### 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 grou ndwater remediation project for a jet fuel spill at the former Pease Air Force Base (Pease AFB) at the Pump House 2 loca tion (PH2). Based on a regulatory analysis, AMEC d etermined that the proposed PH2 emissions, when added to the exist ing Plume 13/14 air sparging/soil vapor extraction (AS/SVE) system, will result in combined, potential, uncontrolled VO C 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 tp y.

CHANGES FROM PREVIOUS PERMIT Not applicable.

FACILITY/PROCESS DESCRIPTION PH2 and the associated hydrant laterals were used t o transport JP-4 from 1956 through 1966. Over the course of its operation, leakage from the PH2 systems contaminate d adjacent soils and groundwater forming the ground water plumes 6, 7, 8, and 9. These plumes are collectively referre d to as the PH2 site. AMEC has been contracted by the Air Force to conduct a groundwater remediation project for the P H2 jet fuel spill. The jet fuel will be removed us ing an AS/SVE system. Remediation of the Plume 13/14 area is an ongoing A S/SVE system operated by the URS Corp (under contra ct with the Air Force) for removal of jet fuel from groundwater. O n 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 fl ightline on the former Pease AFB. From 1961 to 198 8, Site 8 was an active fire training area using jet fuel and mixed waste oils, solvents and fuels. Clean-up operation s at Site 8 currently include a SVE system and an air stripper, and an ai r sparge system has recently been added. This site is regulated under EPA’s Comprehensive Environmental Response, Compens ation, and Liability Act (CERCLA). Clean-up sites regulated under CERCLA are exempt from state air permitting r equirements 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 co ntrolled by a catalytic oxidizer with an expected c ontrol efficiency of 95%. VOC emissions from the Plume 13/14 AS/SVE system ar e controlled by a catalytic oxidizer with a control efficiency of 95%.

EMISSION CALCULATIONS Emissions for the PH2 remediation system were deriv ed 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 t he calculation methodologies that were used for Plume 13/14 (see e ngineering summary for application FY04-0453) to es timate 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 co ntinued operation of the AS/SVE system has not been achieved, no test ing of actual organic concentrations of the system has been conducted. The emission estimates are based on a pilot test st udy which assumed all organics were fuel oil. It h as been determined there is a high amount of methane gas trapped in th e 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 quant ity of that compound can be subtracted from the tot al organic concentrations. This will lower the predicted VOC emissions. Until that number is determined, the or iginal estimates must be used. VOC emissions from Site 8 are currently less than o ne ton per year and will have minimal impact on pot ential emissions as currently configured. However, to increase contami nant removal, air sparging has recently been added to the system for Site 8. Emissions data for Site 8 with the air spa rging are not yet available. The emissions from th e other systems will need to be balanced in order to keep the actual, fa cility-wide, uncontrolled emissions below the propo sed permitted level of 50 tpy. The following table summarizes the predicted VOC em issions 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 res tricted 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 t he requirements of VOC RACT.

Air Toxics Review For air toxics, it is assumed that all of the organ ic emissions are equal to jet fuel (JP-4). Both th e pre-control and postcontrolled emission rates are greater than the de m inimus values of 7.9 lb/day and 2,888 lb/yr. The a pplicant used the proposed flow rates of the remediation system to ca lculate adjusted in-stack concentrations. The foll owing table summarizes this information and compares the number s 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) ( μ g/m 3 ) (lb/hr) ( μ g/m 3 ) ( μ g/m 3 ) ( μ g/m 3 ) 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 uncont rolled emission rates is greater than the AALs. Th e source could conduct an air dispersion modeling analysis to dete rmine if impacts from uncontrolled emissions are in compliance with the AALs. The applicant has decided to accept permit c onditions requiring the emissions be controlled ins tead of conducting dispersion modeling. As shown above, the adjusted in-stack concentration based on the controlled emis sion rates is less than both the annual and 24-hr AALs.

MODELING Dispersion modeling was not conducted for this proj ect 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. ReportsPERMIT 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 we re 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 bur n a Type 5 waste at a capacity less than 200 lb/hr

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

• 607.01(n) – Applicable – Source will restrict emiss ions in order to be a synthetic minor source of VOC s and to opt out of the requirements of VOC RACT

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

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

• Not applicable – the source is opting out of the re quirements 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 di scussion above). If pollutant concentrations decrease sufficiently and the source demonstrates compliance with the AALs wi thout the use of the oxidizers, then the operation of the oxidizer w ill no longer be required.

Federal Regulations

No Federal Regulations apply to this source.