State of New Hampshire Department of Environmental Services Air Resources Division State Permit to Operate Facility ID No: 3301100173 Permit No: FP-S-0193 County: Hillsborough Date Issued: July 12, 2004 Amended December 8, 2005 This certifies that: has been granted a State Permit to Operate for: 2 Boilers, 2 Emergency Generators and 9 Wet Fan Fume Scrubbers 91 Northeastern Boulevard, Nashua, NH which includes devices that emit air pollutants into the ambient air as set forth in the permit application filed with the New Hampshire Department of Environmental Services, Air Resources Division (Division) on March 9, 2004, in accordance with RSA 125-C of the New Hampshire Laws. Request for permit renewal is due to 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 July 31, 2009. This permit is valid provided that each device is operated in accordance with all the legally enforceable conditions specified within this permit. I. The Owner or Operator shall be subject to all applicable state and federal air pollution control regulations, including (but not limited to): A. The New Hampshire Code of Administrative Rules Env-A 100 et seq., New Hampshire Rules Governing the Control of Air Pollution; and B. The Code of Federal Regulations (CFR), 40 CFR Part 60, Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units. II. All equipment, facilities and systems installed and used to achieve compliance with the terms and conditions of this permit shall at all times be maintained in good working order and be operated as efficiently as possible to minimize air pollutant emissions. SEE ATTACHED SHEETS FOR ADDITIONAL PERMIT CONDITIONS The Owner or Operator of the devices covered by this permit shall submit an application for a permit amendment to the Division at least 90 days prior to the implementation of any proposed change (unless authorized by this permit) to the physical structure or operation of the devices covered by this permit which increases the amount of a specific air pollutant currently emitted by such devices or which results in the emission of any regulated air pollutant currently not emitted by such devices. The change shall not take place until a new permit application is submitted and acted upon by the Director pursuant to Env-600. This permit (or a copy) should be appropriately displayed near the devices for which it is issued. Director Air Resources Division
July 12, 2004 amended December 8, 2005 FP-S-0193 Page 2 of 9 Abbreviations and Acronyms AAL Ambient Air Limit NO X Oxides of Nitrogen ags above ground surface PM 10 Particulate Matter < 10 microns Btu British thermal units RTAP Regulated Toxic Air Pollutant CFR Code of Federal Regulations scf standard cubic foot CO Carbon Monoxide SO 2 Sulfur Dioxide EG Emergency Generator TSP Total Suspended Particulate ft 2 square feet tpy tons per consecutive 12-month period HAP Hazardous Air Pollutant USEPA United States Environmental Protection Agency hr Hour VOC Volatile Organic Compound lb Pound WFFS Wet Fan Fume Scrubber MM million III. Operating Conditions A. This permit covers the devices identified in Tables 1 and 2 and replaces permits previously issued for these devices: Device Boiler 1 Boiler 2 Standby EG 1486 hp Life Safety EG 170 hp Manufacturer, Model No. and Serial No. Cleaver Brooks CB 400-250 & L-78501 Cleaver Brooks CB 439-350 & L-47183 Hanover 6041 & unknown Kohler 45RZ82 & 387324 Table 1 Device Identification Fuel Burning Devices Install Date May 1981 June 2001 June 2000 June 1997 Nameplate Rating in MMBtu/hr Permitted Fuel Type 10.4 MMBtu/hr Natural gas - equivalent to 10,200 scf/hr 1 14.6 MMBtu/hr Natural gas - equivalent to 14,300 scf/hr 11.2 MMBtu/hr Natural gas - equivalent to 11,000 scf/hr 0.69 MMBtu/hr Natural gas - equivalent to 675 scf/hr B. The fuel consumption for the two boilers combined shall be limited to 214.7 MMscf of natural gas in any consecutive 12-month period. C. Env-A 1605.01, Maximum Sulfur Content Allowable in Gaseous Fuels: The sulfur content of natural gas combusted in any of the boilers and emergency generators (EGs) shall be limited to 15 grains of sulfur per 100 scf of natural gas, calculated as hydrogen sulfide at standard temperature and pressure. D. Env-A 1211.02(o), emergency generator : The EGs shall only operate: 1. As a mechanical or electrical power source and only when the primary power source for the Facility has been lost during an emergency such as a power outage; or 2. During normal maintenance and testing as recommended by the manufacturer. E. Env-A 1211.01(j)(1), Applicability: The hours of operation of each EG shall be limited to 500 hours during any consecutive 12-month period. 1 The hourly fuel rates presented in Table 1 are set assuming a heating value of 1,020 Btu/scf for natural gas.
