DEPARTMENT OF ENVIRONMENTAL SERVICES. Thomas S. Burack, Commissioner

Transcription

1 '\- NH D ES The State of New Hampshire DEPARTMENT OF ENVIRONMENTAL SERVICES Thomas S. Burack, Commissioner Mr. Douglas W. York Plant Manager DG Whitefield LLC 260 Airport Road Whitefield, NH July 09, 2008 Re: Compliance Inspection Report Dear Mr. York: The New Hampshire Department of Environmental Services, Air Resources Division ("DES") conducted an Off-site Full Compliance Evaluation of your facility on May 16, Enclosed is a copy of the Inspection Report for your records. The following deficiencies were found during the inspection, all of which are detailed in the enclosed report. Please note the following: V ) DG Whitefield LLC must report ALL fuel usage at the facility in the annual emissions statement: the waste oil heater(s) plus the diesel fuel used in the two RSCR heaters. If the fuel usage is zero, then DO Whitefield should state this occurrence. V /. DO Whitefield LLC shall also include a the sulfur content of the fuel (which may be obtained from the fuel delivery tickets or by actual testing). Note that the wood-fired boiler is not currently permitted to burn waste oil. It is / listed on the annual emission statement as a secondary fuel. DO Whitefield LLC V should either delete the reference to the secondary fuel (waste oil) or file an amendment to the permit requesting that it be added. The "Certification of Accuracy" statement was missing on several report submittals. Other report submittals had this statement on a separate page. DO Whitefield LLC should include this statement on ALL submittals including applications in the body of the cover letter. It should be noted, that the current permit has "Steven Mueller" as the responsible official required to sign submittals. DouglasVi as been sfgning as the responsible official. DG Whitefield LLC must submit an ARD-1 form to amend the permit stating that Douglas York should be the responsible official (as on the original permit). DES Web site: P.O. Box 95, 29 Hazen Drive, Concord, New Hampshire Telephone: (603) Fax: (603) TDD Access: Relay NH

2 The results of this inspection have been refeed to the Enforcement Section for review. If you have any questions, please feel free to contact me at (603) or Tara Olson, Compliance Assessment Supervisor, at (603) Sincerely, Gre e Sr. Compliance Assessment Engineer Air Resource Division Enclosure: DG Whitefield Inspection Report Cc: Town Administrator for Whitefield

3 fen~~ NEW HAMPSHIRE DEPARTMENT OF vironmental Services AIR RESOURCES DIVISION OFF SITE COMPLIANCE EVALUATION FULL RECORDS REVIEW DG Whitefield, LLC 260 Airport Road Whitefield, NH Coos County AFS # Final Report: July 10, 2008

4 DG WhitejIeld LLC Inspection Date. May 16, Off Site Compliance Evaluation Report Date: July 10, 2008 Date: May 16, 2008 Type of Evaluation: Off Site Compliance Evaluation Written by: Greg Helve, Sr. Compliance Engineer Source Contact: Douglas York, Plant Manager Permit Number: TV-OP-007 Expires: September 30, 2010 Last Inspection: September 27, 2006 Inspection Result: Discussed in Section I "Inspection" Inspection On May 16, 2008, the New Hampshire Department of Environmental Services, Air Resources Division ("DES") completed an Off Site Full Compliance Evaluation ("FCE") of DG Whitefield LLC, Whitefield, NH, Coos County (formally known as "Whitefield Power and Light"). DG Whitefield LLC was targeted for inspection based on DES inspection criteria, which requires that a major source with a Title V Permit be inspected once every two years. DES' off site records review was conducted in accordance with the EPA's Compliance Monitoring Strategy. DES last inspected DG Whitefield LLC on September 27, 2006 which was an on-site inspection. That inspection report is dated January 24, During the 2006 onsite inspection, the following issues were noted: DG Whitefield LLC should contact the Testing and Monitoring Section to discuss when ammonia slip testing is scheduled to be conducted; DG Whitefield LLC must retain documentation demonstrating its compliance with Env-A 1400 and be able to present this information to DES when requested; DG Whitefield LLC should review its wood chip delivery practice to ensure that it is compliant with Env-A 1002 fugitive dust requirements; DG Whitefield LLC must make sure that the wood chips received and combusted in its boiler comply with the requirements of the permit. DG Whitefield LLC is not allowed to burn construction and demolition debris in its boiler; and DG Whitefield LLC must control fugitive dust in accordance with the permit and Env-A Facility Description DG Whitefield LLC operates one Babcock and Wilcox Wood-Fired boiler capable of producing 16 MWe of electrical power (stack #1). The wood-fired boiler (EU1) is designed to consume wood fuel consisting of sawmill residue, whole tree chips, and chipped wood pallets. DG Whitefield LLC also operates one 470-horsepower diesel Cummins emergency generator (EU2) with a permit limit of 500 hours per year and a 187-horsepower diesel fire pump (EU3). A cooling tower is also used for the facility. Air pollution control equipment consists of one Page 2 of 18

