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The State of New Hampshire DEPARTMENT OF ENVIRONMENTAL SERVICES Thomas S. Burack, Commissioner October 1, 2009 Mr. Russell Dowd Plant Manager Pinetree Power - Tamworth, Inc. P.O. Box 233 West Ossipee, NH 03890 RE: Inspection Report for Pinetree Power - Tamworth Dear Mr. Dowd: The New Hampshire Department of Environmental Services, Air Resources Division co.nducted an Off-site Full Compliance Evaluation of Pinetree Power-Tamworth (PPT) on September 29, 2009. DES identified the following deficiencies during the inspection: PPT is not attaching the "Certification of Accuracy Statement" as outlined in Section XXLB of the Title V Permit (TV-OP-018) to the stack test report submittals. PPT should attach the statement to all submittals to DES. PPT did not calculate the emissions from the cooling tower, fire pump and insignificant activities and did not pay the fees associated with those emissions from 2004-2008. PPT should calculate the emissions from the cooling tower, fire pump and insignificant activities for the years 2004 through 2008 and pay the associated fees for those emissions. See Table below for applicable fees per year. Year Emission Fee Rate ($/ton) 2004 86.75 2005 88.61 2006 90.95 2007 102.04 2008 125.85 PPT is not providing the annual NOx Reporting Requirements as required by Table 8, Item 4 of the Title V Permit. PPT should include the required information by April. 15 following the year of emissions. DES Web site: www.des.nh.gov P.O. Box 95, 29 Hazen Drive, Concord, New Hampshire 03302-0095 Telephone: (603) 271-1370 • Fax: (603) 271-1381 • TDD Access: Relay NH 1-800-735-2964

The State of New Hampshire DEPARTMENT OF …The New Hampshire Department of Environmental Services, Air Resources Division co.nducted an Off-site Full Compliance Evaluation of Pinetree

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Page 1: The State of New Hampshire DEPARTMENT OF …The New Hampshire Department of Environmental Services, Air Resources Division co.nducted an Off-site Full Compliance Evaluation of Pinetree

The State of New Hampshire

DEPARTMENT OF ENVIRONMENTAL SERVICES

Thomas S. Burack, Commissioner

October 1, 2009

Mr. Russell Dowd Plant Manager Pinetree Power - Tamworth, Inc. P.O. Box 233 West Ossipee, NH 03890

RE: Inspection Report for Pinetree Power - Tamworth

Dear Mr. Dowd:

The New Hampshire Department of Environmental Services, Air Resources Division co.nducted an Off-site Full Compliance Evaluation of Pinetree Power-Tamworth (PPT) on September 29, 2009. DES identified the following deficiencies during the inspection:

PPT is not attaching the "Certification of Accuracy Statement" as outlined in Section XXLB of the Title V Permit (TV-OP-018) to the stack test report submittals. PPT should attach the statement to all submittals to DES.

PPT did not calculate the emissions from the cooling tower, fire pump and insignificant activities and did not pay the fees associated with those emissions from 2004-2008. PPT should calculate the emissions from the cooling tower, fire pump and insignificant activities for the years 2004 through 2008 and pay the associated fees for those emissions. See Table below for applicable fees per year.

Year Emission Fee Rate ($/ton)

2004 86.75 2005 88.61 2006 90.95 2007 102.04 2008 125.85

PPT is not providing the annual NOx Reporting Requirements as required by Table 8, Item 4 of the Title V Permit. PPT should include the required information by April. 15 following the year of emissions.

DES Web site: www.des.nh.gov P.O. Box 95, 29 Hazen Drive, Concord, New Hampshire 03302-0095

Telephone: (603) 271-1370 • Fax: (603) 271-1381 • TDD Access: Relay NH 1-800-735-2964

Page 2: The State of New Hampshire DEPARTMENT OF …The New Hampshire Department of Environmental Services, Air Resources Division co.nducted an Off-site Full Compliance Evaluation of Pinetree

Pinetree Power- Tamworth

Page 2 Off-site Full Compliance Evaluation

Enclosed is a copy of the Inspection Report for your records.

If you have any questions regarding the inspection or the final report, please feel free to call me at (603) 271-0650.

