STATE OF NEW HAMPSHIRE Department of Environmental Services Air Resources Division 

# Title V Operating Permit

Permit No: TV-0055 Date Issued: March 15, 2010

This certifies that: Northeast Utilities Public Service of New Hampshire 780 North Commercial Street Manchester, NH 03101

has been granted a Title V Operating Permit for the following facility and location: Public Service of New Hampshire Merrimack Station 97 River Rd. Bow, NH 03304-3314 Facility ID No: 3301300026 ORIS Code: 2364 Application No: FY96-TV048 , received on July 1, 1996, Original Title V Operat ing Permit application

This Title V Operating Permit is hereby issued unde r the terms and conditions specified in the Title V application referenced above filed with the New Hampshire Depar tment of Environmental Services under the signature of the following responsible official certifying to the be st of their knowledge that the statements and infor mation therein are true, accurate and complete.



### Responsible Official: Designated Representative: John MacDonald (603) 634-2236 John MacDonald (603) 634-2236 Alternate Designated Representative: Technical Contact: William Smagula (603) 634-28 51 Laurel Brown (603) 634-2331 Authorized Account Representative: John MacDonald (603) 634-2236 Alternate Authorized Account Representative: William Smagula (603) 634-2851

This Permit is issued by the New Hampshire Departme nt of Environmental Services, Air Resources Divisio n pursuant to its authority under New Hampshire RSA 1 25-C, D, J, and O, and in accordance with the provi sions of the Code of Federal Regulations, Title 40, Part 70.

This Permit is effective upon issuance and expires on xxxx.

__________________________________ Director, Air Resources Division 

# Proposed

### Proposed

PSNH – Merrimack Station Page 2 97 River Road, Bow, NH TV-0055



## TABLE OF CONTENTS

ABBREVIATIONS......................................

................................................... ................................................... ..... 4

FACILITY SPECIFIC TITLE V OPERATING PERMIT CONDITIO NS ................................................. ........... 6

I. F ACILITY 

### D ESCRIPTION OF 

### O PERATIONS



### ................................................... ................................................... .. 6 II. P ERMITTED 

### A CTIVITIES



### ................................................... ................................................... ......................... 6 III. S IGNIFICANT 

### A CTIVITIES 

### I DENTIFICATION AND 

### S TACK 

### C RITERIA



### ................................................... ............. 6 A. Significant Activity Identification................

................................................... ........................................ 6 B. Stack Criteria .....................................

................................................... ................................................. 8 IV. I NSIGNIFICANT 

### A CTIVITIES 

### I DENTIFICATION



### ................................................... ............................................. 9 V. E XEMPT 

### A CTIVITIES 

### I DENTIFICATION



### ................................................... ................................................... .... 9 VI. P OLLUTION 

### C ONTROL 

### E QUIPMENT 

### /M ETHOD 

### I DENTIFICATION



### ................................................... ................. 9 VII. A LTERNATIVE 

### O PERATING 

### S CENARIOS



### ................................................... ............................................... 10 A. Trial Test Burns with Other Fuels (Temporary Permit s FP-T-0054 & TP-B-0462) ........................... 10 B. Fly Ash Re-injection (Temporary Permit Nos. FP-T-00 54, TP-B-0462):.................................... ........ 12 C. Early Mercury Emission Reduction Methods (RSA 125-O :13) (State Enforceable Only): ................. 12 VIII. A PPLICABLE 

### R EQUIREMENTS



### ................................................... ................................................... ........... 12 A. State-only Enforceable Operational and Emission Lim itations........................................... ................ 12 B. Federally Enforceable Operational and Emission Limi tations ............................................ ............... 17 C. Annual SO 2 

### Allowance Programs (40 CFR 72, 40 CFR 73, Env-A 61 1.07, and Env-A 2900)............ 26 D. Ozone Season NOx Budget Trading Program (Env-A 3200 ).................................................. ............. 27 E. Non-Ozone Season NOx Allowances and NOx RACT Orders (NOx RACT Orders ARD-97-001 and ARD-98-001) ........................................

................................................... ................................................... .... 30 F. Multiple Pollutant Annual Budget Trading and Bankin g Program (Env-A 2900) [State-only enforceable] .......................................

................................................... ................................................... ...... 33 G. Discrete Emission Reduction Trading Program (Env-A 3100).............................................. .............. 36 H. Carbon Dioxide (CO 2 

### ) Budget Trading Program (Env-A 4600) (State-only E nforceable)................. 36 I. Monitoring/Testing Requirements ....................

................................................... .................................... 38 J. Recordkeeping Requirements.........................

................................................... ................................... 59 K. Reporting Requirements.............................

................................................... ....................................... 71 IX. R EQUIREMENTS 

### C URRENTLY 

### N OT 

### A PPLICABLE



### ................................................... ..................................... 86

GENERAL TITLE V OPERATING PERMIT CONDITIONS........

................................................... ................. 86

X. I SSUANCE OF A 

### T ITLE 

### V O PERATING 

### P ERMIT



### ................................................... ......................................... 86 XI. T ITLE 

### V O PERATING 

### P ERMIT 

### R ENEWAL 

### P ROCEDURES



### ................................................... ........................... 86 XII. A PPLICATION 

### S HIELD



### ................................................... ................................................... ...................... 86 XIII. P ERMIT 

### S HIELD



### ................................................... ................................................... ............................... 87 XIV. R EOPENING FOR 

### C AUSE



### ................................................... ................................................... ................... 88 XV. A DMINISTRATIVE 

### P ERMIT 

### A MENDMENTS



### ................................................... ........................................... 88 XVI. O PERATIONAL 

### F LEXIBILITY



### ................................................... ................................................... ............. 88 XVII. M INOR 

### P ERMIT 

### A MENDMENTS



### ................................................... ................................................... ........ 91 XVIII. S IGNIFICANT 

### P ERMIT 

### A MENDMENTS



### ................................................... ............................................... 91 XIX. T ITLE 

### V O PERATING 

### P ERMIT 

### S USPENSION 

### , R EVOCATION OR 

### N ULLIFICATION 

### ....................................... 91 XX. I NSPECTION AND 

### E NTRY



### ................................................... ................................................... .................. 92 XXI. C ERTIFICATIONS



### ................................................... ................................................... .............................. 92 A. Compliance Certification Report ....................

................................................... .................................. 92

### Proposed

PSNH – Merrimack Station Page 3 97 River Road, Bow, NH TV-0055

B. Certification of Accuracy Statement ................

................................................... ................................. 92 XXII. E NFORCEMENT



### ................................................... ................................................... ................................ 93 XXIII. E MISSION 

### -B ASED 

### F EE 

### R EQUIREMENTS



### ................................................... ............................................ 93 XXIV. D UTY 

### T O 

### P ROVIDE 

### I NFORMATION



### ................................................... ................................................... 95 XXV. P ROPERTY 

### R IGHTS



### ................................................... ................................................... ....................... 95 XXVI. S EVERABILITY 

### C LAUSE



### ................................................... ................................................... ................ 95 XXVII. E MERGENCY 

### C ONDITIONS



### ................................................... ................................................... ............ 95 XXVIII. P ERMIT 

### D EVIATION



### ................................................... ................................................... ............... 96

FEDERAL ACID RAIN REQUIREMENTS .....................

................................................... ............................... 97

XXIX. P HASE 

### II A CID 

### R AIN 

### P ERMIT 

### A PPLICATION



### ................................................... ..................................... 97 XXX. G ENERAL 

### A CID 

### R AIN 

### P ROVISIONS



### ................................................... .................................................. 9 7

### Proposed

PSNH – Merrimack Station Page 4 97 River Road, Bow, NH TV-0055



## ABBREVIATIONS AAL Ambient Air Limit AEL Alternative Emission Limit AP-42 Compilation of Air Pollutant Emission Factors ARD Air Resources Division ASTM American Society for Testing and Materials ATS Allowance Tracking System BACT Best Available Control Technology BHP (or bhp) Brake Horse Power BTU British Thermal Units CAA Clean Air Act, 42 U.S.C. § 7401, et seq. CAM Compliance Assurance Monitoring CAS Chemical Abstracts Service CEMS Continuous Emission Monitoring System CFR Code of Federal Regulations CNG Compressed Natural Gas CO Carbon Monoxide CO 2 

### Carbon Dioxide COMS Continuous Opacity Monitoring System DER Discrete Emission Reduction Env-A New Hampshire Code of Administrative Rules – Air Resources Division Env-Wm New Hampshire Code of Administrative Rules – Waste Management Division ECS Emission Control System ERC Emission Reduction Credit ETS Emissions Tracking System FR Federal Register gal/hr Gallons per hour HAP Hazardous Air Pollutant HHV High Heat Value HCl Hydrochloric acid hr Hour kscfm 1,000 standard cubic feet per minute kGal 1,000 gallons KVDC Kilovolt Direct Current KW Kilowatt LAER Lowest Achievable Emission Rate lb/hr Pounds per hour LNB Low NO x 

### Burner LNG Liquid Natural Gas LPG Liquid Petroleum Gas (Propane) MACT Maximum Achievable Control Technology mg/L Milligrams per liter mmBtu Million British Thermal Units MMCF Million Cubic Feet MW Megawatt NAAQS National Ambient Air Quality Standard

### Proposed

PSNH – Merrimack Station Page 5 97 River Road, Bow, NH TV-0055



## ABBREVIATIONS (cont.) NATS NOx Allowance Tracking System NESHAPs National Emissions Standards for Hazardous Air Pollutants NG Natural Gas NHDES (or DES) New Hampshire Department of Environm ental Services NMOC Non-Methane Organic Compound NO x 

### Oxides of Nitrogen NSPS New Source Performance Standard NSR New Source Review PCB Polychlorinated biphenyls PE Potential Emission PM Particulate Matter PM 10 

### Particulate Matter less than 10 microns diameter ppm part per million ppmdv part per million by dry volume PSD Prevention of Significant Deterioration PSI Pounds per Square Inch PTE Potential to Emit PUC Public Utilities Commission RACT Reasonably Available Control Technology RTAP Regulated Toxic Air Pollutant SIP State Implementation Plan SO 2 

### Sulfur Dioxide T-12M Tons during any consecutive 12-month period TAP Toxic Air Pollutant TSP Total Suspended Particulate Matter TPY Tons per Year USEPA United States Environmental Protection Agency VER Voluntary Emission Reduction VOC Volatile Organic Compound

### Proposed

PSNH – Merrimack Station Page 6 97 River Road, Bow, NH TV-0055



## Facility Specific Title V Operating Permit Conditio ns

I. Facility Description of Operations

PSNH - Merrimack Station is a fossil fuel-fired ele ctricity generating facility, owned and operated by Public Service of New Hampshire (PSNH), a subsidiar y of Northeast Utilities. The facility is comprised of two utility boilers, two combustion tu rbines operating as load shaving units, an emergency generator, an emergency boiler, and prima ry and secondary coal crushers. The facility operations also include various activities that are classified as insignificant or exempt activities.

The two utility boilers (MK1 and MK2) primarily bur n bituminous coal; the two combustion turbines primarily burn No. 1 fuel oil or JP-4; the emergency generator burns No. 2 fuel oil or diesel fuel, and the emergency boiler burns No. 2 fuel oil or low sulfur diesel fuel. PSNH – Merrimack Station ignites the two utility boilers with No. 2 fuel oil.

Each utility boiler stack is equipped with continuo us emissions monitoring systems (CEMS) and a continuous opacity monitoring system (COMS). PSNH – Merrimack Station emits NOx, SO 2 

### , CO, VOCs, PM, CO 2 

### , RTAPs, and HAPs. PSNH – Merrimack Station has in stalled control equipment and implemented operational changes to reduce emiss ions, including selective catalytic reduction (SCR) systems to control NOx emissions, and electro static precipitators (ESP) to control PM emissions.

PSNH – Merrimack Station operates a fly ash re-inje ction system in each of the two Boilers. Flyash is reinjected from the ash hoppers into the cyclone boilers for up to 24 hours per day and each day of the year. This is considered normal operation of t he flyash injection system. 1



### II. Permitted Activities

In accordance with all of the applicable requiremen ts identified in this permit, the Permittee is authorized to operate the devices and or processes identified in Sections III, IV, V and VI within the terms and conditions specified in this Permit.

III. Significant Activities Identification and Stack Cri teria

A. Significant Activity Identification

The activities identified in the following table (T able 1) are subject to and regulated by this Title V Operating Permit:

1 Particulate matter emissions from the boiler are g enerally lower when flyash is not reinjected into t he boiler.

### Proposed

PSNH – Merrimack Station Page 7 97 River Road, Bow, NH TV-0055

Table 1 Significant Activity Identification Emission Unit Number Description of

Emission Unit Maximum Gross Heat Input Rate or Maximum Power Output Maximum Operating Conditions

MK1 Steam Generating Unit 1

(Installed in 1960) Front wall firing Bituminous Coal: 1,238 mmBtu/hr A) Maximum fuel consumption rate of bituminous coal shall be limited to 48.5 tons/hr, not to exceed 425,289 tons during any consecutive 12-month period 2 B) No. 2 fuel oil consumption shall not exceed 14.5 million gallons during any consecutive 12 month period. MK2 Steam Generating Unit 2

(Installed in 1968) Opposed wall firing Bituminous Coal: 3,473 mmBtu/hr A) Maximum fuel consumption rate of bituminous coal shall be limited to 136.2 tons/hr, not to exceed 1,193,078 tons during any consecutive 12-month period 3

. B) No. 2 fuel oil consumption shall not exceed 14.5 million gallons during any consecutive 12 month period. MKCT1 Combustion Turbine #1

(Installed in 1968) One-end only firing No. 1 fuel oil or JP-4: 319 mmBtu/hr Maximum fuel consumption rate shall not exceed 2,279 gal/hr 4

.

MKCT2 Combustion Turbine #2

(Installed in 1969) One-end only firing No. 1 fuel oil or JP-4: 319 mmBtu/hr Maximum fuel consumption rate shall not exceed 2,279 gal/hr 5

. MKPCC Primary Coal Crusher

System consisting of two crushers that operate in parallel (Installed in 1960) NA Maximum operating rate of MKPCC shall be limited to 885 ton/hr coal.



### MKSCC Secondary Coal Crusher

System consisting of two crushing systems employing two crushers (for a total of four NA Maximum operating rate of MKSCC shall be limited to 690 ton/hr coal.

2 The heating value of bituminous coal is assumed to be 12,750 Btu/lb. The fuel consumption rates may vary based on the actual heat content of the fuel burned. 3 The heating value of bituminous coal is assumed to be 12,750 Btu/lb. The fuel consumption rates may vary based on the actual heat content of the fuel burned. 4 The heating value of JP-4 and No. 1 fuel oil is as sumed to be 140,000 Btu/gal. The fuel consumption rates may vary based on the actual heat content of the fuel burned. 5 The heating value of JP-4 and No. 1 fuel oil is as sumed to be 140,000 Btu/gal. The fuel consumption rates may vary based on the actual heat content of the fuel burned.

### Proposed

PSNH – Merrimack Station Page 8 97 River Road, Bow, NH TV-0055

Table 1 Significant Activity Identification Emission Unit Number Description of

Emission Unit Maximum Gross Heat Input Rate or Maximum Power Output Maximum Operating Conditions

crushers) operating in parallel (Installed in 1960) 

### MKEG Emergency Generator

(Installed in 1988) Diesel fuel or No. 2 fuel oil: 3.93 mmBtu/hr A) Maximum fuel consumption rate of diesel fuel shall not exceed 28.7 gal/hr. 6 B) Maximum fuel consumption rate of No. 2 fuel oil shall not exceed 28.1 gal/hr. 7



### MKEB Emergency Boiler

(Temporary – Each installation) No. 2 fuel oil (with a maximum sulfurcontent of 0.4% by weight), or onroad low sulfur diesel oil (with a maximum sulfur content of 0.05% by weight): 96 mmBtu/hr A) Maximum fuel consumption rate of No. 2 fuel oil shall not exceed 520 gal/hr and 11,760 gal/day 8 ; or B) Maximum fuel consumption rate of on-road low sulfur diesel oil shall not exceed 701 gal/hr



### B. Stack Criteria

A. The following devices at the Facility shall have ex haust stacks that discharge vertically, without obstruction, and meet the criteria in Table 2:

Table 2 – Stack Criteria Stack Number Emission

Unit Number Emission Unit

Description Minimum Stack

Height (Feet) Above Ground Level Maximum

Inside Stack Diameter (Feet)

STMK1 MK1 Steam Generating Unit No. 1 225 8.6

STMK2 MK2 Steam Generating Unit No. 2 317 14.5

STMKCT1 MKCT1 Combustion Turbine #1 20 10.5 x 14

STMKCT2 MKCT2 Combustion Turbine #2 20 10.5 x 14 STMKEG MKEG Emergency Generator 12 0.5 STMKEB MKEB Emergency Boiler 22.33 4.0

6 The heating value of the fuel is assumed to be 137 ,000 Btu/gal. The fuel consumption rates vary base d on the actual heat content of the fuel burned. 7 The heating value of No. 2 fuel oil is assumed to be 140,000 Btu/gal. The fuel consumption rates may vary based on the actual heat content of the fuel burned. 8 The heating value of No. 2 fuel oil is assumed to be 140,000 Btu/gal. The fuel consumption rates may vary based on the actual heat content of the fuel burned.

### Proposed

PSNH – Merrimack Station Page 9 97 River Road, Bow, NH TV-0055

B. Stack criteria described in Table 2 may be chang ed without prior approval from the Division provided that: 1. An air quality impact analysis is performed eith er by the facility or the Division (if requested by the facility in writing) in accordance with Env-A 606, Air Pollution Dispersion Modeling Impact Analysis Requirements, a nd the “Guidance and Procedure for Performing Air Quality Impact Modelin g in New Hampshire,” and 2. The analysis demonstrates that emissions from th e modified stack will continue to comply with all applicable emission limitations and ambient air limits. C. All air modeling data and analyses shall be kept on file at the facility for review by the Division upon request. D. The Owner or Operator shall provide written noti fication to the Division of the stack change within 15 days after making the change. Suc h notification shall include: 1. A description of the change; and 2. The date on which the change occurred.

IV. Insignificant Activities Identification

All activities at this facility that meet the crite ria identified in Env-A 609.04(d), shall be conside red insignificant activities. Emissions from the insig nificant activities shall be included in the total facility emissions for the emission-based fee calcu lation described in Section XXIII. of this Permit.

V. Exempt Activities Identification

All activities identified in Env-A 609.03(c) shall be considered exempt activities and shall not be included in the total facility emissions for the em ission based fee calculation described in Section XXIII of this permit.

VI. Pollution Control Equipment/Method Identification

The devices and/or processes identified in Table 3 are considered pollution control equipment or techniques for each identified emissions unit:

Table 3 – Pollution Control Equipment/Method Identi fication Pollution Control Equipment Number Description of Equipment/Method Emission Unit Number

MK1-PC1 Electrostatic Precipitator (ESP) #1 on MK1 MK1 MK1-PC2 ESP #2 on MK1 MK1 MK1-PC3 Selective Catalytic Reduction (SCR) System MK1 MK2-PC4 ESP #1 on MK2 MK2 MK2-PC5 ESP #2 on MK2 MK2 MK2-PC6 SCR System MK2

### Proposed

PSNH – Merrimack Station Page 10 97 River Road, Bow, NH TV-0055

VII. Alternative Operating Scenarios

While operating under an alternative operating scen ario, the Permittee shall comply with all applicable requirements specified in this permit, i ncluding but not limited to, state and federal operational and emission limitations specified in S ection VIII.A and H, monitoring, and testing requirements specified in Section VIII. I, recordke eping requirements specified in Section VIII. J and reporting requirements specified in Section VIII.K. Pursuant to 40 CFR 70.6 (a)(9), the Permittee shall keep all applicable records pertaining to the alternative operating scenario during such operation. The Permittee shall keep a record of th e scenario under which it is operating.

A. Trial Test Burns with Other Fuels (Temporary Permit s FP-T-0054 & TP-B-0462)

Prior to the use of any fuel other than bituminous coal, No. 2 fuel oil or other fuels previously reviewed and approved by DES, PSNH – Merrimack Stat ion shall submit a proposal to DES, which shall include, but not be limited to the foll owing:

1. Type of fuel;

2. Analysis data of the fuel proposed, which shall inc lude proximate and ultimate analysis, volatile and semi-volatile analyses (i.e., EPA Meth od 8240, 8250, 8260, or 8270) and metals analysis (i.e., Method 3050 and mercury).

3. Specification of baseline operating conditions at P SNH - Merrimack Station including coal feed rate, percent moisture of coal feed, oil firin g rate, ESP and SCR operating conditions, and emissions values of SO 2 

### , NOx, particulate matter (TSP and PM 10 

### , if available), CO (if available), and opacity;

4. A comprehensive test plan, which shall present the proposed operating conditions for the trial burn, to include but not be limited to the fo llowing:

a) Length of fuel trial;

b) New fuel rate;

c) Means of measuring new fuel feed rate;

d) Description of new fuel feed process;

e) New fuel preparations prior to burning;

f) Percent moisture of new fuel feed;

g) Time table for operation stability;

h) Coal feed rate;

i) Coal percent moisture;

### Proposed

PSNH – Merrimack Station Page 11 97 River Road, Bow, NH TV-0055

j) ESP and SCR operating conditions;

k) Expected emission values of opacity, SO 2 

### , NOx , particulate matter (TSP and PM 10 

### , if available), and CO;

l) The test plan shall also address the continuous tra cking or operational data prior to the fuel trial, during the fuel trial, and for a short time after the fuel trial. SO 2 

### , NOx, and opacity can be monitored using the existing CEMs.

m) A compliance stack test protocol for TSP emissions using US EPA Methods 1 through 4, Method 5, Method 17, or a DES approved alternative, when requested by DES.

n) Operational parameters to be monitored and recorded , which shall include, but not be limited to steam flows, boiler temperatures, ammoni a flow, and oxygen;

o) The effects of the new fuel on flyash characteristi cs and resulting effect on the ESP and SCR operations;

p) The effects of the new fuel on bottom ash character istics;

q) Specification and description of expected operation al and combustion conditions when the trial burn has reached stable conditions with t he new fuel feed; and

r) A timetable or schedule with approximate dates of t he trial test burn.

5. Based on information regarding the proposed trial f uel burn provided by PSNH – Merrimack Station, the DES may request additional specific in formation on the proposed trial burn operations. In addition, metal emission stack test ing may be required dependent upon DES review of the new fuel metal analysis.

6. If the new fuel is to be consumed on a regular basi s, PSNH – Merrimack Station shall apply for a Temporary Permit or apply for an amendment to this Title V Operating Permit, as determined by DES. If the new fuel results in a ma jor modification, NSR or PSD program requirements may apply, as well as a public notice, and comment period.

7. DES shall respond within 30 days of receipt of a pr oposal with approval, conditional approval, denial, or request for additional informa tion.

8. DES Waste Management Division may have additional r equirements and concerns and shall be contacted by PSNH – Merrimack Station prior to t he initiation of any trial burn, if applicable.

9. A summary report shall be submitted to DES within 6 0 days after the end of the trial fuel burn, which should include a summary of operational results and trends, emission values to include CEM and stack test data, and proposed futur e use of the trial fuel.

### Proposed

PSNH – Merrimack Station Page 12 97 River Road, Bow, NH TV-0055

B. Fly Ash Re-injection (Temporary Permit Nos. FP-T-00 54, TP-B-0462): Fly ash has historically been, and is currently re- injected at PSNH – Merrimack Station as part of normal operation. As necessary, based on operatio nal and/or technical drivers, including available options for storage and beneficial reuse, PSNH – Merrimack Station is authorized to cease fly ash re-injection, as an alternative opera ting scenario.

C. Early Mercury Emission Reduction Methods (RSA 125- O:13) (State Enforceable Only): Prior to July 1, 2013, PSNH is authorized to test a nd implement mercury reduction control technologies or methods, including sorbent injectio n, to achieve early reductions in mercury emissions below the baseline mercury emissions, as an alternative operating scenario. Prior to any testing, PSNH shall submit a trial plan to DES for review and approval. The plan must contain, at a minimum, the following information:

1. Description of the early mercury emission reduction control methodology.

2. Expected values of mercury, SO 2 

### , and TSP emissions, and opacity.

3. Compliance stack test protocol in accordance with E nv-A 800 for TSP emissions testing using Method 1 through 4, Method 5, or a DES approv ed alternative or other pollutant testing, when requested by DES. If this testing is also to demonstrate the effectiveness of the mercury reduction method and amount of reductio n, then compliance testing for mercury shall be conducted using a DES approved method.

4. The effects of the methodology on fly ash character istics, bottom ash characteristics, and ESP operation.

5. Based on information regarding the proposed trial m ercury emission reduction methodology, DES may request additional specific information on the proposed methodology.

6. If the new methodology is to be used on a regular b asis, PSNH must submit the necessary information for a permit application, as applicable

.

7. A summary report shall be submitted to DES within 6 0 days after stack testing is completed. The report shall include a summary of operational r esults and trends, emissions values including CEM, COM, and stack test data, and propos ed future use of the methodology.

VIII. Applicable Requirements

A. State-only Enforceable Operational and Emission Lim itations

The Permittee shall be subject to the state-only op erational and emission limitations identified in Table 4 below.

### Proposed

PSNH – Merrimack Station Page 13 97 River Road, Bow, NH TV-0055

Table 4 – State-Only Enforceable Operational and Em ission Limitations Item No. Regulatory Cite Applicable Emission Unit Applicable Requirement

1. Env-A 1403 All devices subject to RSA 125-I and Env-A 1400 All devices or processes, subject to RSA 125-I and Env-A 1400, shall

comply with Env-A 1400 (Regulated Toxic Air Pollutants).