5 DG WhitefleldLLC Inspection Date. May 16, Off Site Compliance Evaluation Report Date: July 10, 2008 multicyclone (PCE1), one electrostatic precipitator (PCE2) and one Regenerative Selective Catalytic Reduction System (RSCR). The ESP is for primary and secondary particulate control on the boiler and vents through the boiler stack (EU1). EU1 is equipped with a CEM that is continuously run and measures oxides of nitrogen (NOx), carbon monoxide (CO), carbon dioxide (CO2), opacity and stack flow rate. The RSCR is used to reduce NOx and CO emission from the flue gas from the boiler. During periods of boiler malfunction when the RSCR is bypassed, emissions are sent directly to the stack. Once the appropriate repairs have been made, flue gasses are redirected to the RSCR. Bringing the RSCR back on line causes disruption in the stack flow, at which time, there is typically a spike in opacity greater than the 20% permit limit. Once steady state is achieved, opacity emissions return to below 20%. To heat the RSCR catalyst bed, DG Whitefield LLC operates 2 diesel oil-fired burners. The facility has installed and is operating a 0.14 MMBtu/hr Reznor used-oil burner. The device is rated at 1 gallon per minute of used-oil. The used-oil burner provides space heat in the laboratory room and is a means for disposal of used-oil. Since DG Whitefield LLC installed the used-oil burner, the facility has not burned any used-oil in the wood-fired boiler. DG Whitefield LLC consumes about gallons of waste oil annually, all of which is generated onsite. The used-oil burner only operates in the winter and the facility does not generate enough oil to last the season. During the permitting process, the used-oil burner was evaluated and determined to be below permitting threshold. DG Whitefield LLC also operates a Thermopride 126,000 Btü/hr #2 fuel oil fired space heater for the utility shed. (See on site inspection report dated January 24, 2007). It should also be noted that DG Whitefield LLC completed installation of a Synterprise EcoJet over fire air system to improve combustion in the wood-fired boiler to reduce CO emissions in June 29, The modification was completed without DES approval. This was discovered when DG Whitefield LLC applied for a tax exemption in a letter to DES-Permitting dated September 26, III. Compliance With Permitting Refluirements CHAPTER ENV-A Ambient Air Quality Standards (AAQS) DES conducted modeling on April 2, 1992, October 27, 1993 and June 23, 2004 (for NH3). No violations of AAQS for the criteria pollutants were predicted. In order to comply with the AAQS and for PSD avoidance, DES set a cap on CO emissions of 57 lb/br, which is averaged over 365- day rolling period. To determine emissions from EU1, the facility calculates CO emission using the CEM. A review of the facility emissions indicates DG Whitefield LLC is not exceeding this requirement. CHAPTER ENV-A Statewide Permit System The facility is a major source of NOx and CO and therefore requires a Title V Operating Permit. A Title V Operating Permit "TV-OP-007" was issued by DES on September 30, 2005 for the operation of a wood-fired boiler, emergency diesel generator, diesel fire pump and a cooling tower. A modification for the RSCR operation was made on July 23, Page 3 of 18

6 DG 911hitefleldLLC Inspection Date. May 16, Off Site Compliance Evaluation Report Date: July 10, 2008 DG Whitefield LLC filed a Temporary Permit application on March 06, 2008 (Application # FY ) requesting to make physical modifications to the wood-fired boiler. Specifically, DG Whitefield LLC is proposing to make boiler modifications that will increase the amount of steam produced by the boiler and provided to the steam turbine generator, which will increase the power output of the facility from 16 MWe to approximately 18 MWe net output. The boiler's steam generating capacity will be increased from 160,000 pounds per hour (lb/br) to 170,000 lb/hr and will be achieved without an increase in the heat input rate to the boiler, i.e., an increase in wood usage is not necessary to increase the steam production rate. This application is currently under review. DG Whitefield LLC operates the boiler 365 days per year with pollution control equipment. Emissions from the boiler are recorded by the CEM and COM and emissions from the cooling tower and emergency generator are calculated from AP-42 data. Table 1 shows the operating limits, fuel usage and the emission rates for the permitted devices. Table 2 shows data for the pollution control devices, Table 3 shows facility total emissions and Table 4 shows the boiler specific conditions. A. Fuel and Operating Data Table 1 - Significant Activities Emission tjmiit. Emission Lnit Maximum. DesI2n C alcltv Permitted Operating Limits Reported Operating and Fuel Usage Data EUI Maximum Firing Rate: No fuel usage 2007: 8568 total hrs: 185,012 tons of wood 1. Babcock and 220 MMBTU/hr for wood limits imposed. Opacity in compliance based on reported CEM equivalent to: Wilcox Wooddata fired Boiler 160,000 lb/hr of steam averaged over 24-hour Installed : 8089 total hrs: 185,413 tons of wood period at 900 F and Less than 20% Opacity in compliance based on reported CEM 885 psig; and Opacity data Stack Ht= 145' Stack dia =6.5' 252,000 tpy for wood chips at 55% moisture; (Proposed change a: 170,000 lb/hr of steam averaged over 24 hour period at 900 degf and 920 psig) 2005: 8439 total hrs; 193,152 tons of wood Opacity in compliance based on reported CEM data EU2 Maximum Firing Rate : 14.4 total hrs; gals-diesel MMBTU/hr EU2 shall be Cummins Diesel limited to less Rated Output-470 HP; Emergency than 500 hours 2006: 27.4 total hrs; gals-diesel Generator of operation Installed 1987 consecutive 12- month_period. 2005: 25.1 total hrs; gals-diesel Page 4 of 18

