PERMIT APPLICATION REVIEW SUMMARY

Transcription

1 AFS #: Application #: FY Date: January 17, 2006 Page 1 of 10 APPLICATION & OTHER COMMUNICATION Date November 12, 2004 December 15, 2004 March 11, 2005 Brief Description Application for title V permit renewal received Completeness letter sent Fax information on the pressure differential gage and the manufacturers performance rating on the multiclone Diagram of stack heights for the 4 boilers Response to comments of the external draft title V permit sent to Ron Guerin Comments received for external draft permit June 9, 2005 June 21, 2005 October 13, 2005 November 30, 2005 Sent response to comments received from TRC October 13, 2005 January 11, 2006 Comments on stack height of EU1 from GZA via January 20, 2006 Response to comments received from GZA on letter sent FACILITY DESCRIPTION Tillotson Rubber Co., Inc. (TRC) owns and operates four fuel-burning devices (Power Plant) to produce steam and electricity for the Balsams Resort and a tenant operating a manufacturing process (Healthco International). TRC also has two diesel emergency generators as backup power. TRC is a major source of CO and is therefore required to obtain a title V permit. PROJECT DESCRIPTION TRC has submitted a renewal of their title V operating permit (TV-OP-026) in a complete and timely fashion. TRC has included a CAM plan as part of the permit renewal. DEVICE DESCRIPTION Unit ID Device Description EU1 Wicks 1 boiler Manufacturer: Wickes Type A Serial #: NB2884 Installed: 1978 PCE1 Multi-cyclone dust collector w/o ash reinjection Manufacturer: Zurn EU2 Wicks 2 boiler Manufacturer: Wickes Type A Serial #: NB2480 Installed: 1981 EU3 Dillon boiler #1 Manufacturer: Dillon, HRT Serial #: 2RLHC Installed: 1914 EU4 Dillon boiler #2 Manufacturer: Dillon, HRT Serial #: HC Installed: MMBtu/hr; Air-type stoker; one end only firing; 6.6 tons/hr firing rate; Wood characteristics: 95% greenwood (½ to ⅔ green sawdust), < 5% kiln dried, 50% moisture, ⅓ to ½ green hardwood bark 40 9 diameter collector tubes; Predicted collection efficiency: 90% (this is NOT a vendor guaranteed control efficiency) 33.2 MMBtu/hr; steam atomization; one end only firing; No. 4 or No. 6 fuel oil; 221 gallons/hr fuel flow rate; 8.2 MMBtu/hr; rotary cup; one end only firing; No. 4 or No. 6 fuel oil; 54.7 gallons/hr fuel feed rate; 8.2 MMBtu/hr; rotary cup; one end only firing; No. 4 or No. 6 fuel oil; 54.7 gallons/hr fuel feed rate; Combined fuel limit of 2,088 gallons for EU3 & EU4 based on modeling for PM 10 and SO 2 ;

2 AFS #: Application #: FY Date: January 17, 2006 Page 2 of 10 Unit ID Device Description EU5 400 KW EG Manufacturer: Cat D379 Serial #: 76B415 Installed: 1960 EU6 600 KW EG Manufacturer: Cat D3412 Serial #: 81Z08025 Installed: MMBtu/hr; diesel gal/hr fuel flow rate; 610 HP; 5.74 MMBtu/hr; diesel 44.1 gal/hr fuel flow rate; 890 HP; INSIGNIFICANT ACTIVITIES Device/Process Comments Hot air furnace Distillate oil-fired 0.39 MMBtu/hr; located in truck maintenance garage; Furnace Distillate oil-fired MMBtu/hr; located in the hydro building; Boiler pilots Parts cleaner Parts cleaner PERMITTING HISTORY Propane fired located in power plant; <1,000 lb/yr emissions; 30 gallons in Power plant; <5 tpy for both parts cleaners; 34 gallons in truck maintenance garage; < 5 tpy for both parts cleaners; Device Comments Last Permit # Wickes wood Initial permit application for this device was dated Oct. 27, 1977, went through NSR/PSD review for particulate and SO 2 (due to the reduction in the amount of #6 oil that would be burned in the other boilers); 1. Estimated PM rate 198 lb/hr (uncontrolled) and 273 tpy; 2. Allowed PM rate 34 tpy by NH rule; 3. SO tpy from fuel oil (2.2% sulfur in fuel by weight allowed); 4. PSD net decrease in SO 2 ; Date Last Issued PO-B-1515 July 5, 1994 Wickes A 12/81 installed as stand-by boiler to replace 4 existing smaller stand-by boilers PO-B-1510 July 5, 1994 Dillon #1 Installed 1914 PO-B-517 July 5, 1994 Dillon #2 