu s te d. A s no te d

abo ve

, f u e l s w i tc h i ng wo u l d r e d e fi ne t h i

s s ou r c e and i s not pa r t of t h e MS E R

r

evie w

. ” T h i s s tat e me nt i s d ece p ti v el y i n c o m p lete

. A maj or r ea s on t h a t a

b i o m a s s p la nt e mit s s o m u c h m ore CO 2 t h a n a c o a l p la n t , for i n s ta n ce

, i s not

b eca u s e t h e fu e l ca rbon t o e n e rgy r ati o i s s o m u c h h i g h e r ( i n f a c t c o a l a nd

w ood h a v e a s imila r ca rbon t o e n e rgy r ati o) but b e c a u s e b i o ma s s p la n t s a re

p h e no m e n a l l y i n e ff icie n t

. I t i s l ud ic rous t o p e r m i t a t e c hno l ogy a s i n e ff ic i e nt a s

b i o ma s s c o m bu s ti on t o c on s t i t u t e “ B A C T ” for CO 2 c on t ro l

.

2. S a y ing “ T h e A g e n c y f in ds t h a t t h e P e r mi t t ee ’ s ob j ec t i v e i s to b u i l d a b i o m a s s
f u e l e l ec t r i c g e n e r a t i ng f ac i l i t y ” i s n o d i f f e r e n t f r o m s a y ing t h e i r obje c t i v e i s to

b u i l d a c o a l f ac i l i t y

. I n t h a t c a s e

, t h e a pp li ca n t wo u l d l i k e ly s t i ll be c o m p e l l e d to

c o n s i d e r a l te r n a te f u e l s a n d t ec hn o l o g i e s , p a r t i c u l a r ly if ot h e r f u e l s w e r e i n u s e

a t t h e p l a n t

, f or in s ta n c e d u r i n g s ta r t u p.

3. T h e s ta t e m e n t “ T h e A g e n c y f u r th e r no t e s t h at t h e p r o

p o s e d f a c i l i t

y is d e s i gn e d

t o a l l ow low g r ade h e at f r om the s te a m tu r bine at t h e e l e c t r i c g e n e r at i n g plant to

s u pply t h e r mal e n e r gy f o r the a dja c e nt indu s t r ial p a r k

” i s i rr e l e v a n t to t h e n a t u r e

of t h e f u e l u s e d. L ow g r a d e h ea t c o ul d be h a r v e s t e d f r om a n y ki n d of f ac i l i t y

pow e r e d by a n y ki n d of f u e l

. I t do e s n ot r e f l ec t w e l l on t h e A g e n c y to in c l u de t hi s

a r g u m e n t a s a r e a s on t h a t wo o d i s “ in te g r a l ”

.

Respon s e: BACT does not necessarily include consideration of a different type of fuel from the one proposed, especially if using another type of fuel would be inconsistent with the fundamental purpose of the facility. With respect to the NSSEP, the proposed fuel is biomass. As the Agency explains in the technical su pport document, requiring NSSEP to switch fuels would be inconsistent with the fundamental purpose of the facility. Having established this, it is appropriate for BACT to consider the most energy efficient design and control options for the proposed wood

- fired power plant.

With respect to hypothetical coal

- fired power plant raised by the commenter , there are a number of instances where applicants proposing to build a coal

- fired power plant have not been required by EPA as a part of a BACT analysis to switch to a lessVermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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Air Pollution Control Division

March 29, 2013 Page 20 of 28 polluting type of fuel. See e.g., In re SEI Birchwood, Inc., 5 E.A.D. 25, 29

- 30 n.8 (EAB 1994) (switch to natural gas would redefine coal

- fired electric generating plant); In re Haw. Commercial & Sugar Co., 4 E.A.D. 95, 99

- 100 (EAB 1992) (switch from coal to

oil

- fired combustion turbine not required); In re Old Domi nion Elect. Coop., 3 E.A.D. 779, 793 (Adm’r 1992) (switch to natural gas would redefine coal

- fired electric generating plant).

The Agency agrees that the thermal energy loop is irrelevant in the discussion of

whether or not alternate fuels should be c onsidered in the GHG BACT analysis; we will remove this reference on page 31 of the Technical Support Document.