July 12, 2004 amended December 8, 2005 FP-S-0193 Page 3 of 9 III. Operating Conditions (continued) Table 2 Device Identification Wet Fan Fume Scrubbers (WFFS) Process Line Control Device Make Model No. Job No. Date Installed Penc 1 WFFS 1 MAPCO MW-100 12427 May 1997 East WFFS 2 DUALL F-101 2909 1984 West WFFS 3 DUALL F-101 2909 1984 Etcher WFFS 4 MAPCO MW-100 11327 Sept. 1995 WWTP WFFS 5 MAPCO MW-100 12646 July 1997 DESD WFFS 6 MAPCO MW-100 12646 July 1997 LPI WFFS 7 MAPCO MW-100 13106 Nov. 1998 ASF/Prep WFFS 8 MAPCO MW-100 14159 Oct. 1999 Penc 2 WFFS 9 MAPCO MW-100 15235 Jan. 2001 IV. F. Env-A 1400, Regulated Toxic Air Pollutants: Emissions of Regulated Toxic Air Pollutants (RTAPs) from the process lines identified in Table 2 shall be controlled in accordance with Condition VI to maintain compliance with Condition IV.F. Emission Limitations A. Hourly and annual emissions from individual devices shall be limited as provided in Table 3: Table 3 Emission Limitations for Criteria Pollutants 2 Device CO NO x PM 10 SO 2 VOCs Hourly Emission Limitations (lb/hr) Boiler 1 0.86 1.0 0.08 0.01 0.06 Boiler 2 1.2 1.4 0.11 0.01 0.08 Standby EG 6.2 9.5 0.01 0.01 1.3 Life Safety EG 0.38 0.58 0.01 0.01 0.08 Annual Emission Limitations (tpy) 3 2 Boilers Combined 9.02 10.74 0.82 0.064 0.59 2 EG Combined 1.66 2.52 0.01 0.01 0.35 9 WFFS Not applicable Not applicable Not applicable Not applicable 9.9 B. Env-A 2003.02, Visible Emission Standard for Fuel Burning Devices Installed After May 13, 1970: The opacity of emissions from each boiler and each EG shall not exceed 20 % for any continuous 6-minute period 4. 2 3 4 The emission limitations for the fuel burning devices in Table 3 are set based on United States Environmental Protection Agency (USEPA) AP-42 (5 th Edition 1/1995, updated 7/98), Section 1.4, Natural Gas Combustion (updated 7/98) and Section 3.2, Natural Gas Fired Reciprocating Engines (updated 7/00). Compliance with emission limitations found in this section is to be verified using fuel utilization records and the appropriate emission factors. The Facility does not have the potential to emit the criteria pollutants NO x and SO 2, CO, PM 10 or VOCs, or Hazardous Air Pollutants (HAPs, as defined in Section 112 of the 1990 Clean Air Act Amendments) at levels greater than the major source thresholds for these pollutants. Therefore, the Facility is a true minor source for these pollutants. Compliance with visible emission limitations is to be determined using 40 CFR 60, Appendix A, Method 9. Steam/water
July 12, 2004 amended December 8, 2005 FP-S-0193 Page 4 of 9 IV. Emission Limitations (continued) C. Env-A 2107.01 Visible Emission Standards: The opacity from each WFFS shall not exceed 20 percent for any continuous 6-minute period. D. Env-A 2003.07, Particulate Emission Standards for Fuel Burning Devices Installed on or after May 13, 1970 but before January 1, 1985: The emissions of TSP from Boiler 1 shall be limited to 0.59 lb/mmbtu. E. Env-A 2003.08, Particulate Emission Standards for Fuel Burning Devices Installed on or After January 1, 1985: The emissions of TSP from Boiler 2 and each generator shall be limited to 0.30 lb/mmbtu. F. Env-A 1400: Facility-wide emissions of any RTAP shall not cause an exceedance of its associated 24-hr or annual Ambient Air Limit (AAL) as set forth in Env-A 1450, Table Containing the List Naming All Regulated Toxic Air Pollutants. At the time of permit issuance, the RTAPs in Attachment A were reviewed and determined to be in compliance. V. Process Changes A. For the purposes of this permit, a Process Change is defined as: 1. The change, addition, or removal of a process line; 2. The removal of WFFS listed in Condition VI, or addition of equivalent control devices; 3. The change, addition, or removal of stacks listed in Condition VII, or change in the processes and/or control devices that discharge through those stacks. B. The Owner or Operator may make Process Changes without requiring revisions or amendments to this permit as long as: 1. The Process Change does result in an exceedance of any emission limitation in Condition IV, and 