Installed 1914 PO-B-518 July 5, 1994 Cyclotherm (4.7MMBtu/hr) Superior boiler (9.4MMBtu/hr) Installed 1951; Permit cancelled when removed from site PO-B-516 July 1, 1985 Installed 1970; Permit cancelled (device no longer located at facility); PO-B-519 May 6, 1982 Nebraska boiler (45.6 MMBtu/hr) Installed August 1980; application indicated this would be used in lieu of the existing Babcock & Wilcox boiler (no information was found on this device in the source file); PO-B-1598 July 6, 1980 EtOH sterilizer Sterilizer taken out of service TP-BP-568 Aug. 25, 1995 Title V permitting activity for this facility is listed below. Date Application Device Date Issued July 2, 1996 FY96-TV051 Initial title V permit (TV-OP-026) May 25, 2000 July 24, 2003 FY Administrative Amend. July 25, 2003 Nov. 21, 2003 FY Modification to remove glove lines, and change name to Tillotson Rubber Healthcare filed for bankruptcy 5/17/02; Aug. 5, 2004 POLLUTION CONTROL EQUIPMENT PCE1 is a multi-cyclone, which controls particulate emissions from EU1 (Wicks wood boiler), and is the only pollution control device at the facility. A maintenance schedule for the multiclone was submitted to DES on May 31, 2000

3 AFS #: Application #: FY Date: January 17, 2006 Page 3 of 10 in connection with permit application FY96-TV051. This maintenance schedule will be referred to in the Permit in the monitoring/testing section. TRC submitted a copy of the technical specifications for the multiclone (Zurn) which indicated a predicted performance of 90% collection efficiency. However, this was not a manufacturer s guarantee. An assumed control efficiency of 90% was used in setting the original title V permit conditions for PM. EPA indicated in AP-42 (Chapter 1.6.4) that the collection efficiency of a multiclone ranges from 25 to 65%. TRC uses the mechanical control AP-42 emission factor for calculation of PM emissions for their annual emissions reports and fees. Since the EPA emission factor assumes lower control efficiency, and the vendor does not guarantee the 90% control efficiency, the boiler emissions were modeled using the AP-42 emission factors. See results of modeling requested on March 29, 2005 EU1 is subject to Compliance Assurance Monitoring plan (CAM) pursuant to 40 CFR Part 64. The facility submitted a CAM plan as part of the renewal application. This unit meets the requirements as specified in that: The unit is subject to a specific emission limitation (PM); The unit uses a control device (PCE1) to achieve compliance with the emission limitation; and The unit s pre-control emissions of PM are 100% of the amount required for the source to be classified as a major source. The proposed monitoring approach is: 0.56lb 52.8MMBtu 8760hr MMBtu hr yr 2000 ton lb = 129.5tpy PM Multiclone Indicator No.1 Pressure Drop Indicator No. 2 Inspection & Maintenance 1. Measurement Approach Differential pressure drop across the unit Inspection and cleaning of the outlet boots and vanes Indicator No.3 Leak Test Smoke tube testing for indications of leaks 2. Indicator Range 1.0 to 5.0 inches water column NA No visible leak detected 3. Performance Criteria Data Representativeness Magnehelic gauge accurate to 0.2 in w.c. QA/QC practice Semiannual calibration of gauge NA NA Monitoring Frequency Pressure drop every 2 hours At least annually Leak test monthly Data Collection Procedures Record in logbook Record in I/M log Record in logbook Indicator No. 3 has not been placed into the permit since visible leaks would be detected at the multiclone. EMISSION CALCULATIONS Emissions from the permitted devices were verified by DES using fuel use information from the 2003 annual compliance certification report dated April 7, NA NA Example calculation: EU1 (Wicks wood) potential NO x = 1.28lb NOx 57,000tons wood 2,000lb 36tons NO = ton of wood year ton year x Emission Summary (tpy) 1 Device TSP PM 10 SO x NO x CO VOC HAPs Potential EU1 Wicks A wood Emission rates are from AP-42 unless otherwise noted.

