# APPENDIX F Killington/Pico Ski Resort Partners, LLC . Operating Permit RACT provisions

AOP-04-025a Issued onJune 14, 2007 Only portions highlighted are intended for inclusion in the SIP. Strikeout text is not intended for inclusion in SIP .#A -0P A 4-0-26a ~-G#RV-19-7 0001

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P.O . Box 95 KillintE,- 9~eFatiGRG} LCillinn " nn/Rinn Ski Resort D~rFna ' . 

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### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a 

## FINDINGS OF FACT

-.a,--~-5~ p . Equipment SpeGifilGations k~ ~#R~ S ¬W Qate Bear#4- SateFpillar-35-9~ 7-75 3-,999 49M Rear~#2- Saterpillar--35s~ 77-5 31999 ~22F"~ Saterpillaf3599 7-75 3199A 1984 ~ea~-#~ ed with SGR On fall 2 illar 3516(e Cater ui 485 4 6 (= 499~ pp p q , -,-

### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a

Rear-PJev~W4 ~ea~-PJew--~1n+~#~ 

### S-.nQ-I.A .1S-.hed-#ISnew-S#ed-#2 Snow Shee3 Snow -S#ed-#4 S-newr-S#ed-#5 Snow Shp SpgarvS#p-#-7 Snow Sheeg Snow

She ~#9 S176W-She-#-a-B Tube-Park-#4 Tube P3Fk-#2 Make and Fn aw Gpw ~ gate iRstalled a-,69A Rentals 

### 2) 1 1 Fall 2002 ® 

## Caterpillar3509 I Proposed 

### 4-,6W I PFGposed 

### 7-75 I 3,000 

### I 6-6-0 I 2,7e0 I 77-5 I 

### I 650 I 2-,A)e I VTA 28 o 2,790

, 2,_79 0 7-75 I ~999 

### 7-75 I 3-IWe

s ncxTF e a-,609 ReRtal ¬ aIl--2092 Rental Fall -2003

### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a

[Date ofAGt*Gn May ^,nn4 januaFy 7, 1997 july 1, 1994 

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# I Ee I VOCS 2397 64 Total crfteroa #A4~

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### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a

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### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a 1G\ REVIEW FOR TI-IC PERMIT TO OPERATE

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### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a

### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a

o ^-i ^f ^- Title V Perm it +^ n^oF"to ° s°

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### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a

nnn~~ineiJ ir, fhiS Permit .

### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a



## PERMIT CONDITIONS

FequiFed by this PeFrn4-.-

(3) The Permittee shall, by the commencement of the 2002-2Q03 ski season, control emissions of nitrogen oxides (NOx) fromthe existing Caiterpillar 3516diesel engine (unit BR11) located at the Killington Resort by iristalling and operating a Selective Catalytic Reduction (SCR) system that is designed and operated to achieve a minimum of seventy (70,) percent reduction in the emissions of nitrogen oxides (NOx) during all periods of operation of the engine. The SCR control device system shall also be designed and operated to limit ammonia slip emissions to a maximumof ten (14) parts per million by volume on a dry basis (ppmvd) in the outlet exhaust during all periods of operation of the engine. All elements of these air pallution control systems shall be maintained in good working order at all times and operated in accordance with` the manufacturer's operation and maintenance recommendations. The air, pollution control systems shall be in operation whenever the respective emission source is in operation. [10 VS.A. §§556(c) and 556a(d)] [§5-251(3)©fthe Regulations] 

### (4) The Permittee shall, by July 1, 2007, either remove, render inoperable or replace all remaining existing engines as identified in Appendix Ato this Permit with the exception of unit BR11 as noted above. For each engine being replaced, the Permittee shall replace said engine with the cleanest air pollution emitting engine reasonably available at the time of replacement and shall at a minimummeet the emission limitations as provided in the Emission Limitations section of this Permit below . [10 V .S.A. §§556(c) and

### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a 556a(d)] [§§5-251(3), 5-271 and 5-404 of the Regulations] (5) For any given year in which engines are being replaced in accordance with the above condition, the total rated horsepower output of the replacement engines as specified by the,manufacturer shall not exceed the total horsepower of the engines being replaced as specified in Appendix A to this Permit, the Agency may grant an exception to the above where the Permittee can demonstrate that the total cumulative rated horsepower output of the replacement engines since the initiation of replacements does not exceed the total horsepower of the engines replaced as specified in Appendix A to this Permit. [1o v.s.A. §§556(c) and556a(d)1 [§5-251(3)ofthe Regulations] 