2. The Process Change does not cause the facility to become subject to any requirements not covered in this permit. C. The Owner or Operator shall provide written notification to the Division of each Process Change within 15 days of making the change. Such notification shall include: 1. A description of the change; 2. A description of the resulting facility setup including processes, control devices, and stacks; 3. The date on which the change occurred; and 4. Documentation demonstrating compliance with the emission limitations in Condition IV. D. Any Process Change made pursuant to this permit condition that is later determined to either not qualify as a Process Change or violates any applicable requirement or permit condition shall be considered a violation of this permit. vapor is not included in Method 9 observations.
July 12, 2004 amended December 8, 2005 FP-S-0193 Page 5 of 9 VI. VII. Air Pollution Control Equipment A. Control of the emissions of RTAPs from the plating processes is required. Plating processes that require control to meet Env-A 1400 shall operate only when the associated WFFS is operating. Teradyane shall determine and document which plating processes can remain operational while its associated fume scrubber is not operational. Control equipment shall be maintained in good working order and, at a minimum, meet the maintenance and monitoring requirements as recommended by the manufacturer and presented in Teradyne s Fume Scrubber Equipment Inspection and Preventative Maintenance Procedure. B. The WFFS shall maintain the following minimum removal efficiencies: 2 Butoxy Ethanol 90% Formic Acid 90% Nitric Acid 77.5% Ammonia 80% Glycol Ether 90% Phosphoric Acid 90% EGMEA 90% Hydrochloric Acid 90% Potassium Hydroxide 90% EGNBE 90% Isopropyl Alcohol 90% Sulfuric Acid 97% Formaldehyde 90% Monoethanolamine 90% Stack Criteria The following devices at the Facility shall have exhaust stacks that discharge vertically, without obstruction, and meet the criteria in Table 4: Table 4 Stack Criteria Device No. Boilers WFFS 1 2 1 2 3 4 5 6 7 8 9 Minimum Height (ft ags) 30 38 33 37 37 32 42 41 43 43 44 Maximum Exit Area (ft 2 ) 2.01 2.01 3.14 16.8 16.8 5.31 3.14 9.62 9.62 4.91 6.29 VIII. Stack Testing Requirements When conditions warrant, the Division may require the Owner or Operator to conduct stack testing in accordance with USEPA or other Division approved methods. IX. Recordkeeping Requirements A. Env-A 902, Availability of Records: The Owner or Operator shall keep the records required by this permit on file for a minimum of 5 years. These records shall be available for review by the Division upon request. B. Except for information that meets the criteria of Env-A 103, Claims of Confidentiality, all data submitted to the Division, including emission data and applicable emission limitations, shall be available to the public. C. Env-A 903.02, General Recordkeeping Requirements for Process Operations: The Owner or Operator shall maintain the following records, on a monthly basis, of the raw material utilization in the processes controlled by the WFFS including the following data: 1. The total quantities of raw materials utilized in each process which are required to calculate emissions, verify applicability and compliance with emission limitations, or to verify production capacities and quantities; 2. The distribution of raw materials usage, or other appropriate data for each process so that the distribution of emissions among the emission points can be estimated, and 3. The Fume Scrubber Equipment Inspection and Preventative Maintenance Procedure shall be maintained at the Facility & be available for review by the Division upon