4 AFS #: Application #: FY Date: January 17, 2006 Page 4 of 10 Emission Summary (tpy) 1 Device TSP PM 10 SO x NO x CO VOC HAPs EU2 Wicks A oil EU3 Dillon #1 EU4 Dillon # EU5 400KW Cat EU6 600KW Cat Total Facility (tpy) Actual EU1 Wicks A wood EU2 Wicks A oil EU3 Dillon # EU4 Dillon # EU5 400KW Cat EU6 600KW Cat Total Facility (tpy) TRC may burn either No.4 and/or No. 6 fuel oil in EU2, EU3, and EU4. Due to the configuration of the oil tanks and lines at the facility, they are not able to track the specific amount of each type of fuel oil. Currently, the tank containing No. 6 fuel oil is connected directly to EU2, EU3, and EU4. If TRC wants to burn No. 4 fuel oil in EU2, EU3, and/or EU4, they must transfer this oil from another tank into the No. 6 fuel oil tank to feed the boilers. As a result, there is no point when TRC can determine when the oil in the tank ceases being a mixture of No. 6 and No. 4 fuel oil. Emission factors for No. 6 fuel oil shall be used to determine compliance and emissions of NAAQS compounds. STACK INFORMATION 7 Stack # Emission Unit Exit Temp ( F) Diameter (feet) Height (feet ags) 1 EU EU EU3 & EU EU EU MODELING HISTORY June 10, 1999 Modeling was performed by DES for PM 10, SO 2, NO x, and CO for EU1, EU2, EU3, & EU4. Modeling results predicted SO 2 and PM 10 NAAQS violations (SO 2 for annual, 24-hr, and 3-hr; PM 10 for the 24-hr standard). Changes were instituted by TRC, which included: EU1 - Emissions of PM, SO 2, VOC and HAPs are based on AP-42 Table and (09/03) for bark/wet wood (controlled) and permitted fuel limitations. The emission rates for NO x and CO are based on the stack test performed 2/8/96. 3 Potential emissions for EU2 are based on SO 2 annual limit of 39.9 tpy. 4 EU2 - Current permit limit reflects the existing cap on SO x emissions imposed to correct for PSD violations for SO 2 prior to Total Facility - Current permit limit based on modeling performed June 10, 1999 to avoid NO x RACT. 6 Actual emissions are those calculated by Compliance for the 2004 emission based fees. 7 Stack information taken from ARD-3 forms submitted as part of the permit renewal, and from the diagram submitted by the facility during a meeting on June 9, The EU1 stack height is 55 feet when referenced to the base elevation at the end of the building where the stack is located. If referenced from the west end of the building (the same base elevation as that of EU2, EU3, and EU4), the stack height is 38 feet above ground surface.

