PERMIT APPLICATION 

REVIEW SUMMARY

New Hampshire Department of Environmental Services 

Air Resources Division 

P.O. Box 95, 29 Hazen Drive

Concord, NH 03302-0095

Phone: 603-271-1370 Fax: 603-271-7053 

Facility: Former Pease Air Force Base Engineer: B. Dorfschmidt 

Location: Newington 

AFS #: 3301590949 Application #: 09-0113 Date: 8/6/09 Page 1 of 3 

 

PROJECT DESCRIPTION 

The Air Force has contracted AMEC to conduct a groundwater remediation project for a jet fuel spill at the former Pease 

Air Force Base (Pease AFB) at the Pump House 2 location (PH2). Based on a regulatory analysis, AMEC determined that 

the proposed PH2 emissions, when added to the existing Plume 13/14 air sparging/soil vapor extraction (AS/SVE) system, 

will result in combined, potential, uncontrolled VOC emissions exceeding the major source threshold of 50 tpy. This 

application requests a Temporary Permit to restrict the VOC emissions from the site to less than 50 tpy. 

CHANGES FROM PREVIOUS PERMIT 

Not applicable.

FACILITY/PROCESS DESCRIPTION 

PH2 and the associated hydrant laterals were used to transport JP-4 from 1956 through 1966. Over the course of its 

operation, leakage from the PH2 systems contaminated adjacent soils and groundwater forming the groundwater plumes 6, 

7, 8, and 9. These plumes are collectively referred to as the PH2 site. AMEC has been contracted by the Air Force to 

conduct a groundwater remediation project for the PH2 jet fuel spill. The jet fuel will be removed using an AS/SVE 

system. 

Remediation of the Plume 13/14 area is an ongoing AS/SVE system operated by the URS Corp (under contract with the Air 

Force) for removal of jet fuel from groundwater. On April 9, 2007, DES determined that no permit was required for this 

system, as it was proposed, see engineering summary for application FY04-0453. The AS/SVE system was installed but 

due to unforeseen problems, continued operation of the system has yet to be achieved. 

Site 8 is located at the north end of the former flightline on the former Pease AFB. From 1961 to 1988, Site 8 was an 

active fire training area using jet fuel and mixed waste oils, solvents and fuels. Clean-up operations at Site 8 currently 

include a SVE system and an air stripper, and an air sparge system has recently been added. This site is regulated under 

EPA’s Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Clean-up sites regulated 

under CERCLA are exempt from state air permitting requirements in accordance with 40 CFR 300.400(e)(1). However, 

these emissions must be considered when evaluating major source applicability. 

POLLUTION CONTROL EQUIPMENT 

VOC emissions from the PH2 AS/SVE system will be controlled by a catalytic oxidizer with an expected control efficiency 

of 95%. 

VOC emissions from the Plume 13/14 AS/SVE system are controlled by a catalytic oxidizer with a control efficiency of 

95%. 

EMISSION CALCULATIONS 

Emissions for the PH2 remediation system were derived from measured soil vapor data obtained during a pilot test 

conducted in the fall of 2008. AMEC used this data, the design vacuum flow rate for the system, and the calculation 

methodologies that were used for Plume 13/14 (see engineering summary for application FY04-0453) to estimate the 

emissions. Detailed calculations are contained in Attachment 2 of the application. 

Emission estimates for Plume 13/14 have not changed since the time of application FY04-0453. Since continued operation 

of the AS/SVE system has not been achieved, no testing of actual organic concentrations of the system has been conducted. 

The emission estimates are based on a pilot test study which assumed all organics were fuel oil. It has been determined 

there is a high amount of methane gas trapped in the ground in the area of the plume. Methane is not a VOC, therefore, 
PERMIT APPLICATION REVIEW SUMMARY 

Facility: Former Pease Air Force Base Engineer: B. Dorfschmidt 

Location: Newington 

AFS #: 3301590949 Application #: 09-0113 Date: 8/6/09 Page 2 of 3 

 

when the amount of methane is determined, the quantity of that compound can be subtracted from the total organic 

concentrations. This will lower the predicted VOC emissions. Until that number is determined, the original estimates must 

be used. 