7 DG Whitefield LLC Inspection Date: May 16, Off Site Compliance Evaluation Report Date: July 10, 2008 I Enission tlnit # Emission II nit Maximum Design Capacity Permitted Oráting Limits Reported Operating and FuèlUsage.ãta EU3 Maximum Firing Rate-2.4 EU3 shall be 2007: 27.1 total hrs; gals-diesel MMBTU/hr limited to less Cummins Diesel Rated output-i 87 HP; than 500 hours Fire Pump 2006: 11.1 total hrs; gals-diesel of operation Installed 1987 during any consecutive : 6 total hrs; 77 gals-diesel month period. EU4 Drift Factor= % 2007: 8568 total hrs; 5898 MMgal H20 Cooling Towers Circulation Rate=1 1,473 gpm 2006: 8089 total hrs: 5568 MMgal H : 8439 total hrs; 5809 MMgal H20 Installed 1987 The devices are in compliance with their permitted operating limits. B. Control Equipment Table 2 - Pollution Control Equipment Identification Pollution Control Equipment # Unit # Description of Equipment Activity 1 Emission 1 PCE1 Multicyclone (Multiclone) Primary particulate matter control EUI PCE2 Electrostatic Precipitator (ESP) Secondary particulate matter EU1 control PCE3 Regenerative Selective Catalytic Reduction NOx control and optional CO EUI System (RSCR) with NOx and optional CO control catalyst The RSCR is equipped with 2 Diesel oil fired Fuel Usage for these burners has burners with combined rating of 1.8 MMBTU/hr NOT been reported from 2001 to Present. Fuel usage MUST be - reported in the annual emission statement, even if it is Zero. Fuel Usage for PCE3 burners has NOT been reported from 2001 to Present. Fuel usage MUST be reported in the annual emission statement, even if it is Zero. Page 5 of 18

8 DG WhiteJleldLLC 2008 Off Site Compliance Evaluation Inspection Date: May 16, 2008 Report Date: July 10, 2008 C. Facility Emissions NOx and CO emissions are based on continuous emission monitoring equipment data. Particulate Matter, VOC's, and Ammonia are based on stack test data, Sulfur Dioxide is based on AP42 emission factors. Table 3 - Facility Total Emissions ag 10 rg The facility is in compliance with their permifted emission limits. Table 4 - Emissions - Wood - Boiler Specific (EU#1) itri&ii Oxides Nitrogeii Pii'ticulate AN'g of calciidar Oxides \latter, 365 da (IMit) (tpy) rolling avg Carbon Monoxide 365 day rolling avg (lb/b r) Permitted Emission Limits 1bIMMBTU 57.0 <96, No quarterly exceedences No quarterly exceedences No quarterly exceedences The wood-fired boiler is in compliance with these limits. DG Whitefield LLC is also required to limit the CO emission rate to 225 lbs/hr (max) averaged over each calendar day. DG Whitefield LLC has not reported any exceedences to this limit in their deviation reports. *The facility chose to comply with NOx emission limit based on the Renewable Portfolio Standard. This limit is a voluntary limit. Page 6 of 18

9 DG WhiteJieldLLC 2008 Off Site Compliance Evaluation Inspection Date.' May 16, 2008 Report Date.' July JO, 2008 Part Env-A 609 Title V Operating Permit On January 11, 1999, DES issued to DG Whitefield LLC its original Title V Permit TV-OP-007 ("the permit") to operate a Babcock and Wilcox wood-fired boiler, cooling tower, Multiclone, Electrostatic Precipitator, Regenerative Selective Catalytic Reduction System, Cummins Emergency Diesel Generator, and Cummins Diesel Fire Pump. DG Whitefield LLC submitted a Title V permit renewal application on June 07, 2003, and amendments on January 25, DES issued a Title V permit # TV-OP-007 to DG Whitefield LLC on September 30, 2005 and amended on July 23, The permit expires September 30, ENV-A Insignificant Activities DG Whitefield LLC has identified insignificant activities Part Env-A Non-attainment Areas DG Whitefield LLC is located in Coos County, NH, which is part of the Northeast Ozone Transport Region. The facility is not a new source or a major source making a major modification in the region. IV. Monitoring and Testing Procedures The DG Whitefield LLC is subject to the monitoring and testing requirements as contained in Table 5 below: Table 5 - Monitoring/Testing Requirements Item # Parameter Method of Compliance Frequency of Method Device Status Stack Testing DG Whitefield LLC shall conduct annual EPA Method Annually EUI, for Ammonia stack tests at maximum operating rate, and br at the PCE1, request of the Division, at any other operating rate at which PCE2 & maximum emissions might occur. Testing for ammonia PCE3 DG Whitefield LLC shall be performed on the exhaust Stack from EU1 and has been performing PCE3 as follows: yearly testing. Last test was performed Ammonia concentration shall be measured following July 20, Similar EPA CTM 0027 method or DES approved alternative; tests were performed DG Whitefield LLC may use facility's CEM data to in 2006 and 2005 and correct the ammonia emissions to the units of the results are standard ( %dv 02); documented in the The testing shall follow all requirements specified in Envyearly emission A 802, Compliance Stack Testing for Stationary Sources. reports. In Compliance. 2 Periodic If the indicator ranges specified in Table 6A and 613 Item Continuously PCEI& DG Whitefield LLC Monitoring 2, of the permit, accumulate exceedances over 5% of the PCE2 has not reported any QIP rolling 12-month total operating time for each pollution indicator range control device, DG Whitefield LLC shall prepare and exceedances, submit a Quality Improvement Plan (QIP). The QIP shall therefore, is not include procedures for evaluating the control performance I required to prepare Page 7 of 18