Comment #20 : There were several comments about rated energy efficiency of the

propose d project.
“The combination of low efficiency and high emissions means that it is not renewable. ”
( Commenter 6)

“ Please note that the NSSEP will only be 26.1% efficient (electricity production without
the heating loop) according to the petitioner’s information provided to the PSB.”
( Commenter 9)

“I ask, is thi s electricity really needed and at such a low efficiency rate that this plant
will operate at. I recall that the developer has stated that the plant will operate at about
a 35% efficiency at best, and that includes a possible heating loop for which there are no firm plans dealing with the infrastructure

— other than laying the main pipes.”
( Commenter 14)
“According to many authorities, not only does wood biomass fail to achieve efficiency
standards but the efficiency shortcomings are compounded by the pollut ants that come
from wood biomass combustion and threats to public health.” (Commenter 27)

Response: The Air Pollution Control Construction Permit does not directly establish
the acceptable process energy efficiency. It has been the practice for Air Pol lution

Control Permits to limit the air emissions of regulated facilities, a boiler in the case of NSSEP, through the use of emission limits based on the rated heat input of the boiler.
With the recent need to establish limits on greenhouse gas (GHGs) emissions from
major sources of GHGs, this practice has changed and recent GHG limits are based on
the energy output of the boiler/energy system. With an output based limit

, the overall energy efficiency of the process becomes an important factor in the ability to meet the
permit li mit. As established in the Technical Support Document, the GHG BACT limit
for this project is based on the performance of wood fired boiler/steam turbine process.

T

he established GHG BACT limit for NSSEP is 2,675 lb CO 2 e/MW

- hr after the 3 rd year of opera tion. To achieve this limit it is anticipated that the project will need to have an overall energy efficiency (based on electric and heat output) of 27.8%.Vermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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### Comments related to wood supply and wood fuel:

Comment # 21 : Several comments focused on wood fuel procurement issues: wood
availability, forest harvesting practices, sustainable harvesting, invasive insect,
deforestation, etc. ( Commenters 7, 13, 15, 22, 23, 24, 26, 27, 29) . One commenter

questioned the I N R S f u e l a v ai l a b i l i t y s t u d y claiming that it m i s r e p r e s e n t s s u pp ly and the

commenter concluded the w oo d s u pp ly is i n a d e q u a t e

. (Commenter #26)

Respon s e: The review of fuel wood availability is outside the Vermont Air Pollution

Control Division’ s area of expertise so th e Air Division has provided the Vermont Department of Forest and Parks a copy of the commenter’s review of the INRS study

for their consideration

.

It should be noted that at this time Agency is not establishing wood procurement requirements in its air permits for biog enic sources. This may change in the future, for example when an accounting method for biogenic CO 2 emissions from the stationary

sources is finalized. The Agency reserves its right to raise any issues related to the management of forest resources, and the potential impact of this or any other facility, in the context of other proceedings such as Act 250, Section 248, or other permitting regimes.

Comment # 22 : Why is the facility allowed to burn wood residues from wood product
industries, such as plywood plants? These wood residues may contain chemicals.
Also the applicant did not request the use of these types of wood fuels in their permit
application. ( Commenters 3, 11)

Response: The provision for the allowable use of “wood residues from wood product
businesses, including, but not limited to: fuel wood, sawmills, veneer mills, and the
wood products manufacturing sector” will be removed from the permit.

Comment # 23 : Of concern to me also is the material that would be incinerated in this plant. Once a permit is granted for wood byproducts of lumbering, would further post
construction wood by products be granted? ( Commenter 11)

Response: The Air Pollution Control Permit to Construct being issued to NSSEP does

not allow for the use of wood fuel from construction and demolition debris. If, in the
future, the applicant wants to include this type of material as a fuel, they would need to
submit a permit application to modify their permi t and this request would be reviewed
by the Agency which will include a opportunity for the public to review and comment
on the proposed change(s).



### Comments related to trucking:Vermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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March 29, 2013 Page 22 of 28

Comment # 24 : Concerns with the pollution from the tractor trailer trucks coming and going from the Facility. ( Commenters 2,6,7,9,11,13,14,15,16,18,20,24,29)

Response: The Air Pollution Control Permit to Construct only has the authority to
regulate the stationary equipment at the facility. This permit does not apply to the t ruck
traffic associated with the facility.

However, since the emissions from the diesel truck engines represent an air quality
concern, the APCD did review the potential emissions from the anticipated truck traffic.

This review was based on 18,720 trucks/yr (5 trucks/hr * 12 hr/day * 6 day/week * 52
weeks/yr) with an average roundtrip travel distance of 40 miles to represent both the
travel to the NSSEP site and the return trip. This review used the most recent release
of the EPA’s mobile source (v ehicles) emission estimating tool: MOVES2010b.