5 AFS #: Application #: FY Date: January 17, 2006 Page 5 of 10 Maintaining a maximum sulfur content in the fuel oil burned of 0.5%; Raising the stack associated with EU2 to 55 feet above baseline elevation; Limiting the hours of operation of EU3 and EU4 to 38-hours per day combined; Limiting the combined hourly fuel use rate for EU3 & EU4 to 87.0 gal/hr of #6 fuel oil; and Assuring a particulate control of 90% for the multiclone associated with EU Modeling was performed by GZA (consultant) using DES modeling files to reflect corrections to the stack heights and flow rates. Modeling indicted that under the current permit conditions, TRC is in compliance with NAAQS. However, an assumption of 90% PM control was assumed for PCE1. The following table indicates changes in stack parameters since 1999 modeling. These corrections have been made to Table 2 in the permit renewal. Stack Height (ft AGL) Flow Rate (cfm) Maximum Stack Diameter (ft) Emission Unit EU ,000 NC 4.0 NC EU ,500 14, EU3 & EU ,060 5, NC no change November 2005 DES requested modeling for criteria pollutant emissions from EU1, EU2, EU3, and EU4 using: 1. The AP-42 emission factors (Table /03) for wet wood/bark using a mechanical collector (PCE1 for EU1) [DES Compliance bureau raised concerns over the 90% collection efficiency of the multiclone in the original title V permit.]; and 2. The revised stack heights and flow rates noted in the table above, and submitted in the permit application; Modeling results indicated further fuel limitations were needed to maintain compliance with the NAAQS for PM 10, due to the estimated increase in PM 10 from EU1. The restrictions are: EU1 120 tons per consecutive 24-hour period of wood/bark; this equates to 22,000 lb of steam/hr and 40.8MMBtu/hr heat input rating. Compliance with the PM 10 emission limit will be based on steam production monitoring on a daily average basis. October 19, 2005 modeling was performed on two possible operating scenarios submitted by TRC (wood only firing and oil only firing). The fuel limits currently in the permit for EU2, EU3 & EU4 would not change under the oil only firing. The fuel limits for these devices were based mainly on the 24-hour SO 2 impact, for which oil is the predominant contributor. Under the wood only condition for EU1 the wood firing limit could be raised to 130 tons/day. The 24-hour PM 10 impact is the limiting factor in this scenario since the majority of the particulate emissions are from the firing of wood. TRC decided not to request these alternatives be placed in their permit. TRC indicated that they would have difficulty demonstrating compliance with the wood firing only limit since EU2 is operated in the automatic mode. In this mode, the boiler will begin firing fuel oil when the demand for steam from EU1 cannot be met of when there are operational difficulties with EU1. EU2 has an hour meter, but readings are currently taken only once per day, and the additional recordkeeping and reporting burden would not be worth the extra effort. EMISSION TESTING Date March 23, 1995 Brief Description Wicks wood boiler (EU1) for NO x, and CO; these results are used to determine emissions for annual reporting; No stack tests have been performed at this facility as of the issuance of the last permit on July A requirement for stack

6 AFS #: Application #: FY Date: January 17, 2006 Page 6 of 10 testing for PM once per permit cycle will be incorporated into the permit s monitoring and testing table. SITE VISITS/INSPECTIONS Date September 28, 2004 September 12, 2001 Brief Description Full compliance evaluation records review by A. Moulton Inspection conducted by Alan Moulton; EMISSION LIMITATIONS: NO x The facility has taken a 49.9 tpy facility wide permit limit to opt out of NO x RACT. SO 2 emissions from EU2 (Wicks #2) is limited to 39.9 tpy to end PSD/NSR violations triggered when EU2 was installed. Based on modeling conducted in 2005 for PM, TRC will be required to limit the amount of steam produced by EU1 to less than 22,000 pounds of steam per hour on a calendar day average (this equates to approximately 120 tons per day of wood). REVIEW OF