### (6) Prior to replacing each engine as required above, the Permittee shall provide theAgency with thefollowing: (a) Alisting of each-erigir9e being,,replaced; (b) The engine specifcatiars and emission specifications of each proposed replaceni,ent engine; (c) ` 'A cumulative listing of the manufacturer's rated horsepower output of all prior engine replacements and the currently, proposed engine replacements compared to the horsepower ratings of all existing engines that have been replaced and that are currently being proposed to be replaced; and - (d) Documentation and certification by the Permittee that the proposed replacement engines are the cleanest engines that are reasonably available to the best of their knowledge after reasonable inquiry. [10 V .3 .A. §§556(c) and 556a(d)] [§§5-251(3), 5-271 and 5-404 of the Regulations] (7) Prior t4 ,,all existing engines~ being 'replaced a$ ,required above, _unit BR11 shall be operated as the primary engine for the Bear Mtn. snovirmaking pad, being the first engine to be used when feasible when snawmakirfg compressed air is required at the Bear mountain location. [14v .S.A: §§556(c) and 556a(d)] [§§5-251(3)ofthe Regulations]


### - Operational°Limitations - (8) The annual fuel consumption in the stationary diesel engine units identified in Appendix A to this Permit, including those engines installed ,as replacements for such engines as well as any ri~%~r` installation of an engine installedx as part ,of the increased capacity approved "In this Pei`ifiit,~ shal(~,,Obt exceed a combined 1,070,00Q gallons per calendar year, ~<,ased -upon any, irolling twelve (12) donsecuti~re calendar month period. [1o v.s.A. §§556(c) and 556a(d)] [§5-2513) ofthe Regulations] (apPlicatidrifor#AOP-t74-025]



### (10) Only No. 2fuel oil, off-road diesel fuel, highway-grade diesel fuel, or lighter grade fuel oils with a maxirriurn'sulfur content not to exceed 0 .5 percent by weight may be used as

### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a 

### ine .-- obtains prior :writteri ; approval from the Agency; to use ano'ther .type of fuel . I1o v .s.a. §§556(c),anc! 556a(d)I L§a-129(9)(a) of the RO gufafions]



### - Emission Limitations - (14) Diesel Engine - Unit BR11 - Nitrogen Oxides and Ammonia Emission Limits: Emissions of nitrogen, oxides (NOx) fromthe existing Caterpillar ~596 diesel engine unit BR11 after installation- of thd SCRcatalyst'emission contrrol 'system `"shall not exceed 4

.8 grams per brake horsepower. (g/bhphr) and shall continuously -aohievea minimumof seventy (70) percent reduction in NOx emissionsduring all periods of engine operation. Emissions of ammonia shall not exceed ten (10) parts per million by volume on a dry basis (ppmvd) during all periods of engine operation. Any emission testing conducted to demonstrate compliance with the above emission limits shall be performed in accordance with 40 CFR Part 60, Appendix A, Reference Method 7E for NOx or an alternative method which has been published in 40 CFR, provided thefederally approved alternative method has been accepted in writing by the

### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a Agency before testing

: The Agency is requiring elsewhere in this Permit the use of, a 556a(d)] [§§5-251(3)and 5-404of the Regulations] 

### portable NOx analyz~t` to serve as an indication of cqmpliance but if the Agency has reason to believe the above emission limits are being exceeded it may require a compliance test in accordance with the above specified test methods. [10V .S.A. §§556(c) and Diesel Engines - Replacement Units and Installation of NewUnits after July 1 2002: Emissions from all stationary diesel engines purchased, rented or leased after July 1, 2002, including those engines installed as replacements for the existing engines identified in Appendix A to this Permit as we,ll,as any nowinstallation of an engine installed as park of th'e increased capacity approved in this Permit, shall at a minimum complywith the following limits: PoijutOot Emission, Limitations Replacementengines Emission Limitations g!bhphr' ppmvd z Nitrogen oxides (as NO) 4~8 350 Carbon monoxide 2 .6 315 Particulate matter 0 .15 0 .021 gldscm
~ glbhphr equals grams of pollutant emitted per brake horsepower hour. ppmvd equals parts per million volume on a dry basis corrected to fifteen (15) % oxygen.