10 DG Whitefleld LLC Inspection Date: May 16, Off Site Compliance Evaluation Report Date: July 10, 2008 Item Parameter Method of Compliance Frequency Device Status problems. Based on the evaluation, DG Whitefield LLC shall modifj the plan to include procedures for conducting one or more of the following: and submit a QIP. Improve preventive maintenance practices; Operational changes; Appropriate improvements to control methods; Other steps to improve control performance; and More frequent or improved monitoring. 3. Stack Testing Compliance stack testing for particulate matter shall be Every 5 EUI for Total planned and carried out at the frequency specified. The pre- years, within Suspended test protocol shall be submitted 30 days prior to the 90 days of Particulate commencement of testing. The pre-test protocol shall the In Compliance. contain the following information: anniversary DG Whitefield LLC Calibration methods and sample data sheets; stack test last performed a stack test on May 26, Description of the test methods to be used; Next test is due within Pre-test preparation procedures; 90 days of May 26, Sample collection and analysis methods; Process data to be collected; and Complete test program description. At least 15 days prior to the test date, the facility and any contractor that the facility retains for performance of the test, shall participate in a pre-test conference with a Division representative. The pre-test protocol must be submitted by the facility at least 30 days prior to the commencement of testing. Emission testing shall be carried out under the observation of a Division representative. Upon commencement of any performance test, the performance test shall not be aborted unless approved by DES. DG Whitefield LLC shall submit the stack test report to DES within 60 days of completion of the actual testing. 4. Opacity CEM The COMS shall meet the requirements of 40 CFR 60, Continuously EU1 DG Whitefield LLC is (COMS) Appendix B, Performance Specification I and Env-A 808. in compliance. Daily Determination of compliance with opacity emission limits averages are recorded established in Table 5, Item 2 of the permit shall be made and reported in the by the facility COMS or visible emission readings taken quarterly excess once per day following the procedures specified in 40 CFR emissions report. 60, Appendix A, Method 9. Calculations shall be performed as specified in Table 6, Item 14 of the permit. Page 8 of 18

11 DG PVhitefleld LLC Inspection Date. May 16, Off Site Compliance Evaluation Report Date. July 10, 2008 [Item Parameter Method of Compliance 1 Frequency oçetiio Device Status 5. NOx CEM The NOx CEM system shall meet the requirements of 40 Continuously EU1 CFR 60, Appendix B, Performance Specification 2 and Env-A 808. Determination of compliance with NOx emission limits established in Table 5, Item 9 and Item 10 and Table 4, Item 7 of the permit shall be made using data from the facility NOx CEM. The NOx emission rate shall be calculated daily in lb/hr averaged over a rolling 365-day period The NOx emission rate shall be calculated in lb/mmbtu: Averaged over 24-hrs; and Averaged over a calendar quarter. Calculations shall be performed as specified in Table 6, Item CO CEM The CO CEM system shall meet the requirements of 40 Continuously EUI CFR 60, Appendix B, Performance Specification 4 and Env-A 808. Determination of compliance with CO emission limits established in Table 5, Item 7, 8, and 9 of this permit shall be made using data from the facility CO CEM. The CO emission rate shall be calculated daily in lb/hr: Averaged over 24-hrs; and Averaged over a rolling 365-day period, Calculations shall be performed as specified in Table 6, Item 14. DG Whiteield LLC is in compliance. Daily averages are recorded and reported in the quarterly excess emissions report and the annual emissions report. DG Whitefield LLC is in compliance. Daily averages are recorded and reported in the quarterly excess emissions report and the annual emissions report. 7. Carbon The CO2 CEM shall meet the requirements of 40 CFR 60, Continuously EUI DG Whitefield LLC is Dioxide Appendix B, Performance Specification 3 and Env-A 808. in compliance. Daily (CO2) CEM averages are recorded and reported in the quarterly excess emissions report and the annual emissions report. 8. Volumetric CERM shall meet all of the requirements of 40 CFR 60, Continuously EUI DG Whitefield LLC is Flow CERJ's4 Appendix B, Performance Specification 6. The stack flow in compliance. Daily monitor shall have an automatic blow-back purge system averages are recorded installed and activated, at all times, during boiler operation. and reported in the quarterly excess The stack volumetric flow measuring device combined emissions report. with the NOx and CO concentration obtained from CEM, shall be used to calculate mass emission rates for The automatic blowcomparison with the emission standard specified in Table back purge system 5, Item 7, 8, 9, 10 and Table 4, Item 7. could not be verified as this is an off-site records review. Page 9 of 18