2. Env-A 1403.01(d) All devices subject to RSA 125-I and Env-A 1400 Documentation for the demonstration of compliance s hall be retained at

the facility and shall be made available to DES for inspection upon request.

3. Env-A 1404.01 All devices subject to RSA 125-I and Env-A 1400 A) The owner of a new or modified device or process re quiring a permit

under this chapter shall submit an application for a temporary permit in accordance with Env-A 607.03. B) Pursuant to RSA 125-I:5,I, the owner shall not oper ate the device or process until a temporary permit is issued. 4. Env-A 1405.01 All devices subject to RSA 125-I and Env-A 1400 The owner of any device or process that emits an RT AP shall determine

compliance with the AAL by using one of the methods provided in EnvA 1405. Upon request, the owner of any device or p rocess that emits an RTAP shall provide documentation of compliance with the AAL to DES.

5. Env-A 1405.02 MK1 & MK2 Ammonia slip stream emis sions from the SCR units shall not exceed 10 ppmdv at 3% oxygen (dry basis), as measured at the stack outlet. 6. Env-A 1002.04 Fugitive Dust Facility wide The Permittee shall prevent, abate, a nd control fugitive dust emissions, including fugitive coal dust using best management practices such as wetting, covering, shielding, or vacuuming. 9 7. RSA 125-O:13,I. Compliance MK1 & MK2 The owner shall install and have operatio nal scrubber technology to control mercury emissions at Merrimack Units 1 and 2 no later than July 1, 2013. 8. RSA 125-O:13,II. Compliance Affected

sources as defined in RSA 125- O:12, namely MK1, MK2, SR4, & SR6 Beginning on July 1, 2013, total mercury emissions from the affected

sources shall be at least 80 percent less on an ann ual basis than the baseline mercury input, as defined in RSA 125-O:12, III.

9. RSA 125-O:13,III. Compliance MK1 & MK2 Prior to July 1, 2013, the owner shall te st and implement, as practicable, mercury reduction control technologies or methods t o achieve early reductions in mercury emissions below the baseline mercury emissions. The owner shall report the results of any testing t o the DES and shall submit a plan for DES approval before commencing im plementation of mercury reduction control technologies or methods.

9 To comply with this provision, PSNH – Merrimack St ation shall use Best Management Practices to manage and minimize fugitive coal dust. See the Best Management Practice polici es established in the PSNH Generation Environmental Management System Plan for Fugitive Plant Emissions.

### Proposed

PSNH – Merrimack Station Page 14 97 River Road, Bow, NH TV-0055

Table 4 – State-Only Enforceable Operational and Em ission Limitations Item No. Regulatory Cite Applicable Emission Unit Applicable Requirement

10. RSA 125-O:13,V. Compliance MK1 & MK2 Mercury reductions (achieved by the scrub ber technology) that are greater than 80 percent, shall be sustained in so far as th e proven operational capability of the system, as installed allows. DES in consultation with the owner shall determine the maximum sustainable rate of mercury emission reductions for each of the boilers and incorporate such emission reductions rate as a permit condition of operationa l permits issued by DES for units MK1 & MK2. 11. RSA 125-O:13,VI. Compliance MK1 & MK2 The purchase of mercury emissions allowan ces or credits from any established emissions allowance or credit program s hall not be allowed for compliance with the mercury reduction requireme nts of RSA 125- O:16,II. 12. RSA 125-O:13,VII. Compliance MK1 & MK2 If the mercury reduction requirement of R SA 125-O:13,II. is not achieved in any year after the July 1, 2013 implementation d ate, and after full operation of the scrubber technology, then the owne r may utilize early emissions reduction credits or over-compliance cred its, or both, to make up any shortfall, and thereby be in compliance. 13. RSA 125-O:13,VIII. Compliance MK1 & MK2 If the mercury reduction requirement of R SA 125-O:13,II. is not achieved in any year after the July 1, 2013 implementation d ate despite the owner’s installation and full operation of scrubber technol ogy, consistent with good operational practice, and the owner’s exhausti on of any available early emissions reduction or over-compliance credit s, then the owner shall be deemed in violation of this section unless it submits a plan to the DES, within 30 days of such non-compliance, and sub sequently obtains approval of that plan for achieving compliance with in one year from the date of such non-compliance. The DES may impose co nditions for approval of such plan.

### Proposed

PSNH – Merrimack Station Page 15 97 River Road, Bow, NH TV-0055

Table 4 – State-Only Enforceable Operational and Em ission Limitations Item No. Regulatory Cite Applicable Emission Unit Applicable Requirement

14. RSA 125-O:16,I. Economic Performance Incentives MK1 & MK2 A) DES shall issue to the owner early emissions reduct ion credits in the form of credits or fractions thereof for each pound of mercury or fraction thereof reduced below the baseline mercury emissions, on an annual basis, in the period prior to July 1, 2013. B) Ratios of early reduction credits to pounds of merc ury reduced shall be as follows: i) 1.5 credits per pound reduced prior to July 1, 2008 ; ii) 1.25 credits per pound for reductions between July 1, 2008 and December 31, 2010; and iii) 1.1 credits per pound for reductions between Januar y 1, 2011 and July 1, 2013. C) Reductions shall be calculated based upon the resul ts of stack tests conducted, measurement by continuous emission monit oring, or other methodology approved by the DES to confirm emission s during the time of operation of mercury reduction technology. D) Early emissions reduction credits may be banked by the owner or utilized after July 1, 2013 to meet the reduction r equirement of RSA 125-O:13,II. as allowed under RSA 125-O:13,VII. E) Early emissions reduction credits are not sellable or transferable to non-affected sources; however, upon the July 1, 201 3 compliance date, the owner may request a one-for-one conversio n of early emissions reduction credits to over-compliance cred its. F) Should a federal rule applicable to mercury emissio ns at one or more of the affected sources be enacted with an implemen tation date prior to July 1, 2013, then early reduction credits may o nly be earned for emissions reductions that exceed the level required by the federal rule of the affected sources in aggregate or the baselin e mercury emissions level, whichever is lower, at the same ratios liste d in B), above. G) Early emissions reduction credits shall not be used for compliance with the requirement of RSA 125-O:13,II. prior to t he installation of scrubber technology, and shall not be used as a mea ns to delay the installation of the scrubber technology.

### Proposed

PSNH – Merrimack Station Page 16 97 River Road, Bow, NH TV-0055

Table 4 – State-Only Enforceable Operational and Em ission Limitations Item No. Regulatory Cite Applicable Emission Unit Applicable Requirement

15. RSA 125-O:16,II. Economic Performance Incentives MK1 & MK2 

### A) DES shall issue to the owner over-compliance credit s in the form of credits or fractions thereof for each pound of merc ury or fraction thereof reduced in excess of the emissions reductio n requirement of RSA 125-O:13,II., on an annual basis, following the compliance date of July 1, 2013. 

### B) The ratios of over-compliance credits to excess pou nds of mercury reduced shall be as follows: i) 0.5 credits per pound reduced for reductions betwee n 80 and 85 percent; ii) 1 credit per pound reduced for reductions between 8 5 and 90 percent reduction; and iii) 1.5 credits per pound reduced for reductions of 90 percent or greater. 

### C) Over-compliance credits may be banked for future us e. The requirements of RSA 125-O:13,V. shall not alter the emissions levels at which over-compliance credits are earned. 

### D) Should a federal rule applicable to mercury emissio ns at one or more of the affected sources be enacted, then over-compl iance credits may only be earned for emissions reductions that exceed the level required by the federal rule of the affected sources in aggr egate or the requirement of RSA 125-O:13,II., whichever is lower , at the same ratios listed in B), above. 

### E) At the request of the owner of an affected source, over-compliance credits may be surrendered by the owner to the DES and SO 2 allowances shall be transferred to the owner at a r ate of 55 tons SO 2 allowances for every one over-compliance credit. T ransfer shall be limited to a maximum of 20,000 total tons SO 2 allowances transferred in a given year, defined as the sum of all SO 2 allowances received by the affected sources under RSA 125-O:4,IV(a)(2) and IV(a)(3), and under this subparagraph. SO 2 allowances shall be credited to the affected sources’ accounts in the following year in accordance with RSA 125-O:4,IV(a)(4).

### Proposed

PSNH – Merrimack Station Page 17 97 River Road, Bow, NH TV-0055

B. Federally Enforceable Operational and Emission Limi tations

1. The Permittee shall be subject to the federally enf orceable operational and emission limitations identified in Table 6 below:

Table 5 – Federally Enforceable Operational and Emi ssion Limitations Item No. Regulatory Cite Applicable Emission Unit Applicable Requirement

1. Temporary Permit FP-T-0054 & Temporary Permit TP-B-0462 MK1 & MK2 No. 2 fuel oil is used to light off fires in MK1 and MK2 before establishing the main coal fires.

2. Env-A 1606.01(a) (formerly Env-A 402.04(a) and (b)) Coal Sulfur Limits MK1 & MK2 For coal-burning devices placed in operat ion before April 15, 1970: A) The sulfur content of coal fired in MK1 and MK2 sha ll not exceed 2.0 lb/mmBtu averaged over any consecutive 3-month period; and B) The sulfur content of coal fired in MK1 and MK2 sha ll not exceed 2.8 lb/mmBtu.

3. Env-A 1604.01(a) (formerly Env-A 402.02(a)) & 

### 40 CFR 60 Subpart Dc § 

### 60.42c(d) Sulfur Content Limits for Liquid Fuels MKEB &

Facility Wide The maximum sulfur content of No. 2 fuel oil and JP -4 aviation fuel shall

not exceed 0.40% sulfur by weight. 10

4. Temporary Permit FP-T-0054 MK1-Maximum Fuel Consumption Rates MK1 A) Coal: The maximum bituminous coal consumption rate for MK1 shall be limited to 48.5 tons per hour and shall no t exceed 425,289 tons during any consecutive 12 month period. 11 B) No. 2 Fuel Oil: The maximum No. 2 fuel oil consump tion rate to MK1 shall be limited to 1,656 gallons per hour and shall not to exceed 14.5 million gallons during any consecutive 12 month period. 12

10 DES has streamlined the sulfur content limits for liquid fuel. The MKEB is required by 40 CFR 60 Sub part Dc § 60.42c(d) to use fuel oil with a sulfur content less than 0.5% sulfu r by weight. This requirement to use fuel oil with a sulfur content of less than 0.40% by weight is a more stringent requirement. 11 The heating value of bituminous coal is assumed to be 12,750 Btu/lb. The fuel consumption rates vary based on the actual heat content of the fuel burned. 12 The heating value of No. 2 fuel oil is assumed to be 140,000 Btu/gal. The fuel consumption rates may vary based on the actual heat content of the fuel burned.

### Proposed

PSNH – Merrimack Station Page 18 97 River Road, Bow, NH TV-0055

Table 5 – Federally Enforceable Operational and Emi ssion Limitations Item No. Regulatory Cite Applicable Emission Unit Applicable Requirement

5. Temporary Permit TP-B-0462 MK2-Maximum Fuel Consumption Rates MK2 A) Coal: The maximum bituminous coal consumption rate for MK2 shall be limited to 136.2 tons per hour and shall n ot exceed 1,193,078 tons during any consecutive 12 month period. 13 B) No. 2 Fuel Oil: The maximum No. 2 fuel oil consump tion rate to MK2 shall be limited to 1,656 gallons per hour and shall not to exceed 14.5 million gallons during any consecutive 12 month period. 14

6. Temporary Permit FP-T-0054 MK1-ESP Operation MK1 A) All available sections of each ESP on Unit #1 (MK1- PC1 and MK1- PC2) shall be in service at greater than 35 MW load . No more than a total of 7 sections in the two ESP units shall be o ut of service at greater than 35 MW load. If more than 7 sections a re out of service at greater than 35 MW load, the owner or operator m ust notify (e.g., call or e-mail) DES within 24 hours of discovery un less the DES offices are closed then the next DES business day. At DES’ request, PSNH shall be required to conduct particulate matte r testing if more than 7 sections are out of service. During startup and when Unit #1 is below 35 MW of generation, 16 of 22 fields in MK1-P C1 must be in service and 4 of 10 fields in MK1-PC2 must be in se rvice. B) PSNH –Merrimack Station shall continuously operate and maintain the ESP systems to minimize particulate matter emis sions to meet permit conditions and to maintain compliance with E nv-A 2000. The operation and maintenance shall include normal roun ds by a qualified operator for checking and cleaning of the hoppers a nd transport lines. PSNH – Merrimack Station shall inspect and perform necessary maintenance on the ESP during each planned outage. All critical maintenance activities performed and corrective act ions taken on the ESP systems shall be recorded and shall be made ava ilable for review at the request of DES.

13 The heating value of bituminous coal is assumed to be 12,750 Btu/lb. The fuel consumption rates may vary based on the actual heat content of the fuel burned. 14 The heating value of No. 2 fuel oil is assumed to be 140,000 Btu/gal. The fuel consumption rates may vary based on the actual heat content of the fuel burned.

### Proposed

PSNH – Merrimack Station Page 19 97 River Road, Bow, NH TV-0055

Table 5 – Federally Enforceable Operational and Emi ssion Limitations Item No. Regulatory Cite Applicable Emission Unit Applicable Requirement

7. Temporary Permit TP-B-0462 MK2-ESP Operation MK2 A) All available sections of each ESP on Unit #2 (MK2- PC4 and MK2- PC5) shall be in service at greater than 120 MW of generation. If more than 8 sections are out of service at greater than 120 MW load, the owner or operator must notify (e.g., call or e- mail) DES within 24 hours of discovery unless the DES offices are close d then the next DES business day. At DES’ request, PSNH shall be r equired to conduct particulate matter testing if more than 8 s ections are out of service. During startup and when Unit #2 is below 120 MW of generation, 4 of 12 fields in MK2-PC4 must be in se rvice and 12 of 24 fields in MK2-PC5 must be in service. B) PSNH –Merrimack Station shall continuously operate and maintain the ESP systems to minimize particulate matter emis sions to meet permit conditions and to maintain compliance with E nv-A 2000. The operation and maintenance shall include normal roun ds by a qualified operator for checking and cleaning of the hoppers a nd transport lines. PSNH – Merrimack Station shall inspect and perform necessary maintenance on the ESP during each planned outage. All maintenance activities performed and corrective act ions taken on the ESP systems shall be recorded and shall be made ava ilable for review at the request of DES. 8. Temporary Permits FP-T-0054 & TP-B-0462 MK1 & MK2 Opacity Limits MK1 & MK2 In accordance with Env-A 2002.01, during normal operation, the average opacity shall not exceed 40% for any continuous 6-m inute period, except under the following conditions. In accordance with Env-A 2002.04(b), the average opacity may exceed 40% during periods o f startup, shutdown, malfunction, soot blowing, grate cleaning, and clea ning of fires, for a non-overlapping set or sets of time up to 60 minute s in any 8-hour period. The hourly average opacity may not exceed 30% opaci ty except during the eight hours preceding the generator being phase d on-line (boiler startup) or the eight hours after the generator bei ng tripped off-line (boiler shutdown).

### Proposed

PSNH – Merrimack Station Page 20 97 River Road, Bow, NH TV-0055

Table 5 – Federally Enforceable Operational and Emi ssion Limitations Item No. Regulatory Cite Applicable Emission Unit Applicable Requirement

9. Env-A 404.01 State Acid Rain Deposition Control Program & Temporary Permits FP-T-0054 and TB-B-0462 MK1 & MK2 The total sulfur dioxide emissions from P SNH - Merrimack Station (MK1 & MK2), Newington Station (Unit 1), and Schiller St ation (Units 4, 5, & 6) shall not exceed 55,150 tons per calendar year.

10. Env-A 2002.06 (formerly Env-A 1202.05(b)) and Temporary Permit FP-T-0054 MK1 TSP Emission Limit MK1 A) The maximum allowable total suspended partic ulate matter (TSP) emission rate from MK1, including emissions rates e xperienced during periods of flyash re-injection, shall be limited to 0.27 lb/mmBtu. The maximum TSP emission rate is obtained from use of t he equation below: E = 0.880 * I -0.166

Where: E = maximum allowable particulate matter emission r ate in lb/mmBtu; and I = maximum gross heat input rate in mmBtu/hr. B) Maximum TSP emissions from MK1 shall not exceed 1,463.1 tons during any consecutive 12 month period. 15

11. Env-A 2003.06 (formerly Env-A 1202.05(b)) and Temporary Permit TP-B-0462 MK2 TSP Emission Limit MK2 A) The maximum allowable total suspended partic ulate matter (TSP) emission rate from MK2, including emissions rates e xperienced during periods of flyash re-injection, shall be limited to 0.227 lb/mmBtu. The maximum TSP emission rate is obtained from use of t he equation below: E = 0.880 * I -0.166

Where: E = maximum allowable particulate matter emission r ate in lb/mmBtu; and I = maximum gross heat input rate in mmBtu/hr. B) Maximum TSP emissions from MK2 shall not exceed 3,458.6 tons during any consecutive 12 month period. 16 12. 40 CFR §76.6(a)(2), Env-A 1211.03(d)(1),RACT Order ARD97-001 Condition D.1.a.ii, and Env-A 1211.18 MK2 The maximum NOx emissions from MK2 shall not ex ceed the following: A) 0.86 lb NOx/mmBtu heat input on an annual averag e basis pursuant to 40 CFR 76.6(a)(2); B) 15.4 tons per 24-hour calendar day pursuant to 1 211.03(d)(1); and C) 29.1 tons per calendar day pursuant to RACT Orde r ARD-97-001 Condition D.1.a.ii issued in accordance with Env-A 1211.18 when combined with MK1 (See Condition VIII, E.1.).13. RACT Order ARD97-001 Condition D.1.c, Condition MK1 The maximum NOx emissions from MK1 shall not ex ceed the following: A) 1.22 lb NOx/mmBtu heat input on a 7-calendar day average basis 17 pursuant to RACT Order ARD-97-001 Condition D.1.c i ssued in

15 The maximum TSP emission limitation for MK1 of 1,4 63.1 tons during any consecutive 12-month period is calculated based on the lb/mmBtu limitation pursuant to Env-A 2002.06 (with out rounding) multiplied by the maximum design cap acity of 1238 mmBtu/hr multiplied by 8760 hours/yr and divided by 2000 lb/ ton

. 16 The maximum TSP emission limitation for MK2 of 345 8.6 tons during any consecutive 12-month period is calculated based on the lb/mmBtu limitation pursuant to Env-A 2002.06 (with out rounding) multiplied by the maximum design cap acity of 3473 mmBtu/hr multiplied by 8760 hours/yr and divided by 2000 lb/ ton.

### Proposed

PSNH – Merrimack Station Page 21 97 River Road, Bow, NH TV-0055

Table 5 – Federally Enforceable Operational and Emi ssion Limitations Item No. Regulatory Cite Applicable Emission Unit Applicable Requirement

D.1.b, and Condition D.1.a.ii issued in accordance with Env-A 1211.18 accordance with Env-A 1211.18; B) 18.1 tons per 24-hour calendar day when MK2 is n ot in full operation 18 pursuant to RACT Order ARD-97-001 Condition D.1.b issued in accordance with Env-A 1211.18 (See Condit ion VIII, E.2.); and C) 29.1 tons per calendar day when combined with MK 2 pursuant to RACT Order ARD-97-001 Condition D.1.a.ii issued in accordance with Env-A 1211.18 (See Condition VIII, E.1.1). 14. State Permits to Operate PO-B-0034 & PO-B-0035 MKCT1 & MKCT2 Maximum fuel consumption rate of No.1 fuel oil or J P-4 shall not exceed

2,279 gal/hr and 19.96 million gallons during any c onsecutive 12-month period for each CT. 19

15. Env-A 2002.01 (formerly Env-A 1202.01) MKCT1 & MKCT2 Average opacity from the CTs shall not be in excess of 40% for any

continuous 6 minute period.

16. State Permit to Operate PO-B-1788 MKEG Maximum fuel consumption rate of No. 2 fuel oi l shall not exceed 28.7 gal/hr and 14,350 gallons during any consecutive 12 month period. 20

17. Env-A 1211.02(j) (formerly Env-A 1211.01(j)) MKEG Each emergency generator shall be limited to a maximum of 500 hours of operation during any consecutive 12-month period. T he combined theoretical potential NOx emissions of all emergenc y generators at PSNH – Merrimack Station are limited to less than 25 ton s for any consecutive 12-month period. If either of these conditions is exceeded, all such emergency generators become immediately subject to Env-A 1211.11. 18. Env-A 2002.02 MKEG Average opacity from the MKE G shall not be in excess of 20% for any continuous 6 minute period.

17 This rolling 7-day average shall be calculated by adding up 7 consecutive 24-hour calendar day averag es and dividing the sum by 7. Each 24-hour calendar day average shall be calcula ted using valid CEM data only. Hours when there ar e no fires in the boiler and the CEM is not activated shall not be included in the 2 4-hour calendar day average. The rolling 7-day ave rage shall be calculated using days when there is valid CEM data only. Days when there are no fires in the boiler and the CEM is not activated shall not be included in the 7-day average. 18 Full operation is defined as a unit operating with the CEM activated collecting valid data for all 24 hours in a calendar day. The CEM is activated and starts collecting valid data w hen fires are put in the boiler. 19 The heating value of the fuel is assumed to be 140 ,000 Btu/gal. The fuel consumption rates may vary based on the actual heat content of the fuel burned. 20 The heating value of the fuel is assumed to be 137 ,000 Btu/gal. The fuel consumption rates may vary based on the actual heat content of the fuel burned.

### Proposed

PSNH – Merrimack Station Page 22 97 River Road, Bow, NH TV-0055

Table 5 – Federally Enforceable Operational and Emi ssion Limitations Item No. Regulatory Cite Applicable Emission Unit Applicable Requirement

19. Env-A 2002.02, Env-A 2002.04, & 40 CFR 60 Subpart Dc Section 60.43c(c) and (d) MKEB A) Pursuant to Env-A 2002.02, the owner or ope rator shall not cause or allow average opacity in excess of 20% for any cont inuous 6-minute period except as specified in Condition C) below. B) Pursuant to 40 CFR 60.43c (c) and (d), no owner or operator shall cause to be discharged into the atmosphere any gase s that exhibit greater than 20 percent opacity (6-minute average), except for one 6-minute period per hour of not more than 27 percent opacity . This opacity standard applies at all times, except during period s of startup, shutdown or malfunction. C) Pursuant to Env-A 2002.04 (a), for steam genera ting units subject to 40 CFR 60, no more than one of the following two ex emptions shall be taken: 1. During periods of startup, shutdown and malfunct ion, average opacity shall be allowed to be in excess of 20% for one period of 6 continuous minutes in any 60-minute period; or 2. During periods of normal operation, soot blowing , grate cleaning, and cleaning of fires, average opacity shall be all owed to be in excess of 20% but not more than 27% for one period of 6 continuous minutes in any 60-minute period. D) Pursuant to Env-A 2002.04 (d), (e), and (f), exc eedances of the opacity standard in Env-A 2002 shall not be conside red violations if the Owner or Operator demonstrates to DES that such exc eedances: 1. Were the result of the adherence to good boiler operating practices which, in the long term, result in the most efficie nt or safe operation of the boiler; 2. Occurred during periods of cold startup of a boi ler over a continuous period of time resulting in efficient he at-up and stabilization of its operation and the expeditious achievement of normal operation of the unit; 3.Occurred during periods of continuous soot blowin g of the entire boiler tube section over regular time intervals as determined by the operator and in conformance with good boiler operat ing practice; or 4. Were the result of the occurrence of an unplanne d incident in which the opacity exceedance was beyond the control of the operator and in response to such incident, the operator took appropriate steps in conformance with good boiler operating practice to eliminate the excess opacity as quickly as possible. 20. Env-A 2002.08 (formerly Env-A 1202.07) MKEG The TSP emission rate shall not exceed 0.30 lb/mmBt u based on a 24- hour calendar day. 21

21 The Owner or Operator shall demonstrate compliance with this requirement by using an approved EPA AP- 42 emission factor and EPA/DES approved heat input content (Btu/gal). Thi s calculation shall be maintained on file at the fa cility.

### Proposed

PSNH – Merrimack Station Page 23 97 River Road, Bow, NH TV-0055

Table 5 – Federally Enforceable Operational and Emi ssion Limitations Item No. Regulatory Cite Applicable Emission Unit Applicable Requirement

21. State Permits to Operate PO-BP-2416 & PO-BP-2417 MKPCC & MKSCC Based on the maximum coal usage allowed in MK1 and MK2, the

maximum annual coal throughput shall be limited to 1,618,367 tons during any consecutive 12-month period.

22. State Permits to Operate PO-BP-2416 & PO-BP-2417 MKPCC & MKSCC The primary crusher is located underground beneath the rail car track

hopper and is fully enclosed to reduce fugitive emi ssions. The secondary coal crushers are fully enclosed in an aboveground building to reduce fugitive emissions. The coal crusher systems shall be inspected and maintained regularly. Any failures of these enclos ures to prevent fugitive emissions shall be repaired, as necessary. 23. Env-A 2103.02 (formerly Env-A 1203.05) MKPCC & MKSCC Visible fugitive emissions or visible stack emissio ns shall not exceed an

average of 20% opacity for any continuous 6 minute period, except one period of 6 continuous minutes in any 60-minute per iod during startup, shutdown, or malfunction. 24. 40 CFR 72, 73, 75, 76, and 77. MK1 & MK2 PSNH – Merrimack Station shall comply wit h the applicable Federal Acid Rain Program provisions. 25. 40 CFR 68 and 1990 CAA Section 112(r)(1) Accidental Release Program Requirements Facility wide The facility is subject to the Purpos e and General Duty clause of the 1990 Clean Air Act, Section 112(r)(1). General Duty inc ludes the following responsibilities: (A) Identify potential hazards that may result from suc h releases using appropriate hazard assessment techniques; (B) Design and maintain a safe facility; (C) Take steps necessary to prevent releases; and (D) Minimize the consequences of accidental releases th at do occur. The facility stores quantities of ammonia above the threshold level and has submitted a risk management plan to the Part 68 implementing agency as required by the 1990 Clean Air Act, Secti on 112(r)(7)(ii). Administrative controls will be established by PSNH – Merrimack Station in order to monitor that inventories of reg ulated substances (except for ammonia) are maintained below the speci fied threshold quantities.

