The State of New Hampshire DEPARTMENT OF ENVIRONMENTAL SERVICES. Robert R. Scott, Commissioner. December 26, 2017

Transcription

1 The State of New Hampshire DEPARTMENT OF ENVIRONMENTAL SERVICES Robert R. Scott, Commissioner December 26, 2017 Michael O Leary, Asset Manager Bridgewater Power Company, LP PO Box 678 Ashland, NH RE: On-Site Full Compliance Evaluation Report Dear Mr. O Leary: The New Hampshire Department of Environmental Services, Air Resources Division (NHDES) has completed a Full Compliance Evaluation of Bridgewater Power Company, LP facility (Bridgewater) located in Bridgewater, NH. The purpose of the evaluation was to determine compliance with its Title V Operating Permit (TV-0008). The compliance evaluation included an on-site inspection completed on December 8, This is a copy of the On-Site Full Compliance Evaluation Report for your review and records. NHDES identified deficiencies during this compliance evaluation, as detailed in this report. If you have any questions, please contact David Smith at (603) or by at david.smith@des.nh.gov. Sincerely, David Smith Senior Compliance Assessment Engineer Air Resources Division cc: Board of Selectmen, Town of Bridgewater, 297 Mayhew Turnpike, Bridgewater, NH DES Web site: P.O. Box 95, 29 Hazen Drive, Concord, New Hampshire Telephone: (603) Fax: (603) TDD Access: Relay NH

2 Abbreviations and Acronyms AAL acf ags ASTM Btu CAS CEMS cfm CFR CO DER Env-A ERC ft ft 3 gal HAP hp hr kw lb LPG MM MSDS MW NAAQS NHDES NOx NSPS PM 10 ppm psi RACT RATA RSCR RTAP scf SNCR Ambient Air Limit actual cubic foot above ground surface American Society of Testing and Materials British thermal units Chemical Abstracts Service Continuous Emissions Monitoring System cubic feet per minute Code of Federal Regulations Carbon Monoxide Discrete Emission Reduction New Hampshire Code of Administrative Rules Air Resources Division Emission Reduction Credit foot or feet cubic feet gallon Hazardous Air Pollutant horsepower hour kilowatt pound Liquefied Petroleum Gas million Material Safety Data Sheet megawatt National Ambient Air Quality Standard New Hampshire Department of Environmental Services Oxides of Nitrogen New Source Performance Standard Particulate Matter < 10 microns parts per million pounds per square inch Reasonably Available Control Technology Relative Accuracy Test Audit Regenerative Selective Catalytic Reduction Regulated Toxic Air Pollutant standard cubic foot Selective Non-Catalytic Reduction Page 2 of 52

3 SO 2 TSP tpy USEPA VOC Sulfur Dioxide Total Suspended Particulate tons per consecutive 12-month period United States Environmental Protection Agency Volatile Organic Compound Page 3 of 52

4 I. Facility Description NHDES conducted an On-Site Full Compliance Evaluation of the Bridgewater Power Company, LP (Bridgewater) on December 8, 2017 and the results are presented herein. The compliance evaluation covers the period from 2016 to December 8, Bridgewater has a wood-fired power plant with a gross electricity generation capacity of 15 MW. Bridgewater produces electricity by the combustion of whole wood chips (having up to 50 percent moisture content) in a Foster Wheeler Treebrook overfeed, air swept, vibrating grate, stoker boiler. The boiler has a maximum heat input rate of 250 MMBtu/hr. In addition, the facility has a diesel-fired emergency generator rated at 1.8 MMBtu/hr gross heat input (269 hp) that provides emergency lighting at the facility. Additionally, the facility has an emergency diesel-fired fire pump rated at 1.1 MMBtu/hr gross heat input (121 hp). The facility is a major source of NOx and CO emissions and, therefore, requires a Title V Permit. Bridgewater operates a RSCR system with two burners, which use 2 fuel oil. Emissions from the burners are combined with the 2 fuel oil emissions from the wood-fired boiler. Facility name and address County Telephone (603) AFS Source Type Inspection Date/Time Inspection Type Weather Bridgewater Power Company, LP 300 RTE 3 Bridgewater, New Hampshire Grafton Title V December 8, 2017, 8:30 a.m. On-Site Full Compliance Evaluation 28 degrees, sunny, calm winds Inspection Period 2016 to December 8, 2017 Inspected by David Smith, Senior Compliance Assessment Engineer Source Contact(s) Michael O Leary, Asset Manager Peter Mather, Operations Manager Last Inspection February 19, 2016 Last Inspection Results: 1. During the last inspection guidance was given to change the calculation approach for determining the 365 day rolling hourly average for CO and NOx. Bridgewater has incorporated this guidance into their calculation approach accordingly. 2. Bridgewater had reported multiple opacity exceedances and took prompt and Page 4 of 52