12 DG WhitefieldLLC 2008 Off Site Compliance Evaluation Inspection Date: May 16, 2008 Report Date. July 10, 2008 F Item #4j.:, F I?arameter I Methodof Co m pliance F Frequency of Method 9. QA/QC Plan DG Whitefield LLC is required to operate and maintain an Annually EU1 Requirements opacity and gaseous CEM system and shall: The CEM system Maintain a quality assurance/quality control (QA/QC) operational plan, which shall contain written procedures for availability is reported implementation of its QA/QC program for each CEM to be greater than the system; minimum limit of 90% and is in Review the QA/QC plan and all data generated by its compliance. implementation at least once each year; DG Whitefield LLC Revise or update the QA/QC plan, as necessary, based has completed annual on the results of the annual review, by documenting any reviews of the QA/QC changes made to the CEM or changes to any plan and that they information provided in the monitoring plan; have certified in Make the revised QA/QC plan available for on-site writing that they will review by the division at any time; continue to implement their existing QA/QC Within 30 days of completion of the annual QA/QC plan. plan review, certif' in writing that DG Whitefield LLC will continue to implement the source's existing QA/QC plan or submit in writing any changes to the plan and the reasons for change. 10. General Required quarterly CEM audits shall be done anytime Quarterly EU 1 Quarterly audits are Audit performed and noted during each calendar quarter, but successive quarterly Requirements in the excess emission audits shall occur no more than 4 months apart; and reports. Dates for the audits are not reported and DES cannot verify that audits occur no more than 4 months apart. DG Whitefield LLC shall notifj the division at least 30 DO Whitefield LLC is days prior to the performance of a Relative Accuracy notif y'ing DES of Test Audit (RATA). RATA tests. Last test was successfully completed June, Device 11. Gaseous Audit requirements for gaseous CEM systems shall be Quarterly EU 1 These are on-site CEM Audit performed in accordance with procedures described in 40 records and DG Requirements CFR 60, Appendix F and Env-A Whitefield LLC has certified that they are in compliance (see annual compliance certification report) Status Page 10 of 18

13 DG'VVhiteJIeldLLC 2008 Off Site Compliance Evaluation Inspection Date: May 16, 2008 Report Date: July 10, 2008 Item I: Parameter Method.of Compliance Frequency of Method Device Status Opacity CEM Audit requirements for gaseous CEM systems shall be Quarterly EUI These are on-site Audit performed in accordance with procedures described in 40 records and DG Requirements CFR 60, Appendix B, Specification 1 and Env-A Whitefield LLC has certified that they are in compliance (see annual compliance certification report) Data DG Whitefield LLC shall operate the CEM at all times As specified EU1 Availability during operation of the source in accordance with Env-A The CEM system Requirements , except for periods of CEM breakdown, repairs, operational calibration checks, preventive maintenance, and zero/span availability is reported adjustments. in the quarterly excess The percentage CEM data availability for opacity and all emissions report to be gaseous concentration monitors shall be maintained at a minimum of 90% on a calendar quarter basis. greater than the minimum limit of 90% and is in compliance. Calculations Calendar day average shall be calculated as follows: As specified EU1 In compliance. of CEM Reference the Calendar day average=(sum of all valid hour lb/hr Averages quarterly excess averages for the calendar day)/(24 hours - hours of emission reports and CEM system downtime for the day); the annual emission Calendar day averages shall only be valid for days report. with 18 or more valid hours of CEM data; A valid hour of CEM data shall be defined as a minimum of 42 minutes collection of CEM readings taken in a calendar hour; and Hours of CEM system downtime shall be defined as the number of calendar hours when the CEM system has not collected data or is out-of-control for greater than 18 minutes for any reason (i.e. audits, CEM system calibration, CEM system failures, etc.) Consecutive 365-day average shall be calculated as follows: Consecutive 365-day Average(Sum of all valid calendar day averages for the 365-day period)/(365 days - days of CEM system downtime); Days of CEM system downtime shall be defined as the number of calendar days when the CEM system has collected less than 18 valid hours of CEM data; Hours or days when the CEM system has been intentionally shutdown when the facility is not operating shall not be counted as CEM system downtime. In Compliance. See above. Page 11 of 18