Sincerely,

Greg Helve Senior Compliance Assessment Engineer Air. Resources Division

Enclosure: Pinetree Power- Tamworth Off-site Full Compliance Evaluation cc: Town of Ossipee - Board of Selectmen

Page 3: The State of New Hampshire DEPARTMENT OF …The New Hampshire Department of Environmental Services, Air Resources Division co.nducted an Off-site Full Compliance Evaluation of Pinetree

NEW HAMPSHIRE DEPARTMENT OF WEnvironmental Services

OFF-SITE FULL COMPLIANCE EVALUATION

Pinetree Power-Tamworth, Inc. • 469 Plains Road, Route 41,P.O. Box 233

West Ossipee, New Hampshire 03890 • Carrol County

(603) 323-8187 AFS # 3300300019

Inspection Date: September 29, 2009 Final Report: September 29, 2009

Inspected and Prepared by:

New Hampshire Department of Environmental Services Air Resources Division

29 Hazen Dr., P.O. Box 95 Concord, New Hampshire 03302-0095

rx~ ~ 4, 4 ' e, ~ _ , Greg4lelve / Sr. Compliance Assessment Engineer

Page 4: The State of New Hampshire DEPARTMENT OF …The New Hampshire Department of Environmental Services, Air Resources Division co.nducted an Off-site Full Compliance Evaluation of Pinetree

Pinetree Power- Tamworth

Inspection Date.' 0912912009 Tamworth

Report Date.' 0912912009

Inspection

On September 29, 2009, the New Hampshire Department of Environmental Services, Air Resources Division (DES) completed an Off-Site Full Compliance Evaluation of Pinetree Power-Tamworth. Inc.(PPT), located in Tamworth, NH. PPT was targeted for inspection based on DES inspection criteria, which specifies that a major source with a Title V Permit to Operate be inspected once every two years.

Date/Time of Inspection: September 29, 2009, Type of Inspection: Off-Site Full Compliance Evaluation Inspected by: Greg Helve, Senior Compliance Engineer Weather: N/A Source Contacts: Russell Dowd, Plant Manager

Last Inspection: September 06, 2007 Inspection Result: No deficiencies were observed during that inspection Permit Numbers: TV-OP-0 18: Expires October 31, 2010

TP-B-0543: Expires September 30, 2009 (app. Shield applies)

Facility Description

PPT burns whole tree wood chips in a boiler producing steam to spin a turbine. The Zurn-designed, spreader stoker, waterwall boiler uses 15 screw feeders to distribute wood chips across the grated floor of the boiler. The boiler is rated at a maximum of 404.13 million British thermal units per hour ("MMBtu/hr") and can produce approximately 220,000 lb/hr of steam at 700 psig and 900°F while burning approximately 47.5 tons/hr of wood chips with an average heating value of 4,250 Btu/lb (assuming a 50% moisture content of the chips). PPT controls its particulate matter ("PM") emissions from the boiler using a multiclone and an electrostatic precipitator ("ESP"). In March 2008, PPT installed a selective non-catalytic reduction system and a selective catalytic reduction system to control nitrogen oxide ("NOx") emissions. The SNCR and SCR require the use of ammonia (in this case, urea, a form of ammonia).

PPT has a 745 horsepower ("hp") emergency generator, which can fire diesel fuel at a maximum rate of 39.9 gallons/hr in the event of a Public Service of New Hampshire ("PSNH") blackout or when the boiler is shutdown for maintenance purposes. It also has a 187 hp diesel fire pump to be used in the event of a fire emergency. In addition, PPT has a 26,000 gallonlminute cooling tower. The tower lets the water which flows through the tubes of the main condenser lose the heat it has gained from the condensation of the primary side steam. The steam, after spinning the blades of the turbine, is condensed back to liquid on the shell side of the condenser and then fed back to the boiler tubes by the feedwater pumps. The entrainment of water treatment chemicals in the water mist that evaporates from the cooling tower is also a source of particulate emissions from the facility. Table 1 lists the significant emission units, Table 2 lists the pollution control equipment and Table 3 lists the

Page 2 of 13

Page 5: The State of New Hampshire DEPARTMENT OF …The New Hampshire Department of Environmental Services, Air Resources Division co.nducted an Off-site Full Compliance Evaluation of Pinetree

Pinetree Power- Tamworth

Inspection Date. 0912912009 Tamworth

Report Date. 0912912009

stack information.