5 effective corrective actions. 3. Several RAA and RATA reports had been submitted late. RAA and RATA reports were submitted timely for the current inspection period. Below is the permitting timeline for this facility. Permitting Timeline Permit TV-0008 Issued January 2, 2013 Expires January 31, 2018 A permit renewal application for TV-0008 was filed on July 5, The on-site inspection included an opening meeting to discuss the purpose of the inspection as well as the rules pertaining to claims of confidentiality and facility safety concerns. Bridgewater agreed to the inspection and authorized access. Material provided and operations conducted by the facility at the time of the inspection were not claimed as confidential. II. Emission Unit Identification and Facility Wide Emissions Table 1 below, taken from Permit TV-0008, lists the permitted emission units as verified during the inspection. Table 1 - Significant Activities Emission Unit ID Description of Emission Unit Installation Date Maximum Design Capacity and Permitted Fuel Types EU01 Wood/Oil-fired Boiler Foster Wheeler Model Unknown Serial 6770 Peabody Engineering Burner Model BCT AA Burner Serial MMBtu/hr Equivalent to 165,000 lb steam/hr averaged over a 24-hour period at 850 F, 695 psig, with a boiler efficiency of 68%, boiler feedwater temperature of 340 F, and chip moisture content of 50% Whole tree wood chips and mill residue at approximately 8.8 MMBtu/ton (at 50% moisture); Untreated wood fuel ranging from approximately 8.8 to 14 MMBtu/ton at 20-50% moisture; No. 2 fuel oil; and On-spec used oil that meets the contaminants levels identified in Table 4 3 at a maximum of 0.4% sulfur by weight. Page 5 of 52

6 Table 1 - Significant Activities Emission Unit ID Description of Emission Unit Installation Date Maximum Design Capacity and Permitted Fuel Types EU02 Emergency Generator Caterpillar Model 3208TB Serial 30A MMBtu/hr Max. fuel usage = 13.1 gal/hr diesel fuel 269 HP EU03 Emergency Fire Pump Caterpillar Model 3208 Serial 90N MMBtu/hr Max. fuel usage = 8.0 gal/hr 121 HP EU04 Cooling Pond 1987 Circulation rate =15,800 gallons per minute EU05 Package Oil Fired Boiler MMBtu/hr Maximum fuel usage = gal/hr No. 2 Fuel Oil Note: EU05 is below the state permitting threshold in Env-A 607. However, the device is subject to EPA s area source boiler rule codified in 40 CFR 63 Subpart JJJJJJ and, therefore, has been included in Table 1 as a significant activity in accordance with Title V permitting policy guidelines. NHDES observed the devices identified in this table and the facility has made no changes to these devices nor has it added devices classified as significant or insignificant activities. During the inspection the following hour meter data was collected from the emergency generator and fire pump engine: Unit Emergency Generator Caterpillar (EU02) Caterpillar Fire Pump Engine (EU03) Hour Meter Reading as of 2/19/2016 (hours) Hour Meter Reading as of 12/08/2017 (hours) Operating Hours The table below lists the permitted device reported annual emissions for the review period. Total Permitted Device Emissions (tpy) PM 10 SO 2 NOx CO VOCs Non VOC HAP / Total RTAPS Permitted Limits Page 6 of 52

7 Bridgewater uses a combination of stack test, CEM, and AP-42 emission factors to report its facility emissions. III. Stack Criteria Table 2 below, taken from Permit TV-0008, lists the permitted stack requirements for the facility. During the inspection, NHDES observed that the stack was vertical and unobstructed, with no modifications. Table 2 - Stack Criteria Stack Emission Unit Minimum Height (feet above ground surface) Maximum Exit Diameter (feet) Stack 1 Boiler (EU01) IV. Control Equipment Table 3 below, taken from Permit TV-0008, lists the required control equipment for the facility s devices, as verified during the inspection. Table 3 Pollution Control Equipment Identification Pollution Control Equipment Number (PCE) Description of Equipment Activity PCE1 Multi-cyclone (Multiclone) Primary particulate matter control for EU01. PCE2 Gravel Bed Filter (GBF) Secondary particulate matter control for EU01. PCE3 Baghouse-Reverse Jet Pulse Final particulate matter control for PCE2. PCE4 Regenerative Selective Catalytic Reduction (RSCR) System Nitrogen oxide control for EU01. Note: PCE4 was installed voluntarily by Bridgewater and as such, Bridgewater may operate this device at its discretion. In addition, Bridgewater has added an additional catalyst to reduce CO emissions by 30 %. The CO catalyst is positioned as the final layer of catalyst in the PCE4 RSCR system. The installation was completed in May of 2015 and NHDES was notified. Page 7 of 52

8 V. Compliance with Operating and Emission Limitations Table 4 below taken from Permit TV-0008, lists the State-only operation and emission limitations for the facility, and any deficiencies noted during the evaluation. Table 4 - State-only Enforceable Operational and Emission Limitations Requirements Emission Unit Citation 24-hour and Annual Ambient Air Limit Facility Wide Env-A The emissions of any Regulated Toxic Air Pollutant (RTAP) shall not cause an exceedance of its associated 24-hour or annual Ambient Air Limit (AAL) as set forth in Env-A , Table Containing the List Naming All Regulated Toxic Air Pollutants. Revisions of the List of RTAPs Facility Wide RSA 125-I:5 IV 2. In accordance with RSA 125-I:5 IV, if the Division revises the list of RTAPs or their respective AALs or classifications under RSA 125-I:4, II and III, and as a result of such revision the Owner or Operator is required to obtain or modify the permit under the provisions of RSA 125-I or RSA 125-C, the Owner or Operator shall have 90 days following publication of notice of such final revision in the New Hampshire Rulemaking Register to file a complete application for such permit or permit modification. Not Findings: Bridgewater did not determine, within 90 days following the publication of notice of the revision to Env-A 1400, whether it needed to apply for a permit or modify its existing permit as a result of the latest revision to the AALs in Env-A A compliance demonstration pursuant to Env-A 1400 was performed on December 8 th, 2017 and from this demonstration, it was determined that Bridgewater did not need to obtain or modify the permit. Page 8 of 52