14 DG frhitefield LLC Inspection Date: May 16, Off Site Compliance Evaluation Report Date: July 10, 2008 Item Frequency of Method. Device Status 15., CEM Excess Excess emissions indicated by the CEM system shall be Continuously EUI DG Whitefield LLC is Emissions considered violations of the applicable emission limit for compliant by purposes of this permit, except where the owner or operator submitting permit can adequately demonstrate to the DES that the recorded deviation forms. No exceedance resulted from a CEM malfunction. violations have been noted. Continuous The owner or operator shall install, maintain and operate a Annually EUI DG Whitefield LLC is Steam Flow continuous steam flow rate monitoring/recording system compliant and reports Monitor which shall meet all applicable ASME specifications. steam flows in their Calibration of the steam flow transducer shall occur at least quarterly excess once annually. If an adequate straight length of piping is emission reports and not available, then in lieu of a measuring system that meets certifies that annual ASME specifications, the owner or operator may use a calibrations are steam flow rate monitoring system that can be calibrated performed. by instruments installed, maintained and calibrated per ASME specifications or by other methods approved by the DES. Ammonia The ammonia flow to PCE3 shall be continuously Continuous PCE3 DG Whitefield LLC is Flow monitored using an approved ammonia flow meter. & daily compliant and reports Ammonia usage shall be calculated and recorded daily. calculations ammonia flows in their quarterly excess emission reports 18, RSCR The temperature in the RSCR catalyst bed shall be Continuous PCE3 DG Whitefield LLC is Catalyst Bed continuously monitored using an approved temperature & average compliant and reports Temperature monitor. Whitefield shall calculate and record the average daily temperatures in their daily temperature within the RSCR catalyst bed. calculations quarterly excess emission reports. Note that permit does not specif' a mm temperature limit. 19. Ammonia Whitefield shall calculate and record the ratio of the Daily EU1 & DG Whitefield LLC is Flow/NOx average daily ammonia flow rate in lb/hr, based on the PCE3 compliant and reports Emission ammonia flow meter, to the average daily NOx emission data in their quarterly Rate rate in lb/hr, based on the NOx CEM data. excess emission reports and ammonia slip reports. V. Compliance with Recordkeepin2 and Reporting CHAPTER Env-A Owner or Operator Recordkeeping and Reporting Obligations. Table 5 lists all the documentation filed by DG Whitefield LLC in accordance with permit condition VIII.F. Page 12 ofl8

15 DG WhitefieldLLC Inspection Date. May 16, Off Site Compliance Evaluation Report Date: July 10, 2008 Table 5 - Reporting Requirements Item # Reporting Requirements Frequency of Reporting Status Certification of Accuracy As specified in Several Reports have been Any report submitted to the DES and/or EPA shall include the Permit submitted w/o this statement. the certification of accuracy statement outlined in Section Others were submitted with this XXI.B of the Permit and shall be signed by the responsible statement on a separate page. official. All submittals including applications should contain this statement in the body of the cover letter for each submittal Note: current permit has "Steven Mueller" as the responsible official. Douglas York has been signing as the responsible official. DG Whitefield should send a letter stating that Douglas York should be the responsible official as on the original permit. Annual Compliance Certification Annually (no Compliant Annual compliance certification shall be submitted in later than April 15th of the DG Whitefield LLC has accordance with Section XXI of the Permit. following year) submitted these reports annually and on time. Permit Deviations Prompt reporting Compliant (within 24-hours Prompt reporting of deviations from Permit requirements of discovery of DG Whitefield LLC is reporting including those attributed to upset conditions as defined in an occurrence) deviations within the permit the permit, the probable cause of such deviations, and any guidelines. Majority of corrective actions or preventative measures taken shall be deviations concern opacity conducted in accordance with Section XXVIII of the permit. exceedences. No enforcement actions have been warranted. / See Item 9 below 4 Semi-Annual Permit Deviation and Monitoring Report Semi-annually Compliant The Permittee shall submit a summary report of monitoring by July 3Pt and DG Whitefield LLC has and permit deviations including the following: January 31 S of each calendar submitted the' required reports Summary of maintenance for fuel burning devices and year. on time and accurately. pollution control devices; Summary of permit deviations including data specified in Table 7, Item 4 a), b), c), e) and Item Annual Emissions Report Annually (no The owner or operator shall submit an annual report of the later than April actual emissions including: 15th of the following year) Compliant On time and accurate reports Page 13 ofl8