If, in the future, PSNH – Merrimack Station wishes to store quantities of other regulated substances above the threshold leve ls, a risk management plan shall be submitted to the Part 68 implementing agency in a timely manner, prior to exceeding threshold quantity level s.

### Proposed

PSNH – Merrimack Station Page 24 97 River Road, Bow, NH TV-0055

Table 5 – Federally Enforceable Operational and Emi ssion Limitations Item No. Regulatory Cite Applicable Emission Unit Applicable Requirement

26. Temporary Permit TP-B-0490 MKEB The maximum gross heat input rate of the Emerg ency Boiler is limited to less than or equal to 96.0 mmBtu/hr. 27. RSA 125-C:6, RSA 125-C:11, Env-A 606.04, & Temporary Permit TP-B-0490 MKEB A) Pursuant to Env-A 606.04, the owner or oper ator shall limit the maximum fuel consumption rate of MKEB to the follow ing: 1) For No. 2 fuel oil, 520 gal/hr and 11,760 gal/da y 22 ; or 2) For on-road low sulfur diesel oil, 701 gal/hr. B) To avoid NSR/PSD, the owner or operator shall li mit the maximum fuel consumption rate of MKEB to the following: 1) For No. 2 fuel oil, 1,405,000 gallons per consec utive 12-month period; or 2) For on-road low sulfur diesel oil, 2,490,000 gal lons per consecutive 12-month period; or 3) For any combination of the above fuels, fuel con sumption rates such that the emissions do not exceed the significa nce levels contained in Table 5, Item 33. 28. RSA 125-C:6, RSA 125-C:11, Env-A 606.04, & Temporary Permit TP-B-0490 MKEB A) The Emergency Boiler is allowed to operate for trai ning purposes or performance testing with MK1 or MK2 in operation. B) The Emergency Boiler is allowed to operate with eit her or both Combustion Turbines #1 & #2 in operation and the Em ergency Generator in operation. 29. Temporary Permit TP-B-0490 MKEB The Emergency Boiler can be replaced each year with a similar unit at or below the fuel consumption limits in Table 1 and wh ich satisfies the stack height requirements in Table 2. 30. 40 CFR 60 Subpart Dc § 60.42c(i) MKEB The fuel oil sulfur limits apply at all times, including periods of startup, shutdown, and malfunction.

31. Env-A 606.04 & 40 CFR 60 Subpart Dc § 60.42c(d) MKEB The sulfur content of on-road low sulfur diese l oil shall not exceed 0.05 percent sulfur by weight. 23

22 The heating value of No. 2 fuel oil is assumed to be 140,000 Btu/gal. The heating value of on-road l ow sulfur diesel fuel is assumed to be 137,000 Btu/gal. The fuel consumption rates may vary based on the actual heat content of the fu el burned. 23 DES has streamlined the sulfur content requirement s for on-road low sulfur diesel oil. MKEB is requi red by 40 CFR 60.42c(d) to use fuel oil with a sulfur content less than 0.5% s ulfur by weight. To comply with the SO 2 NAAQS as demonstrated through air dispersion modeling conducted pursuant to Env-A 606 .04, the on-road low sulfur diesel oil must have a sulfur content that does not exceed 0.05% sulfur by weight. The 0.05% sulfur by weight limit required by Env-A 606.04 (modeling f or SO2 NAAQS) is more stringent than the 0.5% sulfur by weight limit spec ified in 40 CFR 60.42c(d). Note that no additional limit on sulfur content beyond that required by Env-A 1604.01(a) (0.4% sulfur by w eight) is necessary for compliance with the SO 2 NAAQS for No. 2 fuel oil.

### Proposed

PSNH – Merrimack Station Page 25 97 River Road, Bow, NH TV-0055

Table 5 – Federally Enforceable Operational and Emi ssion Limitations Item No. Regulatory Cite Applicable Emission Unit Applicable Requirement

32. Env-A 606.04 and Temporary Permit TP-B-0490 MKEB Pursuant to Env-A 606.04, the owner or operator sha ll limit the hourly 24 emissions from MKEB as provided in the Table below:

Pollutant Short-term limit

(lb/hr) 25

NOx 13.72 SO2 38.96 CO 3.43 PM10 2.26 VOC 0.14 33. Temporary Permit TP-B-0490 (PSD/NSR Avoidance) MKEB To avoid NSR/PSD, the owner or operator shall limit the consecutive 12- month emissions from MKEB as provided in the Table below:

Pollutant Tons per

consecutive 12- month period 26

NOx 25.0 SO2 40.0 CO 100.0 PM10 15.0 VOC 25.0 34. 40 CFR 61 Subpart M, Env-A 504.01(e) and Env-A 1800 Asbestos Management and Control Facility wide PSNH – Merrimack Station shall comply with the asbestos requirements of Env-A 1800 and 40 CFR 61.145 during demolition a nd/or renovation.

35. 40 CFR 63 Subpart YYYY MACT for Stationary Combustion Turbines MKCT1 & MKCT2 The MACT is applicable to the combustion turbines, but no emission

limitations, operating requirements or monitoring, recordkeeping, or reporting requirements are specified for existing u nits.

24 The TSP and PM10 emission limits have been streaml ined. Env-A 2002.08 limits TSP emissions to 0.30 l b/mmBtu. The PM10 hourly and annual emission limits of 2.26 lb/hr and 15 tpy are more stringent. 25 Short term emissions limits of criteria pollutants in pounds per hour (lb/hr) are based on United Sta tes Environmental Protection Agency (EPA) AP-42 5 th Edition January 1995, Section 1.3 Fuel Combustion (Updated 9/98) Tables 1.3-1, 1.3-2, and 1.3-3. 26 Consecutive 12-month period emissions limits are t he significance levels to keep the PSNH - Merrimack Station below major modification levels requiring Non-Attainment Review or Prevention of Significant Deterioration Review.

### Proposed

PSNH – Merrimack Station Page 26 97 River Road, Bow, NH TV-0055

Table 5 – Federally Enforceable Operational and Emi ssion Limitations Item No. Regulatory Cite Applicable Emission Unit Applicable Requirement

36. Env-A 2002.08 (formerly Env-A 1202.07) MKCT1 & MKCT2 The maximum allowable total suspended particulate m atter (TSP)

emission rate from each device shall be limited to 0.34 lb/mmBtu. The maximum TSP emission rate is obtained from use of t he equation below: E = 0.880 * I -0.166

Where: E = maximum allowable particulate matter emission r ate in lb/mmBtu; and I = maximum gross heat input rate in mmBtu/hr. 37. Env-A 2002.08 (formerly Env-A 1202.07) MKEB The TSP emission rate from MKEB shall not exceed 0. 30 lb/mmBtu.

38. Env-A 1211.12 NOx RACT MKEB The maximum NOx emission rate from MKEB shall not exceed 0.20 lb/mmBtu based on a 24-hour calendar day average.



### C. Annual SO 2 

### Allowance Programs (40 CFR 72, 40 CFR 73, Env-A 61 1.07, and Env-A 2900)

1. SO 2 

### Allowance Allocation

a) In accordance with 40 CFR Part 73, SO 2 

### allowances pursuant to the Federal Acid Rain Program for this facility are allocated as indicate d in the following table:

Table 6 – Federal Annual SO 2 

### Allowance Allocations (tons) (40 CFR 73.10 Table 2)

2000 - 2009 2010 and Beyond MK1 4288 4296

MK2 9242 9257

b) Pursuant to Env-A 2906.02 [State-only enforceable], Allocation of SO2 Allowances , for 2007 and subsequent years, PSNH’s Schiller, Merrima ck and Newington stations shall transfer the SO 2 

### Allowances allocated pursuant to the Federal Acid Rain Program to DES, and DES shall transfer SO 2 

### allowances (7,289 tons) calculated pursuant to Env -A 2900 plus any potential bonus allowances calculated pursuant to Env-A 2906.07, Bonus Allocation of SO2 Allowances , back to PSNH’s Schiller, Merrimack, and Newington stations. The amount of SO 2 

### Allowances allocated to PSNH Merrimack shall be determined according to the methodology in Env-A 29 06.05, Allowance Allocation Methodology

.

### Proposed

PSNH – Merrimack Station Page 27 97 River Road, Bow, NH TV-0055

2. Compliance

a) Pursuant to 40 CFR 73.35, the Permittee shall compl y with the SO 2 

### emission limitation requirements.

b) At the end of each calendar year, the Permittee sha ll hold sufficient SO 2 

### allowances equivalent to the SO 2 

### emissions during that calendar year.

3. General Provisions

Pursuant to Env-A 611.07, SO 2 

### allowances lawfully held or acquired by the Permitt ee shall be governed by the following:

a) Emissions from the affected units shall not exceed any SO 2 

### allowances held by the affected unit;

b) The number of SO 2 

### allowances held by the Permittee shall not be limit ed;

c) The Permittee shall not use SO 2 

### allowances to avoid compliance with any other applicable requirement of either state or federal r ules or of the provisions of the Clean Air Act; and

d) Any SO 2 

### allowances held by the Permittee shall be accounted for according to the procedures established in the applicable provisions of 40 CFR 72, 40 CFR 73, and 40 CFR 76.

4. Excess Emissions

Pursuant to 40 CFR 72.9(e), if the Permittee has ex cess emissions, the Permittee shall submit a proposed offset plan as required under 40 CFR 77 and pay the penalty and any interest without demand pursuant to 40 CFR 77.

5. Allowance Transfer

The Permittee shall transfer allowances according t o the procedures in 40 CFR 73.50.

D. Ozone Season NOx Budget Trading Program (Env-A 3200 )

1. The NOx allowances shall be allocated to PSNH - Mer rimack Station for each subsequent control periods according to the methodology in Env -A 3207.04, Allowance Allocation Methodology

.

2. Ozone Season NOx Emissions Cap

a) Pursuant to Env-A 3200, PSNH - Merrimack Station sh all not emit NOx emissions during any control period in excess of the amount o f NOx allowances held in Merrimack Station’s NATS compliance account for that control period as of the allowance transfer deadline of November 30.

### Proposed

PSNH – Merrimack Station Page 28 97 River Road, Bow, NH TV-0055

b) Pursuant to Env-A 3200, PSNH - Merrimack Station ma y obtain additional NOx allowances to comply with the NOx Budget Program.

3. Allowance Transfer and Use

a) Pursuant to Env-A 3209.01, Marketable Emissions Authorization , an allowance shall be a marketable emissions authorization that may be boug ht, sold, or traded at any time during any year, not just the current year.

b) Pursuant to Env-A 3209.02, Limited Authorization, an allowance shall only be used for compliance with the NOx Budget Program in a designa ted compliance year by being in a compliance account as of the allowance transfer dea dline of November 30, or by being transferred into the compliance account by an allow ance transfer submitted by the allowance transfer deadline.

c) PSNH - Merrimack Station shall comply with the NOx allowance transfer and use provisions pursuant to Env-A 3209, Allowance Transfer and Use

. d) Pursuant to Env-A 3209.09, Price Disclosure, subject to a claim of confidentiality in accordance with Env-A 103, PSNH - Merrimack Station shall make available to any person, all information regarding transaction cost and allowance price.

4. Allowance Banking

a) Pursuant to Env-A 3210.01, Retention of Unused Allowances, the banking of allowances shall be permitted to allow the retention of unused allowances from one year to a future year in either a compliance account, an overdraft a ccount, or a general account.

b) Pursuant to Env-A 3210.02, Account Designation, unused allowances as of the end of the allowance transfer deadline shall be retained in th e compliance, overdraft, or general account and designated as banked allowances after t he NATS administrator has made all deductions for a given control period from the comp liance account or overdraft account pursuant to Env-A 3215, End-of-Season Reconciliation.

c) Pursuant to Env-A 3210.03, Requirements for Use , banked allowances may be used in the current year on a 1-for-1 basis.

5. End-of-Season Reconciliation

a) Pursuant to Env-A 3206.01, Limited Authorization , PSNH - Merrimack Station shall, no later than November 30th of each calendar year, hol d a quantity of NOx allowances in PSNH - Merrimack Station’s current year NATS accoun t that is equal to or greater than the total NOx emitted from PSNH - Merrimack Station during the pe riod May 1st through September 30th of the subject year.

b) PSNH - Merrimack Station shall determine compliance and reconcile allowances by November 30th of each year for the control period o f that year pursuant to Env-A 3215.

### Proposed

PSNH – Merrimack Station Page 29 97 River Road, Bow, NH TV-0055

6. Authorized Account Representative (Env-A 3211.04)

a) Only the AAR or alternate AAR shall request transfe rs of allowances in a NATS account.

b) The AAR or alternate AAR shall be responsible for a ll transactions and reports submitted to the NATS.

c) The alternative AAR shall have the same authority a s the primary representative, however, all correspondence from the NATS administr ator shall be directed to the primary AAR.

d) Pursuant to Env-A 3211.05 (f), PSNH - Merrimack Sta tion shall replace an AAR by submitting a revised Account Certificate of Represe ntation to the NATS administrator along with the information contained in Env-A 3211. 05(b) and (c) and the name of the AAR who is being replaced.

7. Conversion of Allowances to DERs

Pursuant to Env-A 3207.05, PSNH - Merrimack Station may convert unused allowances to DERs in accordance with Env-A 3206.02(e) for use as NSR offsets during the ozone season and the procedures for DER generation pursuant to E nv-A 3103. Upon conversion, PSNH - Merrimack Station shall surrender those converted a llowances as if they had been used for actual emissions. Under no circumstances, except a s noted above, shall unused allowances be converted to, or used as, DERs or ERCs.

8. Prohibition on Property Rights (Env-A 3207.07)

a) Neither an allowance nor any future allocations, wh ich are subject to modification by DES, shall constitute a security or other form of p roperty.

b) An allowance shall not be used prior to the control period for which the allowance is allocated.

9. Excess Emissions and Enforcement Provisions (Env-A 3217)

a) If emissions exceed the allowances held by PSNH - M errimack Station by the allowance transfer deadline (November 30th), the NATS adminis trator shall automatically deduct three tons of allowances from the next control peri od for every ton of excess emissions from PSNH - Merrimack Station’s compliance account or overdraft account.

b) In accordance with RSA 125-J:4-a., for purposes of enforcement of the NOx Budget Program, in determining the number of days of viola tion, any excess emissions for the control period shall presume that each day in the c ontrol period of 153 days, constitutes a day in violation unless PSNH - Merrimack Station ca n demonstrate, through use of verifiable emissions data that a lesser number of d ays should be considered. In addition, each ton of excess emissions shall constitute a sep arate violation.

### Proposed

PSNH – Merrimack Station Page 30 97 River Road, Bow, NH TV-0055

E. Non-Ozone Season NOx Allowances and NOx RACT Orders (NOx RACT Orders ARD-97- 001 and ARD-98-001)

1. Pursuant to NOx RACT Order No. ARD-97-001, Conditio n D.1.a.ii., no later than May 31, 1999, PSNH - Merrimack Station shall comply with a NOx emissions cap no greater than 29.1 tons per calendar day for the combined NOx emi ssions from MK1 and MK2. This requirement shall not supersede future requirements for MK2 as listed in Env-A 1211.03(f) (formerly) (now it is Env-A 1211.03(d)) and any ame ndments, thereto.

2. Pursuant to NOx RACT Order No. ARD-97-001, Conditio n D.1.b., when MK2 is not in full operation, PSNH - Merrimack Station shall comply wi th a NOx emissions cap of 18.1 tons per calendar day for the NOx emissions from MK1 by May 31, 1995. This cap applies indefinitely into the future, until such time that it is modified or rescinded by DES and approved by EPA as a State Implementation Plan revi sion. This requirement shall not supersede future requirements for MK1. “Full opera tion” shall be defined as a unit operating with the CEM activated collecting valid d ata for all 24 hours on a calendar day. The CEM is activated and starts collecting valid da ta when fires are put in the boiler.

3. Pursuant to NOx RACT Order No. ARD-97-001, Conditio n D.1.c., PSNH - Merrimack Station shall comply with a NOx emission rate limit of 1.22 lb/mmBtu based on a rolling 7- day average for MK1 by May 31, 1995. This emission rate limit applies indefinitely into the future, until such time that it is modified or resc inded by DES and approved by EPA as a State Implementation Plan revision. This requireme nt shall not supersede future requirements for MK1. This rolling 7-day average s hall be calculated by adding up 7 consecutive 24-hour calendar day averages and divid ing the sum by 7. Each 24-hour calendar day average shall be calculated using vali d CEM data only. Hours when there are no fires in the boiler and the CEM is not activated shall not be included in the 24-hour calendar day average. The rolling 7-day average sh all be calculated using days when there is valid CEM data only. Days when there are no fires in the boiler and the CEM is not activated shall not be included in the 7-day averag e.

4. Pursuant to NOx RACT Order No. ARD-97-001, Conditio n D.1.d., PSNH – Merrimack Station shall demonstrate compliance with all of th e above alternative emission limits (AEL) by monitoring the hourly emissions from MK1 and MK2 in accordance with Env-A 1211.22 (formerly Env-A 1211.21). “Alternative emission li mits” or AEL shall be defined as limits other than those listed in Env-A 1211, and the abov e limits in Items 1., 2., and 3. are not alternatives to each other.

5. Pursuant to NOx RACT Order ARD-97-001, Condition D. 1.e., within 30 days following the end of each calendar quarter, PSNH – Merrimack Stat ion shall report any excess emissions (emissions greater than the above AEL) which occurr ed.

6. Pursuant to NOx RACT Order ARD-97-001, Condition D. 1.f., PSNH – Merrimack Station shall comply with the remainder of the original com pliance plan as listed in C.5.b. – C.5.e. of the NOx RACT Order No. ARD-97-001 (Items 7 throu gh 10 below).

### Proposed

PSNH – Merrimack Station Page 31 97 River Road, Bow, NH TV-0055

7. Pursuant to NOx RACT Order ARD-97-001, Condition C. 5.b., PSNH – Merrimack Station shall comply with the requirement in Env-A 1211.03( c)(1)b.2. of maintaining an emission rate from MK2 at or below 1.40 lb/MMBtu based on a 24-hour calendar day average and with the requirements in Env-A 1211.03(d) of mainta ining emissions from MK2 at or below 35.4 tons/day and 12,921 tons/year during the perio d May 31, 1995 through May 31, 1999 by the installation of Selective Catalytic Reductio n (SCR).

8. Pursuant to NOx RACT Order ARD-97-001, Condition C. 5.c.i., PSNH – Merrimack Station shall initially comply with the requirement in Env -A 1211.13(b) of maintaining emission rates from MKCT1 and MKCT2 at or below 0.90 lb/MMBt u based on an hourly average; and Condition C.5.c.ii., based on the results of fu ture periodic testing, PSNH – Merrimack Station shall maintain future compliance by emissio ns averaging (if necessary) between MK1, MK2, MKCT1, and MKCT2.

9. Pursuant to NOx RACT Order ARD-97-001, Condition C. 5.d., PSNH – Merrimack Station shall comply with Env-A 1211.11 for the MKEG (emerg ency generator).

10. Pursuant to NOx RACT Order ARD-97-001, Condition C. 5.e., PSNH – Merrimack Station shall comply with the testing requirements in Env-A 1211.20 (formerly Env-A 1211.21), the monitoring requirements in Env-A 1211.21 (formerly Env-A 1211.22), and the recordkeeping and reporting requirements in Env-A 9 05 and Env-A 909, respectively (formerly Env-A 901.06 and Env-A 901.07, respective ly).

11. Pursuant to NOx RACT Order ARD-97-001, Condition E. , the preamble to the USEPA’s proposed Model Open Market Trading Rule or OMTR (60 Federal Register 39668, August 3, 1995) states: “b. Overcompliance With An Alterna tive Emission Limit - In many states, sources are given flexibility from RACT requirement s when the State grants them an alternative emission limit (AEL) that is less strin gent than the RACT standard. The OMTR would not allow sources to generate DER’s by reduci ng emissions below levels required by an AEL but still above levels required by the other wise applicable RACT standard. Sources subject to AEL’s could, however, generate DER’s by reducing emissions below the levels associated with the otherwise applicable RACT stand ard.”

a) PSNH - Merrimack Station shall not be allowed to ge nerate DERs by reducing emissions below levels required by the above AEL, but PSNH - Merrimack Station shall be allowed to generate DERs by reducing emissions below the em issions limitations and emission rate limitations as listed in Env-A 1211. In the e vent that PSNH - Merrimack Station cannot meet the above AEL for some unforeseen reaso n (e.g., control equipment malfunction), PSNH - Merrimack Station may use DERs for compliance purposes.

b) This Order grants approval to PSNH - Merrimack Stat ion to quantify DERs in accordance with the protocols submitted by PSNH - Merrimack St ation to comply with these AEL. Upon submittal by PSNH - Merrimack Station of a “No tice of Generation” and accompanying documentation, as described in Env-A 3 100 which was proposed for adoption on October 10, 1996, PSNH - Merrimack Stat ion shall be allowed to trade 142 tons of NOx DERs created during the period June 22, 1995 through September 30, 1995 to other sources in New Hampshire in accordance wit h Env-A 3100. PSNH - Merrimack

### Proposed

PSNH – Merrimack Station Page 32 97 River Road, Bow, NH TV-0055

Station may be allowed to trade additional tons of NOx DERs created during subsequent periods, upon submittal of additional “Notices of G eneration” and accompanying documentation.

12. Pursuant to NOx RACT Order No. ARD-98-001, Conditio n D.1.a., PSNH - Merrimack Station shall comply at all times with a maximum em ission limit for MK2 of 15.4 tons of NOx per 24-hour calendar day by May 31, 1999. Ozon e season Discrete Emissions Reductions (DERs) may be used to comply with this l imit during the ozone season and nonozone season DERs may be used during the non-ozone season.

13. Pursuant to NOx RACT Order No. ARD-98-001, Conditio n D.1.c., PSNH’s Schiller, Merrimack, and Newington Stations (MK1, MK2, NT1, S R4, SR5, and SR6) shall comply with a combined NOx emissions cap of 8208 tons for the non-ozone season beginning on October 1st and ending on April 30th. Ozone season DERs and non-ozone season DERS may be used to comply with this non-ozone season li mit. Previously generated (1995 through 1998) DERs may be used to comply with this emissions cap. For the purpose of compliance with this RACT Order, DERs may be genera ted from PSNH’s Newington and Schiller Stations, in accordance with the PSNH Disc rete Emissions Reductions Protocol dated April 10, 1998, submitted by PSNH and listed in Items 17 and 18 below to comply with this emissions cap. 27



### 14. Pursuant to NOx RACT Order No. ARD-98-001, Conditio n D.1.d., beginning in 2003, PSNH Merrimack Station shall comply during the 153- day ozone season with an emission limit in terms of a seasonal NOx emissions cap of 3 ,727 tons minus any tons allocated to new sources and minus 100 tons allocated to a set-a side account dedicated to fulfilling alternative I/M requirements (while such requiremen ts are in effect in New Hampshire) per calendar season for the combined NOx emissions from MK1, MK2, NT1, SR4, SR5, and SR6 during the 2003 and post-2003 ozone seasons in accordance with Env-A 3200 upon adoption. Consistent with the OTC Model NOx Budget Trading Program, compliance may be achieved by allowance trading within the Ozone T ransport Region (OTR). The specific methodology for allocating allowances among applica ble budget sources for 2003 and beyond shall be determined by NHDES – Air Resources Division and implemented as an amendment to Env-A 3200 prior to 2003. 28



### 15. Pursuant to NOx RACT Order No. ARD-98-001, Conditio n D.1.f., PSNH Merrimack Station shall demonstrate compliance with the alter native emission limits in this RACT Order by monitoring the hourly emissions from MK1, MK2, NT1, SR4, SR5, and SR6 in accordance with Env-A 1211.21 (formerly Env-A 1211. 22) and Env-A 3200. Alternative emission limits shall be defined as limits other th an those listed in Env-A 1211 and RACT Order No. ARD-97-001, and the above limits are not alternatives to each other.

16. Pursuant to NOx RACT Order No. ARD-98-001, Conditio n D.1.g., within 30 days following the end of each calendar quarter, PSNH Me rrimack Station shall report any excess emissions (emissions greater than the above alterna tive emission limits) which occurred.

27 Note that the provisions of Env-A 2900 contain mor e stringent provisions. 28 This provision has been superceded by Env-A 3200.

### Proposed

PSNH – Merrimack Station Page 33 97 River Road, Bow, NH TV-0055

F. Multiple Pollutant Annual Budget Trading and Bankin g Program (Env-A 2900) [Stateonly enforceable]

1. SO 2 

### Allowance Allocation

Pursuant to Env-A 2900, Multiple Pollutant Annual Budget Trading and Bankin g Program

, and subsequent revisions, DES shall allocate SO 2 

### Allowances to PSNH - Merrimack Station according to the methodology in Env-A 2906.05, Allowance Allocation Methodology for 2007 and subsequent years.

2. NOx Allowance Allocation

a) Pursuant to Env-A 2900, Multiple Pollutant Annual Budget Trading and Bankin g Program , and subsequent revisions, DES shall allocate NOx Allowances to PSNH - Merrimack Station according to the methodology in E nv-A 2906.05, Allowance Allocation Methodology for 2007 and subsequent years.

b) Pursuant to Env-A 2900 [State enforceable only], Multiple Pollutant Annual Budget Trading and Banking Program , and subsequent revisions, for 2007 and subsequent years, DES shall calculate the difference between the annu al NOx budget (no more than 3,644 tons) and the ozone season NOx allowances allocated pursuant to Env-A 3200.

c) Pursuant to Env-A 2900 [State enforceable only], Multiple Pollutant Annual Budget Trading and Banking Program , and subsequent revisions, for 2007 and subsequent years, DES shall allocate annual NOx allowances equivalent to the difference between the annual NOx budget and the ozone season NOx allowanc es to PSNH’s Schiller, Merrimack, and Newington stations.