9 Table 4 - State-only Enforceable Operational and Emission Limitations Requirements Emission Unit Citation 3. On Spec Used Oil Fuel Usage Limitations On-spec used oil fuel consumption shall be limited to 4,187 gallons in any consecutive 24-hour period and in accordance with the following: a. The used oil has not been mixed with hazardous waste; and b. The oil meets all of the standards in the Table below and does not otherwise exhibit any of the hazardous waste characteristics specified in Env-Hw 403 Used Oil Constituents Constituent Max. Concentration Dry weight basis (PPM) Arsenic 5 Cadmium 2 Chromium 10 Lead 100 Total Halogens 1,000 PCBs 2 Flashpoint 100 o F minimum temperature c. Generators storing used oil on-site shall comply with the requirements of Env-Hw (b). Sampling and analysis of used oil shall be conducted in accordance with Env-Hw EU01 Env-A 1400 Env-Hw Env-Hw (b) Env-Hw & TP-B-0533 Findings: Bridgewater burned 813 gallons of used oil all of which was generated from onsite automotive sources. Precautions to Prevent, Abate, and Control Fugitive Dust Facility wide Env-A The Owner or Operator shall take precautions to prevent, abate, and control the emission of fugitive dust. Such precautions shall include but are not limited to wetting, covering, shielding, or vacuuming. Findings: The majority of the Bridgewater property is paved and dust is controlled using sweeping and watering equipment. On the day of the inspection, no fugitive dust was observed. 11. Activities Exempt from Visible Emission Standards Exceedances of the opacity standard in Env-A 2002 shall not be considered violations if the Owner or Operator demonstrates to the Division that such exceedances: EU01 Env-A (d), (e), and (f) and TP-B-0533 a. Were the result of the adherence to good Page 9 of 52

10 Table 4 - State-only Enforceable Operational and Emission Limitations Requirements boiler operating practices which, in the long term, result in the most efficient or safe operation of the boiler; Emission Unit Citation 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 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. 12. Activities Exempt from Visible Emission Standards The average opacity shall be allowed to be in excess of those standards specified in Env-A for one period of 6 continuous minutes in any 60 minute period during startup, shutdown and malfunction. EU02, EU03 Env-A (c) effective (formerly Env-A 1202) Table 5 below, taken from Permit TV-0008, lists the Federal enforceable operation and emission limitations for the facility, and any deficiencies noted during the evaluation. Table 5 - Federally Enforceable Operational and Emission Limitations Requirement Emission Unit Cite 1. NSPS Particulate Matter Emission Limit Particulate matter emissions from the wood-fired boiler shall be limited to 0.10 lb/mmbtu of heat input. EU01 40 CFR 60.43b(c)(1) Subpart Db Finding: Results from the 8/28/2014 Stack Test were lb/mmbtu. Therefore, Bridgewater is in compliance with this condition. Page 10 of 52

11 Table 5 - Federally Enforceable Operational and Emission Limitations Requirement Emission Unit Cite 2. Opacity Limit The opacity from the wood-fired boiler shall not exceed 20% (6-minute average), except for one 6- minute period per hour of not more than 27% opacity. Compliance with the opacity limit shall be determined using a continuous opacity monitoring system. EU01 40 CFR 60.43b(f) Subpart Db & Env-A No Findings: Bridgewater reported opacity exceedances on two occasions during the evaluation period. The causes of the exceedances were determined and the necessary corrective action taken. See Section IX for more information on the reported deviations. Opacity from the main stack during the inspection was determined to be less than 5 %. 3. NSPS Particulate Matter and Opacity Standards The particulate matter and opacity standards apply at all times, except during periods of startup, shutdown, or malfunction. EU01 40 CFR 60.43b(g) Subpart Db 4. NOx RACT for Utility Boilers NOx emissions from the wood-fired boiler shall not exceed 0.33 lb/mmbtu, based on a 24-hour calendar day average. EU01 Env-A (c)(1) (formerly Env-A (c)(5)(a)) Finding: Results from CEM data for the compliance period show that the NOx emissions are less than 0.33 lb/mmbtu. 5 Annual Capacity Limitation for Liquid Fuels The owner or operator is opting out of Subpart Db NOx emissions limitations: a. By limiting the annual No. 2 fuel oil and onspec used oil capacity factor to less than 10% of the annual capacity; and b. The nitrogen content of No. 2 fuel oil and onspec used oil combusted in the Boiler shall be less than 0.3% by weight. EU01 40 CFR 60 Subpart Db Section 60.44b(j) and (k) & TP-B-0533 Finding: a. The use of 2 fuel oil and on-spec used oil is 1.0% of the annual capacity factor for 2016, which meets the requirement of less than 10%. b. Bridgewater received documentation from its fuel vendor that the nitrogen content of the 2 fuel oil is less than 0.1% by weight, which meets the requirement of less than 0.3%. Bridgewater retains documentation that demonstrates nitrogen content of automotive oil is below 0.1%, which meets the criteria of 0.3%. 6 Prevention of Significant Deterioration (PSD) Avoidance To avoid the federal PSD program, facility wide emissions of carbon monoxide (CO) and Nitrogen Oxide (NOx) shall be limited to less than 250 tons Facility Wide 40 CFR Page 11 of 52

