State of New Hampshire Department of Environmental Services Air Resources Division. Temporary Permit

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1 State of New Hampshire Department of Environmental Services Air Resources Division Temporary Permit Permit No: TP-0120 Date Issued: December 26, 2012 This certifies that: Northeast Utilities Public Service Company of New Hampshire 780 North Commercial Street Manchester, NH has been granted a Temporary Permit for: Temporary Steam Boiler at the following facility and location: 165 Gosling Road Newington, NH Facility ID No: Application No: , received July 26, Temporary Permit which includes devices that emit air pollutants into the ambient air as set forth in the permit application referenced above which was filed with the New Hampshire Department of Environmental Services, Air Resources Division (Division) in accordance with RSA 125-C of the New Hampshire Laws. Request for permit renewal must be received by the Division at least 90 days prior to expiration of this permit and must be accompanied by the appropriate permit application forms. This permit is valid upon issuance and expires on June 30, Acting Director Air Resources Division

2 TP-0120 Page 2 of 10 Abbreviations and Acronyms AAL Ambient Air Limit acf actual cubic foot ags above ground surface ASTM American Society of Testing and Materials Btu British thermal units CAS Chemical Abstracts Service cfm cubic feet per minute CFR Code of Federal Regulations CO Carbon Monoxide DER Discrete Emission Reduction DES New Hampshire Department of Environmental Services New Hampshire Code of Administrative Rules Air Related Programs ERC Emission Reduction Credit ft foot or feet ft3 cubic feet gal gallon HAP Hazardous Air Pollutant hp horsepower hr hour kw kilowatt lb pound LPG Liquified Petroleum Gas MM million MSDS Material Safety Data Sheet MW megawatt NAAQS National Ambient Air Quality Standard NG Natural Gas NOx Oxides of Nitrogen NSPS New Source Performance Standard PM10 Particulate Matter < 10 microns ppm parts per million psi pounds per square inch RACT Reasonably Available Control Technology RSA Revised Statutes Annotated RTAP Regulated Toxic Air Pollutant scf standard cubic foot SO2 Sulfur Dioxide TSP Total Suspended Particulate tpy tons per consecutive 12-month period USEPA United States Environmental Protection Agency VOC Volatile Organic Compound

3 TP-0120 Page 3 of 10 I. Facility Description - (PSNH-Newington) is a fossil fuel-fired electric generating facility, owned and operated by, a subsidiary of Northeast Utilities. The facility is comprised of one utility boiler, two auxiliary boilers, one emergency generator, two bulk oil storage tanks, and one bulk oil storage day tank. The facility operations also include various activities that are classified as insignificant or exempt activities. Title V Operating Permit TV-OP-054 was issued to PSNH-Newington on March 9, The Title V Permit was subsequently amended on December 17, 2007 and January 29, The Title V Permit expired on March 30, PSNH-Newington is currently operating under the application shield provision of PSNH-Newington has proposed to install and operate a temporary natural gas fired boiler rated at 99.9 million British Thermal Units per hour (MMBtu/hr). This boiler is identified as emission unit, which is the subject of this permit. This boiler will be used for building heat and startup of the main unit (NT1) during the heating season. The same boiler or a similar boiler will be used in future heating seasons. The proposed boiler is a portable rental unit and will not be attached to a foundation while on site. The temporary boiler will exhaust through the existing stack for Auxiliary Boiler No. 1A (designated as NTAB1 in TV-OP-054). NTAB1 will not operate at times when the temporary boiler is in operation. This Temporary Permit includes emission limitations and operating conditions for the temporary boiler. All conditions of previously issued TV-OP-054 that this permit supersedes are specifically identified in this permit. Upon issuance of this permit, the Owner or Operator shall comply with terms and conditions of TV-OP-054 and this permit. II. Emission Unit Identification This permit covers the devices identified in Table 1: Table 1 - Emission Unit Identification Emission Unit ID Device Identification Manufacturer Model Number Serial Number Installation Date Maximum Design Capacity and Permitted Fuel Type(s) Temporary Steam Boiler equipped with low NOx burners TBD MMBtu/hr Natural gas NTAB1 Auxiliary Boiler No. 1A Erie City Energy Division Model No. 15Mkeystone MMBtu/hr No. 2 fuel oil

4 TP-0120 Page 4 of 10 III. Stack Criteria A. The following devices at the Facility shall have exhaust stacks that discharge vertically, without obstruction, and meet the criteria in Table 2: Stack Number Emission Unit or Pollution Control Equipment ID Table 2 - Stack Criteria Minimum Height (feet above ground surface) Maximum Exit Diameter (feet) STNTAB1 NTAB1 or B. Stack criteria described in Table 2 may be changed without prior approval from the Division provided that: 1. An air quality impact analysis is performed either by the facility or the Division (if requested by the facility in writing) in accordance with 606, Air Pollution Dispersion Modeling Impact Analysis Requirements, and the Guidance and Procedure for Performing Air Quality Impact Modeling in New Hampshire, and 2. The analysis demonstrates that emissions from the 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 notification to the Division of the stack change within 15 days after making the change. Such notification shall include: 1. A description of the change; and 2. The date on which the change occurred. E. The stack criteria listed in Table 2 identifies emission points used in air dispersion modeling analysis for the Facility.