Emission Unit Identification and Operating Conditions

Table 1 -Sk,nificant Emission Unit Identification

Description ofLE misslon Emissions Unit Maximum Permitted Reported Operating and Fuel Use Unit Capacity Data

Zurn Two Drum The maximum operating rate of the boiler is 2008: 283,847 tons Waterwall Wood-fired limited to 404.13 MMBTU/hr of heat input,

Boiler which is equivalent to 47.5 tons/hour of

Model No: 2-Drum Open wood chips with a heating value of 4,250 2007: 320,334 tons

ass BTU/lb, assuming approximately 50 /o

moisture. This is equivalent to 220,000 Type of Burner: Spreader lbs/hr of steam production as averaged over

Stoker any consecutive 24-hour period at 900 °F

Date of installation. July and 700 PSIG, assuming a boiler efficiency

1987 of7l.47% and boiler feedwater temperature of 405 °F.

745 hp Caterpillar All emergency generators including the fire 2008: 223.7 gal-4iesel, 17 hrs Emergency Diesel pump, are limited to operate less than 500

Generator, Model #3412 hours each during any consecutive 12

Date of installation: month-period and the combined theoretical 2007: 479.25 gal-diesel, 24.5 hrs

November 1987 potential emissions of NOx from all such generators are limited to less than 25 tons for any consecutive 12-month period.

187 hp Fire P'P No data reported

Cooling Tower Drift Factor = 0.002% (Manufacturer's data) No data reported

Date of installation: 1987 Circulation Rate = 26,000 gallons/minute

Control Eiuipment

Table 2 - Pollution Control Equipment Identification

Pollution Emission Control Description of Equipment Activity

Unit # Equipment #

PCE1 Multiclone Primary particulate mattercontrol EUO I

Secondary particulate matter EUO 1 PCE2 Electrostatic Precipitator (ESP) control

PCE3 Selective Non-Catalytic Reduction Control of nitrogen oxides EUO I

(new) (SNCR) System PCE4 Selective Catalytic Reduction (SCR)

Control of nitrogen oxides EUO I (new) System

Page3 ofl3

Page 6: The State of New Hampshire DEPARTMENT OF …The New Hampshire Department of Environmental Services, Air Resources Division co.nducted an Off-site Full Compliance Evaluation of Pinetree

Pinetree Power- Tamworth

InspectiOn Date; 0912912009 Tamworth

Report Date: 0912912009

Stack Criteria Table 3- Stack Criteria

L Compliance with Permitting Requirements

CHAPTER ENV-A 300 - Ambient Air Quality Standards ("AAQS")

PPT is in compliance. Reference DES modeling memo dated July 8, 1986 that demonstrated compliance with the National Ambient Air Quality Standards ("NAAQS).

CHAPTER ENV-A 500 - Standards Applicable to Certain New or Modified Facilities and Sources of Hazardous Air Pollutants

PPT is subject to the New Source Performance Standard ("NSPS") specified in Env-A 503.01, 40 CFR 60 Subpart Db Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units. PPT is in compliance with the particulate requirements of 40 CFR 60.43 Subpart Db of 0.1 Ib/MMBtu. In the 2009 stack test, PPT showed that its particulate matter emissions were less than 0.025 lb PM/MMBtu heat input. PPT is not subject to any of the National Emission Standards for Hazardous Air Pollutants ("NESHAP") specified in Env-A 504.01 or any of the National Emission Standards for Hazardous Air Pollutants for Source Categories (Maximum Achievable Control Technology, or MACT, Standards) specified in Env-A 505.01. Based on emission testing for hydrochloric acid at PPT in June 2004, and similar testing at Bridgewater Power Company's wood-fired boiler on June 10, 2004, for benzene, acrolein and styrene, DES concluded that PPT is a true minor source of hazardous air pollutants. Therefore, PPT is not subject to NESHAP (40 CFR 61 and 63).