12 Table 5 - Federally Enforceable Operational and Emission Limitations Requirement Emission Unit Cite during any consecutive 12-month period (b)(1)(i)(b) 7. Prevention of Significant Deterioration Avoidance To avoid the federal PSD program, CO and NOx emissions from the wood-fired boiler shall not exceed 57.0 lb/hr each averaged over any consecutive 365-day period. Compliance with this emission limit shall be demonstrated using the CO and NOx CEMS. EU01 40 CFR 52.21(b)(1)(i)(b) (July 1, 2001 edition) & Findings: Bridgewater installed a CO catalyst in May 2015 to ensure compliance with this condition as stated in Section 4 of this report and did not report any exceedances of this condition during the evaluation period. Particulate Matter Pollution Control Equipment EU01 TP-B The multiclone, gravel bed filter and reverse jet pulse baghouse for the gravel bed filter (PCE1, PCE2, PCE3) shall not be bypassed during startup, operation, or shutdown of the steam generating unit. 9 Ammonia Slip Emissions Limit EU01, PCE3 TP-B-0533 Ammonia slip emissions from the wood-fired boiler shall be limited to 20 6% oxygen (O 2 ). Finding: Annual Ammonia slip testing results were as follows: % O 2 ; % O 2. Therefore, Bridgewater is in compliance with this condition. Page 12 of 52

13 Table 5 - Federally Enforceable Operational and Emission Limitations Requirement Emission Unit Cite Activities Exempt from Visible Emission Standards For those steam generating units subject to 40 CFR 60, no more than one of the following two exemptions shall be taken: EU01 Env-A (a) and TP-B a. During periods of startup, shutdown and malfunction, average opacity shall be allowed to be in excess of 20% for one period of 6 continuous minutes in any 60-minute period; or b. During periods of normal operation, soot blowing, grate cleaning, and cleaning of fires, average opacity shall be allowed to be in excess of 20% but not more than 27% for one period of 6 continuous minutes in any 60- minute period. 11. NSPS General Provisions a) At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source EU01 40 CFR 60.11(d) & 40 CFR 60.11(g) b) For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any standard in this part, nothing in this part shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. Page 13 of 52

14 Table 5 - Federally Enforceable Operational and Emission Limitations Requirement Emission Unit Cite 12. 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. EU02, EU03 Env-A effective (formerly Env-A 1202) Unknown Finding: The opacity from EU02 and EU03 could not be verified because these devices were not in operation during the inspection. However, at the time the permit was issued, NHDES had sufficient information to indicate that under normal operating conditions, these devices are capable of meeting this permit condition. Particulate Emission Standards for Fuel Burning Devices Installed on or After January 1, 1985 EU02, EU03 Env-A Total suspended particulate matter emissions from fuel burning devices installed on or after January 1, 1985 shall not exceed 0.30 lb/mmbtu. Finding: Compliance can only be verified by stack testing, which is not required at this time. However, at the time the permit was issued, NHDES had sufficient information to indicate that under normal operating conditions, these devices are capable of meeting the particulate matter standard. AP-42 emission factors are used to calculate the annual particulate matter emissions. Emergency Generators Each emergency generator shall only operate: EU02 Env-A a. As a mechanical or electrical power source when the primary power source for the Facility has been lost during an emergency such as a power outage; or b. During normal maintenance and testing as recommended by the manufacturer. 14. c. During periods in which ISO New England, or any successor Regional Transmission Organization, directs the implementation of operating procedures for voltage reductions of 5% of normal operating voltage requiring more than 10 minutes to implement, voluntary load curtailments by customers, or automatic or manual load-shedding, in response to, or to prevent the occurrence of, unusually low frequency, equipment overload, capacity or energy deficiency, unacceptable voltage levels, or other such emergency conditions. Finding: Bridgewater only operates the units for maintenance or emergency purposes. The facility does not have a contract with ISO New England to use the emergency generator to generate power for the grid. Operating logs were used to verify compliance with this condition. Page 14 of 52

15 Table 5 - Federally Enforceable Operational and Emission Limitations Requirement Emission Unit Cite 15. The emergency generator and the fire pump shall each be limited to 500 hours of operation during any consecutive 12-month period. The emergency generator and the fire pump shall each be limited to 100 hours per year of operation for maintenance checks and readiness testing EU02, EU03 Env-A (j)(1) & 40 CFR , Subpart ZZZZ The emergency generator (EU02), in addition to the above limitation, shall be limited as detailed in 40 CFR (f)(1)(ii) and (iii). Maximum Sulfur Content Allowable in Liquid Fuels EU02, EU03 Env-A (a) 16. a. The sulfur content of No. 2 oil shall not exceed 0.40 percent sulfur by weight; b. The sulfur content of used oil shall not exceed 2.00 percent sulfur by weight. Findings: Bridgewater only burned No. 2 fuel oil in these engines during the evaluation period and demonstrated compliance with the fuel sulfur limit from delivery tickets. Bridgewater also stated that the emergency engines could not burn used oil, although it is allowed by this condition. Requirements for Emergency Stationary Reciprocating Internal Combustion Engines The emergency generator and the fire pump shall be operated as follows after May 3, 2013: EU02, EU03 40 CFR & 40 CFR Subpart ZZZZ a. Change oil and filter every 500 hours of operation or annually, whichever comes first; b. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first; 17. c. Inspect hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary; d. Minimize idle time during startup and minimize startup time to a period needed for appropriate and safe loading, not to exceed 30 minutes; and e. Operate and maintain the engine according to the manufacturer's emission-related operation and maintenance instructions. 19. The Owner or Operator shall operate and maintain the affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for EU02, EU03 40 CFR Subpart ZZZZ Page 15 of 52