5 TP-0120 Page 5 of 10 IV. Operating and Emission Limitations Item # The Owner or Operator shall be subject to the operating and emission limitations identified in Table 3: Table 3 - Operating and Emission Limitations Requirement 1 Visible Emission Standard for Fuel Burning Devices Installed After May 13, 1970 The average opacity from fuel burning devices installed after May 13, 1970 shall not exceed 20 percent for any continuous 6-minute period. 1 2 Activities Exempt from Visible Emission Standards The average opacity shall be allowed to be in excess of those standards specified in 2002 for one period of 6 continuous minutes in any 60 minute period during startup, shutdown, malfunction, soot blowing, grate cleaning, and cleaning of fires. 2 3 Activities Exempt from Visible Emission Standards Exceedances of the opacity standard in 2002 shall not be considered violations if the Owner or Operator demonstrates to the Division that such exceedances: a. Were the result of the adherence to good boiler operating practices which, in the long term, result in the most efficient or safe operation of the boiler; b. Occurred during periods of cold startup of a boiler over a continuous period of time resulting in efficient heat-up and stabilization of its operation and the expeditious achievement of normal operation of the unit; c. Occurred during periods of continuous soot blowing of the entire boiler tube section over regular time intervals as determined by the operator and in conformance with good boiler operating practice; or d. Were the result of the occurrence of an unplanned 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. Applicable Emission Unit Regulatory Basis (c) (d), (e), and (f) 1 2 Compliance with visible emission limitations shall be determined using 40 CFR 60, Appendix A, Method 9, upon request by the Division. Cleaning of fires means the adjusting of a combustion process to improve and optimize operation of the device. This includes the adjustment of the flame using visual and process information. ( )

6 Item # TP-0120 Page 6 of 10 Table 3 - Operating and Emission Limitations Requirement 4 Particulate Emission Standards for Fuel Burning Devices Installed on or After January 1, 1985 The particulate matter emissions from fuel burning devices installed on or after January 1, 1985 shall not exceed 0.30 lb/mmbtu. 5 Sulfur Content Limitations for Gaseous Fuels Gaseous fuels shall contain no more than 15 grains of sulfur per 100 cubic feet of gas at standard temperature and pressure. 6 Fuel Usage Limitation The amount of natural gas combusted in the temporary boiler shall be limited to million cubic feet per year. 7 The temporary boiler shall not be operated at any time that Auxiliary Boiler No. 1A is in operation. 8 Nitrogen Oxides (NOx) Reasonable Achievable Control Technology (RACT) Requirements for Boilers Firing Gas Exclusively The Owner or Operator shall install, operate and maintain low-nox burners (LNB) on the temporary boiler. Applicable Emission Unit Regulatory Basis & NTAB (w) (w)

7 V. Monitoring and Testing Requirements TP-0120 Page 7 of 10 The Owner or Operator is subject to the monitoring and testing requirements as contained in Table 4: Item # Table 4 - Monitoring and Testing Requirements Parameter Method of Compliance Frequency 1 To Be Determined 2 Sulfur content of gaseous fuels When conditions warrant, the Division may require the Owner or Operator to conduct stack testing in accordance with USEPA or other Division approved methods. Conduct testing to determine the sulfur content in grains of sulfur per 100 cubic feet, of gaseous fuels. Upon request by the Division Upon written request by EPA or the Division Applicable Unit Facility Wide Regulatory Basis RSA 125- C:6, XI VI. Recordkeeping Requirements Item # The Owner or Operator shall be subject to the recordkeeping requirements identified in Table 5: Table 5 - Recordkeeping Requirements Requirement 1 Record Retention and Availability Keep the required records on file. These records shall be available for review by the Division upon request. 2 General Recordkeeping Requirements for Combustion Devices Maintain the following records: a. Amount of fuel burned; b. Hours of operation; and c. Number of days temporary boiler remained at the facility. Duration/ Frequency Retain for a minimum of 5 years Applicable Unit Facility Wide Regulatory Basis 902 Monthly &

