APPENDIX F 

Killington/Pico Ski Resort Partners, LLC. 

Operating Permit RACT provisions 

AOP-04-025a 

Issued on June 14, 2007 

Only portions highlighted are intended for inclusion in the SIP. 

Strikeout text is not intended for inclusion in SIP. 
#A -0 P A 4-0-26a 

~-G#RV-19-7 0001 

State of VeFMGn 

ow G 

Wa«..--.,u, .. 

TITLE V 

TO OPERA rc -.--o 

. , 2004 

P.O. Box 95 

KillintE,- 

9~eFatiGRG} 

LCillinn "nn/Rinn Ski Resort D~rFna 

' . 

, LLG 
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~-#~ Cater p illar 3516 (e q ui pp ed with SGR On fall 2 4 , 485 6 -,- (= 499~ 
Killington/Pico Ski Resort Partners, LLC #AOP-04-025a 

Rear-PJev~W4 

~ea~-PJew--~1n+~#~ 

S- .nQ-I.A.1 S- .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 

® 

Caterpillar 3509 

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,_7 90 

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 of AGt*Gn 

May ^,nn4 

januaFy 7, 1997 

july 1, 1994 

requ"'**eMeRt& 

itoo ~ 91 nnn.. . . ., .+ troo on nFfi 

in. 

~}B~&-tG ^^t^^ Resort °^.t M^^ 

3,150 --Sp26es. 

rtoor~I nn~ ArnpAdmp n w.,mt"Ai itduH^^t^^ 'Ad 'e^t c., , ° oer"'~t n 

' I , , 

Spa62S: 
Killington/Pico Ski Resort Partners, LLC #AOP-04-025a 

PMIRMW I Ee I VOCS 

2397 64 

Total 

crfteroa 

#A4~ 

,< 

1 
Killington/Pico Ski Resort Partners, LLC #AOP-04-025a 

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

1G\ REVIEW FOR TI-IC PERMIT TO OPERATE 

IF}-FUel . 
Killington/Pico Ski Resort Partners, LLC #AOP-04-025a 
Killington/Pico Ski Resort Partners, LLC #AOP-04-025a 

o ^-i ^f ^- Title V Permi t +^ n^oF"to ° s° 

/n\ Cnfnrno~hilif~i 

uw ~r 
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) from the existing Caiterpillar 3516 diesel 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 maximum of 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) ©f the Regulations] 

(4) The Permittee shall, by July 1, 2007, either remove, render inoperable or replace all 

remaining existing engines as identified in Appendix A to 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 minimum meet 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) and 556a(d)1 [§5-251(3) of the Regulations] 

(6) Prior to replacing each engine as required above, the Permittee shall provide the Agency 

with the following: 

(a) A listing 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 BR 11 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 . [14 v.S.A : §§556(c) and 556a(d)] [§§5-251(3) of the 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) of the Regulations] (apPlicatidri for #AOP-t74-025] 

(10) Only No. 2 fuel 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) from the existing Caterpillar ~596 diesel engine unit BR11 after 

installation- of thd SCR catalyst 'emission contrrol 'system `"shall not exceed 4.8 grams per 

brake horsepower. (g/bhphr) and shall continuously -aohievea minimum of seventy (70) 

percent reduction in NOx emissions during 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 the federally 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 5-404 of 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. [10 V.S .A . §§556(c) and 

Diesel Engines - Replacement Units and Installation of New Units 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 now installation of an engine 

installed as park of th'e increased capacity approved in this Permit, shall at a minimum 

comply with the following limits : 

PoijutOot Emission, Limitations 

Replacement engines 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 . 

404 of 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 'from all 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 new iftstallation 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 tQ the Agency that 

after reasonable effort such engines , atwe not available and , .the Permittee obtains prior 

Written approval from ,the, Agency., to install alternative engines: 
Killington/Pico Ski Resort Partners, LLC #AOP-04-025a 

Pollutant Emis4iart ~ :imltations 

Replaceme4 engines 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/bhphr equals grams of pollutant emitted per brake horsepower hour. 

2 ppmvd equals parts per million volume on a dry basis corrected to fifteen (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 the Agency at the 

rated load end 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 III emission standards or better . [1© v.s .a . §§556(c) and 556a(d)] [§§5-251(3), 5-271 and 5- 

4©4 of the Regulations] 

before 

,c~t~_n,p . 
Killington/Pico Ski Resort Partners, LLC #AOP-04-025a 

n v c n 

- 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 system on 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 5404 of the Regulations) 

(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 system and to thereafter determine periods of abnormally high or low urea 

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-a04 of 
Killington/Pico Ski Resort Partners, LLC #AOP-04-025a 

- Record Keeping and Reporting - 

(25) Records of Fuel Use: The Permittee shall maintain records of the total quantity of fuel 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 from the fuel 1 s,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 of fuel oil delivered, 

and a statement from the fuel oil supplie,rt that the ,oil cdmplies with the specifications for 

fuel oil numbers 1 or, 2, as defined by the American Society,of, Testing and Materials in 

ASTM D396, "Standard Specifications for Fuel Oils" or a statement as to the sulfur 

content of the fuel oil in percent sulfur by weight: 110 v.s.a_ §§556(c) and 556a(d)] [§5-4o5(1) of the 

Regulations] 

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

e 

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" 

11 

report containing the following information 

regarding the'pre ceding 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 from the 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 engines during the reporting period . 

(§§5-402(1), 5-A05(1) and 5-1015(5) of the Regulations] 

sertifiGatiGR ; 

repertiRg -per+eda suririiat'y of 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&M performed on the Facility engines and SCR catalyst 
Killington/Pico Ski Resort Partners, LLC #AOP-04-025a 

, MA 02203 

May 15 of eaGh y . 

w 

r'CO Part 82 , v..~ . .~. .~.. Ci ihr, "+r+ C 

.

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

- Standard Permit Condlotmens 

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

; 

008( p )(4) . .f fhc oo.-.uiRtr.,.,~ 

kept by this PeFFAit. 

§,--~6(a)(6)(417 

5662(d)] 

a-BA8(&) 

GC)ndifinno 

of 

}his oe.rm*-[u 
Killington/Pico Ski Resort Partners, LLC #AOP-04-025a 

Reguiations3 

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

de 

n(o-^^ Si.- oe°^N ~A 
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 SCR in fall 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 Cummins VTA-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 cfm - cubic feet per minute' r ated output of compressor.