July 12, 2004 amended December 8, 2005 FP-S-0193 Page 6 of 9 request. IX. Recordkeeping Requirements (continued) D. Env-A 903.03, General Recordkeeping Requirements for Combustion Devices: The Owner or Operator shall maintain the following records, on a monthly basis, of fuel characteristics and utilization for the fuel used in the combustion devices: 1. The hours of operation; 2. The amount of natural gas burned in each device and the hours of operation of each device to be used to apportion fuel use between the multiple devices; and 3. Sulfur content of gaseous fuel burned in terms of grains sulfur per scf fuel, or percent sulfur by weight, calculated as hydrogen sulfide at standard temperature and pressure. E. Env-A 905.02, General NO x Recordkeeping: If the actual annual NO x emissions from the Facility are greater than or equal to 10 tpy, the Owner or Operator shall record the following information: 1. Identification of each combustion device; and 2. Operating schedule during the high ozone season, (June 1 through August 31) for each combustion device identified in Condition IX.E.1, including: a. Hours and days of operation per calendar month; b. Number of weeks of operation; c. Type and amount of each fuel burned; d. Heat input rate in MMBtu/hr; e. Actual NO x emissions for the calendar year and a typical high ozone day during that calendar year; and f. Emission factors and the origin of the emission factors used to calculate the NO x emissions. F. Env-A 1406.01, Methods of Demonstrating Compliance: The Owner or Operator shall maintain records demonstrating compliance with the most recent list of RTAPs and associated AALs presented in Env-A 1450. G. 40 CFR 60, Subpart Dc: The Owner or Operator shall maintain records for Boiler 2 sufficient to ascertain the amount of natural gas consumed during each calendar month (e.g., records of natural gas consumed in the boilers during the month and hours of operation for each boiler. X. Reporting Requirements A. Env-A 907.01, General Reporting Requirements: 1. The Owner or Operator shall submit an annual emissions report to the Division on or before April 15 th of the following year. For example, the annual emissions report for calendar year 2004 shall be submitted on or before April 15, 2005; and 2. The annual emissions report shall include the following information: a. Actual calendar year emissions from each boiler, of NO x, CO, PM 10, SO 2, TSP, and VOCs; b. Actual calendar year emission from the processes of VOCs (speciated by individual VOC) and RTAPs (speciated by individual RTAP); c. The methods used in calculating such emissions in accordance with Env-A 704.02, Determination of Actual Emissions for Use in Calculating Emission-based Fees; and d. All information recorded in accordance with Conditions IX.C and IX.D.
July 12, 2004 amended December 8, 2005 FP-S-0193 Page 7 of 9 X. Reporting Requirements (continued) XI. B. Env-A 909, NO x Emission Statements Reporting Requirements: If the actual annual NO x emissions from the Facility are greater than 10 tpy, the Owner or Operator shall: 1. Break down the NO X emissions reported pursuant to Condition X.A.2.a by month; and 2. Include all data recorded pursuant to Condition IX.E in the annual emissions report required in Condition X.A. C. 40 CFR Part 60, Subpart Dc: The Owner or Operator shall submit, to the Division and to USEPA Region 1, the Subpart Dc report described below. The address for USEPA Region 1 is: Chief, Air Technical Unit U.S. Environmental Protection Agency Region 1 One Congress Street Suite 1100 Mail Code SEA Boston, MA 02203-2211 Fuel Certification Reports: The Owner or Operator shall submit an annual fuel certification report, postmarked no later than 30 days after the end of the reporting period, that includes the following information: 1. The calendar dates covered in the reporting period; 2. The type of fuel combusted during the reporting period; and 3. A certified statement signed by the Owner or Operator of the Facility that the data submitted represents all of the fuel combusted during the reporting period. Permit Deviation Reporting Requirements A. Env-A 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. B. Env-A 911.04(b), Reporting Requirements: In the event of a permit deviation that causes excess emissions, the Owner or Operator shall notify the Division of the permit deviation and excess emissions by telephone (603-271-1370), fax (603-271-7053) or e-mail (pdeviations@des.state.nh.us), within 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.