16 Table 5 - Federally Enforceable Operational and Emission Limitations Requirement Emission Unit Cite minimizing emissions. Accidental Release Program Requirements Facility wide CAAA 112(r)(1) 20. The quantities of regulated chemicals stored at the facility are less than the applicable threshold quantities established in 40 CFR The facility is subject to the Purpose and General Duty clause of the 1990 Clean Air Act, Section 112(r)(1). General Duty includes the following responsibilities: a. Identify potential hazards which result from such 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 that do occur. Work Practice Standards for Industrial/Commercial Boilers EU01,EU05 40 CFR Subpart JJJJJJ 21. a. No later than the compliance date established in 40 CFR and annually thereafter, the Owner or Operator shall conduct a tuneup of the boiler as specified in Table 6, 20; and b. No later than March 21, 2014, the Owner or Operator shall conduct a one-time energy assessment as specified in Table 6, 21 (only required for EU01). Finding: Tune-ups for both boilers were due to be completed by March 21, On April 24, 2013, Bridgewater conducted a tune-up of the wood-fired boiler. In September 2013 Bridgewater conducted a tuneup of the package boiler. Bridgewater has subsequently conducted annual tune-ups of both boilers with the most recent being the wood fired boiler on May 12, 2017 and the package boiler on February 20, Bridgewater completed the energy assessment of the facility in February Therefore, Bridgewater is in compliance with this condition. 22 General Compliance Requirements At all times, the Owner or Operator must operate and maintain the boiler in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require the Owner or Operator to make any further efforts to EU01, EU05 40 CFR Subpart JJJJJJ Page 16 of 52

17 Table 5 - Federally Enforceable Operational and Emission Limitations Requirement Emission Unit Cite reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Division that may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. Permit Deviations Facility Wide Env-A In the event of a permit deviation, the Owner or Operator of the affected device, process, or air pollution control equipment shall 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. VI. Compliance with Monitoring and Testing Requirements Table 6 below, taken from Permit TV-0008, lists the monitoring and testing requirements for the facility, and any deficiencies noted during the evaluation. Table 6 - Monitoring/Testing Requirements Parameter Method of Compliance Frequency of Method Device Cite 1. Opacity Continuous Opacity Monitoring System Operate and maintain a continuous opacity monitoring system (COMS) for measuring the opacity of emissions from the wood-fired boiler. The COMS shall be maintained and operated in accordance with 40 CFR 60, Appendix B, and Performance Specification 1. Determination of compliance with the opacity limits established in Table 5, 2 shall be made by the COMS or, during any COMS downtime, by visible emission readings taken once per shift following the procedures specified in 40 CFR 60, Appendix A, Method 9. Continuous EU01 40 CFR 60.48b(a) & Env-A Page 17 of 52

18 Table 6 - Monitoring/Testing Requirements Parameter Method of Compliance Frequency of Method Device Cite 2. O 2, NOx, CO and diluent gas CEMS O 2, NOx, CO and diluent gas Continuous Emission Monitoring System Operate, calibrate and maintain CEMS for NOx, CO and diluent gas (O 2 ) which shall be used to determine compliance with NOx and CO emission limits established in Table 5, items 4, 6, & 7. The CEMS shall be operated and maintained in accordance with 40 CFR 60, Appendix B and Env-A 808. Continuous EU01 Env-A (a)(2) (effective ) & TP-B-0533 Minimum Specifica- tions for CEMS and COMS Minimum Specifications for CEM Systems The Owner or Operator shall ensure that each CEMS and COMS meets the following operating requirements: N/A EU01 Env-A (effective ) a. Each CEMS shall average and record the data for each calendar hour; b. Each COMS shall average the opacity data to result in consecutive, non-overlapping 6- minute averages; c. All combined opacity and gaseous CEM systems shall; 3. i. Include a means to display instantaneous values of percent opacity and gaseous emission concentrations; and ii. Complete a minimum of one cycle of operation, which shall include measuring, analyzing, and data recording for each successive 5-minute period for systems measuring gaseous emissions and each 10-second period for systems measuring opacity, unless a longer time period is approved in accordance with Env-A 809. d. A valid hour of CEM emission data Page 18 of 52

19 Table 6 - Monitoring/Testing Requirements Parameter Method of Compliance Frequency of Method Device Cite means a minimum of 42 minutes of gaseous or opacity CEMS readings taken in any calendar hour, during which time the CEM is not in an out of control period as defined in Env-A (g), and the facility is in operation. Stack volumetric flow Operate and maintain a stack volumetric flow measuring device for measuring stack flow from the woodfired boiler which meets the following requirements: Continuous EU01 Env-A (d) & (e) (effective ) a. All differential pressure flow monitors shall have an automatic blow-back purge system installed, and in wet stack conditions, shall have the capability for drainage of the sensing lines; 4. b. The stack flow monitoring system shall have the capability for manual calibration of the transducer while the system is online and for a zero check; and c. Alternatives to in-stack flow monitoring devices for determination of stack volumetric flow rate may be used if the Owner or Operator provides the Division with technical justification that the alternative can meet the same requirements for data availability, data accuracy, and quality assurance as an in-stack device. 5. Continuous steam flow monitor Operate and maintain a continuous steam flow rate monitoring system for measuring steam production from the wood-fired boiler output steam pipe which meets the following requirements: As specified EU01 Env-A a. The steam flow rate monitoring system shall meet all applicable ASME specifications; b. The steam flow transducer shall Page 19 of 52