MOVES2010B estimated an annual PM emission due to the exhaust from these trucks
to be 0.29 tons/yr distributed over the entire road network used by the trucks . This
level of emissions from trucks traveling on the roads is not expected to have a
measurable impact on the ambient air quality.

Comment #25 : Concerns with noise from the facility and/or truck traffic associated
with the facility. ( Commenters 7, 13, 24)

Response: The issue raised by this comment is outside the scope of the Agency’s

air permitting authority under 10 VSA Chap. 23, and therefore the Agency is not
considering it in the final decision for this permit.

Comment #26 : Safety concerns with tractor trailer trucks traveling through streets in North Springfield ( Commenters 2,7,9,10,13,14,15,16,18,24,27,29)

Response: The issue raised by this comment is outside the scope of the Agency’s air
permitting authority under 10 VSA Chap. 23, and therefore the Agency is not
considering it in the final decision for this permit.Vermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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March 29, 2013 Page 23 of 28 

### Comments relating to future compliance by NSSEP with the Air Pollution

Control Permit to Construct:

Comment #27 : The VOC emission rate is unlikely to be achieved (Commenter #26)

NSSEP promises a VOC emission rate of 0.005 lb/mmbtu. The AP

- 42 standard

emission rate for wood

- fired boilers is 0.017 lb/mmbtu. In our database of biomass
facility air permits, there are 30 facilities that specify a VOC emission rate. These rates
range f rom 0.005 lb/mmbtu (only one has this rate

- the Beaver Fair Haven facility) to
0.19 lb/mmbtu. The Palmer facility, which proposes to use an oxidation catalyst, was
only able to promise to meet a rate of 0.01 lb/mmbtu, or twice the rate at the NSSEP

plant. In other cases, for instance consideration of NOx rates proposed for the Beaver
facility in Fair Haven, ANR and the applicant have dismissed rates specified in the
Palmer permit as unachievably low. However in this case, the limit proposed is only

one

- hal f that proposed at the Palmer plant, which intends to use control equipment that NSSEP will not use, and yet the applicant, and ANR, see no problem in proposing a

rate that is much lower than that at the Palmer plant.

Respon s e: The Agency’s experience wi th VOC emissions from large wood boilers is
based on the two operating wood fired EGUs in Vermont. The VOC testing at these
two facilities both indicate that they emit VOCs at a rate less than 0.005 lb/MMBtu.

Therefore

, the Agency feels this rate is both achievable and has been achieved and therefore is MSER. NSSEP will be required to periodically test their VOC emission rate

to demonstrate compliance with this emission limit.

Comment #28 : The Agency received comments regarding the compliance record of the biomass energy sector: ref. Wall Street Journal articles on August 17, 2012 and
July 23. 2012. The concerns extended to the anticipated compliance, or lack thereof by
NSSEP ( Commenters 3, 14

, 26)

Response: There are several levels of compliance o versight related to the air permit for this proposed facility: (1) annual reporting of operations (fuel usage, electrical
output, etc) and emission of pollutants; (2) annual site inspections by representative(s)
of the Agency; (3) semiannual compliance certification reports; (4) continuou s emission
monitoring systems for carbon monoxide, and nitrogen oxides; and (5) periodic
emissions testing for other pollutants. While the Agency cannot guarantee that NSSEP
will comply with all the terms of their permit, the Agency will be closely monito ring the
operation and performance of this facilit y and, if necessary, will address any air permit
compliance issues that arise.

Comment #29 : If there are odors and particulates at my house or aggravation of my
wife’s asthma what recourse do I have? (8)Vermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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March 29, 2013 Page 24 of 28

Response: If you experience objectionable odors or if someone experiences
aggravation of a respiratory condition such as asthma and you believe that these
event(s) are caused or contributed to by the emission(s) of NSSEP, contact the Air

Pollution Control Division a nd they will investigate the complaint to determine if there is
a permit violation and/or an identifiable condition at the facility that is causing the
objectionable odors.