3. Allowance Transfer and Use

a) Pursuant to Env-A 2907.01, Marketable Emissions Authorization , an allowance shall be a marketable emissions authorization that may be boug ht, sold, or traded at any time during any year, not just the current year.

b) Pursuant to Env-A 2907.02, Limited Authorization, an allowance shall only be used for compliance with the Multiple Pollutant Annual Budge t Trading and Banking Program in a designated compliance year by being in a complian ce or overdraft account as of the allowance transfer deadline, or by being transferre d into the compliance account by an allowance transfer submitted by the allowance trans fer deadline.

c) PSNH - Merrimack Station shall comply with the allo wance transfer and use provisions pursuant to Env-A 2907, Allowance Transfer and Use, and Env-A 2909, Allowance Tracking System

. d) Pursuant to Env-A 2907.08, Price Disclosure, subject to a claim of confidentiality in accordance with Env-A 103, PSNH - Merrimack Station shall make available to any person, all information regarding transaction cost and allowance price.

### Proposed

PSNH – Merrimack Station Page 34 97 River Road, Bow, NH TV-0055

e) Pursuant to Env-A 2907.09, Use of Allowances by Utilities and RSA 125-J:5, X, the use of allowances by a utility as defined in RSA 362:2, shall be subject to such additional conditions as ordered pursuant to applicable law by the PUC.

4. Allowance Banking

a) Pursuant to Env-A 2908.01, Retention of Unused Allowances, the banking of allowances shall be permitted to allow the retention of unused allowances from one year to a future year in either a compliance account, an overdraft a ccount, or a general account.

b) Pursuant to Env-A 2908.02, Account Designation, unless otherwise permitted pursuant to Env-A 2909.03, General Accounts, unused allowances as of the end of the allowance transfer deadline shall be retained in the complian ce, overdraft, or general account and designated as banked allowances after the ATS admin istrator has made all deductions for a given year from the compliance account or overdra ft account pursuant to Env-A 2913, Compliance Certification.

5. Authorized Account Representative (Env-A 2909.04)

a) Only the AAR or alternate AAR shall request transfe rs of allowances in an ATS account.

b) The AAR or alternate AAR shall be responsible for a ll transactions and reports submitted to the ATS.

c) The alternative AAR shall have the same authority a s the primary representative, however, all correspondence from the ATS administra tor shall be directed to the primary AAR.

d) Pursuant to Env-A 2909.05 (f), PSNH - Merrimack Sta tion shall replace an AAR by submitting a revised Account Certificate of Represe ntation to the ATS administrator along with the information contained in Env-A 2909. 05(b) and (c) and the name of the AAR who is being replaced.

6. End-of-Year Reconciliation

a) Pursuant to Env-A 2904.01, Limited Authorization , PSNH - Merrimack Station shall, no later than January 30th of each calendar year, hold respective quantities of SO 2 

### , NOx, and CO 2 

### allowances in the PSNH - Merrimack Station’s respe ctive ATS accounts equal to or greater than the respective total SO 2 

### , NOx, and CO 2 

### emitted from PSNH - Merrimack Station during the previous year.

b) Pursuant to Env-A 2912.01, Determination of Compliance , monitored emissions data as reported by PSNH - Merrimack Station to the ETS adm inistrator, and as adjusted by the administrator to be in accordance with Env-A 2910, Emissions Monitoring , combined with allowance allocations and transfers recorded i n the ATS, shall provide the basis for a determination of compliance.

### Proposed

PSNH – Merrimack Station Page 35 97 River Road, Bow, NH TV-0055

c) PSNH - Merrimack Station shall determine compliance and reconcile allowances by January 30th of each year beginning in 2008 pursuan t to Env-A 2913.

d) Pursuant to Env-A 2912.02, Request for Deduction of Allowances , each year prior to January 30th, the AAR shall request the ATS adminis trator to deduct previous year allowances from the compliance account or overdraft account equivalent to the number of available allowances to cover the emissions during the previous year. The AAR shall identify the compliance account or overdraft accoun t from which the deductions shall be made and shall identify the serial number of the al lowances to be deducted. If the AAR does not specify a serial number, allowances useabl e for that compliance year shall be deducted in the order of their arrival into PSNH - Merrimack Station’s account, with allocated allowances being deducted first, followed by the deduction of transferred allowances.

e) Pursuant to Env-A 2912.04, Procurement of Additional Allowances, if the emissions of PSNH - Merrimack Station in the previous year excee d the allowances in PSNH - Merrimack Station’s compliance account and overdraf t account, PSNH - Merrimack Station shall obtain additional allowances by Janua ry 30th so that the total number of allowances in PSNH - Merrimack Station’s compliance account and overdraft account, including allowance transfers properly submitted to the ATS administrator by January 30th, equals or exceeds the previous year annual em issions rounded to the nearest whole

ton.

7. Excess Emissions and Enforcement Provisions (Env-A 2914)

a) If emissions from PSNH – Merrimack Station exceed a llowances held in PSNH - Merrimack Station’s compliance account or overdraft account for the year as of the allowance transfer deadline (January 30th), the All owance Tracking System administrator shall automatically deduct allowances from PSNH – M errimack Station’s compliance account or overdraft account for the next year at a rate of three allowances for every one ton of excess emissions.

b) In accordance with RSA 125-O:7, for purposes of enf orcement of the Multiple Pollutant Annual Budget Trading and Banking Program, in deter mining the number of days of violation, any excess emissions for the year shall create a presumption that each day in the year of 365 days, constitutes a day in violatio n unless PSNH - Merrimack Station can demonstrate, through use of verifiable emissions da ta that a lesser number of days should be considered. In addition, each ton of excess emi ssions shall constitute a separate violation.

8. Conversion of Allowances to DERs

a) Pursuant to Env-A 2904.01 (d), allowances shall not be considered offsets, although NOx allowances which are not used to satisfy the requir ements of Env-A 2900, and which are not banked, may be converted to non-ozone season NO x DERs in accordance with Env-A 3100.

### Proposed

PSNH – Merrimack Station Page 36 97 River Road, Bow, NH TV-0055

b) Pursuant to Env-A 2904.02, Conversion of Allowances to DERs or VERs if PSNH - Merrimack Station converts unused NOx allowances to NOx DERs in accordance with Env-A 2904.01(d) and the procedures for DER generat ion pursuant to Env-A 3103, or converts unused CO2 allowances to VERs in accordanc e with Env-A 3800, PSNH - Merrimack Station shall surrender those converted a llowances as if they had been used for actual emissions.

9. Prohibition on Property Rights (Env-A 2904.04)

a) Neither an allowance nor any future allocations, wh ich are subject to modification by DES, shall constitute a security or other form of p roperty.

b) An allowance shall not be used prior to the year fo r which the allowance is allocated.

G. Discrete Emission Reduction Trading Program (Env-A 3100)

PSNH - Merrimack Station shall be allowed to bank D ERs for PSNH - Merrimack Station’s own future use or trade with others in accordance with Env-A 3100.

H. Carbon Dioxide (CO 2 

### ) Budget Trading Program (Env-A 4600) (State-only E nforceable)

1. CO 2 

### Allowance Requirements (Env-A 4605.01)

a. The Owner or Operator of each CO 2 

### budget source and each CO 2 

### budget unit at the source shall hold CO 2 

### allowances available for compliance deductions und er Env-A 4605.04, as of the CO 2 

### allowance transfer deadline, in the source’s compl iance account, in an amount not less than the total CO 2 

### emissions from fossil fuel-fired generation for the control period from all CO 2 

### budget units at the source, as determined in accor dance with Env-A 4605, Env-A 4607, Env-A 4609.18, and Con dition VIII.H.1.c, below.

b. CO 2 

### allowances shall be held in, deducted from, or tra nsferred among CO 2 

### allowance tracking system accounts in accordance with Env-A 4 606, Env-A 4607, Env-A 4608, and Env-A 4700.

c. For the purpose of determining compliance with Env- A 4600, total tons of CO 2 

### emissions for a control period 29 

### shall be calculated as the sum of all recorded hou rly emissions, or the tonnage equivalent of the recorded hourly emiss ions rates, in accordance with Env-A 4609, with any remaining fraction of a ton equal to or greater than 0.50 ton rounded up to equal one ton and any fraction of a ton less than 0 .50 ton rounded down to equal zero

tons.

2. CO 2 

### Allowance Limitations (Env-A 4605.02)

a. A CO 2 

### allowance shall be a limited authorization to emit one ton of CO 2 

### in accordance with the CO 2 

### budget trading program.

29 Control period means compliance period as defined in New Hampshire RSA 125-O:20, IV.

### Proposed

PSNH – Merrimack Station Page 37 97 River Road, Bow, NH TV-0055

b. A CO 2 

### allowance shall not be deducted, in order to compl y with the requirements of EnvA 4605.01(a), for a control period that ends prior to the year for which the CO 2 

### allowance was allocated.

c. A CO 2 

### offset allowance shall not be deducted, in order t o comply with the requirements of Env-A 4605.01(a), beyond the applicable percent limitations set out in Env-A 4605.04(b).

d. Subject to Env-A 4605.02(e) and (f), no provision o f the CO 2 

### budget trading program, the CO 2 

### budget permit application, or the CO 2 

### budget permit shall be construed to limit the authority of the department to terminate or limit s uch authorization.

e. A CO 2 

### allowance shall not constitute a property right.

3. Allowances Available for Compliance Deduction (Env- A 4605.04)

a. CO 2 

### allowances that meet the following criteria shall be available to be deducted for compliance with the requirements of Env-A 4605 for a control period:

i. 

### For CO 2 

### allowances other than CO 2 

### offset allowances, the allowances are from allocation years that fall within a prior control p eriod or the same control period for which the allowances will be deducted; and

ii. 

### The CO 2 

### allowances are: 1. Held in the CO 2 

### budget source’s compliance account as of the CO 2 

### allowance transfer deadline for that control period; or 2. Transferred into the compliance account by a CO 2 

### allowance transfer correctly submitted for recordation under Env-A 4608.01 by th e CO 2 

### allowance transfer deadline for that control period;

b. As provided in RSA 125-O:22, II, a CO 2 

### budget source may use offset allowances for up to 3.3 percent of its compliance obligation, subjec t to the following:

i. 

### If the Department determines that there has been a stage one trigger event, the CO 2 

### budget source may use offset allowances for up to 5 percent of its compliance obligation; and

ii. 

### If the Department determines that there has been a stage two trigger event, the CO 2 

### budget source may use offset allowances for up to 1 0 percent of its compliance obligation.

c. CO 2 

### allowances shall not be available for current comp liance if the allowances were deducted for excess CO 2 

### emissions for a prior control period under Env-A 4 605.08.

d. Allowances deducted for the purpose of compliance s hall not be available for any other

purpose.

4. Excess CO 2 

### Emissions Requirements (Env-A 4605.07) The Owner or Operator of a CO 2 

### budget source that has excess CO 2 

### emissions in any control period shall:

a. Forfeit the CO 2 

### allowances required for deduction under Env-A 4605 .08, provided CO 2 

### offset allowances shall not be used to cover any pa rt of such excess CO 2 

### emissions; and

### Proposed

PSNH – Merrimack Station Page 38 97 River Road, Bow, NH TV-0055

b. Pay any fine, penalty, or assessment or comply with any other remedy imposed under RSA 125-O:22, V.

5. Deductions for Excess CO 2 

### Emissions (Env-A 4605.08)

a. As provided by RSA 125-O:22, V, the deduction of CO 2 

### allowances for excess CO 2 

### emissions shall be equal to 3 times the number of t he source’s excess CO 2 

### emissions.

b. Within 14 calendar days of receipt of notice from t he regional organization 30 

### that a shortage exists, the source shall transfer sufficie nt allowances into its compliance account to cover the shortage.

c. No CO 2 

### offset allowances shall be deducted to account for the source’s excess CO 2 

### emissions.

d. Any CO 2 

### allowance deduction required under 5.a, above, sha ll not affect the liability of the owner(s) and operator(s) of the CO 2 

### budget source or the CO 2 

### units at the source for any fine, penalty, or assessment, and shall not aff ect the obligation of the owner(s) and operator(s) to comply with any other remedy, for th e same violation, as ordered under applicable state law.

6. Determination of Violations and Deduction of Allowa nces (Env-A 4605.11)

a. For purposes of determining the number of days of v iolation, if a CO 2 

### budget source has excess CO 2 

### emissions for a control period, each day in the co ntrol period shall constitute a day of violation unless the owner(s) and operator (s) of the unit demonstrate that a lesser number of days should be considered; and

b. Each ton of excess CO 2 

### emissions shall constitute a separate violation.

7. Submission of CO 2 

### Allowance Transfers (Env-A 4608.01)

a. Any CO 2 

### AAR seeking recordation of a CO 2 

### allowance transfer shall submit the transfer request to the regional organization in accordance with Env-A 4608.01(b).

I. Monitoring/Testing Requirements

1. The Permittee is subject to the monitoring/testing requirements as contained in Table 7 below:

30 Regional organization as defined in NH RSA 125-O:2 0, XIII

### Proposed

PSNH – Merrimack Station Page 39 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite 1. MK1 & MK2 NOx

Emissions For MK1 and MK2, the owner or operator shall

install, certify, operate and maintain, a NOxdiluent continuous emission monitoring system (consisting of a NOx pollutant concentration monitor and an O 2 or CO 2 diluent gas monitor) with an automated data acquisition and handling system for measuring and recording NOx concentration (in ppm) averaged on an hourly and 24-hour calendar day basis, O 2 or CO 2 concentration (in percent O 2 or CO 2 ) and NOx mass emission rate (in lb/mmBtu) averaged on an hourly, 24-hour calendar day, and annual basis for each unit. The owner or operator shall account for total NOx emissions, both NO and NO 2 , either by monitoring for both NO and NO 2 or by monitoring for NO only and adjusting the emissions data to account for NO 2 . The owner or operator shall calculate hourly, quarterly, and annual NOx emission rates (in lb/mmBtu) by combining the NOx concentration (in ppm), diluent concentration (in percent CO 2 ), and percent moisture according to the procedures in 40 CFR 75 Appendix F. Continuously Env-A 808.02 (a) (new) and 40 CFR 75 § 75.10(a)(2), § 75.12, and Env-A 1211.03 (f)

2. MK1, MK2, MKCT1, & MKCT2 NOx Mass

Emissions For MK1, MK2, MKCT1, and MKCT2, the

owner or operator shall calculate hourly NOx mass emissions (in lbs) by multiplying the hourly NOx emission rate (in lbs/mmBtu) by the hourly heat input rate (in mmBtu/hr) and the unit or stack operating time. The owner or operator shall also calculate quarterly and cumulative year-to-date NOx mass emissions and (in tons) by summing the hourly NOx mass emissions according to the procedures in 40 CFR 75 Appendix F Section 8. Hourly, quarterly, and cumulative year-to-date 40 CFR 75

§75.71, and §75.72 and Env-A 3212 and Env-A 2910

3. MK1, MK2, MKCT1, & MKCT2 Ozone Season

NOx Emission Rate and NOx

mass emissions The owner or operator shall determine the ozone

season NOx emission rate (in lb/mmBtu) by dividing ozone season NOx mass emissions (in lbs) by heat input. The owner or operator shall also calculate cumulative NOx mass emissions for the ozone season (in tons) by summing the hourly NOx mass emissions according to the procedures in 40 CFR 75 Appendix F Section 8. Hourly and at the end of the

ozone season Env-A 3212.01

and 40 CFR 75 §75.75(b) and §75.72

### Proposed

PSNH – Merrimack Station Page 40 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite 4. MKCT1 & MKCT2 CO 2 , SO 2 ,

opacity monitoring, recordkeeping, and reporting exemptions The requirements of 40 CFR 75 Subpart H for

CO 2 , SO 2 , opacity monitoring, recordkeeping, and reporting do not apply to units that are subject to a State or Federal NOx mass emission reduction program only and are not affected units with an Acid Rain Program emission limitation (i.e., MKCT1 & MKCT2)



### . NA 40 CFR 75 §75.70(a)(2)

5. MK1 & MK2 General CEM

Requirements A) Pursuant to 40 CFR 75.5 (b), the Permittee

must operate MK1 and MK2 in compliance with the requirements of 40 CFR 75.2 through 75.75 and 40 CFR 75 Appendices A through I. B) Pursuant to 40 CFR 75.5 (d), the Permittee shall account for all emissions of SO 2 , NOx, and CO 2 in accordance with 40 CFR 75.10 through 75.19. C) Pursuant to 40 CFR 75.5 (e), the Permittee shall not disrupt the continuous emission monitoring system or other approved emission monitoring method, and thereby not monitor or record SO 2 , NOx, and CO 2 , except for periods of recertification, or periods when calibration, quality assurance, or maintenance is performed pursuant to 40 CFR 75.21 and 40 CFR 75 Appendix B. D) The CEMS shall meet the most stringent requirements of 40 CFR 75 and Env-A 808 (new). Continuously 40 CFR 75§75.5 and EnvA 808 (new)

6. MK1 & MK2 CEMS

Performance and Audit Requirements The Permittee shall ensure that each CEMS

meets the following requirements: A) Each CEMS meets equipment, installation, and performance specifications in 40 CFR 75 Appendix A; B) Each CEMS is maintained according to the quality assurance and quality control procedures in 40 CFR 75 Appendix B; and C) Each CEMS shall record SO 2 and NOx emissions in the appropriate units of

measurement. D) The permittee shall comply with the most stringent CEM audit requirements contained in 40 CFR 75 and Env-A 808.07, General Audit Requirements , Env-A 808.08, Audit Requirements for Gaseous CEM Systems

, and Env-A 808.09, Audit Requirements for Opacity CEM Systems. As specified by regulation 40 CFR 75

§75.10(b) and Env-A 808.07, 808.08, and 808.09 and 40 CFR 75 Appendices A and B

### Proposed

PSNH – Merrimack Station Page 41 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite

7. MK1 & MK2 Valid

Averaging Periods for Gaseous and Opacity CEM Systems The number of hours of valid CEM data

required for determining a valid averaging period for the different emission standard periods shall be: A) For a 3-hour emission standard period, 2 hours of valid data; B) For a 4-hour emission standard period, 3 hours of valid data; C) For an 8-hour emission standard period, 6 hours of valid data; D) For a 12-hour emission standard period, 9 hours of valid data, and E) For a 24-hour emission standard period, 18 hours of valid data. As applicable Env-A 808.14(formerly EnvA 805.09)

8. MK1 & MK2 SO 2 Emissions The owner or operator shall install, cer tify, operate and maintain, an SO 2 CEMS automated data acquisition and handling system for measuring and recording SO 2 concentration (in ppm) averaged on an hourly and 24-hour calendar day basis, volumetric gas flow (in scfh), and SO 2 mass emissions (in lb/hr averaged over one hour and each 24-hour calendar day, and tons/consecutive 12-month period and tons/calendar year) for each unit. The owner or operator shall also measure and record the SO 2 emission rate (in lb/mmBtu) averaged over each 24-hour calendar day. The owner or operator shall demonstrate compliance with the State Acid Rain Program emission caps by using the CEMS data. Continuously Env-A 808.02 (a)(1) (new) and 40 CFR 75 §75.10 (a)(1)

9 MK1 & MK2 CO 2

Emissions The owner or operator shall install, certify,

operate and maintain, a CO 2 CEMS automated data acquisition and handling system. The owner or operator shall measure and record CO 2 emissions in lb/hr over each 24-hour calendar day and CO 2 concentration in percent on an hourly average and over each 24-hour calendar day. The owner or operator shall use applicable procedures specified in 40 CFR 75 Appendix G to calculate CO 2 emissions. Please note that equation G-1 of 40 CFR 75 Appendix G shall not be used to determine CO 2 emissions under Env-A 4609. Continuously 40 CFR 75 §75.10(a)(3), 40 CFR 75 Appendix G, & Env-A 4609

### Proposed

PSNH – Merrimack Station Page 42 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite 10. MK1 & MK2 Heat input rate

measurement The owner or operator shall determine the heat

input rate (in mmBtu/hr) to each unit for every hour or part of an hour any fuel is combusted following the procedures in 40 CFR 75 Appendix F. Hourly 40 CFR 75 §75.10(c) Federally Enforceable & Env-A 2910.02 11. MK1 & MK2 Stack

Volumetric Flow Rate The owner or operator shall install, certify,

operate and maintain, a CEMS automated data acquisition and handling system to measure and record stack volumetric flow rate (in kscfm) on an hourly average and over each 24-hour calendar day. Continuously 40 CFR 75 §75.10(a) & Env-A 2910.02

12. MK1 & MK2 Stack

Volumetric Flow Measuring Device The owner or operator shall meet the following

requirements for the stack volumetric flow measuring device: A) All differential pressure flow monitors shall have an automatic blow-back purge system installed and in wet conditions, shall have the capability for drainage of the sensing lines; and B) The stack flow monitoring system shall have the capability for manual calibration of the transducer while the system is on-line and for a zero check. Continuously Env-A 808.03(d)

13. MK1 & MK2 Opacity The owner or operator shall install, certif y, operate and maintain, a continuous opacity monitoring system with the automated data acquisition and handling system for measuring and recording the opacity of emissions (in percent opacity) for each 6-minute period for each unit. When the COMS does not meet the minimum operating requirements, then the owner or operator shall also use US EPA Method 9 to estimate opacity. Continuously 40 CFR 75 §75.10(a)(4) and Env-A 805.02 (old) and Env-A 808.02 (a) (new) and 807.02 (new)

14. MK1, MK2, MKCT1, & MKCT2 Net Electrical

Output The owner or operator shall monitor and/or

calculate net electrical output as reported to and publicly available from US Department of Energy, Energy Information Agency. Annually Env-A 2910.02, Env-A3207.04, EnvA 3705and 40 CFR 75.53 15. MK1, MK2, MKCT1, & MKCT2 Ozone Season

Heat Input The owner or operator shall calculate ozone

season heat input for purposes of providing data needed for determining allocations by summing each unit’s hourly heat input determined according to the procedures in 40 CFR 75 for all hours in which the unit operated during the

ozone season Hourly during

ozone season Env-A 3212.01

and 40 CFR 75 §75.75(a)

### Proposed

PSNH – Merrimack Station Page 43 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite 16. MK1 & MK2 CEM Hourly

Operating Requirements & Valid Hour of CEM Data Pursuant to Env-A 808.01, 808.03, and 40 CFR

75.10(d), the Permittee shall ensure that the CEMS and components meet the following hourly operating requirements: A) The Permittee shall ensure that each CEM is capable of completing a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15- minute interval pursuant to Env-A 40 CFR 75.10(d) and pursuant to Env-A 808.03(c)(2) for each successive 5-minute period for gaseous emissions, unless a longer time period is approved in accordance with Env-A 809 B) The Permittee shall reduce all SO 2 concentrations, volumetric flow, SO 2 mass emissions, CO 2 concentration, CO 2 mass emissions (if applicable), NOx concentration, and NOx emission rate data collected by the monitors to hourly averages. C) The Permittee shall use all valid measurements or data points collected during an hour to calculate the hourly averages. All data points collected during an hour shall be, to the extent practicable, evenly spaced over the hour. D) Failure of an SO 2 or CO 2 pollutant concentration monitor, NOx concentration monitor, flow monitor, or NOx-diluent CEMS to acquire the minimum number of data points for calculation of an hourly average shall result in the failure to obtain a valid hour of data and the loss of such component data for the entire hour. E) For a NOx-diluent monitoring system, an hourly average NOx emission rate in lb/mmBtu is valid only if the minimum number of data points is acquired by both the NOx pollutant concentration monitor and the diluent monitor (CO 2 ). F) If a valid hour of data is not obtained, the Permittee shall estimate and record emissions, moisture, or flow data for the missing hour by means of the automated data acquisition and handling system, in accordance with the applicable procedure for missing data. Hourly 40 CFR 75 §75.10(d) and Env-A 808.01(i) and 808.03

### Proposed

PSNH – Merrimack Station Page 44 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite 16. MK1 & MK2 CEM Hourly

Operating Requirements & Valid Hour of CEM Data (continued) G) Pursuant to Env-A 808.01(i), a valid hour of

CEM emissions data means a minimum of 42 minutes of CEM readings taken in any calendar hour, during which the CEM is not in an out of control period and the facility is in operation. H) Pursuant to Env-A 808.03(a), the owner or operator shall average and record the CEM data for gaseous emissions for each calendar hour. I) Pursuant to Env-A 808.03(c)(1), all CEM systems shall include a means to display instantaneous values of percent opacity and gaseous emission concentrations. Hourly 40 CFR 75 §75.10(d) and Env-A 808.01(i) and 808.03

17. MK1 & MK2 COMS Hourly

Operating Requirements Pursuant to 40 CFR 75.10(d), the Permittee shall

ensure that each COMS and components meet the following hourly operating requirements: A) The Permittee shall ensure that each continuous opacity monitoring system is capable of completing a minimum of one cycle of sampling and analyzing (and recording pursuant to Env-A 808.03(c)(2) unless a longer time period is approved in accordance with Env-A 809) for each successive 10-second period and one cycle of data recording for each successive 6- minute period. B) The Permittee shall reduce all opacity data to 6-minute averages calculated in accordance with the provisions of 40 CFR 51 Appendix M, except where the SIP or operating permit requires a different averaging period, in which case the State requirement shall satisfy this Acid Rain Program requirement. C) Pursuant to Env-A 808.03(b)(1), the owner or operator shall average the opacity data to result in consecutive, non-overlapping 6- minute averages; and D) Pursuant to Env-A 808.03(b)(2), the COMS must total number of minutes in any 8-hour period where the opacity, as averaged in non-overlapping 6-minute periods, exceeds the applicable opacity standard. E) Pursuant to Env-A 808.03(c)(1), all CEM systems shall include a means to display instantaneous values of percent opacity and gaseous emission concentrations. Sampling for successive 10- second period and recording for successive 6-minute period 40 CFR 75