20 Table 6 - Monitoring/Testing Requirements Parameter Method of Compliance Frequency of Method Device Cite be calibrated at least once annually in accordance with manufacturer s specifications; and c. If adequate straight length of piping is not available, then in lieu of a measuring system that meets ASME specifications, the Owner or Operator may use a steam flow rate monitoring system that can be calibrated by instruments installed, maintained and calibrated per ASME specifications or by other methods approved by the NHDES. Findings: The steam transducer was last calibrated on May 3, Therefore, Bridgewater is in compliance with this condition. QA/QC Plan Require- ments a. Prepare and maintain a quality assurance/quality control (QA/QC) plan, which shall contain written procedures for implementation of a QA/QC program that meets the criteria specified in 40 CFR 60, Appendix F, Procedure 1, section 3 for each CEMS; Review annually and revise as necessary EU01 Env-A (effective ) b. Review the QA/QC plan and all data generated by its implementation at least once each year; c. Revise or update the QA/QC plan, as necessary, based on the results of the annual review, by: 6. i. Documenting the replacement of any damaged or malfunctioning CEM system components in order to maintain the collection of valid CEM data and to maximize data availability; ii. Documenting any changes made to the CEM or changes to any information provided in the monitoring plan submitted in accordance with Page 20 of 52

21 Table 6 - Monitoring/Testing Requirements Parameter Method of Compliance Frequency of Method Device Cite Env-A ; iii. 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; iv. Describing how the audits and testing required by Env-A 808 will be performed; and v. Including examples of the reports that will be used to document the audits and tests required by Env-A 808; d. Make the revised QA/QC plan available for on-site review by the Division at any time; and 6. Cont. e. No later than April 15 of each year, either: i. Submit to NHDES the revised QA/QC plan and the reasons for each change, and certify in writing that the Owner or Operator is implementing the revised QA/QC plan; or ii. Certify in writing that no changes have been made to the plan and that the Owner or Operator will continue to implement the existing QA/QC plan. General Audit Require- ments for All Gaseous and Opacity CEMS The Owner or Operator shall audit each CEMS in accordance with the following: a. Required quarterly audits anytime during each calendar quarter, provided that successive quarterly audits shall occur no more than 4 months apart. b. Subject to (d), below, within 30 calendar days following the end of each quarter, the Owner or Quarterly EU01 Env-A (effective ) Page 21 of 52

22 Table 6 - Monitoring/Testing Requirements Parameter Method of Compliance Frequency of Method Device Cite 7. Operator shall submit to NHDES a written summary report of the results of all audits required by (a), above, that were performed during that quarter, in accordance with the following: i. For gaseous CEM audits, the report format shall conform to that presented in 40 CFR 60, Appendix F, Procedure 1; and ii. For opacity CEM audits, the report format shall conform to that presented in EPA- 600/ , April 1992, Technical Assistance Document: Performance Audit Procedures for Opacity Monitors. c. The Owner or Operator shall notify NHDES: 7. Cont. i. At least 30 days prior to the performance of a RATA; and ii. At least 2 weeks prior to any other planned audit or test procedure required under Env-A 808. d. The Owner or Operator shall file with the Division a written summary of the results of the RATA testing required by Env-A by the earlier of 45 calendar days following the completion of the RATA test or the date established in the section of 40 CFR 60 that requires performance of the RATA. 8. CEMS Audit Require- ments Gaseous CEMS audits shall be conducted in accordance with 40 CFR 60, Appendix F and Env-A Quarterly EU01 Env-A (effective ) 9. COMS Audit Require- The Owner or Operator shall perform audits for COMS in accordance with procedures described in Env-A and 40 CFR 60, Appendix B, Quarterly EU01 Env-A (effec tive Page 22 of 52

23 Table 6 - Monitoring/Testing Requirements Parameter Method of Compliance Frequency of Method Device Cite ments Specification ) 10. Audit require- ments for the stack flow monitor a. Whenever compliance with a mass flow emissions limit is determined using a stack flow volumetric monitor, the Owner or Operator shall conduct, at least once every 4 calendar quarters, a minimum 9-run RATA with the relative accuracy calculated in the units of the mass emissions measurement as specified in 40 CFR 60, Appendices B and F; As specified EU01 Env-A (e) & (f) (effective ) b. The Owner or Operator of a stationary source subject to a. above, and using a stack volumetric flow monitor for the mass flow emissions calculation shall in addition to the 9-run RATA, also perform one of the audit options specified in Env-A or Env-A Data Availabil- ity Require- ments a. The Owner or Operator shall operate the CEM at all times during operation of the source, except for periods of CEM breakdown, repairs, calibration checks, preventive maintenance, and zero/span adjustments; N/A EU01 Env-A (effective ) 11. b. The percent CEM data availability shall be maintained at a minimum of 90% on a calendar quarter basis for all opacity monitors, gaseous concentration monitors, and stack volumetric flow monitors; c. The percent CEM data availability shall be calculated as follows: ( VH CalDT ) x100 PercentDataAvailability ( OH AH) where: VH means the number of valid hours of CEM data in a given time period for which the data Page 23 of 52