16 DG frhitefield LLC Inspection Date: May 16, Off Site Compliance Evaluation Report Date: July 10, 2008 tii1iiirêits, : Status For combustion devices, all information in accordance with Env-A and listed in Table 7, Item 5 For process operations, all information in accordance with Env-A and listed in Table 7, Item 7; and The actual annual emissions speciated by individual New Hampshire RTAP including a breakdown of VOC emissions by compound. In compliance except for the inclusion of insignflcant activities. DGWhitefield LLC must report insignificant activities such as; the waste oil heater for the laboratory, the #2 fuel oil heater for the utility shed, the #2 fuel oil heaters for the RSCR and any other fuel using device that may have been installed. If the yearly fuel usage for these devices is zero, then it should be reported as such. Emission-Based Fees Report Annually (no later than April Annual reporting of emission-based fees shall be conducted 15th of the in accordance with Section XXIII of this Permit. The owner following year) Compliant or operator of a stationary source, an area source, or device having actual emissions of 1,000 tons or less shall pay to the Paid thrü 2007 department the annual emission-based fee no later than April 15 each subsequent year for emissions from the previous calendar year. NO,, Repoi ort For fuel burning devices, including boilers, and engines, the owner or operator shall submit to the Director reports of the data specified in Table 7, Item 8, including total annual quantities of all NO emissions as collected from the CEM data. Annually (no later than April following year) Compliant Reports are on time and accurate. CEM Audit Report Quarterly (no CEM audit report for the quarter conducted as specified in later than 30 Env-A 808 and Table 7, Item 6 shall be submitted within 30 days following Compliant days following the close of each calendar quarter. the end of each Reports are on time and quarterly accurate. reporting period) Excess Emission Reports The owner or operator of a source that is required to install and operate a CEM system by part other than 40 CFR 60, shall submit an excess emissions report as follows: j) Excess emission data recorded by the CEM system, including: The date and time of the beginning and ending of each period of excess emission; The magnitude of each excess emission; Quarterly Plus Permit Deviations as they occur Compliant Reports are on time and accurate. Page 14of18

17 S DG Whitefield LLC 2008 Off Site Compliance Evaluation Inspection Date: May 16, 2008 Report Date.' July 10, 2008 item Reporting Requirements Frequency of Reporting Status The specific cause of the excess emission; and The corrective action taken. In calendar year 2005, there k) If no excess emissions have occurred, a statement were 35 permit deviation to that effect; reports received (22 were related to opacity exceedances, 1) For gaseous measuring CEM systems, the daily the remaining were either CEM averages of the measurements made and emission rates related malfunctions or calculated; exceedance of criteria pollutant A statement as to whether the CEM system was limit); and in calendar year inoperative, repaired, or adjusted during the reporting 2006 there were 40 permit period; deviation reports received (24 were related to opacity If the CEM system was inoperative, repaired, or exceedances, the remaining adjusted during the reporting period, the following were either related to CEM information: malfunction or exceedance of The date and time of the beginning and ending of criteria pollutant limit). In each period when the CEM was inoperative; calendar year 2007 there were The reason why the CEM was inoperative; 12 deviation reports received (no opacity related, all CEM The corrective action taken; and related) No enforcement action was warranted at the time of The percent data availability calculated in review. accordance with Env-A for each flow, diluent, or pollutant analyzer in the CEM system. CEM availability has been h) For all "out of control periods" the following greater than the minimum information; requirement of 90%. The times beginning and ending the out of control period; The reason for the out of control period; and The corrective action taken. i) The date and time beginning and ending each period when the source of emissions which the CEM system is monitoring was not operating. j) The span value, of each analyzer in the CEM system and units of measurement for each instrument; and k) When calibration gas is used, the following information: 1) The calibration gas concentration; 2) If a gas bottle was changed during the quarter: The date of the calibration gas bottle change; The gas bottle concentration before the change; The gas bottle concentration after the change; and 3) The expiration date for all calibration gas bottles used. 10. Ammonia Slip Report Quarterly Compliant For the RSCR System, the Permittee shall report the Page 15 of 18 Reports are on time and

18 DG' Whitefleld LLC Inspection Date: May 16, Off Site Compliance Evaluation Report Date. July 10, 2008 Item Reportin" Requirements Frequency of Reporting Status following information quarterly with the CEM Excess Emissions Report: accurate. Daily ammonia usage in gallons; Average daily ammonia flow in lb/hr; Ratio of the average daily ammonia flow (lb/hr) to the average daily NOx flow (lb/hr); and Average daily temperature of the RSCR catalyst bed. 11. Quality Improvement Plan Submittal As expeditiously as practicable The Permittee shall submit to DES the QIP required in Table 7, Item 12 and notif' DES if submittal will exceed 180 days None Required from the day the source becomes subject to the permit condition. VI. Compliance with RACT CHAPTER ENV-A Prevention, Abatement, and Control of Stationary Source Air Pollution PART Env-A Stationary Sources of VOCs DG Whitefield LLC is not subject to VOC RACT. PART Env-A Nitrogen Oxides DG Whitefield LLC is in compliance (see Tables 3 & 4 NOx RACT requirements). DG Whitefield LLC has actual NOx emission considerably above the theoretical potential emissions threshold of 50 tons of NOx per year and therefore is subject to NOx RACT. Since installing the RSCR in 2004, its NOx emissions have decreased to 145 tons in 2004, 58 tons in 2005, 67 tons in 2006, and 74 tons in The permit limits DG Whitefield LLC to 500 hours of operation of either the diesel generator or the diesel fire pump. DG Whitefield LLC is in compliance with this requirement (see Table 1). VI. Compliance with Toxics Regulations PART Env-A Applicability and Part Env-A Permit Requirements DG Whitefield LLC is using virgin fuels and therefore is exempt from the requirements of this chapter. DES's engineering summary dated September 30, 2005, summarizes the results of the analysis to demonstrate that regulated toxic air pollution from the facility do not exceed the daily or annual deminimus limits. This summary was reviewed recently when DG Whitefield LLC applied for their temporary permit and found to still be accurate. Page 16of18