§75.10(d) and Env-A 808.03(b) and (c)

### Proposed

PSNH – Merrimack Station Page 45 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite 18. MK1 & MK2 Minimum

measurement capability requirement The Permittee shall ensure that each CEMS is

capable of accurately measuring, recording, and reporting data, and shall not incur an exceedance of the full scale range, except as provided in 40 CFR 75 Appendix A Sections 2.1.1.5, 2.1.2.5, and 2.1.4.3. As specified by regulation 40 CFR 75

§75.10(f)

19. MK1 & MK2 Specific

provisions for monitoring SO 2 emissions (SO 2 emissions and flow monitors) The owner or operator shall meet the general

operating requirements in 40 CFR 75.10 for an SO 2 continuous emission monitoring system and a flow monitoring system. As specified by regulation 40 CFR 75

§75.11(a), (b)

20. MK1 & MK2 Specific

provisions for monitoring NOx emissions – Coal-fired Units A) Pursuant to 40 CFR 75.12, 75.71, and 75.72

and Env-A 3212, the Permittee shall meet the specific provisions for NOx-diluent CEMS, including the following: 1) Meet general operating requirements in 40 CFR 75.10 for a NOx continuous emission monitoring system. The diluent gas monitor in the NOx CEMS may measure either O 2 or CO 2 concentration in the flue gases. 2) Comply with moisture correction procedures according to 40 CFR 75.12(b) 3) Comply with NOx emission rate procedures contained in 40 CFR 75.12(c). B) The Permittee shall meet the annual and ozone season monitoring requirements according to 40 CFR 75.74, as applicable. Continuously 40 CFR 75 §75.12, 75.71, and 75.72 and Env-A 3212

### Proposed

PSNH – Merrimack Station Page 46 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite 21. MKCT1 & MKCT2 NOx Mass

Emissions - Specific Provisions for Monitoring NOx Emissions for Alternative Monitoring System The owner or operator shall meet the

requirements of 40 CFR 75.12 including using the procedures of 40 CFR 75 Appendix E for estimating hourly NOx emission rate, using the procedures of 40 CFR Appendix D for determining hourly heat input, except for the heat input apportionment provisions of 40 CFR 75 Appendix D Section 2.1.2 to meet the NOx mass reporting provisions. If in the years after certification of the monitoring system, a unit’s operation exceed a capacity factor of 20 percent in any calendar year or exceed a capacity factor of 10.0 percent averaged over three years, or exceed a capacity factor of 20.0 percent in any ozone season or exceed an ozone season capacity factor of 10.0 percent averaged over three years, the owner or operator shall install, certify, and operate a NOx CEMS and also meet the requirements of 40 CFR 75.71(c) no later than December 31 of the following calendar

year. Hourly 40 CFR 75 Appendix E Section 1.1 and 40 CFR 75 §75.12(d)(2) and 75.71(d)

22. MK1 & MK2 Specific

provisions for monitoring CO 2 emissions The owner or operator shall comply with the

applicable CO 2 monitoring provisions of 40 CFR 75 §75.13(a), (b), and (c) for the CO 2 CEMS and flow monitoring systems. Continuously 40 CFR 75 §75.13(a)-(c)

23. MK1 & MK2 Specific

provisions for monitoring opacity Pursuant to 40 CFR 75.14, the continuous

opacity monitoring and recording system shall meet all the design, installation, equipment, and performance specifications of 40 CFR 60, Appendix B, Performance Specification 1, and all the operational and quality assurance requirements of Env-A 808 (new). Continuously 40 CFR 75 §75.14 and Env-A 808 (new)

24. MK1 & MK2 Reference

Test Methods for Certificationor Recertification of CEMS or COMS The Permittee shall use the reference test

method listed in 40 CFR 75.22 and included in Appendix A to 40 CFR 60 to conduct monitoring system tests for certification or recertification of CEMS and expected monitoring systems under 40 CFR 75 Appendix E and quality assurance and quality control procedures. During certification and recertification

tests 40 CFR 75

§75.22

### Proposed

PSNH – Merrimack Station Page 47 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite 25. MK1 & MK2 Out of control

periods A) Pursuant to 40 CFR 75.21(e)(2), whenever a

CEMS or COMS fails a quality assuranceaudit or any other audit, the system is out-ofcontrol, and the Permittee shall follow the procedures for out-of-control periods in 40 CFR 75.24. B) Pursuant to Env-A 3212.10 and 2910.06, whenever any monitoring system fails to meet the quality assurance requirements of 40 CFR 75 Appendix B, the permittee shall substitute the data using the applicable procedures in 40 CFR 75, Subpart D, Appendix D or E. C) Pursuant to 75.24, if an out-of-control period occurs to a monitor or CEMS, the owner or operator shall take corrective action and repeat the tests applicable to the out of control parameter as described in 40 CFR 75 Appendix B. 1) For daily calibration error tests, an out of control period occurs when the calibration error of a pollutant concentration monitor exceeds 5.0% based upon the span value, the calibration error of a diluent gas monitor exceeds 1.0% O 2 or CO 2 , or the calibration error of a flow monitor exceeds 6.0% based upon the span value, which is twice the applicable specification in 40 CFR 75 Appendix A. 2) For quarterly linearity checks, an out of control period occurs when the error in linearity at any of the three gas concentrations (low, mid-range, and high) exceeds the applicable specification in 40 CFR 75 Appendix A. 3) For relative accuracy test audits (RATAs), cylinder gas audit (CGAs), and relative accuracy audits (RAAs), an out of control period occurs when the sampling is completed and the CEMS fails the accuracy criteria until successful completion of the same audit after corrective action has occurred. As specified by regulation 40 CFR 75

§75.21(e)(2) and 75.24 and Env-A 3212.10 and 2910.06 and 808.01(g)

### Proposed

PSNH – Merrimack Station Page 48 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite 25. MK1 & MK2 Out of control

periods (continued) D) Pursuant to Env-A 3212.10, whenever both

an audit of a monitoring system and a review of the initial certification or recertification application reveal that any system or component should not have been certified or recertified because it did not meet a particular performance specification or other requirement pursuant to Env-A 800 or the applicable provisions of 40 CFR Part 75, both at the time of the initial certification or recertification application submission and at the time of the audit, the department shall issue a notice of disapproval of the certification status of such system or component. E) For the purposes of this section, an audit shall be either a field audit or an audit of any information submitted to the department or the administrator. F) The data measured and recorded by the system or component shall not be considered valid quality-assured data from the date of issuance of the notification of the disapproval of certification status until the date and time that the owner or operator completes subsequently approved initial certification or recertification tests in accordance with Env-A 3212.07(t). G) The owner or operator shall follow the initial certification or recertification procedures for each disapproved system. As specified by regulation 40 CFR 75

§75.21(e)(2) and 75.24 and Env-A 3212.10 and 2910.06 and 808.01(g)

### Proposed

PSNH – Merrimack Station Page 49 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite 26. MK1 & MK2 Out of Control

Periods for Opacity Out of control period for a CEMS measuring

opacity is as follows: A) The time period beginning with the completion of the daily calibration drift (CD) check where the CD exceeds 2% opacity for 5 consecutive days, and ending with the CD check after corrective action has occurred that results in the performance specification drift limits being met; B) The time period beginning with the completion of a daily CD check preceding the daily CD check that results in the CD being greater than 5% opacity and ending with the CD check after corrective action has occurred that results in the performance specification drift limits being met; or C) The time period beginning with the completion of a quarterly opacity audit where the CEMS fails the calibration error test as specified in 40 CFR 60, Appendix B, Specification 1 and ending with successful completion of the same audit where the CEMS passes the calibration error test established after corrective action has occurred. As specified by regulation Env-A

808.01(g)(2)

### Proposed

PSNH – Merrimack Station Page 50 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite 27. MK1, MK2, MKCT1 & MKCT2 Data

Availability and Missing Data Substitution Procedures A) The Permittee shall follow the procedures in

40 CFR 75.30 through 75.37, 75.70(f), 75.74, and 40 CFR 75 Appendix E when a valid, quality-assured hour of data is not measured or recorded. B) For MKCT1 & MKCT2, the Permittee shall provide substitute data pursuant to 40 CFR 75.74 and 40 CFR 75 Appendix E Section 2.5, when the QA/QC control parameters are exceeded or missing. C) Pursuant to Env-A 808.02(c)(2), the permittee shall comply with the minimum percentage data availability requirements pursuant to Env-A 808.10(a)-(d) to meet the requirements of Env-A 3200, NOx Budget Program

. D) Pursuant to Env-A 808.10, if the permittee cannot meet the percentage data availability requirements, the permittee shall also follow the provisions of Env-A 808.10(e) – (g). E) Pursuant to 40 CFR 75.24(e), if COMS is out of control, the permittee shall follow the data availability requirements of Env-A 808.10. As specified by regulation 40 CFR 75

§75.30 through 75.37 and 75.50(f) and 75.24(e) and 75.74 and 40 CFR 75 Appendix E Section 2.5 & Env-A 808.10 & 808.02(c)(2)

28. MK1, MK2, MKCT1 & MKCT2 NOx Mass

Emissions - General Provisions A) Pursuant to Env-A 3200, NOx Budget

Program , the permittee shall comply with the provisions of 40 CFR 75 Subparts A, C, D, E, F, and G and Appendices A through G applicable to NOx concentration, flow rate, NOx emission rate and heat input, as set forth and referenced in Subpart H. B) The requirements of Subpart H for CO 2 , SO 2 , opacity monitoring, recordkeeping, and reporting do not apply to units that are subject to a State or federal NOx mass emission reduction program only and are not affected units with an Acid Rain Program emission limitation (i.e., MKCT1 & MKCT2)

. As specified by regulation Env-3212.01

and 40 CFR 75 §75.70(a)

### Proposed

PSNH – Merrimack Station Page 51 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite 29. MK1, MK2, MKCT1, MKCT2 NOx Mass

Emissions Provisions - Prohibitions A) No owner or operator of an affected unit

shall use any alternative monitoring system, reference method, or any other alternative for the required CEMS without approval through petition process in § 75.70(h). (MKCT1 and MKCT2 did get approval of use of Appendix E.) B) No owner or operator of an affected unit shall operate the unit so as to discharge NOx emissions without accounting for all emissions in accordance with the provisions of Subpart H, except as provided in § 75.74. C) No owner or operator of an affected unit shall disrupt the CEMS or any other approved emission monitoring method, and thereby avoid monitoring and recording NOx mass emissions, except for periods of re-certification or periods when calibration, quality assurance testing, or maintenance is performed in accordance with the provisions of Subpart H applicable to the monitoring systems under § 75.71, except as provided in § 75.74. D) No owner or operator of an affected unit shall retire or permanently discontinue use of the CEMS, or any other approved emission monitoring system except under one of the following circumstances: 1) During period that the unit is covered by a retired unit exemption that is in effect under the State or federal NOx mass emission reduction program that adopts the requirements of Subpart H; 2) The owner or operator is monitoring NOx emissions from the affected unit with another certified monitoring system approved, in accordance with the provisions of § 75.70(d); or 3) The designated representative submits notification of the date of certification testing of a replacement monitoring system in accordance with § 75.61. E) The owner or operator shall use the alternative monitoring provisions of 40 CFR 75 Appendix E for determining NOx emissions for MKCT1 and MKCT2. Continuously 40 CFR 75 §75.70(c) and 40 CFR 75 Appendix E

### Proposed

PSNH – Merrimack Station Page 52 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite 30. MK1, MK2, MKCT1, MKCT2 CEMS and

COMS and Alternative Monitoring Certification Pursuant to 40 CFR 75.20 and 40 CFR 75.70(d)

and Env-A 3212.07 and Env-A 3212.10, the Permittee shall recertify the CEMS and COMS and alternative monitoring system whenever the Permittee makes a replacement, modification, or change to the systems or to the facility that could significantly affect the ability of the systems to accurately measure and record the requisite data. The Permittee must submit an application for recertification of the monitoring system to EPA and DES, except pursuant to Env-A 3212.11, notifications for MKCT1 & MKCT2 shall only be sent to DES. Whenever the Permittee makes a replacement, modification, or change to the systems or to the facility that could significantly affect the ability of the systems to accurately measure and record the requisite data 40 CFR 75

§75.20, 75.70(d), and 40 CFR 75 Appendix E Section 1.2 and Env-A 809, 3212.02, 3212.06, 3212.07, 3212.09, 3212.10 and 2910.04

31. MK1 & MK2 QA/QC

Requirements A) Pursuant to 40 CFR 75.21 (a)(1) and 40

CFR 75.70, the Permittee shall operate, maintain, and calibrate each CEMS according to the quality assurance and quality control procedures in 40 CFR 75 Appendix B. B) Pursuant to 40 CFR 75.21(b), the Permittee shall operate, calibrate, and maintain each COMS according to the procedures specified in the SIP, pursuant to 40 CFR 51 Appendix M. C) Pursuant to 40 CFR 75.21(c), the Permittee shall ensure that all calibration gases used to quality assure the operation of the instrumentation shall meet the definition in 40 CFR 72.2. D) Pursuant to 40 CFR 75.21(d) and (e), the Permittee shall comply with the provisions concerning consequences of audits and audit decertification. E) Within and prior to the ozone season, the Permittee shall meet the quality assurance requirements contained in 40 CFR 75.74, as applicable. As specified by regulation 40 CFR 75

§75.21, 75.70, and 75.74

32. MKCT1 & MKCT2 QA/QC

Requirements for Alternative Monitoring Systems The owner or operator shall comply with the

QA/QC procedures of 40 CFR 75 Appendix E and 40 CFR 75.74(c), as applicable. Pursuant to 40 CFR 75.74(b), the owner or operator may choose whether to meet the QA/QC requirements on an annual basis or an ozone season basis. Annually or

ozone season basis 40 CFR 75

§75.70(e) and 40 CFR 75 Appendix E and 40 CFR 75 §75.74(b) and (c)

### Proposed

PSNH – Merrimack Station Page 53 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite 33. MKCT1, MKCT2, MK1 & MK2 NOx Mass

Emissions – Petitions for Alternatives The owner or operator may submit a petition to

DES and EPA requesting an alterative to any requirement of 40 CFR 75 Subpart H. Such a petition shall meet the requirements of § 75.66 and any additional requirements established by Env-A 3200 or other applicable State or Federal NOx mass emission reduction program that adopts the requirements of 40 CFR 75 Subpart H. Pursuant to 40 CFR 75.70(h)(3)(i), the owner or operator filed a petition for an alternate monitoring method for MKCT1 and MKCT2 using Appendix E, which was approved by the USEPA and DES. Upon request by permittee 40 CFR 75

§75.70(h) and 40 CFR 75 Subpart E and 40 CFR 75 Appendix E & Env-A 3212.09

34. MKCT1, MKCT2 NOx Mass

EmissionsAlternative Monitoring System The owner or operator shall comply with the

provisions of 40 CFR 75 Appendix E and Env-A 3212.09 as an alternative to continuous emission monitoring system requirements. During the

ozone season 40 CFR 75

Appendix E and Env-A 3212.09

35. MKCT1, MKCT2 NOx Mass

Emissions – NOx Emission Rate and HeatInput– Oilfired Peaking Units The owner or operator of an affected unit that

qualifies as a peaking unit and as either gas-fired or oil-fired shall either: A) Meet the requirements of 40 CFR 75.71(c);

or B) Use the procedures in 40 CFR 75 Appendix D for determining hourly heat input and the procedure specified in 40 CFR 75 Appendix E for estimating hourly NOx emission rate. The heat input apportionment provisions in Section 2.1.2 of Appendix D shall not be used to meet the NOx mass reporting provisions of Subpart H. In addition, if after certification of an excepted monitoring system under Appendix E, the operation of a unit that reports emissions on an annual basis under 40 CFR 75.74(a) exceeds a capacity factor of 20.0 percent in any calendar year or exceeds an annual capacity factor of 10.0 percent averaged over 3 years, or the operation of a unit that reports emissions on an ozone season basis under 40 CFR 75.74(b) exceeds a capacity factor of 20.0 percent in any ozone season or exceeds an ozone season capacity factor of 10.0 percent averaged over three years, the owner or operator shall meet the requirements of 40 CFR 75.71(c) or, if applicable 40 CFR 75.71(e) by no later than December 31 of the following calendar year. As specified by regulation 40 CFR 75

§75.71(d)

### Proposed

PSNH – Merrimack Station Page 54 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite 36. MK1, MK2, MKCT1, MKCT2 NOx Mass

Emissions – Annual and Ozone Season Monitoring The owner or operator shall meet the

requirements of 40 CFR 75 Subpart H during the entire calendar year for MK1 and MK2 and on an ozone season basis except as specified for MKCT1 & MKCT2. During the calendar year for MK1 and MK2 and during the

ozone season for MKCT1 & MKCT2 40 CFR 75

§75.74(a) and (b)

37. MKCT1 & MKCT2 NOx RACT

Compliance Testing The owner or operator shall conduct stack

testing using US EPA Method 20 to determine the NOx emissions. The owner or operator shall monitor the NOx emissions by calculating the NOx emission rate in lb/MMBtu on a 24-hour calendar day average, lb/hr on a 24-hour calendar day average, and tons/consecutive 12- month period using the stack test results and actual operating hours. Once every 3 years and upon written request by DES and/or EPA Env-A

1211.13(f) Env-A 803.02(c)(formerly EnvA 1211.21) and 40 CFR 70.6 (a)(3)(i)(B)

38. MK1 & MK2 Ammonia slip

testing The owner or operator shall conduct stack

testing at a NOx emission rate, in lb/MMBtu, as specified by DES, using a DES-approved method to determine the ammonia slip. At least once every 5 years or upon request by DES and/or EPA 40 CFR 70.6

(a)(3)(i)(B)

39. MK1-PC3 & MK2-PC6 Ammonia

Consumption The owner or operator shall track ammonia

consumption daily and monthly using an ammonia flow meter installed with the SCR systems. Daily and monthly Temporary

Permits FP-T-0054 & TP-B-0462 40. MK1-PC1, MK1-PC2, MK2-PC4 & MK2-PC5 # of Fields

Out of Service for each ESP unit The owner or operator shall monitor on a daily

basis the total number of fields out of service for each electrostatic precipitator. Daily 40 CFR 70.6(a)(3)(i)(B)

41. MK1-PC1, MK1-PC2, MK2-PC4 & MK2-PC5 Inlet gas

temperature to each ESP The owner or operator shall continuously

monitor the outlet gas temperature of the ESP using a DES-approved monitoring system to ensure that the ESP does not exceed the manufacturer’s recommended temperature. Continuously 40 CFR 70.6 (a)(3)(i)(B)

42. Facility Wide Sulfur Content

of Liquid Fuels PSNH shall conduct testing in accordance with

appropriate ASTM test methods or obtain delivery tickets or other documentation from the fuel supplier to demonstrate compliance with the liquid fuel sulfur content limitations. For each delivery of liquid fuel to the facility Env-A 806.02,

Env-A 806.05, 40 CFR 60 Subpart Dc §60.42c(h)(1), §60.48c(f)(1), & §60.44c(h)

### Proposed

PSNH – Merrimack Station Page 55 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite 43. MK1 & MK2 Sulfur Content

of Bituminous Coal Documentation from the fuel supplier or testing

in accordance with appropriate ASTM test methods that certify the weight-percent of sulfur for each delivery of bituminous coal Each delivery of fuel Env-A 806.04

44. MKCT1, MKCT2, MKSCC, MKEG, MKEB Opacity USEPA Method 22 for visible emissions. If noticeable opacity is observed, USEPA Method 9 Monthly when the device is operating 40 CFR 70.6

(a)(3)(i)(B)

45. MKEG Operating

Hours The owner or operator shall maintain a log of the

operating hours of the emergency generator. Continuously 40 CFR 70.6 (a)(3)(i)(B) 46. MKPCC & MKSCC Coal

Throughput The owner or operator shall maintain records of

the monthly coal received and coal burned (coal throughput). Monthly 40 CFR 70.6 (a)(3)(i)(B) & State Permits to Operate No. PO-BP-2416 & 2417 47. MK1 & MK2 Coal Feed

Rate - Periodic Monitoring E Belt scales for MK1 and MK2 shall be

verified or calibrated once per year. Annually 40 CFR 70.6 (a)(3)(i)(B)

48. MK1 & MK2 TSP Testing The owner or operator shall conduct stack testing using US EPA Methods 1-5 or 1-4 and 17 or other method approved by DES to determine the TSP emissions. The owner or operator shall monitor the TSP emissions by calculating the TSP emission rate in lb/MMBtu on a 24-hour calendar day average and tons/consecutive 12-month period using stack test results and operating hours. The owner or operator may use other EPA-approved emission calculating methods to calculate TSP emissions. Testing at least once every 5 years and upon request by DES and/or EPA Env-A 802 &

40 CFR 70.6 (a)(3)(i)(B)

49. MK1 & MK2 PM 10 Testing The owner or operator shall conduct stack testing using US EPA Method 201a and 202, or other method approved by DES to determine PM 10 emissions. The owner or operator shall monitor the PM 10 emissions by calculating the PM 10 emission rate in tons/consecutive 12- month period using stack test results and operating hours. The owner or operator may use other EPA-approved emission calculating methods to calculate PM 10 emissions. Testing at least once every 5 years and upon request by DES and/or EPA Env-A 802 &

40 CFR 70.6 (a)(3)(i)(B)

### Proposed

PSNH – Merrimack Station Page 56 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite 50. MKEB Performance

Test Each time the owner or operator brings an

Emergency Boiler into the facility for operation, it is required to conduct an initial performance test as required by 40 CFR 60.8 for opacity, within 60 days of achieving maximum production rate or within 180 days of initial startup. Method 9 (6-minute average of 24 observations) shall be used for determining the opacity of stack emissions. Testing will be conducted at the maximum permitted operating rate, 520 gal/hr while firing No. 2 fuel oil, or 701 gal/hr while firing on-road low sulfur diesel fuel. Prior to the removal of Each Emergency Boiler installed 40 CFR 60

Subpart Dc §60.45c(a) & Env-A 802

51. MKEB Fuel flow

meter, recorder, & totalizer A) PSNH shall monitor or measure fuel oil

consumption of MKEB (in gallons per hour and total gallons per day) using a fuel flow meter. B) PSNH shall calibrate or verify the accuracy of the fuel flow meter in accordance with the manufacturers or suppliers recommendation or in a manner approved by DES at a frequency consistent with the manufacturers or suppliers recommendation, but at a minimum annually. Continuously Temporary Permit TP-B-0490

52. Facility wide Inventories of

Regulated Substances The owner or operator shall monitor the quantity

of regulated substances to ensure that the facility is in compliance with the requirements of 40 CFR 68. Continuously 40 CFR 68 and 1990 CAA Section 112(r)(1)

### Proposed

PSNH – Merrimack Station Page 57 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite 53. MK1 & MK2 Baseline

Mercury Input Baseline mercury input shall be determined as

follows: A) No later than August 1, 2006, and continuing for 12 months thereafter, a representative monthly sample of the coal used traditionally (not to include trial or test coal blends) by each affected source shall be collected from each of the units identified in b. below and analyzed to determine the average mercury content of the fuel for each unit expressed in pounds of mercury input per ton of coal combusted at each affected source. The mercury content of the coal derived from these analyses for each affected source shall be multiplied by the average annual throughput of coal for the period 2003, 2004, and 2005 (average tons of coal combusted per year) for each respective affected source to yield the average pounds of mercury input per year into each affected source. The sum of these annual input pound averages from each affected source shall equal the baseline mercury input. B) Determination of the mercury content of the coal shall follow appropriate ASTM testing procedures (ASTM D3684-01). For purposes of baseline mercury input determination, coal sampling shall occur at Merrimack Unit 1 and Unit 2, and at either Schiller Unit 4 or Unit 6, which shall serve to represent all Schiller units. At least 4 of the samples taken from each of these units shall correspond with the stack testing done at each of these units under RSA 125- O:14,II. As specified RSA 125- O:14,I. (State-Only Enforceable)

54. MK1 & MK2 Baseline

Mercury Emissions A) Pursuant to RSA 125-O:14,II, baseline

mercury emissions shall be determined based upon stack testing and DES approval. As specified in

statute RSA 125-

O:14,II. (State-Only Enforceable) 55. MK1 & MK2 Mercury

Emission Monitoring A) Prior to the availability and operation of

CEMS, and subsequent to the baseline emissions testing under RSA 125-O:14, II, stack tests or another methodology approved by DES shall be conducted twice per year to determine mercury emissions levels from the affected sources. Twice per year or until a mercury CEMS is in operation and approved by DES RSA 125-O:15

### Proposed

PSNH – Merrimack Station Page 58 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite B) Any stack tests performed shall employ a federally recognized and approved methodology, proposed by the Owner and employing a test protocol approved by DES. When a federal performance specification takes effect and a mercury CEMS capable of meeting the federal specifications becomes available, a mercury CEMS, approved by DES, shall be installed on MK1 and MK2 as deemed appropriate by DES. 56. MK2 SO 2 , NOx, 31

CO, PM, VOCs Emissions (tons/month and tons/ consecutive 12-month period) Pursuant to the 40 CFR 52.21 (b)(21)(v) (dated

July 1, 2002) 32 , for an electric utility steam generating unit (other than a new unit or the replacement of an existing unit), actual SO2, NOx, CO, PM, VOC emissions of the unit following the physical or operational change shall equal the representative actual annual emissions of the unit, provided PSNH maintains and submits to DES on an annual basis for a period of 5 years from the date the unit resumes regular operation, information demonstrating that the physical or operational change did not result in an emissions increase. A longer period, not to exceed 10 years, may be required by DES, if it determines such a period to be more representative of normal source post-change operations. Pursuant to 40 CFR 52.21(b)(33) (dated July 1, 2002), representative actual annual emission means the average rate, in tons per year, at which the source is projected to emit a pollutant for the two-year period after the physical change or change in the method of operation of a unit (or a different consecutive two-year period within 10 years after that change, where DES determines that such period is more representative of normal source operations), considering the effect any such change will have on increasing or decreasing the hourly emissions rate and on projected capacity utilization. In projecting future emissions, DES shall consider all relevant information, including Monthly 40 CFR 70.6 (a)(3)(i)(B) and 40 CFR 52.21 (b)(21) and (33), dated July 1, 2002

31 SO 2 and NOx emissions are monitored based upon CEM dat a and CO, PM, and VOC emissions are calculated usin g emission factors and fuel data. 32 See the letter dated January 31, 2008 from William H. Smagula, PSNH to Robert R. Scott, DES-Air Resou rces Division and the letter March 31, 2008 from Craig A. Wright, DES-Air Resources Division to William H. Smagula, PSNH con cerning conditional new source review applicability determination concernin g modifications at PSNH-Merrimack Station.