404of the Regulations] Any emissioin testing conducted to demonstrate compliance with the above emission limit shall be performed in accordance with 40 CFR Part 60, Appendix A, Reference Methods 5, 7E, and 10 or equivalent methods approved in writing by the Agency at the rated load and speed of the engine,, Alternatively, compliance may be demonstrated by verifying that the engine has met the engine certification requirements of 40 CFR Part 89 for the Tier ~ emission standards or better. [10 V&A. §§556(e) and 556a(d)](§§5-251(3), 5-271 and 5- 

### (16) Diesel Engines -- Re lacement Units and lnstal(ation of New Units After Jul 12006 : Eniissions 'fromall stationary diesel engines~;purchased; tented or leased after July 1, 2006, .including those engines installed as, replacements for the existing engines identified in Appendix A to this Permit as well as any newiftstallation of an engine installed as part of the increased capacity approved in this Permit, shall at a minimum comply with the following limits unless the Permittee demonstrates tQthe Agency that after reasonable effort such engines, atwe not available and,.the Permittee obtains prior Written approvalfrom,the,Agency .,to install alternative engines:

### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a 

### Pollutant Emis4iart ~:imltations Replaceme4engines Emission Limitations glbhphr' ppmvd z Nitrogen oxides (as N02) 3 .0 220 Carbon monoxide 2~5 3'15 Particulate matter 0 .15 0,021 g/dscm I g/bhphrequalsgrams of pollutant emitted per brake horsepower hour. 2 ppmvd equals parts per million volume on a dry basis correctedtofifteen (15) °10 oxygen, 

### Any emission testing`,conducted to demonstrate compliance with the~ abdvea.Oxnission limit shall be performed in accordance with 40 CFR Part 60 ; Appendix A

; Reference Methods 5, 7E, and 10 or equivalent methods appr,aved in writing by theAgency at the rated load end speed of the engine. Alternatively, compliance may be demonstrated by verifying that the engine has met theengine certification requirements of 40 CFRPart 89 for theTier III emission standards or better. [1©v .s.a. §§556(c) and 556a(d)] [§§5-251(3), 5-271 and 5- 4©4 ofthe Regulations]

before ,c~t~_n,p .

### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a

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### - Compliance Testing and Monitoring - (23) General OW The Permittee shall, by January 1, 2005, develop and implement an operation and maintenance plan for the Facility engines as well as for the SCR catalyst emission control systemon unit BR11 . The plan shall address standard operation and maintenance procedures such as routine engine tune-ups, filter changes, catalyst cleaning frequencies (not to exceed every 500 hours) and routine inspections, including inspection of the urea >injection nozzles. The plan shall also include, but not be limited to, predicted equipment replacement intervals, appropriate monitoring parameters to ensure, proper operation, provisions for maintaining records of routine maintenance inspections, findings of those inspections, and any corrective actions which were taken. In additions;the plan.shall also include provisions for testing the exhaust gases from, at a minimum, unit :Ba11 with a portable NOx analyzer and computing the NOx destruction efficiency., Such

; testing shall be conducted at the beginning and midpoint of each snowmaking season. The portable : analyzer shall be operated, maintained and calibrated in accordance with,th4 manufacturer's recommendations. The Permitte~~ shall revise this plan at the Agbricy's request or on its own 'motion .to reflect equipment or operational changes. Sai& operation and maintenance plan shall be present at the facility at all times and° shall be rriade avajlalrile to representatives of the Agency upon request, [1t} V

.s.A . §§55f"s(d) arid 556a(d)] [§§5-251(3) and 5404oftheRegulations) 

### (24) The Perinittee shall ~monitbr and record the uria~injection quantities on a daily basis

the Regulations] during periods of engine operation in order to establish the normal operating parameters for the SCR systemand to thereafter determine periods of abnormally high or lowurea usage which could indicate stuck open or plugged injectors, respectively, or other problems requiring immediate maintenance. 11©v .s.a. §§55s(c) and 556a(d)] [§§5-251(3) and 5-a04of

### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a



### - Record Keeping and Reporting - (25) Records of Fuel Use: The Permittee shall maintain records of thetotal quantity offuel oil consumed in the Facility engines cornbinc-d,3in gallons, .each month . At the beginnin'g of each month, the Pecmittee shall .dalculate the.total -quantity of fuel, oil cottsumed; in the engines, in gallons;- during the previous t , +velVe`(12) consecutive month period. [10,V .s;a. §§556(c) and 556a(d)] [§5-405(1) of the Regulations]



### (27) Records of Fuel Certifications: The Permittee shali obtairi fromthe fuel1s,upplier, for each shipment of fuel oil received at the Facility for use in the engines, a certification or invoice stating the sulfur content of the fuel oil . ,The certification: or invoice shall include the name of the fuel ciil suppliei-, date of. delivery, fuel type, quantity offuel oil delivered, and a statementfromthefuel oil supplie,rtthat the,oil cdmplies with the specifications for fuel oil numbers 1 or, 2, as defined by the American Society,of, Testing and Materials in ASTMD396, "Standard Specifications for Fuel Oils" or a statement as to the sulfur content of the fuel oil in percent sulfur by weight: 110v .s.a_ §§556(c) and 556a(d)] [§5-4o5(1) ofthe Regulations]

. .

### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a

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Regulations] 

### (33) Semi-Annual Pehiadic Monitoring Reports: Within thirty (30) days after July 1 and January 1 of each year or an alternative schedule if approved in writing by the Agency, the Permittee shall submit to the Agency a"11report containing the following information regarding the'preceding six (S) months: (a) (b) 

### (c) emission Control system ; (d) a summary of the ur,ea'injection usage i-ate (e) the -results of, any erriission testiiig perf+~rrn6d'i~rf the Facility engines including results fromthe use of the portable NOx analyzer, including the NOx reduction efficiency calculation for unit BR11 ; and (f) a statement of the sulfur content of any and all fuel delivered to the Facility for use in the enginesduring the reporting period. (§§5-402(1), 5-A05(1) and 5-1015(5)

### ofthe Regulations]

sertifiGatiGR; repertiRg-per+eda suririiat'yof the, fuel-usage records required by this Permit; a summary of3tFie NOx emissions calculated for the engines installed as part of the increased capacity approved in this Permit; summary of all O&Mperformed on the Facility engines and SCR catalyst

### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a

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May 15 of eaGh y .

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### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a

- Standard Permit Condlotmens

Regulations

### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a
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### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a

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### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a

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### Killington/Pico Ski Resort Partners, LLC #AOP-04-025a

- Appendix A- Equipment Specifications Prior to Commencement of Replacements Under NOx RACT Unit Make and model BHP' CFMl Date Installed Bear#1 Caterpillar 3508 775 3,000 1984 Bear #2 Caterpillar 3508 775 3,000 1985 Bear#3 Caterpillar 3508 775 3,000 1984 Bear#4 Caterpillar 3508 775 3,000 1985 Bear *5 Caterpillar 3508 775 3,000 1985 Bear *6 Caterpillar 35,08 775 3,000 1985 Bear#7 Caterpillar 3508 775 3,000 1985 Bear#8 Caterpillar 3508 775 3,000 1985 Bear*9 Cummins VTA-28-P 650 2,700 1990 Bear *10 Cummins VTA-28-P 650 2,700 1990 Bear#11 Caterpillar 3516 (equipped with SCRinfall 2002) 1,485 6,000 1993 Bear #12 Cummin's VTA-28-P 650 2,700 1990 Snow Shed *1 Caterpillar 3508 775 3,000 1985 Snow Shed#2 CumminsVTA-28-P 650 2,700 1988 Snow Shed *3 Cummins VT'A-28-P 650 2,700 198$ Snow Shed #4 Cummins 1fTA 28-P 650 2,700 1988 Snow Shed #5 Cummins VTA-28-P 650 2,700 1988 Snow Shed *6 Cummins VTA-28-P 650 2,700 1990 Snow Shed *7 Cummins VTA-28-P 650 2,700 1988 Snow Shed #8 Cummins VTA-28-P 650 2,700 1988 Snow Shed #9 Cummins VTA-28-P 650 2,700 1988 Snow Shed "10 Cummins VTA-28-P 650 2,700 1987 22 total engines Totals 16,260 - - 1 bhp - brake horsepower rated output as specified by the manufacturer. 2 ated output of compressor. cfm - feet per minute' cubic r