CHAPTER ENV-A 600 - Statewide Permit System

USEPA Region 1 issued Prevention of Significant Deterioration ("PSD") Permit No. 040-149NH06 ("the PSD Permit") to PPT on November 15, 1990. A PSD permit was necessary, because PPT's emissions typically exceed 275 tons per year ("tpy") of nitrogen oxides ("NOx") and 200 tpy of carbon monoxide ("CO"). The limits of the PSD Permit are incorporated into Title V Operating Permit TV-OP-018 ("the Permit"), which DES originally issued to PPT on September 15, 1999. The Permit was renewed on October 17, 2005. The renewal of the Permit in 2005 incorporated the requirements of 40 CFR 64 Compliance Assurance Monitoring ("CAM"). CAM provides reasonable assurance, by the source's monitoring of operational and maintenance parameters of air pollution control devices, that it is complying with emissions limits. CAM applies to Title V sources with pollution control equipment whose pre-controlled emissions exceed the major source threshold. PPT has pre-controlled emissions of particulate matter ("PM") greater than 100 tpy. It uses a multiclone in series with an electrostatic precipitator to control PM emissions. Hence, the CAM rule is applicable to PM emissions from the wood-fired boiler and the Permit contains CAM requirements for the multiclone and ESP.

Page 4 of 13

Page 7: The State of New Hampshire DEPARTMENT OF …The New Hampshire Department of Environmental Services, Air Resources Division co.nducted an Off-site Full Compliance Evaluation of Pinetree

Pin etree Power-Tamworth

Inspection Date. 0912912009 Tamworth

Report Date. 0912912009

PPT is also a major source of NOx and CO. However, it also has continuous emissions monitoring ("CEM") system to constantly monitor its actual emissions of NOx and CO, therefore, CAM is not required for NOx and CO. DES granted PPT a Temporary Permit (TP-B-0543 dated March 17, 2008) for the installation of Selective Non-Catalytic Reduction (SNCR) and Selective Catalytic Reduction (SCR) systems to reduce NOx emissions from the wood boiler; ThisPerrnit is setto expireSeptember 30, 2009. PPT has filed forrenewal of both the Temporary Permit and the Title V Permit and qualifies for Appliéation Shield. These Permits will be combined into a final Title V Permit.

Annual emissions for the facility are calculated and submitted by PPT from CEM data, from the amount of fuel combusted with EPA's AP-42 Emission Factors or stack test-derived emission factors. The annual emissions for the last 2 years are listed in Table 4 below.

Table 4 - Facility Wide Emissions (Tons per Year)

Year PM SO2 NO CO VOCs Total

2008 6.39 10.65 158.60 321.66 3.83 501.13

2007 7.21 12.03 338.51 299.17 4.33 661.24 The total emissions in Table 4 only include the wood boiler (EU01) and the emergency generator (EUO2).

PPT has not reported the emissions for the other significant (i.e., cooling tower and fire pump) and insignificant activities for 2004 thru 2008.

The Permit also contains short-term emission limits which are listed in Table 5.

Table 5— CEM data and stack test results

Pollutants Emission Limits 2008 2007

NO (24-hr avg) 107.1 lb/hr 93.3 lb/hr 1 90.29 lb/hr' NO (24-hr avg) 0.265 lb/MMBtu 0.229 lb/MMBtu' 0.241 lb/MMBtu' CO (24-hr avg steady state)

202.10 lbs/hr 147.95 lb/hr 1 __

13 8.8 7 lb/hr' __________________________

CO (24-hr avg steady state)

0.5 lb/MMBtu 0.554 lb/MMBtu 1 '2 0.507 lb/MMBtu"2

PM 10.10 lb/hr 0.95 lb/hr (2009 stack test result) PM 0.025 lb/MMBtu 0.002 lb/MMBtu (2009 stack test result) SO2 40tpy See Table 4. VOCs 3 8.8 0 lb/hr No emissions data VOCs 0.096 lb/MMBtu No emissions data Ammonia NH3 20 ppm 3.8 ppm (2009 stack test result) Opacity (steady state) 15 % 6.54 %1• 7.02 %' 1 Highest 24-hr value during the year 2 Occurred during startup/shutdown. Exceedance is acceptable as long as the CO lb/hr limit is not violated.