24 Table 6 - Monitoring/Testing Requirements Parameter Method of Compliance Frequency of Method Device Cite availability is being calculated when the plant is in operation; OH means the number of facility operating hours during a given time period for which the data availability is being calculated; AH means the number of hours during facility operation when the performance of quarterly audits as required by those procedures specified in Env-A through Env-A , as applicable, require that the CEM be taken out of service in order to conduct the audit; CalDT means the number of hours, not to exceed one hour per day, during facility operation when the CEM is not operating due to the performance of the daily CEM calibrations as required in 40 CFR 60, Appendix F. Require- ment for Substitute Emission Data Any facility that uses the emissions data collected by a gaseous CEM system to calculate and report its annual emissions in accordance with Env-A 900 shall comply with the following: N/A EU01 Env-A (effective ) 12. a. For any facility operating hour during which the gaseous CEM system has not collected a valid hour of CEM system data, the Owner or Operator shall submit to the Division substitute emission data for those hours which has been generated using one of the following methods: i. The missing data substitution procedures specified in 40 CFR 75, Subpart D; ii. If the missing data occurred during a period of steadystate operation, and not during a period of start-up, Page 24 of 52

25 Table 6 - Monitoring/Testing Requirements Parameter Method of Compliance Frequency of Method Device Cite shutdown, or malfunction: 1. An average of the emissions data for the hours prior to and after the period of missing data during which valid CEM data was collected, or 2. Representative emissions data for the device at the same heat input rate, electric generating rate, or steam load; iii. If the missing data occurred during a start-up, shutdown, or malfunction of the device, substitute data collected by the CEM during a similar period of start-up, shutdown or malfunction, respectively; or iv. An alternative method of data substitution that meets the following criteria: 12. Cont. 1. The alternative method was included in the monitoring plan submitted pursuant to Env-A ; 2. The alternative method provides for representative emissions for the conditions of operation of the device during the period of missing data equivalent to the substitution methods described in (i) through (iii), above; and 3. The alternative method was approved by the department as part of its approval of the monitoring plan pursuant to Env-A b. For CEM systems and emissions Page 25 of 52

26 Table 6 - Monitoring/Testing Requirements Parameter Method of Compliance Frequency of Method Device Cite not subject to the missing data substitution procedures of 40 CFR 75 Subpart D, sources shall include substitute emissions data in the calculation of total daily, monthly, quarterly, and annual emissions generated by the permitted device to quantify total actual emissions; c. Substitute emission data shall not be used in the calculation of emissions totals or averages in order to determine or demonstrate compliance with emissions standards; d. Substitute data shall not be included in the calculation of data availability. 13. Valid averaging period The number of hours of valid CEM system data required for the calculation and determination of compliance with a 24-hour emission standard period shall be 18 hours of valid data. N/A EU01 Env-A (effective ) Ammonia Flow to RSCR a. Operate an ammonia flow meter for measuring ammonia flow to the RSCR when in operation; Continuous PCE4 TP-B b. The ammonia flow meter shall be inspected and maintained in accordance with manufacturer s recommendations. Calibrate in accordance with manufac- turer s recommend -ation Findings: Bridgewater takes additional efforts to measure ammonia flow by comparing usage rates to the storage tank levels. 15. Stack Testing Requirement s for particulate matter and ammonia slip a. Conduct compliance stack testing for particulate matter and ammonia slip. Particulate test results will be used to evaluate compliance with the particulate emission limit in Table 5, 1. Ammonia test results will be used to evaluate compliance with the Every 5 years for particulate matter & annually for ammonia slip EU01 TP-B-0533, 40 CFR 70.6(a)(3) & Env-A 802 (effective ) Page 26 of 52

27 Table 6 - Monitoring/Testing Requirements Parameter Method of Compliance Frequency of Method Device Cite ammonia slip emission limit in Table 5, 9. b. Method 5 shall be used to measure the concentration of particulate matter; and c. Ammonia slip shall be determined using NHDESapproved method. Finding: Bridgewater has conducted Ammonia slip testing annually, most recently on August 10, Bridgewater last conducted particulate matter testing on August 28, The next test is due by August Refer to Table 5, 9 for test results. General Stack Testing Requirements Compliance stack testing shall be planned and carried out in accordance with the following schedule: a. A pre-test protocol shall be submitted to the Division at least 30 days prior to the commencement of testing. The pre-test protocol shall contain the information specified in Env- A ; As specified EU01 Env-A 802 b. At least 15 days prior to the test date, the Owner or Operator and any contractor retained by the Owner or Operator to conduct the test shall meet with a Division representative in person or over the telephone; 16. c. A test report shall be submitted to the Division within 60 days after the completion of testing. The test report shall contain the information specified in Env-A (c); d. A compliance test shall be conducted under one of the following operating conditions: i. Between 90 and 100 percent, inclusive, of maximum production rate or rated capacity; ii. A production rate at which maximum emissions occur; or iii. At such operating conditions agreed upon during a pre-test Page 27 of 52