REGULATIONS State Regulations Env-A 600 Permitting (effective ) (c) YES a permit is required due to fuel burning devices >2MMBtu/hr heat input rating (EU1 to EU4) combusting wood (EU1), or No. 6 & No. 4 fuel oil (EU2, EU3, EU4); (d) YES two emergency generators (EU5 & EU6) required for the internal combustion engines with design ratings >200 horse-power output; (g) NO - no VOC emitting processes/operations occur at the facility that meet the permit applicability thresholds; (n) YES a source choosing to limit its potential to emit by accepting enforceable permit conditions which restrict the amount of fuel burned; (facility has taken a 49.9 tpy facility wide permit limit to opt out of NO x RACT) Env-A 700 Emission Based Fees (effective ) (a) YES Emission fees paid through 2004, [2004 fees paid March 5, 2005] Env- A 1200 Prevention, Abatement, and Control of Stationary Source Air Pollution VOC RACT (effective ) NO no VOC emitting processes/operations occur at the facility that meet the permit applicability thresholds; NO x RACT (adopted ) (m) NO The facility has taken a 49.9 tpy NO x permit limit to opt-out of NO x RACT. Env-A 1600 Fuel Specifications (effective ) (a) NO DES does not have the statutory authority to regulate diesel fuel sulfur limits (used by EU5 & EU6). Therefore, this will be removed from the permit. EU2, EU3, and EU4 are limited to 0.5% sulfur by weight in both No. 4 and No. 6 fuel oil to comply with NAAQS for SO 2 based on modeling performed in 1999;

7 AFS #: Application #: FY Date: January 17, 2006 Page 7 of 10 EU2 (Wickes #2) was installed in 1978 to replace 4 existing stand-by boilers (permit application dated 10/27/79). PSD applicability was never done. This resulted in a 39.9 TPY unit cap for SO 2 to end the NSR/PSD violation (equates to a fuel cap of 1,016,561 gal/yr) Env-A 2000 Fuel Burning Devices (effective ) YES Average opacity for EU3, EU4, EU5 installed on or before May 13, 1970 < 40% YES Average opacity for EU1, EU2, EU6 installed after May 13, 1970 < 20% (c) YES Average opacity for EU1 - EU6 may be exceeded for one continuous 6 minute period in any 60 minute period during startup, shutdown, malfunction, sooth blowing, grate cleaning, and cleaning of fires; (d) YES exceedances of the opacity standard for EU1 EU4 shall not be considered violations if the source demonstrates that such exceedances were the result of the adherence to good boiler operating practices, which in the long term, results in the most efficient or safe operation of the boiler (e) YES examples of activities operation of the unit (f) YES Exceedances of the opacity standard.as quickly as possible YES PM for EU3, EU4, EU5 installed on or before May 13, 1970; for I <10 MMBtu/hr E = 0.60lb/MMBtu; YES PM for EU1 & EU2 installed after May 13, 1970 and before January 1, 1985; PM shall not exceed E = x I ; EU1: E = x = 0.43lb/MMBtu 8 ; EU2: E = x = 0.45lb/MMBtu YES PM for EU6 installed on or after January 1, 1985; E = 0.30 lb/mmbtu State Regulations (State only requirements) Env-A 1400 Regulated Toxic Air Pollutants (effective ) NO TRC combusts only virgin fuels (which are exempt from this rule), and do not have any processes or devices that are subject to the rule; Federal Regulations 40 CFR Part 60 NO boilers below applicability levels; Dc EU1 & EU2 meet MMBtu/hr heat input rating but were installed before Jun 9, 1989; EU3 & EU4 do not meet any MMBtu/hr heat input rating limit; 40 CFR Part 61 NO no applicable devices 40 CFR Part 63 subpart DDDDD (promulgated September 23, 2004) NO TRC is not a major source of HAPs and is therefore exempt from this MACT; 40 CFR Part 64 Compliance Assurance Monitoring (promulgated October 22, 1997) YES EU1 (Wicks wood boiler) meets the requirements as specified in that the unit is subject to a specific emission limitation (PM), the unit uses a control device to achieve compliance with the emission limitations (0.041 lb/mmbtu), and the units pre-control emissions of PM are 100% of the amount required for the source to be classified as a major source. 8 The particulate emission limitation for EU1 is based on the permitted maximum firing rate of 40.8 MMBtu/hr.