Page 5 ofl3

Page 8: The State of New Hampshire DEPARTMENT OF …The New Hampshire Department of Environmental Services, Air Resources Division co.nducted an Off-site Full Compliance Evaluation of Pinetree

Pinetree Power- Tarnworth inspection Date. 0912912009 Tamworth Report Date: 0912912009

Compliance with some of the limits in Table 5 is determined by CEM and/or periodic stack emissions tests. In some cases, PPT has reported 24-hour average emissions which exceed the limits in Table 2. Typically, exceedances of lb/MMBtu limits occur during periods when the boiler is in start up mode and boiler oxygen levels are higher than normal. The calculation for lb/MMBtü does not give accurate emissions data in these circumstances, which causes the daily average to be erroneously high. Other exceedances of the 24-hour average emission limit have been reported to DES as permit deviations. Most were due to CEM malfunctions or infrequent boiler upsets. All deviatiOns and appropriate actions have been reviewed and accepted by DES.

Env-A 606 -Modeling

Air dispersion modeling was conducted at the time of PSD application review and is described in the preliminary BACT determination dated February 14,1990.

Compliance with Permit Fee System

CHAPTER ENV-A 700 - Permit Fee System

Env-A 705.04 - Payment of Emission-Based Fee

Emission-based fees are due by April 15 of the year following the emissions year. PPT has demonstrated compliance by timely submission of fees.

PPT has not reported (orpaidfeesfor) the emissions from the other sign jficant (i.e., cooling tower andfire pump) and insigncant activities for 2004 thru 2008.

Source Testing and Monitoring

CHAPTER ENV-A 800 - Testing and Monitoring Procedures

Env-A 802 - Testing and Monitoring for Stationary Sources

PPT last conducted compliance stack emissions testing for hydrogen chloride on May 9, 2004. PPT last conducted compliance stack emissions testing for PM, NH3, S02, NOx and CO on May20 and 21, 2009. PPT has demonstrated compliance with Permit requiremônts.

Part Env-A 808 - Continuous Emission Monitoring

PPT continuously monitors emissions of NOx, CO, 02, volumetric stack flow rate and opacity. The facility actually has 2 gaseous pollutant CEM systems. The primary CEM is the newer SICK Maihak multi-component monitoring system which was last certified on June 1, 2007. PPT also maintains its prior TECO cEM system which serves as a backup, if necessary, for either PPT or the similar PP Bethlehem facility in Bethlehem, NH. PPT is using EPA test method 6C for the determination of sulfur dioxide emissions in lieu of the AP-42 emission factors.

Page 6 of 13

Page 9: The State of New Hampshire DEPARTMENT OF …The New Hampshire Department of Environmental Services, Air Resources Division co.nducted an Off-site Full Compliance Evaluation of Pinetree

Pinetree Power- Tamworth Inspection Date: 0912912009 Tamworth Report Date: 0912912009

PPT is required to have a minimum data availability of 90% per quarter and 75% per month for its CEM system. PT Tamworth reports this data in its quarterly excess emission reports. Data availability falls within this required range.

See the Full Compliance Evaluation Records Review in Appendix A attached to this report for all Relative Accuracy Test Audits ("RATAs"); quarterly Opacity Audits ("OPA5"), Cylinder Gas Audits ("CGAs") and Relative Accuracy Audits ("RAAs"); 7 Day Drift tests ("7DDs"); and quarterly Excess EmissiOn Reports ("EERs") submitted by PPT.

IX. Compliance with Recordkeeping and Reporting

CHAPTER ENV-A 900 - Owner or Operator Recordkeeping and Reporting Obligations

Since this is an off-site inspection, PPT's compliance with recordkeeping obligations could not be verified.

Env-A 907 - General Reporting Requirements

PPT submits to DES the reports required by the Permits. The Full Compliance Evaluation Records Review is included in Appendix A to this report. The appendix lists all the reports that were reviewed in order to complete this compliance evaluation. The appendix includes a determination of each report's timeliness with regard to the required submittal date, and if the report was acceptable in terms of its content.

PPT is not attaching the "Certification ofAccuracy Statement" as outlined in Section XXLB of the Permit to the stack test report submittals.

PPT has not been calculating the emissions from the cooling tower andfire pump or paying the fees associated with those emissions from 2004-2008.

PPT is not providing the annual NOx emissions statement as required by Table 8, Item 4 of the Permit.