8 TP-0120 Page 8 of 10 VII. Reporting Requirements The Owner or Operator shall be subject to the reporting requirements identified in Table 6: Item # Table 6 - Reporting Requirements 1 Semi-annual Permit Deviation and Monitoring Report Submit a semi-annual permit deviation and monitoring report, which contains the following information for the reporting period: a. A summary of all permit deviations previously reported to the Department pursuant to Table 7, Items 2 and 3 of this Permit; b. A list of all permit deviation recorded pursuant to Table 7, Item 1; and c. A summary of monitoring required by applicable air permits. Frequency Semi-annually by July 31st (for period January 1 through June 30) and January 31st (for reporting period July 1 through December 31) Applicable Emission Unit Facility-wide Regulatory Basis (b) & Parts a. and b. of this condition supercede the condition contained in Table 11, Item 17J of Title V Operating Permit TV-OP-054. Part c. of this condition is satisfied by compliance with Table 11, Item 17 A) through I) of Title V Operating Permit TV-OP Annual Emissions Report Submit an annual emissions report which shall include the following information: a. Actual calendar year emissions from each emission unit of NO x, CO, SO 2, TSP, VOCs, and HAPs (speciated by individual HAP); b. The methods used in calculating such emissions in accordance with , Determination of Actual Emissions for Use in Calculating Emission-Based Fees; and c. All information recorded in accordance with Table 5, Item 2. Annually (received by DES no later than April 15th of the following year)

9 TP-0120 Page 9 of 10 VIII. Permit Deviation Recordkeeping and Reporting Requirements This section shall supersede Section XXVIII and Table 11, Item 19 of Title V Operating Permit TV-OP-054. The Owner or Operator shall be subject to the permit deviation recordkeeping and reporting requirements in Table 7 below, where permit deviation and excess emission are defined as follows: 101, Definitions: 1. A permit deviation is any occurrence that results in an excursion from any emission limitation, operating condition, or work practice standard as specified in either a Title V permit, state permit to operate, temporary permit or general state permit issued by the Division. 2. An excess emission is an air emission rate that exceeds any applicable emission limitation. Reporting a permit deviation is not affirmative defense for action brought for noncompliance. Item # Table 7 - Permit Deviation Recordkeeping and Reporting Requirements Requirement 1 Permit Deviation Recordkeeping In the event of a permit deviation, the Owner or Operator shall: a. Investigate and take corrective action immediately upon discovery of the permit deviation to restore the affected device, process, or air pollution control equipment to within allowable permit levels; and b. Record the following information: 1. The permit deviation; 2. The probable cause of the permit deviation; 3. The date of the occurrence; 4. The duration; 5. The specific device that contributed to the permit deviation; 6. Any corrective or preventative measures taken; and 7. The amount of any excess emission that occurred as a result of the permit deviation, if applicable. 2 Permit Deviation Reporting No Excess Emissions If the permit deviation does not cause excess emissions, but continues for a period greater than nine consecutive days, notify the Division of the subsequent corrective actions to be taken by (pdeviations@des.nh.gov), telephone ( ) or fax ( ). Frequency Each permit deviation On the tenth day of the permit deviation, unless it is a Saturday, Sunday, or state or federal legal holiday, in which event, the Division shall be notified on the next day which is not a Saturday, Sunday, or state or federal legal holiday Regulatory Basis

10 TP-0120 Page 10 of 10 Item # Table 7 - Permit Deviation Recordkeeping and Reporting Requirements Requirement 3 Permit Deviation Reporting Excess Emissions In the event of a permit deviation that causes excess emissions: a. Notify the Division of the permit deviation and excess emissions by , telephone or fax; and b. Submit a written report to the Division, which shall include the following information: 1. Facility name; 2. Facility address; 3. Name of the responsible official employed at the facility; 4. Facility telephone number; 5. Date(s) of the occurrence; 6. Time of the occurrence; 7. Description of the permit deviation; 8. The probable cause of the permit deviation; 9. Corrective action taken to date; 10. Preventative measures taken to prevent future occurrences; and 11. Date and time that the device, process, or air pollution control equipment returned to operation in compliance with an enforceable emission limitation, or operating condition; l2. The specific device, process or air pollution control equipment that contributed to the permit deviation; 13. The type and quantity of excess emissions emitted to the atmosphere due to the permit deviation; and 14. The calculation or estimation used to quantify the excess emissions. 4 Data Availability Permit Deviations In the event of a permit deviation caused by a failure to comply with the data availability requirements of 800: a. Notify the Division of the permit deviation by , telephone or fax; and b. Report the permit deviation to the Division, as part of the emissions report required pursuant to Frequency Notification: Within twenty-four (24) hours of discovery of the permit deviation, unless it is a Saturday, Sunday, or state or federal legal holiday, in which event, the Division shall be notified on the next day which is not a Saturday, Sunday, or state or federal legal holiday Written Report: Within ten (10) days of discovery of the permit deviation Notification: Within 10 days of discovery of the permit deviation Written Report: Within 30 calendar days after the end of the calendar quarter Regulatory Basis (c)