28 Table 6 - Monitoring/Testing Requirements Parameter Method of Compliance Frequency of Method Device Cite 16. meeting conducted pursuant to Env-A Cont. 17. Hours of Operation Emergency generator and fire pump shall each be equipped with a nonresettable hour meter by May 3, Continuous EU02, EU03 40 CFR Subpart ZZZZ 18. Sulfur Content of Liquid Fuels a) Conduct testing in accordance with appropriate ASTM test methods or retain delivery tickets in accordance with Table 7, 10 in order to demonstrate compliance with the sulfur content limitation provisions specified in this permit for liquid fuels. b) Testing for delivered fuel must be conducted for each delivery of fuel oil/diesel to the facility. As specified Facility Wide Env-A & Env-A (effective ) & RSA 125- C:6, XI c) Testing for used oil must be conducted at least annually or whenever the source of the used oil has changed. Finding: Bridgewater retains delivery slips to demonstrate compliance with this condition. 19. Periodic Monitoring If the indicator ranges specified in Tables 6A, 6B, and 6C 2 accumulate exceedances over 5% of the rolling 12-month total operating time for PCE1, PCE2, PCE3, and PCE4 the Owner or Operator shall prepare and submit a Quality Improvement Plan (QIP) to the Division. The QIP shall include procedures for evaluating the control performance problems. Based on the evaluation, the Owner or Operator shall modify the plan to include procedures for conducting one or more of the following actions, as appropriate: Continuous PCE1, PCE2, PCE3 40 CFR 64.8 Not. a. Improve preventive maintenance practices; b. Operational changes; Page 28 of 52

29 Table 6 - Monitoring/Testing Requirements Parameter Method of Compliance Frequency of Method Device Cite c. Appropriate improvements to control methods; d. Other steps to improve control performance; and e. More frequent or improved monitoring. Finding: QIP not required since the facility did not accumulate exceedances over 5% during any 12-month rolling period. Boiler Tune-up The tune-up of the boiler(s) shall consist of the following: 1. As applicable, inspect the burner/grate, and clean or replace any components of the burner as necessary; By the compliance date established in 40 CFR EU01, EU05 40 CFR Subpart JJJJJJ 2. Inspect the grate for proper and even fuel distribution. Adjust the fuel distribution spouts and distribution air to optimize fuel distribution. Adjust undergrate and over-fire air for optimal combustion to minimize boiler emissions Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly; 4. Optimize total emissions of carbon monoxide, consistent with the manufacturer s specifications if available; and 5. Measure the concentration in the effluent stream of carbon monoxide in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made. 21. Energy Assessmen t The energy assessment must be performed by a qualified energy assessor and must include: 1. A visual inspection of the boiler system; One time by March 21, 2014 EU01 40 CFR (b) Subpart JJJJJJ Page 29 of 52

30 Table 6 - Monitoring/Testing Requirements Parameter Method of Compliance Frequency of Method Device Cite 2. An evaluation of: a. Operating characteristics of the facility; b. Specifications of energy using systems, c. Operating and maintenance procedures; and d. Unusual operating constraints; 3. An inventory of major systems consuming energy from affected boiler(s); 21. Cont. 4. A review of: a. Available architectural and engineering plans; b. Facility operation and maintenance procedures and logs; and c. Fuel usage; 5. A list of major energy conservation measures; 6. A list of the energy savings potential of the energy conservation measures identified; and 7. A comprehensive report detailing: a. The ways to improve efficiency; b. The cost of specific improvements; c. Benefits; and d. The time frame for recouping those investments. 22 To Be Determine d When conditions warrant, the Division may require the Owner or Operator to conduct stack testing in accordance with USEPA or other Division approved methods. Upon request by the Division Facility Wide RSA 125- C:6, XI Not Finding: During the inspection period, the Division has not required additional testing over and above that specified in Page 30 of 52

31 Table 6 - Monitoring/Testing Requirements Parameter Method of Compliance Frequency of Method Device Cite the permit. Table 6A below, taken from Permit TV-0008, lists the Compliance Assurance Monitoring requirements for the Gravel Bed Filter and any deficiencies noted during the evaluation. Indicator Table 6A-Compliance Assurance Monitoring ( CAM ) 40 CFR 64 Gravel Bed Filter for the control of Particulate Matter Indicator No. 1 Differential Pressure across the GBF Indicator No. 2 Lift Blower Discharge Pressure Indicator No. 3 Purge Air Discharge Pressure Indicator No. 4 Purge Air Temperature Indicator No. 5 Inspection/ Maintenance 1. Measurement Approach The pressure is monitored with a differential pressure transmitter. The results are displayed on the device control panel. The pressure is monitored with a differential pressure transmitter. The results are displayed on the device control panel. The pressure is monitored with differential pressure transmitter. The results are displayed on the device control panel. The temperature is measured with a thermocouple. The results are displayed on the device control panel. a. Inspection and maintenanc e shall be performed according to I/M checklist. b. Inspections shall include inspection for leaks, abnormal noise, hotspots and fires. c. Maintenanc e performed as needed. 2. Indicator Range The indicator range is a pressure differential reading between 2 and 12 of water column. Excursion triggers an inspection, corrective The indicator range is a lift blower discharge pressure between 2 psig and 6 psig. Excursion triggers an inspection, corrective action and a The indicator range is a purge air discharge pressure between 2 psig and 5 psig. Excursion triggers an inspection, corrective action and a reporting The indicator range is a temperature reading between 100 F and 350 F. Excursion triggers an inspection, corrective action and a reporting Failure to perform an inspection triggers a reporting requirement. Equipment failures identified during the inspection trigger corrective Page 31 of 52