Env-A 911 - Recordkeeping and Reporting Requirements for Permit Deviations

PPT has demonstrated compliance by reporting deviations within 24 hours of discovery, sending detailed reports within 10 days and summarizing the deviations in the Semi-Annual Deviation and Monitoring Reports. So far in 2009 through June, there have been 12 reported deviations: 4-opacity exceedances, 4-startup time exceedances, 3-CEM related problems and 1-CO lb/MMBtu exceedance during startup. In 2008 there were 26 deviations reported: 1 0-opacity exceedances, 8-startup time exceedances, 7-CEM related problems and 1 -ESP related problem. In 2007 there were 17 deviations reported: 3-opacity exceedances, 1-CEM related problem, 4-startup time exceedances, 7-CO lb/MMBtu exceedances during startup, I -NOx exceedance during startup and 1-equipment failure.

Page 7 of 13

Page 10: The State of New Hampshire DEPARTMENT OF …The New Hampshire Department of Environmental Services, Air Resources Division co.nducted an Off-site Full Compliance Evaluation of Pinetree

Pinetree Power-Tamworth Inspection Date. 0912912009 Tamworth Report Date: 0912912009

Compliance with RACT

CHAPTER ENV-A 1200 - Prevention, Abatement, and Control of Stationary Source Air Pollution

Env-A 1204 - Stationary Sources of VOCs

PPT has no devices or processes that are subject to Reasonably Available Control Technology ("RACT") requirements for VOCs.

Env-A 1211 - Nitrogen Oxides

Env-A 1211.04(d) is applicable to EUO 1., but the PSD limit is more stringent. The RACT limit is 0.33 lb/MMBtu, whereas the more stringent PSD Permit limit is 0.265 lb/MMBtu, averaged over any consecutive 24-hour period and 107.10 lb/hr averaged over any consecutive 24-hour period. PPT is in compliance with the NOx RACT limit and PSD limit.

The emergency generator and fire pump are exempt from NOx RACT provisions as long as the operating hours of each device are limited to 500 operating hours per year and the combined theoretical potential NOx emissions of these devices is less than 25 tOns per any consecutive 12-month period.

PPTfailed to submit operating hours and NOx emissions for the fire pump, as required by the Permit, therefore, compliance cannot be assessed

Compliance with Toxics Regulations

CHAPTER ENV-A 1400 - Regulated Toxic Air Pollutants ("RTAPs")

The combustion of virgin fuels is exempt from Env-A 1400. PPT uses water additives, including sulfuric acid and sodium hypochiorite, in the cooling tower. Sulfuric acid and sodium hypochiorite are RTAPs. PPT demonstrated compliance with these RTAPs using the de minimis emission method as noted in the Engineering Calculation Sheet dated June 20, 2005 for the Permit. From the usage of urea and ammonia in the SNCR or SCR systems, ammonia emissions (ammonia slip) will occur. Ammonia is an RTAP. PPTdemonstrated compliance with the ammonia ambient air limits using the adjusted in-stack concentration method as noted in the Engineering Calculation Sheet dated February 06, 2008 for the Temporary Permit No. TP-B-0543.

Compliance with Process/Particulate/Opacity Regulations

CHAPTER ENV-A 2000 - Fuel Burning Devices

Env-A 2002.02 - Visible Emission Standard for Fuel Burning Devices Installed After May 13, 1970

Page 8 of 0

Page 11: The State of New Hampshire DEPARTMENT OF …The New Hampshire Department of Environmental Services, Air Resources Division co.nducted an Off-site Full Compliance Evaluation of Pinetree

Pinetree Power- Tamworth Inspection Date.' 0912912009 Tamworth Report Date,' 0912912009

The PSD Permit limits the wood boiler to 20% opacity (6-minute average) during startup/shutdown conditions except for one 6-minute average per hour of not more than 27% opacity. The PSD Permit also limits the wood boiler to 15% opacity (6-minute average) during steady state operating conditions except for one 6-minute average per hour of not more than 27% opacity. PPT continuously monitors the opacity on the wood boiler with a continuous opacity monitor and reports exceedances in permit deviations. Pinetree must not exceed 20% opacity for any continuous 6-minute period from the emergency generator and fire pump. The PSD Permit also limits facility-wide fugitive emissions to 5% opacity at any time. This offsite evaluation does not include observations of opacity; however, PPT reports exceedances in permit deviation reports and has certified compliance with the opacity limitation for the emergency generator, fire pump, and facility-wide.