8 AFS #: Application #: FY Date: January 17, 2006 Page 8 of 10 SUBSTANTIVE CHANGES FROM PREVIOUS PERMIT TV-OP-026 (current) Renewal Reason for change III.A Table 1 Significant Activity Identification Description of Emission Unit column device installation dates have been added Installation dates added to help better determine regulatory applicability of the devices; Exhaust Stack Identification column removed Stack identifications for the emissions units are specified in Table 2. Emission Unit Maximum Design Capacity Changed to...maximum Permitted Capacity Column heading changed to reflect actual contents/purpose of column; III.B Stack Criteria Maximum firing rate of 40.8 million British thermal units per hour (MMBtu/hr) gross heat input, which equates to 22,000 pounds of steam per hour 120 tons of wood/bark at 50% moisture during any consecutive 24-hour period Footnote 1 added The Permittee may use. EU5 & EU6 Design ratings and permitted hours of operation added, and reference to Env-A (i) removed; The facility is a true minor source of HAP emissions added to table bottom. Table 2 Stack Criteria Stack #2 EU2 corrected stack height to 56.63, ACFM to 14,500, and ID to 3.5 feet. Stack #3 EU3 & EU4 corrected stack height to feet, ACFM to 5,720, and ID to 3.17 feet. Stack information for the Emergency Generators were removed from the table. Footnote 3 added to Table 2 The EU1 stack height.. EU1 Change made to permitted fuel rate based on modeling using AP-42 emission factors Table Bark and Wet Wood using a mechanical PM control device (9/03). EU2, EU3, EU4 Footnote added to clarify Permittee s obligation for tracking No.4 and No. 6 fuel oil use and calculation of emissions. Change made to have permit better reflect the proposed contents of the column heading for the two emergency generators; To clarify the status of the facility regarding HAP emissions. Stack criteria corrections. Stack criteria corrections. These generators are restricted to <500hr of operation per year and were not included in the ambient air quality modeling. Clarify the base elevation used for stack height reference for EU1. Minimum Stack Flow Rate (ACFM) Delete column Flow rates for the fuel burning devices will vary dependent upon fuel firing rate. Paragraph 2 last sentence All air modeling. VI. Pollution Control Equipment/Technique Identification Table 3 - Pollution Control Equipment Identification Minimum Efficiency of Equipment Paragraph 1 All equipment, facilities... Paragraph 2 The pollution control... Paragraph 2 last sentence The Facility shall keep... or DES has been added to the last sentence Delete column and 90% control efficiency requirement Move the text in the first paragraph following Table 3 to Table 5, Item 2. The text in the second paragraph following Table 3 moved to Table 5, Item 3. The text in the second paragraph last sentence following Table 3 moved to Table 6, Item 2. DES files contain past modeling performed for the facility by the agency. Emissions of PM from EU1/PCE1 have been modeled based on emission rates given in Table of AP-42 (9/03) for Bark/wet wood using mechanical collectors. Applicable requirement moved to appropriate section of permit. Applicable requirement moved to appropriate section of permit. Applicable requirement moved to appropriate section of permit.