19 DO Whitefield LLC Inspection Date: May 16, Off Site Compliance Evaluation Report Date: July 10, 2008 Compliance with Permit Fee System PART Env-A Emission Based Fees DG Whitefield LLC is in compliance and has paid emission fees in years on time. Compliance with other Miscellaneous Provisions PART Env- A Precautions to Prevent, Abate, and Control fugitive Dust DG Whitefield LLC is subject to this part and shall take precautions to prevent, abate and control the emission of fugitive dust. DO Whitefield LLC certifies that they are in compliance as stated in their annual certification compliance report. PART ENV-A Fuel Specifications DG Whitefield LLC is subject to this part. The facility burns used-oil in the used-oil burner, and #2 diesel fuel in the RSCR heaters, emergency generator and emergency fire pump. DG Whitefield has not provided any documentation as to the sulfur content of the #2 diesel fuel. This is required to be included with the annual emissions statement. CHAPTER ENV-A Fuel Burning Devices DO Whitefield LLC is subject to this part and installed and operates a COM, which records opacity in the stack on a continuous basis. PART Env-A Visible Emission Standard DG Whitefield LLC has a multicyclone and ESP to control the particulate emissions from the boiler stack. All records reviewed demonstrate compliance with this part. Opacity, as indicated by the COM, is maintained between 3% and 9%. PART Env-A (c)(3) - Particulate Emission Standards PM emission rate for EU1 - Boiler shall be limited to the more restrictive NSPS limit of 0.10 lb/mmbtu heat input. DG Whitefield LLC conducted a stack test on May 26, Particulate matter results were below 0.10 Ib/MMBtu heat input. The next stack test is due within 90 days of May 26, Compliance with Applicable Federal Rules DG Whitefield LLC is compliant with the particulate requirements of 40 CFR Subpart Db. In its 2004 stack test, DO Whitefield LLC showed that its particulate matter emissions were less than 0.10 lb/mmbtu heat input. Any source which does not have the potential to emit greater than 250 ton per year of a regulated new source review ("NSR") pollutant is exempt from Prevention of Significant Deterioration ("PSD") 40 CFR Facility boiler emissions from DO Whitefield LLC are limited to less than 250 tons per year of NOx or CO and 57 lb/hr of NOx and CO averaged over each 365 day period, therefore, NSR is not applicable to DO Whitefield LLC. As of the date of this inspection, DO Whitefield LLC was compliant with this requirement. If DO Whitefield LLC calculated that the CO lb/hr rolling average were to exceed the 57 lb/hr limit, the facility would shut down. Page 17 of 18

20 . I l Of DO 7VhiteJield LLC Inspection Date: May 16, Off Site Compliance Evaluation Report Date: July 10, 2008 Based on emission testing for hydrochloric acid at DG Whitefield LLC on May 26, 2004, and similar testing at Bridgewater Power Co's. wood-fired boiler on June 10, 2004, for benzene, acrolein and styrene, DES concluded that DG Whitefield LLC is a true minor source of hazardous air pollutants, therefore, DG Whitefield LLC is not subject to NESHAP (40CFR61/63 and ENV A 500). Enforcement History and Status Since the last onsite inspection, DES has had no enforcement actions against DG Whitefield LLC. Conclusions and Recommended Actions A review of all the records submitted to DES by DG Whitefield LLC since the last on-site inspection in 2006 demonstrates that DG Whitefield LLC is complying with the majority of its permit and with Env-A- 100 et seq. There were some deficiencies found as a result of this off-site inspection. They are as follows: DG Whitefield LLC must report ALL fuel usage at the facility in the annual emissions statement: the waste oil heater(s) plus the diesel fuel used in the two RSCR heaters. If the fuel usage is zero, then DG Whitefield should state this occurrence. DG Whitefield LLC shall also include the sulfur content of the fuel (which may be obtained from the fuel delivery tickets or by actual testing). Note that the wood-fired boiler is not currently permitted to burn waste oil. It is listed on the annual emission statement as a secondary fuel. DG Whitefield LLC should either delete the reference to the secondary fuel (waste oil) or file an amendment to the permit requesting that it be added. The "Certification of Accuracy" statement was missing on several report submittals. Other report submittals had this statement on a separate page. DG Whitefield LLC should include this statement on ALL submittals including applications in the body of the cover letter or on a separate sheet with the company letterhead. It should be noted, that the current permit has "Steven Mueller" as the responsible official required to sign submittals. Douglas York has been signing as the responsible official. DG Whitefield LLC must submit an ARD-1 form to amend the permit stating that Douglas York should be the responsible official (as on the original permit). Greg Helve Sr. Compliance Assessment Engineer Air Resource Division Department of Environmental Services Page 18 of 18