The FPT boiler exceeded the opacity limitation 4 times so far in 2009 during start ups. PFT is modifying startup procedures to minimize the occurrences. In 2008, PPT had problems with the opacity monitor, method 9 was used and no exceedances were noted. The monitor has been replaced. There were 3 instances of exceedance reported in 2007.

Env-A 2002.06 - Particulate Emission Standards for Fuel Burning Devices Installed on or After January 1, 1985

The wood boiler (EUO 1) at PPT is required to meet a PM limit of 0.10 lb /MMBtu according to Env-A 2002.08(c)(3). The New Source Performance Standard (NSPS) for Industrial-Commercial-Institutional Steam Generating Units (40 CFR Subpart Db) requires the wood boiler at PPT to meet a PM limit of 0.10 lb /MMBtu. The PSD permit limit of 0.025 lb/MMBtu and 10.10 lb/hr at all times is the most stringent PM emission limitation. PPT conducted a stack test on May 21, 2009 which shows that the PM emissions are less than 0.002 lb/MMBtu and 0.95 lb/hr. For the wood boiler, PPT is in compliance with the PM emission standards.

The emergency generator and fire pump must meet 0.3 lb PM/MMBtu. Compliance can only be determined by stack testing, and no stack testing has been required.

Env-A 2100— Particulate Matter and Visible Emission Standards

Fugitive emissions from the cooling tower at PPT are limited to 20 percent opacity for any continuous 6-minute period in any 60-minute period. Compliance could not be verified in this off-site records review.

XIII. Compliance With Applicable Federal Rules

40 CFR 60 Subpart Db - Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units. PPT is subject to the requirements of this NSPS, which can also apply to similarly-sized units that burn coal, oil and/or natural gas. Specifically, PPT is subject to the Subpart Db emission limit for PM of 0.1 lb/MMBtu. However, the PSD limit for PM in the Permit is more stringent. In addition, the subpart requires PPT to maintain daily records of the amount of fuel combusted in the boiler, which is also required by Env-A 900.

Page 9 of 13

Page 12: The State of New Hampshire DEPARTMENT OF …The New Hampshire Department of Environmental Services, Air Resources Division co.nducted an Off-site Full Compliance Evaluation of Pinetree

Pinetree Power-Tamworth Inspection Date.' 0912912009 Tamworth Report Date.' 0912912009

40 CFR 64 - Compliance Assurance.Monitoring. Tables 6A and 6B of the Permit stipulate the monitoring and recordkeeping requirements to be met by PPT in order to comply with CAM. Each table lists the parameters (i.e. Indicators) to be monitored, including the acceptable indicator range, QAIQC practices and criteria, monitoring frequency, and data to be recorded for the respective pollution control device. For the ESP, the Secondary Voltage reading is Indicator No. 1, and InspectionlMaintenance of the ESP is Indicator No. 2. For the Multiclone, the Pressure Differential across the device is Indicator No. 1, and InspectionlMaintenance is Indicator No. 2. The data listed in the 2 tables is the minimum deemed necessary to provide reasonable assurance that the emissions limits for PM are being continuously achieved.

Enforcement History and Status

There are no past or ongoing enforcement actions against PPT.

Conclusions & Recommendations

DES believes that PPT is in compliance with the requirements stated in the Permit, however, the following deficiencies were identified during the inspection:

PPT is not attaching the "Cert?fication ofAccuracy Statement" as outlined in Section XXLB of the Title V Permit (TV-OP-018) to the stack test report submittals. PPT should attach the statement to all submittals to DES.

PPT did not calculate the emissions from the cooling tower , fire pump and insignificant activities and did not pay the fees associated with those emissions from 2004-2008. PPT should calculate the emissions from the cooling tower ,fire pump and insigncant activities for the years 2004 through 2008 and pay the associated fees for those emissions. See Table below for applicable fees per year.

Year Ernision.Eee Rate ($/ton)

2004 86.75 2005 88.61 2006 90.95 2007 102.04 2008 125.85

PPTis not providing the annual NOx emission statement as required by Table 8, Item 4of the Title V Permit. PPT should include the required information by April 15 following the year of emissions.