### Comments relating to the proposed location of the project:

Comment #30 : Some comm ent s addressed the close proximity of the proposed project and residential areas in North Springfield.
"The primary lesson learned from the McNeil plant experience in Burlington, Vermont,
is careful attention to the siting of a biomass

- fueled plant. Siting the plant in a
residential neighborhood of a small city has caused a number of problems and extra
expenses over the years: a permit requirement to use trains for fuel supply, high taxes,
high labor rates, local political involvement, and neighborhoo d complaints about odors
and noise." ( Commenter 27)

Response: While the Agency does not control the site selection of proposed projects,
the Agency does require applicants to submit all information that the Agency deems
necessary to determine whether th e proposed construction will be in compliance with
air pollution control laws and regulations. In addition, Vermont law requires a certificate of public good from the Public Service Board before beginning site
preparation or construction of electric ge ner ation facilities such as NSS EP

.

Comment #31 : There was one commenter who raised the concern that there may be an environmental justice issue with the location of the NSSEP.
“This neighborhood surrounding County Road (the main access road) is comprised of
mainly low to middle income families. These families have neither the legal knowledge
nor financial resources to defend their rights for clean air, water, and quality of life in
general. This appears to be an exploitation of this community to its abso lute fullest
without a vote on the matter and without proper and free legal representation.”
( Commenter 14)

Response: Environmental Justice is intended to prevent the disproportionate burden of
exposure to environmental risk on minorities and the poor. The EPA has been tasked
with addressing Environmental Justice issues, and uses the NEPA process to include this review. NEPA covers many projects and/or activities of the Federal government,
but permits issued under the Clean Air Act are conditionally exe mpt from NEPA review.

A review of data available from the EPA’s websites related to Environmental Justice
issues, they offer a tool for establishing the social

- economic composition of populations
based on their geographic location. Using this tool

, the A gency searched for theVermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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March 29, 2013 Page 25 of 28

demographics of an area with a 1 mile radius around the Precision Drive Industrial

Park

– 1 mile is the smallest search area available using this tool. The data shows that
the population in this area is >99% Caucasian and the % of t he population classified as
having incomes below the poverty level were 5.5%. This same database indicates that
9.4% of all Vermonters have incomes below the poverty level. This data indicates that

there is not a notable concentration of minorities livin g near the proposed NSSEP and
there is not a disproportionate level of low income citizens living around the project site.
Additionally, it appears that the interests and concerns of the local population are being
represented by NoSAG in the Public Servic e Board’s Certificate of Public Good (CPG)

process.

Comment #32 : The proposed facility may negatively impact local property values
( Commenters 7, 12)

Response: The issue raised by this comment is outside the scope of the Agency’s air
permitting authority under 10 VSA Chap. 23, and therefore the Agency is not
considering it in the final decision for this permit.



### Other Comments:

Comment 3 3 : A commenter asked if NSSEP has submitted their Acid Rain permit
application as required in Condition (8) of the draft Air Pollution Control Permit to
Construct. ( Commenter 3)

Response: The Acid Rain permit application has not been received by the Agency as
of the date of this document. As stated in the permit condition, the Acid Rain permit
application must be submitted at least 24 months before commencing operation of the

boiler.

Comment #34 : Please explain why the Air Quality Permit Application dated December

28 th 2011, was accepted by ANR, it was signed and certified to be correct by a
professional engin eer who is not registered in Vermont as a professional engineer?
( Commenters 2, 9)

Response: The Agency does not require Air Pollution Control Permit Applications to
be signed by a professional engineer or a professional engineer registered in the State
of Vermont. The application submitted has met the standards required by the Agency.

Comment #35 : Upon examination ANR may also find that the firm who provided the
services for the petitioner for the air quality permit is not registered as a corporation to do work in State of Vermont. ( Commenter 9)Vermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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March 29, 2013 Page 26 of 28

Response: The Agency has confirmed that Epsilon Associates, Inc. was not registered
as a corporation with the State of Vermont’s Secretary of State at the time the Air

Polluti on Permit to Construct Application was submitted to the Agency. Under the advice of the Secretary of State’s Corporations Division, the Air Division advised Epsilon Associates, Inc. that they should register with the Secretary of State’s office.

Comment #3 6 : Several comments referenced the following position of the American Lung Association with regards to wood/biomass energy facilities issued on June 23,

2012: “The American Lung Association does not support biomass combustion for
electricity production, a cat egory that includes wood, wood products, agricultural
residues or forest wastes, and potentially highly toxic feedstocks, such as construction

and demolition waste. If biomass is combusted, state

- of

- the

- art pollution controls must
be required.” ( Commenters 6, 9, 20, 21, 25, 27)

Response: The Agency is approving an Air Pollution Control Construction Permit for

NSSEP that will use state

- of

- the

- art pollution controls. Moreover, the permit does not

authorize NSSEP to use potentially highly toxic feed stocks, such as construction and

demolition waste.