9 AFS #: Application #: FY Date: January 17, 2006 Page 9 of 10 TV-OP-026 (current) Renewal Reason for change VIII.B. Federally Enforceable Operational and Emission Limitations Footnote 4 added NH rules cited..that rule. Clarification of applicable rules by use of effective dates. Table 4, Item 1 & 2 New Item 1 Delete and off road diesel fuel oil DES does not have statutory authority to regulate sulfur content off-road diesel fuel. Footnote 5 added This limit is required to show compliance with NAAQS for SO 2. Clarification of basis for 0.50% by weight sulfur content for No. 4 and No. 6 fuel oil limit. Table 4, Item 3 Remove EU6 as applicable emission unit The opacity exemptions cited do not apply to EU6. Allowed opacity exemptions for steam generating devices EU1, EU2, EU3, & EU4. Clarify specific exemptions for fuel burning devices. Table 4, Item 6 Move to Item 4.c); Change before to after Particulate matter emission limitation for EU6 Table 4, Item 10 New Item 7 Paragraph 1...based on ambient...with the AAQS. VIII.D. Monitoring and Testing Requirements Replaced the language with EU2 to less than 39.9 tons.imposed to correct PSD violations for SO 2 prior to Table 4, Item 9 (new) Addition of maximum pound per hour limit of steam generation on a calendar day average basis for EU1. New footnote 8 NH rules.that rule. Clarification of the reason for limits on SO 2 for EU2 Change made to maximum permitted steam production rate based on modeling performed by DES April 29, 2005 using AP-42 emission factors Table Bark and Wet Wood using a mechanical PM control device (9/03). Clarification of applicable rules by use of effective dates. Table 5, Item 1 Remove annual stack inspection requirements; Elimination of duplicate requirements Table 5, Item 3 Table 5, Item 2 (new) First paragraph of text from Condition VI paragraph 1 Delete manufacturers recommended and specifications with submitted to DES on May 29, Deleted text - 90% control efficiency, Placing text in the proper section of the permit to clarify regulatory requirements. Maintenance schedule clarification Minimum control efficiency requirement deleted from permit. Will use EPA AP-42 emission rates for PM. Deleted text - stack test requirements Requirement moved to new Item 8. Delete maintenance and repair records text Requirements exist in Table 6. Table 5, Item 5 Addition of fuel flow meter language Addition of fuel limits for EU2 based on modeling for facility wide PM Table 5, Item 7 (new) Monitoring of steam production rate for EU1 Table 5, Item 8 (new) Requirement for stack testing for PM for EU1 Table 5, Item 9 (new) Excursion limitation for PCE1 which would trigger the requirement for a Quality Implementation Plan (QIP). Table 5A (new table) Inclusion of CAM requirements for PCE1 Inclusion of monitoring of steam production to assure compliance with AAQS for PM. Inclusion of testing requirements for EU1/PCE1 to assure compliance with PM NAAQS. Inclusion of CAM requirements for PCE1 40 CFR 64 applicability VIII.E. Recordkeeping Requirements New footnote 11 NH rules.that rule. Clarification of applicable rules by use of effective dates. Table 6 Table 6, Item 2 (new) Recordkeeping requirements for PCE1 Table 6, Item 4 (new) Addition of recordkeeping requirements for PCE1 Table 6, Item 5 (new) Addition of QIP Moved from Condition VI paragraph 2 to appropriate section of permit. Addition of CAM requirements for PCE1. Addition of CAM requirements for PCE1

10 AFS #: Application #: FY Date: January 17, 2006 Page 10 of 10 TV-OP-026 (current) Renewal Reason for change requirements Table 6, Item 4 Remove If more than one type of fuel is used... Only wood/bark is fired in EU1 Table 6, Item 5 Renumber to Item 9 Change recordkeeping requirement from monthly to daily Change recordkeeping requirement from month to calendar day Remove If more than one type of fuel is used... Addition of new Item numbers Change to reflect change in fuel use monitoring requirements for EU2 Change to reflect change in fuel use monitoring requirements for EU2 Clarification of fuel type ; EU2 can burn No. 4, or No. 6 fuel oil or a combination (mix) of No. 4 & No. 6 fuel oil. Table 6, Item 6 Renumber to Item 10 Addition of new Item numbers Remove If more than one type of fuel is used... Clarification of fuel type ; EU3 & EU4 can burn No. 4, or No. 6 fuel oil or a combination (mix) of No. 4 & No. 6. VIII.F Reporting Requirements Table 7, Item 1 SUMMARY AND CONCLUSIONS Remove condition a) recordkeeping for hour of operation limitations Requirement a) deleted Addition of requirements e) through h) Table 7, Item 4 (new) Addition of QIP requirement Change to reflect change in fuel use monitoring requirements for EU3 & EU4. Update to reflect change in associated Table 4 Addition of CAM requirements Addition of CAM requirements In summary, the operations as applied for will be capable of meeting all regulations and standards for air quality. A title V permit to operate will be issued.