Page 10 of 13

Page 13: The State of New Hampshire DEPARTMENT OF …The New Hampshire Department of Environmental Services, Air Resources Division co.nducted an Off-site Full Compliance Evaluation of Pinetree

• Pinetree Power-Tamworth Inspection Date: 0912912009 Thinworth Revort Date. 0912912009

Appendix A

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Page 14: The State of New Hampshire DEPARTMENT OF …The New Hampshire Department of Environmental Services, Air Resources Division co.nducted an Off-site Full Compliance Evaluation of Pinetree

I

Pinetree Power-Tamworth Inspection Date. 0912912009 Tamworth Report Date, 0912912009

Full Compliance Evaluation Records Review

Facility: Pinetree Power-Tamworth Date of FCE: September 29, 2009 Reviewer: Greg Helve

Annual Emission Renorts (mci. NOx. VOC etc.'): 'RpbriingPeñod . WinRecd' eportK JnDatabase:: 2008 03/30/2009 Yes Yes 2007 0220/2008 Yes Yes

Annual Emissions-Based Fee Payments: AN/I en/I.ecd :JIáte::

2008 04/06/2009 Yes, in DES Emission Section's Spreadsheet 2007 03/172008 Yes, in DES Emission Section's Spreadsheet

TV Annual Comnlianne Certifications: WliëhReTi1 ReortOTK 'in'Datbasé

2008 ' 04/15/2009 Yes Yes 2007 04/14/2008 Yes Yes

TV Semi-Annual Permit Deviation and Monitorin2 Renorts: ReportmgPeriod WhenRec'd Report OK 'In Database

2009 1st 07/30/2009 Yes Yes 2008 -2'' 02/02/2009 Yes Yes 2008 1st 08/01/2008 Yes Yes 2007 -2nd 01/31.2008 Yes Yes 2007 -1st 07/31/2007 Yes Yes

Quarterly Continuous Emission Monitoring Excess Emission Renorts (CEM EERs'): ReortffigEéi'io.d VlhenRed':'d n Dataláse

2009 2id 07/20/2009 Yes Yes 2009 Pt 04/28/2009 Yes Yes 2008 02/02/2009 Yes Yes 2008 3d 10/29/2008 Yes Yes 2008 08/01/2008 Yes Yes 2008 1st 04/29/2008 Yes Yes 2007 4th 01/31/2008 Yes Yes 2007 -3 rd 10/11/2007 Yes Yes 2007 07/18/2007 Yes Yes 2007 -1st 04/30/2007 Yes Yes

CPM Audits (flPAs CGAs RAAS RATAs'): Re)ortin

enod JReportTvpe \VhenRecd

__

L Report OK

______________

J.Dätabase

RATA,OPA,7day,Fuel 07/20/2009 Yes Yes 2009 1st RATA,OPA,7day,Fuel 04/28/2009 Yes Yes 2008 4th RATA,OPA,7day,Fuel 02/02/2009 Yes Yes 2008 7 RATA,OPA,7day,FueI 10/29/2008 Yes Yes 2008 -2 RATA,OPA,7day,Fuel 08/01/2008 Yes Yes 2008 1st RATA,OPA,7day,Fuel 04/29/2008 Yes Yes

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Pinetree Power-Tamworth

Inspection Date: 0912912009 Tamworth

Report Date.' 0912912009

2007 4th RATA,OPA,7day,Fuel 01/31/2008 Yes Yes

2007 3rd RATA,OPA,7day,Fuel 10/11/2007 Yes Yes

2007 2nd RATA,OPA,7day,Fuel 07/18/2007 Yes Yes

2007 -1st RATA,OPA,7day,Fuel 04/30/2007 Yes Yes

C+..-.L,

STkTë'st DëVidëTdte1 Date

When Ree d Reort OK Jn Datäbase

05/2 1/2009 Wood boiler 07/20/2009 Yes yes

06/06/2008 Wood boiler 08/01/2008 Yes Yes

04/18/2008 Wood boiler 06/06/2008 Yes Yes

06/01/2007 Wood boiler 07/18/2007 Yes Yes

Other renorts: Reportrng Report Type

Period When Rec d Report OK In Database

N/R

h,Ah,;,-1,1 P,rmt fl ihifn PArtc

Reporting Period When Rec d Report OK In Database

See Section IX. Of Report

Yes Yes

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