Comment #37 : Two c ommenters we re not in favor of the use of subsidies, fees and
similar surcharges to help fund development projects such as renewable energy.
( Commenters 7, 24)

Response: The issue raised by this comment is outside the scope of the Agency’s air
permitting authority under 10 VSA Chap. 23, and therefore the Agency is not
considering it in the final decision for this permit.

Comment 38 : A commenter cited news articles about fires and/or explosions at one or
more biomass power plants. ( Commenter 1)

Response: The issue raised by this comment is outside the scope of the Agency’s air
permitting authority under 10 VSA Chap. 23, and therefore the Agency is not
considering it in the final decision for this permit.

Comment 39 : One commenter questioned the validity of the election of Governor
Shumlin and the appointment of Debbie Markowitz, the Secretary of the Agency of
Natural Resources. ( Commenter 1)

Response: The issue raised by this comment is outside the scope of the Agency’s air
permitting authority under 10 VSA Chap. 23, and therefore the Agency is not
considering it in the final decision for this permit.Vermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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Comment 40 : A comment claimed that the air emissio ns from the proposed project
make the facility subject to the American’s With Disabilities Act and it must make
accommodations to individuals living in the area around the plant who have
respiratory disabilities. ( Commenter 1)

Response: The issue raised by this comment is outside the scope of the Agency’s

air permitting authority under 10 VSA Chap. 23, and therefore the Agency is not
considering it in the final decision for this permit.

Comment 41 : Several comments referenced regulatory requirements of other
states, such as Massachusetts regarding renewable energy and biomass facilities
in particular. ( Commenters 9, 14, 15, 21, 22, 24)

Response: The issue raised by this comment is outside the scope of the Agency’s air
permitting authority under 10 VS A Chap. 23, and therefore the Agency is not
considering it in the final decision for this permit.

Comment 42 : Can the Air Pollution Control Division require a performance bond that
will pay for relocation and property value compensation to homeowners experiencing
such problems? What preliminary tests need to be done to ensure a comparison for
such claims? ( Commenter 8)

Response: The issue raised by this comment is outside the scope of the Agency’s air
permitting authority under 10 VSA Chap. 23, and therefore the Agency is not
considering it in the final decision for this permit.

Comment 43 : There is a claim that this project would adversely impact the heath and habitat of the bald eagle and thereby violate of The Bald and Golden Eagle Protection
Act. ( Commenter 1)

Response : The issue raised by this comment is outside the scope of the Agency’s air
permitting authority under 10 VSA Chap. 23, and therefore the Agency is not
considering it in the final decision for this permit. This concern has been forwarded to
the VT Department of Fish and Wildlife.

Comment 44 : The air quality goals of the Springfield town plan were noted in several
comments. ( Commenters 3, 9, 25)

Response : The issue raised by this comment is outside the scope of the Agency’s air
permitting authority under 10 VSA Chap. 23, and therefore the Agency is not
considering it in the final decisio n for this permit.Vermont D e partment of Envir o n me n tal Conserv a tion A gency of Natu r al

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Written and/or oral comments were received from the following individuals and
organizations:

Commenter #1 : Cris Erikson

Commenter #2: Julie Jones

Commenter #3: Fredda Kischko

Commenter #4: Judith Dubreuil

Commenter #5: Bob Flint

Commenter #6 : Richard Hunter

Commenter #7: Henry Kraft

Commenter #8: Walter Dodd

Commenter #9: Robert Kischko

Commenter #10: Lorraine Dubreuil

Commenter #11: Jan Zona

Commenter #12: Steve Sysko

Commenter #13: Jean Willard

Commenter #14 : Margaret Kelly

Commenter #15: Julia Lloyd Wright

Commenter #16: Kerstin Burlingame

Commenter #17: Louise Peale

Commenter #18: Daniel Lewis

Commenter #19: Michael Wiese

Commenter #20: The Vermont American Lung Association.

Commenter #21: Eleanor Rice

Commenter #22: Jan Ameen

Commenter #23: Steve Donovan

Commenter #24 : Jeff and Debbie

Commenter #25: Laurie Fila

Commenter #26: The Partnership for Policy Integrity.

Commenter #27: Randall Susman

Commenter #28: USFS

– Federal Land Manager

Commenter #29: Wendy Thompson

Commenter #30: Reuben Allen