July 12, 2004 amended December 8, 2005 FP-S-0193 Page 8 of 9 XII. Emission-Based Fee Requirements A. Env-A 704.03, Calculation of Emission-based Fees: The Owner or Operator shall pay an emission-based fee annually as calculated each calendar year for the devices listed in Condition III, Table 1 and Table 2 of this permit. B. Env-A 616, Determination of Actual Emissions: The Owner or Operator shall determine the total actual annual emissions from these devices for each calendar year in accordance with the methods specified in Env-A 616. C. The Owner or Operator shall calculate the annual emission-based fee for each calendar year in accordance with the procedures specified in Env-A 704.03 and the following equation: FEE = E * DPT * CP Im* ISF Where: FEE = The annual emission-based fee for each calendar year as specified in Env-A 704. E = The emission-based multiplier is based on the calculation of total annual emissions as specified in Env-A 704.02 and the provisions specified in Env-A 704.03(a). DPT = The dollar per ton fee the Division has specified in Env-A 704.03(b). CPIm = The Consumer Price Index Multiplier as calculated in Env-A 704.03(c). ISF = The Inventory Stabilization Factor as specified in Env-A 704.03(d). D. The Owner or Operator shall contact the Division each calendar year for the values of the Inventory Stabilization Factor and the Consumer Price Index Multiplier. E. Env-A 704.04, Payment of Emission-based Fee: The Owner or Operator shall submit, to the Division, payment of the emission-based fee for each calendar year by October 15 th of the following calendar year. The fee 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
July 12, 2004 amended December 8, 2005 FP-S-0193 Page 9 of 9 ATTACHMENT A List of RTAPs and Emission Rates Evaluated RTAP Chemical Abstracts Service Number Emission Rate (lb/day) Compliance Determination Method 2 Butoxy Ethanol 141-73-5 0.19 De minimus Ammonia 7664-41-7 5.18 In-stack Ethylene Glycol Monobutyl Ether Acetate 112-07-2 1.54 De minimus Ethylene Glycol N-Butyl Ether 111-76-2 0.03 De minimus Formaldehyde 50-00-0 0.120 De minimus Formic Acid 64-18-6 0.12 De minimus Glycol Ether 107-98-2 0.187 De minimus Hydrochloric Acid 7647-01-0 4.584 In-stack Isopropyl Alcohol 67-63-0 2.16 De minimus Nitric Acid 7697-37-2 10.425 In -stack Phosphoric Acid 7664-38-2 0.024 De minimus Potassium Hydroxide 1310-58-3 0.90 In-stack Sulfuric Acid 7664-93-9 1.823 In Stack Notes: 1. This list does not set limits on the type or amount of RTAPs emitted. The list serves to identify the RTAPs and associated facility-wide emission rates that were evaluated by DES at the time the permit was issued, and that were determined to be in compliance with Env-A 1400. 2. Emission rates shown represent controlled emissions for RTAPs where controls are required pursuant to Condition III.F. 3. Annual emissions were evaluated based on continuous operation of all nine WFFS (8760 hrs/yr). 4. If the Owner or Operator intends to emit RTAPs that do not appear on this list, or increase emission rates of any RTAPs appearing on this list, they must document (in accordance with Condition V) that the emissions resulting from such changes are in compliance with Env-A 1400 (as required by Condition IX.F). 5. Actual emissions of these RTAPs, and any RTAPs subsequently emitted that are not on this list, shall be included in the annual emissions report required in Condition X.A.