PERMIT APPLICATION REVIEW SUMMARY FOR FLARE NOS. 1, 5 & 6

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1 AFS #: Application #: FY Date: Page 1 of 5 APPLICATION & OTHER COMMUNICATION Date Brief Description November 23, 2005 Permit Application for Flares 5 and 6 December 2, to Steve Poggi requesting additional information December 7, from Bill Howard regarding additional information for TREE Flares #5 and #6 and Control Capacity Plan December 8, from Mike North regarding additional information for Flares 5 and 6 December 19, from Mike North regarding table with updated modeling parameters (Flare 5 & 6 Applic.pdf) January 13, from Bill Howard updating NOx information for Flares 5 and 6. July 7, from Bill Howard explaining the design rating of Flares 1 and 2. July 13, from Bill Howard with table with all the emission units and associated information. FACILITY DESCRIPTION Waste Management of NH, Inc. (WMNH) (TREE),, is an integrated solid waste management facility located at 30 Rochester Neck Road. TLR-I and TLR-II are closed landfills, and TLR-III is an active landfill. TLR-I closed in 1992; TLR-II closed in 1997; and TLR-III commenced operation in December PROJECT DESCRIPTION Per the Consent Decree between the State and WMNH, Inc. approved by the Strafford County Superior Court on February 28, 2006, TREE is required to install two flares. TREE proposes to add one utility flare (Flare No. 5) and one ultra low emissions flare (Flare No. 6). Flare No. 5 is rated at 3200 scfm and MMBtu/hr (which is equivalent to 3200 scfm and 550 Btu/scf), and Flare No. 6 is rated at 3500 scfm and MMBtu/hr (which is equivalent to 3500 scfm and 550 Btu/scf). TREE will remove Flare No. 4 from service and only use Flare No. 1 as back-up for any permitted control device in order to net out of New Source Review for NOx. When Flare No. 6 is installed, the fuel consumption from Flare No. 5 will be capped to limit the NOx emissions for NSR netting purposes. In addition, the total NOx emissions from Flare Nos. 5 and 6 are capped. PROCESS/DEVICE DESCRIPTION Device/Process Flare No. 5 Flare No. 6 Description Utility flare rated at 3200 scfm and MMBtu/hr (HHV) (which is equivalent to 3200 scfm and 550 Btu/scf) with fuel consumption limitation of 950 mmscf/yr Ultra low emission flare rated at 3500 scfm and MMBtu/hr (HHV) (which is equivalent to 3500 scfm and 550 Btu/scf) Flare No. 1 Utility flare rated at 1500 scfm 1 and 49.5 MMBtu/hr (HHV) (which is equivalent to 1500 scfm and 550 Btu/scf) Flare No. 4 Utility flare rated at 800 scfm and 26.4 MMBtu/hr (HHV) (which is equivalent to 800 scfm and 550 Btu/scf) 1 Note that WMNH applied for a flow rating of 1495; however, the permit lists 1500 scfm to be consistent in significant figure precision with the ratings of the other flares.

2 AFS #: Application #: FY Date: Page 2 of 5 STACK INFORMATION Flare Nos. 5 and 6 shall have exhaust stacks that discharge vertically, without obstruction, and meet the criteria in Table 1. Table 1 - Stack Criteria Device Minimum Stack Height (Discharge Height)(Feet) Above Ground Level Maximum Stack (Tip) Diameter Flare No inches Flare No ft (outside); ft (inside) MODELING See permit application dated November 23, 2005 and memo dated December 19, 2005 from David Healy to Liz Nixon. NO X NETTING CALCULATION Table 2 NOx Netting Calculation Modification Date Baseline (tpy) Actual or Future (tpy) Net Change (tpy) Net Increase (tpy) Add Flare 3 January Add Flare 4 April Add Hauling Co. Repair Bay Space Heater December Remove Flare 4 March Remove Flare 1 March Add Flare 5 March Add Flare 6 August The baseline emissions for Flare Nos. 1 and 4 are based on the 12-month period from September 1, 2004 through August 31, The net change for Flare No. 6 is zero because the NOx emissions for both Flare Nos. 5 and 6 have been limited to 17.8 tons per consecutive 12-month period.

3 AFS #: Application #: FY Date: Page 3 of 5 REVIEW OF REGULATIONS The following regulations are applicable to Flare Nos. 1, 5, and 6 State Regulations Env-A 700 Env-A 800 Env-A 900 Env-A 1211 NOx RACT Env A 1400 Env-A 2000 Federal Regulations 40 CFR 60 Subpart WWW 40 CFR 60 Subpart A 40 CFR 63 Subpart AAAA (This regulation is applicable because the facility meets the criteria of 40 CFR (a)(3).) 40 CFR 63 Subpart A 3 According to Env-A 618 and 40 CFR , dated July 21, 1992.

4 AFS #: Application #: FY Date: Page 4 of 5 EMISSION CALCULATIONS Table 3 and Maximum Allowable Pollutant Potenital for Flare 5 (lb/hr) for Flare 6 (lb/hr) Maximum with Fuel Consumption Limitations ( ) for Flare 5 consecutive 12-months) for Flare 6 consecutive 12-months) Maximum Allowable For multiple devices consecutive 12- months) NOx See combined limit (31.5) See combined limit 17.8 for Flares 5 and 6 combined 3 CO (171.1) 30.4 Less than 250 for all devices 4 PM (2.0) 9.1 NA HCl (2.0) 2.2 NA SO (213.0) Less than 250 for all devices 5 The hourly and annual potential emissions are listed in Table 3. To net out of the New Source Review provisions, WMNH must limit the total combined NOx emissions from Flare Nos. 5 and 6 to 17.8 tons per consecutive 12-month period. To limit the emissions from Flare No. 5, the fuel consumption from Flare No. 5 cannot exceed 950 MMscf per consecutive 12- month period. Therefore, the maximum emissions with the fuel consumption limitation for Flare No. 5 as well as the potential emissions without any fuel consumption limitations are listed in Table 3. According to the Consent Decree, WMNH wanted to remain a minor PSD source; therefore, WMNH is limited to 250 tons per consecutive 12-month period for CO and SO2. Flare No. 1 shall not exceed the annual NOx, CO, and SO2 emission limitations for the control device for which it is replacing. CHANGES FROM PREVIOUS PERMITS Current Permit (permit #) PO-BP-2545 TP-B-0487 Reason for change Need to remove Flare 1 from service upon initial operation of Flare No. 5 and only use Flare 1 as back-up for any permitted device Need to remove Flare 4 from service upon initial operation of Flare No. 5 4 According to the conditions of the Consent Decree, Env-A 619, and 40 CFR According to the conditions of the Consent Decree, Env-A 619, and 40 CFR

5 AFS #: Application #: FY Date: Page 5 of 5 SUMMARY AND CONCLUSIONS Based upon the information submitted by WMNH in the permit application and supplemental information for Flare Nos. 5 and 6, Flare Nos. 5 and 6 must meet the applicable air quality regulations and requirements as outlined in the Temporary permit. Upon installation and operation of Flare Nos. 5 and/or 6, WMNH shall immediately remove Flare Nos. 1 and 4 from service, and only use Flare No. 1 as back-up.