### Proposed

PSNH – Merrimack Station Page 59 97 River Road, Bow, NH TV-0055

Table 7 – Monitoring/Testing Requirements Item No. Device Parameter Method of Compliance Frequency of Method Regulatory

Cite but not limited to, historical operational data, th e company’s own representations, filings with the State or Federal regulatory authorities, and compliance plans under Title IV of the CAA; and exclude, in calculating any increase in emissions that results from the particular physical change or change in the method of operation at an electric utility steam generating unit, that portion of the unit’s emissions following the change that could have been accommodated during the representative baseline period and is attributable to an increase in projected capacity utilization at the unit that is unrelated to the particular change, including any increased utilization due to the rate of electricit y demand growth for the utility system as a whole. In order to calculate annual emissions as required pursuant to 40 CFR 52.21 (dated July 1, 2002), PSNH shall monitor emissions of SO2, NOx, CO, PM, and VOCs for a period of 5 years or more beginning in 2002. 57. MKEB NOx, SO2,

CO, PM10, and VOC emissions PSNH shall monitor the NOx, SO2, CO, PM10,

and VOC emissions (in tons/ consecutive 12- month period) by using appropriate AP-42 emission factors and actual fuel consumption. Monthly and consecutive 12- month period 40 CFR 70.6

(a)(3)(i)(B)

58. Facilitywide Stack Test For any compliance stack test, the owne r or operator must meet the stack testing requirements of Env-A 802, including but not limited to pre-test meeting, pre-test protocol, pre-test notice, scheduling change notifications, and stack test result submittals For each compliance stack test Env-A 802



### J. Recordkeeping Requirements

The Permittee is subject to the Recordkeeping requi rements as contained in Table 8 below:

### Proposed

PSNH – Merrimack Station Page 60 97 River Road, Bow, NH TV-0055

Table 8 – Applicable Recordkeeping Requirements 33



### Item No. Recordkeeping Requirement Frequency of Recordkeeping Applicable

Emission Unit Regulatory Cite

1. Record Retention: A) The Permittee shall retain the records required by this permit on file for a minimum of 5 years, except the certificate of representation for the designated representatives shall be kept beyond the 5- year period. 34 B) Pursuant to Env-A 4605.03(a), unless otherwise provided, the Owner or Operator of the CO 2 budget source and each CO 2 budget unit at the source shall keep on site each of the following documents for a period of 10 years from the date the document is created: 1) The account certificate of representation for the CO 2 AAR for the source and each CO 2 budget unit at the source and all documents that demonstrate the truth of the statements in the account certificate of representation prepared in accordance with Env-A 4604.05, provided that the certificate and documents shall be retained on site at the source beyond such 10-year period until such documents are superseded because of the submission of a new account certificate of representation changing the CO 2 AAR; 2) All emissions monitoring information, in accordance with Env-A 4609 and 40 CFR 75; 3) Copies of all reports, compliance certifications and other submissions andall records made or required under EnvA 4600; and 4) Copies of all documents used to complete a CO 2 budget permit application and any other submission under the CO 2 Budget Trading Program Minimum of 5 year retention of records as specified Facility Wide 40 CFR 

### § 72.9(f)(1), 40 CFR 

### § 75.57, 40 CFR 70.6(a)(3)(ii)(B), Env-A 3213, Env-A 902.01(a)(new), and Env-A 4605.03(a)

33 On April 23, 1999 DES promulgated new Env-A 900 rules to streamline the recordkeeping and reporting requirement sections of the New Hampshire Code of Administrative Rules. Un til such time that the new Env-A 900 rules are appr oved and adopted into the State Implementation Plan (SIP) by EPA, all Title V permits will be incorporating the old Env-A 900 ru les (which became effective on November 11, 1992), unless the new Env-A 900 rules are more stringent. These recordkeeping and report ing requirements shall fall under the Permit Shield provisions as contained in Section XIII of this permit.

34 Note that the record retention requirement for fiv e years contained in Env-A 902.01 and Env-A 3213 ar e more stringent than the three year record retention required in some sectio ns of 40 CFR 75.

### Proposed

PSNH – Merrimack Station Page 61 97 River Road, Bow, NH TV-0055

Table 8 – Applicable Recordkeeping Requirements 33



### Item No. Recordkeeping Requirement Frequency of Recordkeeping Applicable

Emission Unit Regulatory Cite

or to demonstrate compliance with the requirements of Env-A 4600. 2. Monitoring Plan and QA/QC Plan: A) The Permittee shall prepare and maintain a monitoring plan for the CEMS and COMS, which contains sufficient information to demonstrate that all unit SO 2 emissions, NOx emissions, CO 2 emissions and opacity are monitored and reported. B) The Permittee shall prepare and maintain monitoring plans for other approved monitoring methods, which contain sufficient information to demonstrate that all unit NOx emissions are monitored and reported. C) The Permittee shall update the monitoring plan whenever the Permittee makes a replacement, modification or change that could affect the CEMS or COMS or other approved monitoring method. D) The Permittee shall review the QA/QC plan and all data generated by its implementation at least once each year. E) The Permittee shall revise or update the QA/QC plan based on the results of the annual review by conducting the following: 1) Documenting any changes made to the CEM or the monitoring method or changes to any information provided in the monitoring plan; 2) Including a schedule of, and describing, all maintenance activities that are required by the CEM manufacturer or that might have an effect on the operation of the system; 3) Describing how the audits and testing required by this part will be performed; and 4) Including examples of the reports that will be used to document the audits and tests required by this part; 5) Make the revised QA/QC plan available for on-site review by the division at any time; and 6) Within 30 days of completion of the annual QA/QC plan review, certify in writing that the owner or operator will continue to implement the source’s Whenever a change occurs that could affect monitoring method or annually, whichever is more frequent MK1 & MK2,

MKCT1& MKCT2 40 CFR §75.53 (a),

(b), (e), and (f), §75.73(c), Env-A 808.04, Env-A 808.06, Env-A 3212.13, and Env-A 2910.09

### Proposed

PSNH – Merrimack Station Page 62 97 River Road, Bow, NH TV-0055

Table 8 – Applicable Recordkeeping Requirements 33



### Item No. Recordkeeping Requirement Frequency of Recordkeeping Applicable

Emission Unit Regulatory Cite

existing QA/QC plan or submit in writing any changes to the plan and the reasons for each change. F) The QA/QC plan shall be considered an update to the CEM monitoring plan required by Env-A 808.04. G) Pursuant to Env-A 3212.13(a) and Env-A 2910.09, the units subject to acid rain emission limitations (MK1 & MK2) shall comply with the requirements of 40 CFR 75.62, except the monitoring plan shall also include all of the information required by 40 CFR 75, Subpart H. H) Pursuant to Env-A 3212.13(b), a unit not subject to acid rain emission limitations (MKCT1 & MKCT2) shall comply with the requirements of 40 CFR 75.62, except the monitoring plan shall only include the information required by 40 CFR 75, Subpart H. I) Pursuant to 40 CFR 75.73(c)(3), the monitoring plan for a unit not subject to acid rain emission limitations (MKCT1 & MKCT2) shall include the provisions of 40 CFR 75.53(e)(1), 75.53(f)(1)(i), (f)(2)(i), and (f)(4) in electronic format and 40 CFR 75.53(e)(2), 75.53(f)(1)(ii), and (f)(2)(ii) in hardcopy format. J) For MK1 and MK2, the owner or operator shall determine the heat input rate (in mmBtu/hr) to each unit for every hour or part of an hour any fuel is combusted following the procedures in 40 CFR 75 Appendix F, Equation F-15 or other method approved by DES. 3. CEM, COMS and Other Approved Monitoring Methods Recordkeeping Requirements: A) The Permittee shall record and maintain the information required pursuant to 40 CFR 75.57, 75.58, 75.59, and 75.73(b), which includes the certification, quality assurance, and quality control records. B) The Permittee shall record and maintain CEMS and COMS records according to the most stringent requirements of Env-A 808 and 40 CFR 75. As specified by regulation MK1, MK2,

MKCT1, MKCT2 40 CFR §75.57,

75.58,75.59, and 75.73, Env-A 3212, Env-A 903.04 (a) (new), and Env-A 800

4. Sulfur Analysis Records for Liquid Fuel Oil The owner or operator shall maintain fuel For each delivery of liquid fuel to the MK1, MK2,

MKCT1, Env-A 806.05

(new) and

### Proposed

PSNH – Merrimack Station Page 63 97 River Road, Bow, NH TV-0055

Table 8 – Applicable Recordkeeping Requirements 33



### Item No. Recordkeeping Requirement Frequency of Recordkeeping Applicable

Emission Unit Regulatory Cite

delivery tickets for each shipment of fuel oil receeved. The deliver tickets shall be in a form suitable for inspection and available to the DES and/or EPA upon request. Each delivery ticket shall indicate the following: A) The name, address and telephone number of the fuel supplier; B) The type of fuel delivered; C) The quantity of fuel oil delivered; D) The date of delivery; and E) The maximum percent sulfur by weight of the fuel oil delivered. If the delivery tickets do not contain sulfur content of fuel delivered, the Permittee shall provide other documentation from the fuel supplier with the above information or a written statement or other documentation from the fuel supplier that the sulfur content of the fuel as delivered does not exceed state or federal standards for that fuel or perform testing in accordance with appropriate ASTM test methods to determine compliance with the sulfur content limitation provisions in Env-A 1604 for liquid fuel. facility MKCT2, MKEB, MKEG 40 CFR

70.6(a)(3)(ii)(A) and 40 CFR 60 Subpart Dc §60.48c(f)(1) (for MKEB)

5. Delivery Ticket and Sulfur Analysis Records for Coal: The permittee shall maintain delivery tickets from each coal supplier for each shipment of coal received. The delivery tickets shall be in a form suitable for inspection and available to the DES and/or EPA upon request. Each delivery ticket shall indicate the following: A) The name of the fuel supplier; B) The address of the fuel supplier; C) The telephone number of the fuel supplier; D) The type of fuel delivered; E) The quantity of coal delivered; F) The date of delivery; G) The maximum percent sulfur by weight of the coal delivered or the lb sulfur/MMBtu of coal; H) Identification of the mine from which the coal originated; I) The weight percent ash content of the coal; and J) The gross heat content of the coal (Btu per pound). If the delivery tickets do not contain sulfur Each delivery of Coal MK1 & MK2 Env-A 806.05 (new) & 40 CFR 70.6(a)(3)(ii)(A)

### Proposed

PSNH – Merrimack Station Page 64 97 River Road, Bow, NH TV-0055

Table 8 – Applicable Recordkeeping Requirements 33



### Item No. Recordkeeping Requirement Frequency of Recordkeeping Applicable

Emission Unit Regulatory Cite

content of fuel delivered, the Permittee shall provide other documentation from the fuel supplier with the above information or perform testing in accordance with appropriate ASTM test methods to determine compliance with the sulfur content limitation provisions in Env-A 1606 for solid fuels. 6. Solid Fuel Utilization Records: The Permittee shall maintain the following monthly records or records for an alternative period as approved by DES in accordance with Env-A 912, of the bituminous coal characteristics and utilization: A) Fuel consumption; B) Fuel type; C) Ash content; D) Sulfur content as percent sulfur by weight of fuel and pounds per million Btu gross heat content; and E) Btu content per pound of fuel. Monthly or alternative period as approved by DES in accordance with Env-A 912 MK1 & MK2 Env-A 903.03(a)(1) (formerly Env-A 901.03(a)(2))

7. Liquid Fuel Utilization Records: The Permittee shall maintain the following monthly records or records for an alternative period as approved by DES in accordance with Env-A 912, of the liquid fuel characteristics and utilization by device: A) Fuel consumption; B) Fuel type; C) Viscosity (based on generally accepted values); D) Sulfur content as percent sulfur by weight of fuel; E) Btu content per gallon of fuel; and F) Hours of operation of each fuel combustion device while operating with each type of liquid fuel, so the distribution of fuel among each combustion device can be estimated. Monthly or alternative period as approved by DES in accordance with Env-A 912 MK1, MK2,

MKCT1, MKCT2, MKEB, MKEG Env-A 903.03(a)(3)

and (b) (formerly Env-A 901.03(a)(1) and (c))

8. General Recordkeeping Requirements for Process Operations: Keep monthly records of raw material utilization (coal) for each of the crusher systems and coal fed to MK1 and MK2. Monthly and consecutive 12 month periods MKPCC,

MKSCC, MK1, MK2 Env-A 903.02 &

State Permits to Operate PO-BP-2416 & PO-BP-2417

### Proposed

PSNH – Merrimack Station Page 65 97 River Road, Bow, NH TV-0055

Table 8 – Applicable Recordkeeping Requirements 33



### Item No. Recordkeeping Requirement Frequency of Recordkeeping Applicable

Emission Unit Regulatory Cite

9. General NOx Recordkeeping Requirements: The Permittee shall record and maintain the following information for fuel burning devices: A) Facility information, including the following: 1) Source name; 2) Source identification; 3) Physical address; and 4) Mailing address. B) Identification of fuel burning devices; C) Operating schedule for each fuel burning device identified in Condition B) above: 1) Days per calendar week during the normal operating schedule; 2) Hours per day during the normal operating schedule and for a typical ozone season day; and 3) Hours per year during the normal operating schedule. D) Type and amount of fuel burned for each fuel-burning device during normal operating conditions and for a typical ozone season day, if different from normal operating conditions, on an hourly basis in mmBtu/hr. E) Theoretical potential NOx emissions for the calculation year for each fuel burning device: 1) Annual emissions, in tons per year; and 2) Typical ozone season day emissions, in pounds per day. F) Actual NOx emissions for each fuel burning device: 1) Annual emissions, in tons per year; and 2) Typical ozone season day emissions, in pounds per day. G) Emission factors and the origin of the emission factors used to calculate the NOx emissions. Annually and as applicable MK1, MK2,

MKCT1, MKCT2, MKEB, MKEG Env-A 905.02

(formerly Env-A 901.08(c)(1)-(5))

### Proposed

PSNH – Merrimack Station Page 66 97 River Road, Bow, NH TV-0055

Table 8 – Applicable Recordkeeping Requirements 33



### Item No. Recordkeeping Requirement Frequency of Recordkeeping Applicable

Emission Unit Regulatory Cite

10. Recordkeeping Requirements for Sources or Devices with Add-On NOx Air Pollution Control Equipment: The Permittee shall record and maintain the following information: A) Air pollution control device identification number, type, model number, and manufacturer; B) Installation date; C) Unit(s) controlled; D) Type and location of the capture system, capture efficiency percent, and method of determination; E) Emission test results, including inlet NOx concentration (ppm), outlet NOx concentration (ppm), method of concentration determination, and date of determination; F) Information as to whether the air pollution control device is always in operation when the fuel burning device it is serving is in operation; and G) Destruction or removal efficiency of the air pollution control equipment, including the following information: 1) Destruction or removal efficiency, in percent; 2) Current primary and secondary equipment control information codes from EPA AIRS Air Facility Subsystem List for each piece of control equipment; 3) Date tested; and 4) Method of determining destruction or removal efficiency, if not tested. Maintain at the facility at all times MK1 & MK2 Env-A 905.03 (formerly Env-A 901.08(c)(6))

11. Boiler Operating Hour Records: The owner or operator shall maintain a log to record the number of hours of operation of MK1 and MK2 each month. This log may be part of the existing work management system. Monthly MK1 & MK2 Env-A 906 & Temporary Permits FP-T-0054 & TP-B-0462

12. Emergency Generator Operating Records: The owner or operator shall record and maintain monthly and consecutive 12-month records of the operating hours of the emergency generator. Monthly and consecutive 12- month periods MKEG Env-A 906 & State Permit to Operate PO-B-1788

### Proposed

PSNH – Merrimack Station Page 67 97 River Road, Bow, NH TV-0055

Table 8 – Applicable Recordkeeping Requirements 33



### Item No. Recordkeeping Requirement Frequency of Recordkeeping Applicable

Emission Unit Regulatory Cite

13. Coal Crusher Records: The Permittee shall maintain the following information, which may be included in the facility work management system: A) The monthly visible emission observation results for the secondary crusher; B) A log of repairs made to the coal crusher enclosure. The log shall include the following: 1) The date a problem was observed; 2) The date of the repair; 3) A description of the problem; and 4) The corrective actions taken. Monthly for visible emission observation records and for each occurrence for repairs MKPCC &

MKSCC State Permits to

Operate No. POBP-2416 & PO-BP2417

14. Certificate of Representation: The Permittee shall complete and retain a certificate of representation for a designated representative or an alternate designated representative including the elements pursuant to 40 CFR 72.24, Certificate of representation

. Maintain at the facility at all times MK1 & MK2 40 CFR 

### § 72.24

15. Regulated Toxic Air Pollutant Records: The Permittee shall maintain records in accordance with the applicable method used to demonstrate compliance pursuant to Env-A 1405. Maintain at facility at all times All devices

subject to RSA 125-I and Env-A 1400 Env-A 902.01 (c)

State-Only Enforceable

### Proposed

PSNH – Merrimack Station Page 68 97 River Road, Bow, NH TV-0055

Table 8 – Applicable Recordkeeping Requirements 33



### Item No. Recordkeeping Requirement Frequency of Recordkeeping Applicable

Emission Unit Regulatory Cite

16. Monitoring Records : The Permittee shall maintain records of monitoring results as specified in Table 7 of this Permit including the following: A) Visible emission/opacity test results for the MKSCC, MKCT1, and MKCT2; B) NOx , SO 2 , CO 2 , and continuous emissions monitoring data for MK1 & MK2; C) Continuous opacity monitoring data for MK1 & MK2; D) Stack volumetric flow rate (in kscfm) for MK1 & MK2; E) Outlet temperature of each ESP; F) Daily and monthly ammonia consumption of each SCR; G) Coal throughput for the MKPCC & MKSCC (primary and secondary coal crushers); H) Net electrical output; I) Coal E Belt scale calibrations/verifications for MK1 and MK2;J) Quantities of regulated substances facilitywide; K) Monthly and consecutive 12-month NOx, SO2, CO, PM10, and VOC emissions from MKEB; and L) Daily NOx emissions for MKCT1 and MKCT2 in lb/MMBtu and lb/hr, and monthly NOx emissions in tons/month and the tons/consecutive 12-month period using the stack test results and operating hours. Maintain at facility at all times As specified for

each monitoring record 40 CFR

70.6(a)(3)(ii)

17. Operating Scenario Records: PSNH shall maintain a record of the scenarios under which it is operating. PSNH shall specify whether operation is under normal conditions or an alternative operating scenario listed in Section VII. PSNH shall specify which alternative operating scenario is in use. Whenever operation method changes from normal operation to a specific alternative operating scenario Facility wide 40 CFR 70.6 (a)(9)

18. Multi-pollutant Budget and Trading Program Recordkeeping Requirements: The permittee shall comply with the recordkeeping requirements of the multi-pollutant budget and trading program. As required by the rule MK1 & MK2 Env-A 2900 State-Only Enforceable

19. On an hourly and daily basis, the owner or operator shall record fuel consumption for each fuel type, in gallons per hour and totalized gallons per day.. Hourly and daily MKEB 40 CFR 60 Subpart Dc §60.48c(g)

### Proposed

PSNH – Merrimack Station Page 69 97 River Road, Bow, NH TV-0055

Table 8 – Applicable Recordkeeping Requirements 33



### Item No. Recordkeeping Requirement Frequency of Recordkeeping Applicable

Emission Unit Regulatory Cite

20. The owner or operator shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the Emergency Boiler. For each occurrence MKEB 40 CFR 60 Subpart A §60.7(b)

21. The owner or operator shall maintain a file of all fuel flow (gal/hr) and totalizer measurements (gal/day) for the Emergency Boiler; all fuel flow meter and totalizer calibration checks; adjustments and maintenance performed on these systems or devices; and all other information required by this part recorded in a permanent form suitable for inspection. Maintain at facility at all times MKEB 40 CFR 60 Subpart A §60.7(f)

22. Representative Actual Annual Emissions Test Recordkeeping Requirements: PSNH shall maintain records of SO2, NOx, CO, PM, and VOC emissions in tons/month and tons per consecutive 12-month period for MK1 and MK2. Monthly and consecutive 12- month period MK2 40 CFR 52.21(b)(21) and (33), dated July 1, 2002 and 40 CFR 70.6(a)(3)(ii) and Env-A 906 23. ESP Monitoring Records: The owner or operator shall maintain the following records for each ESP: A) Fields out of service for each ESP unit, B) The time the field stopped operating, C) The reason for the field being out of service, D) The time the field was returned to service, and E) Corrective actions taken to return the field to service. Daily MK1-PC1, MK1-PC2, MK2-PC4 & MK2-PC5 40 CFR

70.6(a)(3)(ii)

### Proposed

PSNH – Merrimack Station Page 70 97 River Road, Bow, NH TV-0055

Table 8 – Applicable Recordkeeping Requirements 33



### Item No. Recordkeeping Requirement Frequency of Recordkeeping Applicable

Emission Unit Regulatory Cite

24. VOC Recordkeeping Requirements The owner or operator shall record and maintain the following information at the facility: A) Facility information, including the following: 1) Source name; 2) Source identification; 3) Physical address; 4) Mailing address; B) Identification of each VOC emitting device or process except the following: 1) Processes or devices associated with non-core activities and 2) Processes processes or devices emitting exempt VOCs. C) Operating schedule information for each VOC emitting device/process identified in B) above, including the following: 1) Days of operation per calendar week during the normal operating schedule; 2) Hours of operation per day during normal operating schedule and for a typical high ozone day, if different from the normal operating schedule; and 3) Hours of operation per year under normal operating conditions; D) The following VOC emissions data for each VOC-emitting process/device identified in B) above: 1) Annual theoretical potential emissions, in tons per year and during a typical day during the high ozone season of each, in pounds per day; 2) Applicable emission factors, if used to calculate emissions and origin of the emission factors; and 3) Actual emissions from each VOCemitting device or process identified in B) above, in tons per year and a typical day during the high ozone season in pounds per day. Annually and as applicable MK1, MK2,

MKCT1, MKCT2, MKEB, MKEG Env-A 904.02

(formerly 901.06

### Proposed

PSNH – Merrimack Station Page 71 97 River Road, Bow, NH TV-0055

K. Reporting Requirements

The Permittee is subject to the federally enforceab le reporting requirements identified in Table 9 below:

Table 9 – Applicable Reporting Requirements Item No. Reporting Requirement Frequency of Reporting Applicable

Emission Unit Regulatory

Cite

1. CEMS Recertification Notifications and Reports: A) The Permittee shall notify EPA and DES by telephone or in writing and not later than 21 days prior to the first scheduled day of full recertific ation testing and at least 7 calendar days prior to the f irst scheduled day of partial recertification testing (w hen all of the tests are not required). In emergency situations when equipment fails with lost data, the Permittee may provide notice within 2 business days following the date when testing is scheduled. If t he testing is rescheduled, the Permittee may notify DE S and EPA by telephone or other means within 2 business days prior to the scheduled test date or t he revised test date, whichever is earlier. B) Within 45 calendar days after completing all recertification tests, the Permittee shall submit t o EPA and DES the electronic and hardcopy information contained in 40 CFR 75.63. C) Pursuant to Env-A 3212.14 and Env-A 2910.10, the permittee shall submit an application to DES within 45 days after completing all initial certification or recertification tests including the information req uired under 40 CFR 75, Subpart H. D) Pursuant to Env-A 2910.07, the permittee shall also submit written notification required pursuant to 40 CFR 75.61 to the ATS administrator. 7 days prior to partial recertification, 21 days prior to full recertification, and 45 days after all recertification

tests 35 MK1 &

MK2 40 CFR



### § 75.61 (a)(1), 75.70, 75.63, and 75.73(d) and Env-A 3212 and 2910

2. Relative Accuracy Test Audit (RATA) Notification and Reports: A) The Permittee shall submit written notice to DES no later than 21 calendar days prior to the first sche duled day of testing. If the testing is rescheduled, the Permittee may notify DES by telephone or other means no later than 24-hours in advance of the new 21 calendar days prior to RATA MK1 &

MK2 40 CFR



### § 75.61 (a)(5), 

### § 75.73(d), Env-A 3212.11, Env-A 2910, Env-A 808.05, and

35 For Items 1, 2, and 3, PSNH – Merrimack Station sh all comply with the more stringent notification and reporting requirements specified in Env-A 800 instead of those specified i n 40 CFR 75, with the exception of notification and /or reporting required by Env-A 2900 or Env-A 3200 which shall be done at the frequ encies specified in 40 CFR 75. Env-A 808 requires at least 30 days notification to DES prior to the scheduled date of a CEM certifi cation, Relative Accuracy Test Audit, or Performanc e Specification testing and requires that the final report for the CEM certific ation and the RATA be submitted 30 days following t he end of the quarter and for the Performance Specification Testing be submitted 30 d ays after completion of the testing.