VOC emissions from Site 8 are currently less than one ton per year and will have minimal impact on potential emissions as 

currently configured. However, to increase contaminant removal, air sparging has recently been added to the system for 

Site 8. Emissions data for Site 8 with the air sparging are not yet available. The emissions from the other systems will 

need to be balanced in order to keep the actual, facility-wide, uncontrolled emissions below the proposed permitted level of 

50 tpy. 

The following table summarizes the predicted VOC emissions from the entire site: 

Emission Source Pre-control Emissions Post-Control Emissions 

 max lb/day tpy max lb/day tpy 

PH2 110 20.1 5.5 1.01 

Plume 13/14 180 32.7 8.9 1.64 

Site 8 (actual 2006 emissions) 0.013 < 0.01 

Facility-Wide 290 52.8 14.4 2.65 

The pre-control emissions from the site will be restricted to less than 50 tpy in order for the source to be categorized as a 

synthetic minor source and in order to opt-out of the requirements of VOC RACT. 

Air Toxics Review

For air toxics, it is assumed that all of the organic emissions are equal to jet fuel (JP-4). Both the pre-control and postcontrolled emission rates are greater than the de minimus values of 7.9 lb/day and 2,888 lb/yr. The applicant used the 

proposed flow rates of the remediation system to calculate adjusted in-stack concentrations. The following table 

summarizes this information and compares the numbers to the AALs. 

Emission 

Source 

Flow Rate Pre-Control 

Emissions 

Adjusted 

In-Stack 

Post-Control 

Emissions 

Adjusted 

In-Stack 

24-hr AAL Annual AAL 

 (acfm) (lb/hr) (μg/m3) (lb/hr) (μg/m3) (μg/m3) (μg/m3) 

PH2 560 4.58 0.23 

Plume 13/14 3865 7.47 0.37 

Facility-wide 4425 12.05 1,817 0.60 90 671 1,006 

The adjusted in-stack concentration based on uncontrolled emission rates is greater than the AALs. The source could 

conduct an air dispersion modeling analysis to determine if impacts from uncontrolled emissions are incompliance with the 

AALs. The applicant has decided to accept permit conditions requiring the emissions be controlled instead of conducting 

dispersion modeling. As shown above, the adjusted in-stack concentration based on the controlled emission rates is less 

than both the annual and 24-hr AALs. 

MODELING 

Dispersion modeling was not conducted for this project as stated above. 

EMISSION TESTING 

No emission testing will be required at this time.

COMPLIANCE STATUS 

Emission Testing 

Not applicable 

Inspections

The remediation sites have never been inspected by the Air Resources Division. 

Reports 
PERMIT APPLICATION REVIEW SUMMARY 

Facility: Former Pease Air Force Base Engineer: B. Dorfschmidt 

Location: Newington 

AFS #: 3301590949 Application #: 09-0113 Date: 8/6/09 Page 3 of 3 

 

Not applicable 

Fees 

Since this source has never been permitted, they were required to pay an application fee of $2,000. 

REVIEW OF REGULATIONS 

State Regulations

Env-A 600 – Permitting 

• 607.01(a) – Not Applicable – Burner capacity of the oxidizers are less than 10 MMBtu/hr 

• 607.01(f) – Not Applicable – The oxidizers will burn a Type 5 waste at a capacity less than 200 lb/hr 

• 607.01(g) – Not Applicable – Actual VOC emissions are expected to be less than 10 tpy 

• 607.01(n) – Applicable – Source will restrict emissions in order to be a synthetic minor source of VOCs and to opt 

out of the requirements of VOC RACT 

• 607.01(v) – Applicable – Source is accepting a permit to control emission of RTAPs. 

Env-A 1200 – Prevention, Abatement, and Control of Stationary Source Air Pollution 

• Not applicable – the source is opting out of the requirements of VOC RACT by accepting a permit limit restricting 

the pre-control VOC emissions to less than 50 tpy. 

Env-A 1400 – Regulated Toxic Air Pollutants 

Source will be required to operate the oxidizers in order to control the emissions of jet fuel (see discussion above). If 

pollutant concentrations decrease sufficiently and the source demonstrates compliance with the AALs without the use of 

the oxidizers, then the operation of the oxidizer will no longer be required. 

Federal Regulations

No Federal Regulations apply to this source.