### Proposed

PSNH – Merrimack Station Page 72 97 River Road, Bow, NH TV-0055

Table 9 – Applicable Reporting Requirements Item No. Reporting Requirement Frequency of Reporting Applicable

Emission Unit Regulatory

Cite

testing date. Pursuant to Env-A 808.07, PSNH shall notify DES at least 30 days prior to the performanc e of the RATA. DES shall require rescheduling of the RATA if staff necessary to observe the RATA are not available. B) If requested, the Permittee shall submit the qualit y assurance RATA reports to EPA and DES by the later of 45 days after completing a quality assurance RATA or 15 days of receiving the request. C) Pursuant to Env-A 2910.07, the permittee shall also submit written notification required pursuant to 40 CFR 75.61 to the ATS administrator. Env-A 808.07(c) and (d)

3. CEMS Performance Specification Testing Reports: A) DES shall be notified of the date or dates of the performance specification testing at least 30 days prior to the scheduled dates. B) The owner or operator shall submit to DES a written report summarizing the testing within 30 days of th e completion of the test. 30-day notice to DES prior to test; test report to DES 30 days after the test MK1 &

MK2 Env-A 808.05

4. CEMS General Audit Notification Requirements: The owner or operator shall notify DES at least 2 weeks prior to any planned audit or test procedure except for R ATAs, where the owner or operator shall provide at least 30 days notice prior to the performance of the RATA. 2 weeks prior to any planned audit or test procedure and at least 30 days prior to the RATA. MK1 &

MK2 Env-A 808.07(c)

and (e)

### Proposed

PSNH – Merrimack Station Page 73 97 River Road, Bow, NH TV-0055

Table 9 – Applicable Reporting Requirements Item No. Reporting Requirement Frequency of Reporting Applicable

Emission Unit Regulatory

Cite

5. Monitoring and QA/QC Plan Submittals: A) Electronic copy: The Owner or Operator shall submit a complete, electronic, up-to-date monitoring plan to EPA and DES as follows: 1) No later than 21 days prior to the initial certific ation tests; 2) At the time of recertification application submissi on; 3) In each electronic quarterly report (Item #6 of Tab le 11); and

4) Whenever an update of the electronic monitoring pla n information is required under 40 CFR 75.53(b).

B) Hardcopy: The Owner or Operator shall submit all of the hardcopy information required by 40 CFR 75.53 to EP A and DES prior to initial certification. Thereafter, the Owner or Operator shall submit hardcopy information only if that portion of the monitoring plan is revised. The Owner or Operator shall submit the required hardcop y information as follows: no later than 21 days prior to the initial certification test; with any certification or recertification application, if a hardcopy monitori ng plan change is associated with the certification or rece rtification event; and within 30 days of any other event with w hich a hardcopy monitoring plan change is associated, purs uant to 40 CFR 75.53(b). Electronic submittal of all monito ring plan information, including hardcopy portions, is permissible provided that a paper copy of the hardc opy portions can be furnished upon request.

C) Contents: The monitoring plan shall contain the information specified in 40 CFR 75.53.

D) Format: The designated representative shall submit each monitoring plan in a format specified by EPA. As specified MK1, MK2, MKCT1, & MKCT2 40 CFR 

### § 75.62,



### § 75.73(d) and (e), Env-A 808.04, Env-A 808.06, Env-A 3212, and Env-A 2910

6. Quarterly Reports: A) The Permittee shall submit to DES and EPA in electronic format or other format as approved by DE S and/or EPA 30 calendar days after the end of the calendar quarter the information contained in 40 CF R 75.64(a), 40 CFR 75.73(f), 40 CFR 75.74, Env-A 2912, Env-A 3212, Env-A 3214, Env-A 808.11(new), and Env-A 808.13 (new) and the following information: 1) Opacity, SO 2 , NOx, and CO 2 emissions as calculated by the CEMS. 2) The 24-hour averages of the following shall be reported, whether or not an excess emission has occurred: 30 calendar days after the end of the calendar quarter MK1, MK2, 40 CFR §75.64, §75.73(f), §75.57(f), §75.74, 40 CFR 70.6(a)(3)(iii), Env-A 2910, Env-A 2911, Env-A 3212, Env-A 3214, Env-A 808.11(new), Env-A 808.13 (new) & Temporary

### Proposed

PSNH – Merrimack Station Page 74 97 River Road, Bow, NH TV-0055

Table 9 – Applicable Reporting Requirements Item No. Reporting Requirement Frequency of Reporting Applicable

Emission Unit Regulatory

Cite

a. SO 2 lb/mmBtu, SO 2 ppm, and SO 2 lb/hr; b. NOx lb/mmBtu, NOx ppm, and NOx lb/hr;

c. Percent CO 2 and CO 2 lb/hr as measured by continuous monitor/recorder; d. Stack volumetric flow rate (in kscfm);

e. Load (in MW); f. Steam flow (in klbs/hr);

g. Heat input (mmBtu/hr); h. Opacity (in percent); i. Fuel flow (in tons/day); j. Hours of operation (in hours/day); and k. Ammonia usage (in gallons/day). 3) Excess emission data recorded by the CEM system, including the following:

a. The date and time of the beginning and ending of each of excess emissions; b. The magnitude of each excess emission;

c. The specific cause of the excess emission; and d. The corrective action taken. 4) If no excess emissions have occurred, a statement to that effect; 5) For gaseous emission monitoring systems, the daily averages of the measurements made and emissions rates calculated. 6) A statement as to whether the CEM system was inoperative, repaired, or adjusted during the reporting period; 7) If the CEM system was inoperative, repaired, or adjusted during the reporting period, the following information:

a. The date and time of the beginning and ending of each period when the CEM was inoperative; b. The reason why the CEM was not operating;

c. The corrective action taken; and d. The percent data availability calculated in accordance with Env-A 808.10 for each flow, diluent, or pollutant analyzer in the CEM system; 8) The date and time beginning and ending each period when the source of emissions which the CEM system is monitoring was not operating; 9) When calibration gas is used, the following information:

a. The calibration gas concentration; b. If a gas bottle was changed during the Permits TP-B0462 & TP-B-- 0054

### Proposed

PSNH – Merrimack Station Page 75 97 River Road, Bow, NH TV-0055

Table 9 – Applicable Reporting Requirements Item No. Reporting Requirement Frequency of Reporting Applicable

Emission Unit Regulatory

Cite

quarter: i) The date of the calibration gas bottle change; ii) The gas bottle concentration before the change; and iii) The gas bottle concentration after the change; and

c. The expiration date for all calibration gas bottles used. 10) Excess emissions of SO 2 shall be defined as an annual SO 2 emission, which exceeds the state acid rain emission limitation, as calculated from CEM data. B) The designated representative shall affirm that the component/system identification codes and formulas in the quarterly electronic reports represent curre nt operating conditions. C) The designated representative shall submit a certification in support of each quarterly emission s monitoring report based on reasonable inquiry of those persons with primary responsibility for ensur ing that all of the unit's emissions are correctly and fully monitored. D) The certification shall indicate whether the monitoring data submitted were recorded in accordance with the applicable requirements of this part including the quality control and quality assurance procedures and specifications of 40 CFR 75, and any such requirements, procedures and specifications of an applicable excepted or approve d alternative monitoring method. E) For a unit with add-on emission controls, the designated representative shall also include a certification, for all hours where data are substit uted following the provisions of 40 CFR 75.34(a)(1), tha t the add-on emission controls were operating within the range of parameters listed in the monitoring pl an and that the substitute values recorded during the quarter do not systematically underestimate SO 2 or NOx emissions, pursuant to 40 CFR 75.34. F) For a unit that is reporting on a control period ba sis, the designated representative shall also include a certification that the NOx emission rate and NOx concentration values substituted for missing data under 40 CFR 75 Subpart D are calculated using only values from a control period and do not systematica lly underestimate NOx emissions.

### Proposed

PSNH – Merrimack Station Page 76 97 River Road, Bow, NH TV-0055

Table 9 – Applicable Reporting Requirements Item No. Reporting Requirement Frequency of Reporting Applicable

Emission Unit Regulatory

Cite

G) Pursuant to Env-A 3212.15(e) and Env-A 2910.11(a)(3), the quarterly reports shall be submi tted in the manner specified in 40 CFR 75, Subpart H and 40 CFR 75.64. H) Pursuant to Env-A 3212.15(f) and Env-A 2910.11(a)(4), for MK1 & MK2, the quarterly reports shall include all of the data and information requi red in 40 CFR Subpart H and 40 CFR Subpart G. I) Pursuant to Env-A 3214.01 and Env-A 2911.01, the owner or operator shall also submit emissions and operations information in electronic format as part of the quarterly reports. J) Pursuant to Env-A 3214.02, the owner or operator shall also submit to the NETS administrator in the quarterly reports, NOx emissions in lb/hr for every hour during the control period and cumulative quarterly and seasonal NOx emission data in pounds. K) Pursuant to Env-A 2911.02, the owner or operator shall also submit to the ETS administrator in the quarterly reports, SO 2 , NOx and CO 2 emissions in lb/hr for every hour during the year and cumulative quarterly and annual SO 2 , NOx and CO 2 emissions data in pounds. 7. Excess Emissions Requirements If either of these devices has excess emissions of NOx or SO2 in any calendar year, then the owner or operato r shall submit a proposed offset plan, as required under 40 CFR 77. The owner or operator of an affected source th at has excess emissions in any calendar year shall: A) Pay without demand the penalty required, and pay upon demand the interest on that penalty, as requir ed by 40 CFR 77.6; and B) Comply with the terms of an approved offset plan, a s required by 40 CFR 77.3. Within 60 days after the end of any calendar year where a unit has excess emissions of sulfur dioxide or nitrogen oxide MK1 &

MK2 40 CFR 

### § 72.9(e)

8. Offset Plans for Excess SO 2 Emissions : The Permittee shall submit an offset plan no later than 60 days a fter the end of any calendar year during which a unit has ex cess SO 2 emissions. The offset plan shall contain the information pursuant to 40 CFR 77.3. Within 60 days after the end of any calendar year where a unit has excess emissions of sulfur dioxide MK1 &

MK2 40 CFR 

### § 77.3

### Proposed

PSNH – Merrimack Station Page 77 97 River Road, Bow, NH TV-0055

Table 9 – Applicable Reporting Requirements Item No. Reporting Requirement Frequency of Reporting Applicable

Emission Unit Regulatory

Cite

9. Quarterly Audit Reports: Pursuant to Env-A 808.07 (new), the Permittee shall submit to DES, a written summary report of the results of all required audit s that were performed in that quarter, in accordance with the following: A) For gaseous CEM audits, the report format shall conform to that presented in 40 CFR 60, Appendix F, Procedure 1, Section 7; and B) For opacity CEM audits, the report format shall conform to that presented in EPA-600/8-87-025, April 1992, “Technical Assistance Document: Performance Audit Procedures for Opacity Monitors.” Quarterly, no later than 30 calendar days after the end of the quarter for which reporting is required MK1 &

MK2 Env-A 808.07

(new)

10. Net Thermal and Electrical Output Reporting: The facility shall report the net thermal and electrica l output of each affected source for each month of the calendar year to DES. Annually (no later than April 15 th of the following year) MK1, MK2,

MKCT1, & MKCT2 Env-A

2906.05(g) & Env-A 3207.04(h) 11. Coal Quarterly Reports: Quarterly reports shall be submitted to DES, which include the following information for each coal shipment. The data shall be summarized on a monthly basis. Submittal of the “Monthly Report of Cost and Quality of Fuel for Ele ctric Plants”, will satisfy the requirements of this cond ition. A) The shipment date; B) The weight of coal received in tons; C) Identification of the mine from which the coal came from; D) The ash content in weight percent of the coal; E) The sulfur lb/mmBtu content of coal or the weight percent of sulfur in the coal; and F) The gross heat content of the coal in Btu/lb. Within 30 days after each calendar quarter MK1 &

MK2 Env-A 910 &

Temporary Permits FP-T-0054 & TP-B-0462

### Proposed

PSNH – Merrimack Station Page 78 97 River Road, Bow, NH TV-0055

Table 9 – Applicable Reporting Requirements Item No. Reporting Requirement Frequency of Reporting Applicable

Emission Unit Regulatory

Cite

12. Performance Test Reports : The Permittee shall submit a report to DES documenting the results of the compli ance stack emission test. The compliance stack emission test report shall contain the following information: A) All the information required for the pre-test proto col as described in Env-A 802.04; B) All test data; C) All calibration data; D) Process data agreed by DES and the Permittee to be collected; E) All test results; F) A description of any discrepancies or problems that occurred during testing or sample analysis; G) An explanation of how discrepancies or problems were treated and their effect on the final results; and H) A list and description of all equations used in the test report, including sample calculations for each equation used. No later than 60 days after a performance test Facility wide Env-A 802.11 (new)

13. Quarterly Fuel Usage Report: Monthly fuel usage information by device, fuel type, and sulfur conten t shall be submitted in writing to the DES. Within 30 days after the end of a calendar quarter MK1, MK2,

MKCT1, MKCT2 Env-A 910 &

Temporary Permits FP-T-0054 & TP-B-0462 and Env-A 907.02 State-Only Enforceable 14. NOx Reporting Requirements: The Permittee shall submit reports of the NOx records kept pursuant to the Section VIII. I. Table 10. Annually (no later than April 15 th of the following year) MK1, MK2,

MKCT1, MKCT2, MKEG, & MKEB Env-A 909.03

(formerly Env-A 901.09)

15. Ammonia Consumption of SCR Systems: Submit monthly ammonia consumption for each SCR System (MK1-PC3 and MK2-PC6) during the calendar year. Annually (no later than April 15 th of the following year) MK1-PC3 &

MK2-PC6 40 CFR

70.6(a)(3)(iii) & Temporary Permits FP-T-0054 & TP-B-0462 16. Regulated Toxic Air Pollutant Reports: The Permittee shall report actual emissions speciated by individu al regulated toxic air pollutants, including a breakdo wn of VOC emission compounds. Annually (no later than April 15 th of the following year) All devices

subject to RSA 125-Iand Env1400 Env-A 907.01

(new) State-Only Enforceable

### Proposed

PSNH – Merrimack Station Page 79 97 River Road, Bow, NH TV-0055

Table 9 – Applicable Reporting Requirements Item No. Reporting Requirement Frequency of Reporting Applicable

Emission Unit Regulatory

Cite

17. Semi-Annual Permit Deviation/Monitoring Reports: The Permittee shall submit a permit deviation/monitorin g report of the data specified in Table 9 of this Per mit every 6 months

. All required reports must be certified by a responsible official consistent with 40 CFR 70.5(d) . The report shall contain a summary of the following information, unless this information was provided t o DES pursuant to another requirement: A) Visible emission/opacity test results; B) Summary showing monthly average sulfur content of the liquid and solid fuels from testing and/or deli very ticket and/or other documentation certifications fo r liquid and solid fuel sulfur content; C) Fuel consumption for all combustion devices except for MK1 & MK2; D) Coal throughput for the coal crushers; E) Any fields out of service in any of the ESP’s durin g the reporting period, including the time the field stopped operating, the reason for the field being o ut of service, the time the field was returned to serv ice, and any corrective action taken; and F) All instances of deviations from Permit requirement s. Semiannually (by July 31 st

and January 31 st

of each calendar year) Facility wide 40 CFR 70.6(a)(3)(iii)(A)

18. ESP Reports: A) Within 24 hours of discovery of more than 7 fields out of service on MK1-PC1 and MK1-PC2 combined, the owner or operator shall notify (e.g., via call or email, etc.) DES on the next business day of the number of fields out of service in any of the ESPs. B) Within 24 hours of discovery of more than 8 fields out of service on MK2-PC4 and MK2-PC5 combined, the owner or operator shall notify (e.g., via call or email, etc.) DES on the next business day of the number of fields out of service in any of the ESPs. Each occurrence MK1-PC1, MK1-PC2, MK2-PC4 & MK2-PC5 40 CFR 70.6

(a)(3)(iii)(B)

19. Prompt Reporting of Permit Deviations: The Permittee shall promptly report deviations from permit requir ements by phone, fax or e-mail in accordance with Section XXVIII of this permit and Env-A 911 (new). Within 24 hours of discovery of

occurrence Facility wide Env-A 911 & 40 CFR 70.6 (a)(3)(iii)(B)

20. Certification by the Designated Representative or t he Alternate Designated Representative: Any document submitted under the Acid Rain program shall be sign ed and certified by the designated representative or t he alternate designated representative and include the statements pursuant to 40 CFR 72.21 (a)(1) and (2). With each submittal MK1 &

MK2 40 CFR §72.21

### Proposed

PSNH – Merrimack Station Page 80 97 River Road, Bow, NH TV-0055

Table 9 – Applicable Reporting Requirements Item No. Reporting Requirement Frequency of Reporting Applicable

Emission Unit Regulatory

Cite

21. Certification by a Responsible Official: Any application form, report, or compliance certification submitted to the DES and/or EPA shall contain certification by a responsible official of truth, accuracy, and comple teness as outlined in Section XXI.B of this permit. With each submittal Facility wide 40 CFR 70.5 (d)

22. Emissions Reporting and Emissions Fees: The Permittee shall submit reports of actual emissions of all sig nificant and insignificant activities and payment of emissi onsbased fees in accordance with Env-A 700 and Section XXIII of this permit. Quarterly payment on the 15 th day of the 2 nd quarter after actual emissions occurred; Reporting of actual annual emissions done annually by April 15 th the following year Facility wide Env-A 907.01 (new) & Env-A 705.03 & 705.04

23. NOx Budget Program Annual Compliance Certification: For each control period (May 1 to September 30 of e ach year), the AAR for each budget source shall submit an annual compliance certification to DES containing t he information specified in Env-A 3216.03. November 30 th

each calendar

year MK1, MK2,

MKCT1, MKCT2 Env-A 3216

State-Only Enforceable

24. Multi-pollutant Budget and Trading Program Annual Compliance Certification: The Permittee shall submit an annual compliance certification to DES for the prio r year containing all of the information listed in Env-A 2913.03(a) through (e). By January 30 th of each year, beginning in 2007 MK1 &

MK2 Env-A 2913.01,

2913.02, & 2913.03 State-Only Enforceable 25. Annual Title V Compliance Certification: The Permittee shall submit an annual compliance certification in accordance with Section XXI of this permit. Annually (no later than April 15 th of the following year) Facility wide 40 CFR 70.6(c)(1)

### Proposed

PSNH – Merrimack Station Page 81 97 River Road, Bow, NH TV-0055

Table 9 – Applicable Reporting Requirements Item No. Reporting Requirement Frequency of Reporting Applicable

Emission Unit Regulatory

Cite

26. NSPS Subpart Dc Initial Notification Requiremen ts for the Emergency Boiler : Each time the owner or operator brings in an Emergency Boiler to the PSNH Merrimack Station, the owner or operator shall furnish the EP A and DES written notification of the date of constructio n or reconstruction, anticipated startup, and actual sta rtup, as provided by 40 CFR 60, Subpart A, Section 60.7. Th is notification shall include: A) The design heat input capacity of the boiler and identification of fuels to be combusted in the boil er; B) If applicable, a copy of any federally enforceable requirement that limits the annual capacity factor for the boiler (e.g., a copy of this permit); and C) The annual capacity factor at which the facility anticipates operating the boiler based on all fuels combined and each individual fuel. Notification of the date of construction/installati on of the boiler is commenced is due no later than 30 days af ter such date. Notification of the anticipated initial startup of the boiler, must be postmarked not more than 60 days nor less t han 30 days prior to the initial startup date. Notification of the actual date of initial startup of the boiler is commenced must be postmarked within 15 da ys after the initial startup date. As stated for each installation of an Emergency Boiler MKEB 40 CFR 60 Subpart Dc §60.48c(a)

27. NSPS Subpart Dc Performance Test Report for the Emergency Boiler : Each time the owner or operator brings in an Emergency Boiler for operation, the ow ner or operator shall submit to EPA and DES results of the performance test for opacity and the fuel supplier certification for the first load of No. 2 fuel oil or on-road low sulfur diesel oil for consumption in the Emerge ncy Boiler. Within 60 days of completion of testing MKEB 40 CFR 60 Subpart Dc §60.48c(b)

### Proposed

PSNH – Merrimack Station Page 82 97 River Road, Bow, NH TV-0055

Table 9 – Applicable Reporting Requirements Item No. Reporting Requirement Frequency of Reporting Applicable

Emission Unit Regulatory

Cite

28. NSPS Subpart Dc Semi-annual Fuel Report for the Emergency Boiler: The owner or operator shall submit semi-annual reports to EPA and DES, postmarked with in 30 days following the end of the reporting period, including: A) Calendar dates covered in the reporting period; B) Each 30-day average sulfur content (weight percent) for each fuel type (No. 2 fuel oil and on-road low sulfur diesel oil) for each 30-day period during th e reporting period; reasons for any non-compliance with the emission standards; and description of corrective actions taken. C) If fuel supplier certification is used to demonstra te compliance, the fuel supplier certification must include the name of the fuel supplier, a statement that the fuel oil complies with specifications under the definition of distillate oil for fuel oil no. 2 in 40 CFR 60.41c , and the sulfur content or maximum sulfur content of the no. 2 fuel oil and the on-road low s ulfur diesel fuel oil. D) A certified statement by the responsible official t hat the fuel supplier certification represents all of t he fuel combusted during the period. Semi-annually, (by July 31 st

and January 31 st of each calendar year) within 30 days following the end of the reporting period to DES and EPA MKEB 40 CFR 60 Subpart Dc §60.48c(d), (e), & (j)

29. RSA 125-O Mercury Emissions Reporting Requireme nt The owner shall report by June 30, 2007, and annual ly thereafter, to the legislative oversight committee on electric utility restructuring, established under R SA 374- F:5, and the chairpersons of the House science, technology, and energy committee, and the Senate en ergy and economic development committee, on the progress and status of complying with the requirements of RS A 125-O:13,I. and III., relative to achieving early r eductions in mercury emissions and also installing and operat ing the scrubber technology, including any updated cost information. The last report required shall be af ter the Department has made a determination, under RSA 125- O:13,V., on the maximum sustainable rate of mercury emissions reductions by the scrubber technology. Annually, by June 30 MK1 &

MK2 RSA 125-

O:13,IX. (State-Only Enforceable)

30. CO 2 Budget Trading Program Reports The CO 2 AAR shall submit quarterly reports as follows: A) The CO 2 AAR shall report the CO 2 mass emissions data for the CO 2 budget unit, in an electronic format prescribed by the Administrator unless otherwise prescribed by the regional organization, for each calendar quarter beginning with the calendar quarte r covering January 1, 2009 through March 31, 2009; B) The CO 2 AAR shall submit each quarterly report to Quarterly (no later than 30 days following the end of each quarterly reporting period) MK1 & MK2 Env-A 4609.16(c)

### Proposed

PSNH – Merrimack Station Page 83 97 River Road, Bow, NH TV-0055

Table 9 – Applicable Reporting Requirements Item No. Reporting Requirement Frequency of Reporting Applicable

Emission Unit Regulatory

Cite

the regional organization within 30 days following the end of the calendar quarter covered by the report, in the manner specified in Subpart H of 40 CFR 75 and 40 CFR 75.64; C) Quarterly reports shall be submitted for each CO 2 budget unit which include all of the data and information required in Subpart G of 40 CFR 75, except for opacity, NOx, and SO 2 provisions; and D) The CO 2 AAR shall include a compliance certification with, and in support of, each quarter ly report based on reasonable inquiry of those persons with primary responsibility for ensuring that all o f the unit’s emissions are correctly and fully monitored. The certification shall state that: 1) The monitoring data submitted were recorded in accordance with the applicable requirements of both 40 CFR 75 and Env-A 4600, including the quality assurance procedures and specifications; and 2) The CO 2 concentration values substituted for missing data under Subpart D of 40 CFR 75 do not systematically underestimate CO 2 emissions. 31. Certification by the CO 2 Authorized Account Representative Any submission under the CO 2 budget trading program shall be signed and certified by the CO 2 Authorized Account Representative and shall include the certif ication statement pursuant to Env-A 4604.01(e). With each submittal MK1 &

MK2 Env-A

4604.01(e)

32. CO 2 Budget Program Annual Compliance Certification A) For each control period in which a CO 2 budget source is subject to the requirements of Env-A 4605, the C O 2 AAR of the source shall submit to the Department by March 1 following the relevant control period, a compliance certification report. B) The CO 2 AAR shall include in the compliance certification report under (a), above, the followin g elements, in a format prescribed by the Department: 1) Identification of the source and each CO 2 budget unit at the source; 2) At the CO 2 AAR’s option, the serial numbers of the CO 2 allowances that are to be deducted from the source’s compliance account under Env-A 4605.06 for the control period, including the serial numbers of any CO 2 offset allowances that are to be deducted subject to the limitations of Env-A 4605.04; and 3) The compliance certification specified in (c), By March 1 (following the relevant control period), beginning March 1, 2012 and every 3 years thereafter MK1 &

MK2 Env-A 4605.09

### Proposed

PSNH – Merrimack Station Page 84 97 River Road, Bow, NH TV-0055

Table 9 – Applicable Reporting Requirements Item No. Reporting Requirement Frequency of Reporting Applicable

Emission Unit Regulatory

Cite

below. C) In the compliance certification report required by A), above, the CO 2 AAR shall certify, based on reasonable inquiry of those individuals with primar y responsibility for operating the source and the CO 2 budget units at the source in compliance with the C O 2 Budget Trading Program, whether the source and each CO 2 budget unit at the source for which the compliance certification is submitted was operated during the calendar years covered by the report in compliance with the requirements of the CO 2 Budget Trading Program, including: 1) Whether the source was operated in compliance with the requirements of Env-A 4605; 2) Whether the monitoring plan applicable to each unit at the source has been maintained to reflect the actual operation and monitoring of the unit, and contains all information necessary to attribute CO 2 emissions to the unit, in accordance with Env-A 4609; 3) Whether all CO 2 emissions from the units at the source were monitored or accounted for through the missing data procedures specified in 40 CFR 75 Subpart D, or 40 CFR 75 appendix D or appendix E and reported in the quarterly monitoring reports, including whether conditional data were reported in the quarterly reports in accordance with Env-A 4609. If conditional data were reported, the Owner or Operator shall indicate whether the status of all conditional data has been resolved and all necessary quarterly report resubmissions have been made; 4) Whether the facts that form the basis for certification under Env-A 4609 of each monitor at each unit at the source, or for using an excepted monitoring method or alternative monitoring method approved under Env-A 4609, if any, have changed; and 5) If a change is required to be reported under (c)(iv), above, the nature of the change, the reason for the change, when the change occurred, and how the unit's compliance status was determined subsequent to the change, including what method was used to determine emissions when a change mandated the need for monitor recertification. 33. Representative Actual Annual Emissions Reporting Annually (no MK2 40 CFR

### Proposed

PSNH – Merrimack Station Page 85 97 River Road, Bow, NH TV-0055

Table 9 – Applicable Reporting Requirements Item No. Reporting Requirement Frequency of Reporting Applicable

Emission Unit Regulatory

Cite

Requirements: PSNH shall submit to DES annually, SO2, NOx, CO, PM, and VOC emissions in tons/month and consecutive 12-month period for MK1 and MK2. later than April 15 th the following year) 52.21(b)(21) and (33), dated July 1, 2002 and Env-A 910 (new) 34. Notification Requirements A) Pursuant to Env-A 3212.09, the permittee shall comply with the notification requirements of Env-A 3212.07 and 40 CFR 75.20(f) for MKCT1 & MKCT2 B) Pursuant to Env-A 3212.11, for MKCT1 & MKCT2, the permittee shall submit written notification to DES only. As specified MKCT1& MKCT2 Env-A 3212

35. Quarterly Reports for MKCT1 and MKCT2 The Permittee shall submit to DES and EPA in electr onic format or other format as approved by DES and/or EP A the information as follows: A) Pursuant to Env-A 3212.15(b), the owner or operator shall either meet all of the requirements related t o 40 CFR 75 related to monitoring and reporting NOx mass emissions during the entire year or submit quarterly only for the periods from the earlier of May 1 or the date and hour that the owner or operator successfully completes all of the recertification t ests required in accordance with 40 CFR 75.74 through September 30 th

of each year in accordance with 40 CFR 75.74(b); B) Pursuant to Env-A 3212.15(e), the quarterly reports shall be submitted in the manner specified in 40 CF R 75, Subpart H and 40 CFR 75.64; C) Pursuant to Env-A 3212.15(g), the quarterly reports shall include all of the data and information requi red in 40 CFR 75 Subpart H; and D) Pursuant to Env-A 3214.02, the owner or operator shall also submit to the NETS administrator NOx emissions in lb/hr for every hour during the contro l period and cumulative quarterly and seasonal NOx emission data in pounds. 30 calendar days after the end of the 2 nd and 3 rd calendar quarter MKCT1 &

MKCT2 Env-A 3212,

Env-A 3214, 40 CFR 75, Subpart G & H

36. VOC Reporting Requirements The owner or operator shall submit each the followi ng information: A) Facility information, including the following: 4) Source name; 5) Source industrial classification (SIC) code; 6) Physical address; and 7) Mailing address; B) Identification of each VOC emitting device or

process; Annually (no later than April 15 th of the following year MK1, MK2,

MKCT1, MKCT2, MKEG, & MKEB Env-A 908

(formerly Env-A 901.07)

### Proposed

PSNH – Merrimack Station Page 86 97 River Road, Bow, NH TV-0055

Table 9 – Applicable Reporting Requirements Item No. Reporting Requirement Frequency of Reporting Applicable

Emission Unit Regulatory

Cite

C) Operating schedule information for each VOC emitting device, including the following: 1) A typical business day; 2) A typical high ozone season day, if different from a typical business day. D) Total quantities of actual VOC emissions fro the entire facility and for each device or process incl uding the following: 1) Annual VOC emissions, in tons; and 2) Typical high ozone season day VOC emissions, in pounds per day



### .

IX. Requirements Currently Not Applicable

The Permittee did not identify any requirements tha t are not applicable to the facility.



## General Title V Operating Permit Conditions

X. Issuance of a Title V Operating Permit

A. This Permit is issued in accordance with the provis ions of Part Env-A 609. In accordance with 40 CFR 70.6(a)(2), this Permit shall expire on the date specified on the cover page of this Permit, which shall not be later than the date five (5) yea rs after issuance of this Permit.

B. Permit expiration terminates the Permittee's right to operate the Permittee's emission units, control equipment or associated equipment covered b y this permit, unless a timely and complete renewal application is received by the Department at least 6 months before the expiration date.

XI. Title V Operating Permit Renewal Procedures

Pursuant to Env-A 609.07(b), an application for ren ewal of this Permit shall be considered timely if it is received by the Department at least six months prior to the designated expira tion date of the current Title V operating permit.

XII. Application Shield

Pursuant to Env-A 609.08, if an applicant submits a timely and complete application for the issuance or renewal of a Permit, the failure to have a Permi t shall not be considered a violation of this part until the Director takes final action on the applic ation.

### Proposed

PSNH – Merrimack Station Page 87 97 River Road, Bow, NH TV-0055

XIII. Permit Shield

A. Pursuant to Env-A 609.09(a), a permit shield shall provide that:

1. For any applicable requirement or any state requ irement found in the New Hampshire Rules Governing the Control of Air Pollution specifically included in this Permit, compliance with the conditions of this Permit shall be deemed compl iance with said applicable requirement or said state requirement as of the date of permit iss uance; and

2. For any potential applicable requirement or any potential state requirement found in the New Hampshire Rules Governing the Control of Air Pollut ion specifically identified in this Title V Operating Permit Section IX as not applicable to the stationary source or area source, the Permittee need not comply with the specifically ide ntified federal or state requirements.

B. The permit shield identified in Section XIII.A. of this Permit shall apply only to those conditions incorporated into this Permit in accordance with th e provisions of Env-A 609.09(b). It shall not apply to certain conditions as specified in Env-A 6 09.09(c) that may be incorporated into this Permit following permit issuance by DES.

C. If a Title V Operating Permit and amendments theret o issued by the DES does not expressly include or exclude an applicable requirement or a s tate requirement found in the NH Rules Governing the Control of Air Pollution, that applic able requirement or state requirement shall not be covered by the permit shield and the Permittee s hall comply with the provisions of said requirement to the extent that it applies to the Pe rmittee.

D. If the DES determines that this Title V Operating P ermit was issued based upon inaccurate or incomplete information provided by the applicant or Permittee, any permit shield provisions in said Title V Operating Permit shall be void as to t he portions of said Title V Operating Permit which are affected, directly or indirectly, by the inaccurate or incomplete information.

E. Pursuant to Env-A 609.09(f), nothing contained in S ection XIII of this Permit shall alter or affect the ability of the DES to reopen this Permit for ca use in accordance with Env-A 609.19 or to exercise its summary abatement authority.

F. Pursuant to Env-A 609.09(g), nothing contained in t his section or in any title V operating permit issued by the DES shall alter or affect the followi ng:

1. The ability of the DES to order abatement requiring immediate compliance with applicable requirements upon finding that there is an imminent and substantial endangerment to public health, welfare, or the environment;

2. The state of New Hampshire's ability to bring an en forcement action pursuant to RSA 125- C:15,II;

### Proposed

PSNH – Merrimack Station Page 88 97 River Road, Bow, NH TV-0055

3. The provisions of section 303 of the CAA regarding emergency orders including the authority of the EPA Administrator under that section;

4. The liability of an owner or operator of a source f or any violation of applicable requirements prior to or at the time of permit issuance;

5. The applicable requirements of the acid rain progra m, consistent with section 408(a) of the CAA;

6. The ability of the DES or the EPA Administrator to obtain information about a stationary source, area source, or device from the owner or op erator pursuant to section 114 of the CAA; or

7. The ability of the DES or the EPA Administrator to enter, inspect, and/or monitor a stationary source, area source, or device.

XIV. Reopening for Cause

The Director shall reopen and revise a Title V Oper ating Permit for cause if any of the circumstances contained in Env-A 609.19(a) exist. In all proceed ings to reopen and reissue a Title V Operating Permit, the Director shall follow the provisions sp ecified in Env-A 609.19(b) through (g).

XV. Administrative Permit Amendments

A. Pursuant to Env-A 612.01, the Permittee may impleme nt the changes addressed in the request for an administrative permit amendment as defined in Pa rt Env-A 100 immediately upon submittal of the request.

B. Pursuant to Env-A 612.01, the Director shall take f inal action on a request for an administrative permit amendment in accordance with the provisions of Env-A 612.01(b) and (c).

XVI. Operational Flexibility

A. Pursuant to Env-A 612.02, the Permittee subject to and operating under this Title V Operating Permit may make changes involving trading of emissi ons, off-permit changes, and section 502(b)(10) changes at the permitted stationary sour ce or area source without filing a Title V Operating Permit application for and obtaining an a mended Title V Operating Permit, provided that all of the following conditions are met, as we ll as conditions specified in Section XVI. B through E of this permit, as applicable. DES has in cluded permit terms authorizing the generation of DERs.

1. The change is not a modification under any provi sion of Title I of the CAA;

2. The change does not cause emissions to exceed th e emissions allowable under the Title V operating permit, whether expressed therein as a ra te of emissions or in terms of total

### Proposed

PSNH – Merrimack Station Page 89 97 River Road, Bow, NH TV-0055

emissions;

3. The owner or operator has obtained any temporary permit required by Env-A 600;

4. The owner or operator has provided written notif ication to the director and administrator of the proposed change and such written notification i ncludes:

a) The date on which each proposed change will occur o r has occurred;

b) A description of each such change;

c) Any change in emissions that will result;

d) A request that the operational flexibility procedur es be used; and

e) The signature of the responsible official, consiste nt with Env-A 605.04(b);

5. The change does not exceed any emissions limitation s established under any of the following:

a) The New Hampshire Code of Administrative Rules, Env -A 100-4300;

b) The CAA; or

c) This Title V Operating Permit; and

6. The Permittee, DES, and EPA have attached each writ ten notice required above to their copy of this Title V Operating Permit.

B. For changes involving the trading of emissions, the Permittee must also meet the following conditions:

1. The Title V Operating Permit issued to the stationa ry source or area source already contains terms and conditions including all terms and condit ions which determine compliance required under 40 CFR 70.6(a) and (c) and which all ow for the trading of emissions increases and decreases at the permitted stationary source or area source solely for the purpose of complying with a federally-enforceable e missions cap that is established in the permit independent of otherwise applicable requirem ents;

2. The owner or operator has included in the applicati on for the Title V Operating Permit proposed replicable procedures and proposed permit terms which ensure that the emissions trades are quantifiable and federally enforceable f or changes to the Title V Operating Permit which qualify under a federally- enforceable emissi ons cap that is established in the Title V

### Proposed

PSNH – Merrimack Station Page 90 97 River Road, Bow, NH TV-0055

Operating Permit independent of the otherwise appli cable requirements;

3. The Director has not included in the emissions trad ing provision any devices for which emissions are not quantifiable or for which there a re no replicable procedures to enforce emissions trades; and

4. The written notification required above is made at least 7 days prior to the proposed change and includes a statement as to how any change in em issions will comply with the terms and conditions of the Title V Operating Permit.

C. For off-permit changes, the Permittee must also mee t the following conditions:

1. Each off-permit change meets all applicable require ments and does not violate any existing permit term or condition;

2. The written notification required above is made con temporaneously with each off-permit change, except for changes that qualify as insignif icant under the provisions of Env-A 609.04;

3. The change is not subject to any requirements under Title IV of the CAA and the change is not a Title I modification;

4. The Permittee keeps a record describing the changes made at the source which result in emissions of a regulated air pollutant subject to a n applicable requirement, but not otherwise regulated under this Permit, and the emissions resu lting from those changes; and

5. The written notification required above includes a list of the pollutants emitted and any applicable requirement that would apply as a result of the change.

D. For section 502(b)(10) changes, the Permittee must also meet the following conditions:

1. The written notification required above is made at least 7 days prior to the proposed change; and

2. The written notification required above includes an y permit term or condition that is no longer applicable as a result of the change.

E. Pursuant to Env-A 612.02(f), the off-permit change and section 502(b)(10) change shall not qualify for the permit shield under Env-A 609.09.

### Proposed

PSNH – Merrimack Station Page 91 97 River Road, Bow, NH TV-0055

XVII. Minor Permit Amendments

A. Pursuant to Env-A 612.05 prior to implementing a mi nor permit modification, the Permittee shall submit a written request to the Director in accorda nce with the requirements of Env-A 612.05(b).

B. The Director shall take final action on the minor p ermit amendment request in accordance with the provisions of Env-A 612.05(c) through (g).

C. Pursuant to Env-A 612.05(h), the permit shield spec ified in Env-A 609.09 shall not apply to minor permit amendments under Section XVII. of this Permit.

D. Pursuant to Env-A 612.05(a), the Permittee shall be subject to the provisions of RSA 125-C:15 if the change is made prior to the filing with the Dir ector a request for a minor permit amendment.

XVIII. Significant Permit Amendments

A. Pursuant to Env-A 612.06, a change at the facility shall qualify as a significant permit amendment if it meets the criteria specified in Env -A 612.06(a)(1) through (5).

B. Prior to implementing the significant permit amendm ent, the Permittee shall submit a written request to the Director which includes all the info rmation as referenced in Env-A 612.06(b) and (c) and shall be issued an amended Title V Operatin g Permit from the DES. The Permittee shall be subject to the provisions of RSA 125-C:15 if a r equest for a significant permit amendment is not filed with the Director and/or the change is ma de prior to the issuance of an amended Title V Operating Permit.

C. The Director shall take final action on the signifi cant permit amendment in accordance with the Procedures specified in Env-A 612.06(d), (e) and (f ).

XIX. Title V Operating Permit Suspension, Revocation or Nullification

A. Pursuant to RSA 125-C:13, the Director may suspend or revoke any final permit issued hereunder if, following a hearing, the Director det ermines that:

1. The Permittee has committed a violation of any appl icable statute or state requirement found in the New Hampshire Rules Governing the Control of Air Pollution, order or permit condition in force and applicable to it; or

2. The emissions from any device to which this Permit applies, alone or in conjunction with other sources of the same pollutants, presents an i mmediate danger to the public health.

B. The Director shall nullify any Permit, if following a hearing in accordance with RSA 541-A:30, II, a finding is made that the Permit was issued in whole or in part based upon any information proven to be intentionally false or misleading.

### Proposed

PSNH – Merrimack Station Page 92 97 River Road, Bow, NH TV-0055

XX. Inspection and Entry

EPA and DES personnel shall be granted access to th e facility covered by this Permit, in accordance with RSA 125-C:6,VII, for the purposes of: inspecti ng the proposed or permitted site; investigating a complaint; and assuring compliance with any applica ble requirement or state requirement found in the NH Rules Governing the Control of Air Pollution and/or conditions of any Permit issued pursuant to Chapter Env-A 600.

XXI. Certifications

A. Compliance Certification Report

In accordance with 40 CFR 70.6(c) the Responsible O fficial shall certify, for the previous calendar year, that the facility is in compliance w ith the requirements of this permit. The report shall be submitted annually, no later than April 15 th of the following year. The report shall be submitted to the DES and to the U.S. Environmental Protection Agency - New England Region

. The report shall be submitted in compliance with th e submission requirements below.

In accordance with 40 CFR 70.6(c)(5), the report shall describe:

1. The terms and conditions of the Permit that are the basis of the certification;

2. The current compliance status of the source with re spect to the terms and conditions of this Permit, and whether compliance was continuous or in termittent during the reporting period;

3. The methods used for determining compliance, includ ing a description of the monitoring, record keeping, and reporting requirements and test methods; and

4. Any additional information required by the DES to d etermine the compliance status of the

source.

B. Certification of Accuracy Statement

All documents submitted to the DES shall contain a certification of accuracy statement by the responsible official of truth, accuracy, and comple teness. Such certification shall be in accordance with the requirements of 40 CFR 70.5(d) and contain the following language:

"I am authorized to make this submission on behalf of the facility for which the submission is made. Based on information and belief formed after reasonable inquiry, I certify that the statem ents and information in the enclosed documents are to the best of my knowledge and belief true, accurate and complete. I am aware that there are s ignificant penalties for

### Proposed

PSNH – Merrimack Station Page 93 97 River Road, Bow, NH TV-0055

submitting false statements and information or omit ting required statements and information, including the possibili ty of fine or imprisonment."

All reports submitted to DES (except those submitte d as emission based fees as outlined in Section XXIII of this Permit) shall be submitted to the following address:

New Hampshire Department of Environmental Services

Air Resources Division 29 Hazen Drive P.O. Box 95 Concord, NH 03302-0095 ATTN: Section Supervisor, Compliance Bureau

All reports submitted to EPA shall be submitted to the following address:

Office of Environmental Stewardship Director Air Compliance Program United States Environmental Protection Agency

1 Congress Street Suite 1100 (SEA) Boston, MA 02114-2023 ATTN: Air Compliance Clerk

XXII. Enforcement

Any noncompliance with a permit condition constitut es a violation of RSA 125-C:15, and, as to the conditions in this permit which are federally enfor ceable, a violation of the Clean Air Act, 42 U.S.C. Section 7401 et seq., and is grounds for enforcemen t action, for permit termination or revocation, or for denial of an operating permit renewal applicati on by the DES and/or EPA. Noncompliance may also be grounds for assessment of administrative, c ivil or criminal penalties in accordance with RSA 125-C:15 and/or the Clean Air Act. This Permit doe s not relieve the Permittee from the obligation to comply with any other provisions of RSA 125-C, the New Hampshire Rules Governing the Control of Air Pollution, or the Clean Air Act, or to obtai n any other necessary authorizations from other governmental agencies, or to comply with all other applicable Federal, State, or Local rules and regulations, not addressed in this Permit.

In accordance with 40 CFR 70.6 (a)(6)(ii) a Permitt ee shall not claim as a defense in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this Permit.

XXIII. Emission-Based Fee Requirements

A. The Permittee shall pay an emission-based fee quart erly for this facility as calculated each calendar year pursuant to Env-A 705.03.

### Proposed

PSNH – Merrimack Station Page 94 97 River Road, Bow, NH TV-0055

B. The Permittee shall determine the total actual annu al emissions from the facility to be included in the emission-based multiplier specified in Env-A 70 5.03(a) for each calendar year in accordance with the methods specified in Env-A 616.

C. The Permittee shall calculate the annual emission-b ased fee for each calendar year in accordance with the procedures specified in Env-A 705.03 and t he following equation:

Where:

FEE = The annual emission-based fee for each calen dar year as specified in Env-A 705. E = The emission-based multiplier is based on the calculation of total annual

emissions as specified in Env-A 705.02 and the prov isions specified in Env-A 705.03(a). DPT = The dollar per ton fee the DES has specified in Env-A 705.03(b). CPIm= The Consumer Price Index Multiplier as calcu lated in Env-A 705.03(c). ISF = The Inventory Stabilization Factor as speci fied in Env-A 705.03(d).

D. The Permittee shall contact the DES each calendar y ear for the value of the Inventory Stabilization Factor.

E. The Permittee shall contact the DES each calendar y ear for the value of the Consumer Price Index Multiplier.

F. The Permittee shall submit, to the DES, payment of the emission-based fee and a summary of the calculations referenced in Sections XXIII.B. and C. of this Permit for each calendar year. The total emission-based fee shall be paid in four equa l installments on a quarterly basis. The quarterly payments shall be made in accordance with Env-A 705.04 on the 15 th 

### day of the following months:

1. July of the year to which the fee applies (e.g., Ja nuary, February, March 2009 emissionbased fees are due July 15, 2009);

2. October of the year to which the fee applies (e.g., April, May, June 2009 emission-based fees are due on October 15, 2009).

3. January of the following year (e.g., July, August, September 2009 emission-based fees are due on January 15, 2010);

4. April of the following year (e.g., October, Novembe r, December 2009 emission-based fees are due on April 15, 2010).

The Permittee shall pay any remaining balance of th e total annual emission-based fee no later than April 15 th 

### of the following year. ISF * CPIm * DPT * E = FEE

### Proposed



### PSNH – Merrimack Station Page 95 97 River Road, Bow, NH TV-0055

The emission-based fee and summary of the calculati ons shall be submitted to the following address:

New Hampshire Department of Environmental Services Air Resources Division 29 Hazen Drive P.O. Box 95 Concord, NH 03302-0095 ATTN.: Emissions Inventory

G. The DES shall notify the Permittee of any under pay ments or over payments of the annual emission-based fee in accordance with Env-A 705.05.

XXIV. Duty To Provide Information

In accordance with 40 CFR 70.6 (a)(6)(v), upon the DES's written request, the Permittee shall furnish, within a reasonable time, any information necessary for determining whether cause exists for modifying, revoking and reissuing, or terminating t he Permit, or to determine compliance with the Permit. Upon request, the Permittee shall furnish to the DES copies of records that the Permittee is required to retain by this Permit. The Permittee m ay make a claim of confidentiality as to any information submitted pursuant to this condition in accordance with Part Env-A 103 at the time such information is submitted to DES. DES shall evaluat e such requests in accordance with the provisions of Part Env-A 103.

XXV. Property Rights

Pursuant to 40 CFR 70.6 (a)(6)(iv), this Permit doe s not convey any property rights of any sort, or any exclusive privilege.

XXVI. Severability Clause

Pursuant to 40 CFR 70.6 (a)(5), the provisions of t his Permit are severable, and if any provision of this Permit, or the application of any provision of this Permit to any circumstances is held invalid, the application of such provision to other circumst ances, and the remainder of this Permit, shall not be affected thereby.

XXVII. Emergency Conditions

Pursuant to 40 CFR 70.6 (g), the Permittee shall be shielded from enforcement action brought for noncompliance with technology based 36 

### emission limitations specified in this Permit as a result of an

emergency 37 

### . In order to use emergency as an affirmative defe nse to an action brought for

36 Technology based emission limits are those establis hed on the basis of emission reductions achievable with various control measures or process changes (e.g., a new source performance standard) rather than thos e established to attain health based air quality standards.

37 An "emergency" means any situation arising from sud den and reasonably unforeseeable events beyond the

### Proposed



### PSNH – Merrimack Station Page 96 97 River Road, Bow, NH TV-0055

noncompliance, the Permittee shall demonstrate the affirmative defense through properly signed, contemporaneous operating logs, or other relevant e vidence that:

A. An emergency occurred and that the Permittee can id entify the cause(s) of the emergency;

B. The permitted facility was at the time being proper ly operated;

C. During the period of the emergency, the Permittee t ook all reasonable steps as expeditiously as possible, to minimize levels of emissions that exce eded the emissions standards, or other requirements in this Permit; and

D. The Permittee submitted notice of the emergency to the DES within two (2) business days of the time when emission limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mi tigate emission, and corrective actions taken.

XXVIII. Permit Deviation

In accordance with 40 CFR 70.6(a)(3)(iii)(B), the P ermittee shall report to the DES all instances of deviations from Permit requirements, by telephone, fax, or e-mail (pdeviations@des.state.nh.us) within 24 hours of discovery of such deviation. Th is report shall include the deviation itself, including those attributable to upset conditions as defined in this Permit, the probable cause of such deviations, and any corrective actions or preventat ive measures taken.

Within 10 days of discovery of the permit deviation , the Permittee shall submit a written report including the above information as well as the foll owing: preventive measures taken to prevent future occurrences; date and time the permitted dev ice returned to normal operation; specific device, process or air pollution control equipment that con tributed to the permit deviation; type and quantity of excess emissions emitted to the atmosphere due t o permit deviation; and an explanation of the calculation or estimation used to quantify excess e missions.

Said Permit deviation shall also be submitted in wr iting to the DES in the semi-annual summary report of monitoring and testing requirements due J uly 31st and January 31st of each calendar year. Deviations are instances where any Permit condition is violated and has not already been reported as an emergency pursuant to Section XXVII of this Perm it.

Reporting a Permit deviation is not an affirmative defense for action brought for noncompliance.

control of the source, including acts of God, which situation would require immediate corrective actio n to restore normal operation, and that causes the source to exc eed a technology based limitation under the permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include nonc ompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or impr oper operations, operator error or decision to keep oper ating despite knowledge of any of these things.

### Proposed



### PSNH – Merrimack Station Page 97 97 River Road, Bow, NH TV-0055



## Federal Acid Rain Requirements

XXIX. Phase II Acid Rain Permit Application

The attached Phase II Acid Rain Permit application, dated May 15, 2009, is hereby incorporated by reference into this permit. The Permittee shall co mply with the requirements set forth in the Phase I I Acid Rain Permit Application and this permit.

XXX. General Acid Rain Provisions

The Permittee shall comply with the applicable prov isions of 40 CFR 72, Permit Regulations 

### ; 40 CFR 73, Sulfur Dioxide Allowance System 

### ; 40 CFR 75, Continuous Emission Monitoring 

### ; 40 CFR 76, Acid Rain Nitrogen Oxides Emission Reduction Progra m 

### ; and 40 CFR 77, Excess Emissions



### .