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DEPARTMENT of ENVIRONMENTAL SERVICES ______Clark B The State of New Hampshire DEPARTMENT OF ENVIRONMENTAL SERVICES ____________ Clark B. Freise, Assistant Commissioner May 2, 2017 Abbe Bjorklund, Director of Engineering & Utilities Dartmouth College 6111 McKenzie Hall Hanover, NH 03755-3552 RE: On-Site Full Compliance Evaluation Report Dear Ms. Bjorklund: The New Hampshire Department of Environmental Services, Air Resources Division (NHDES) has completed a Full Compliance Evaluation of Dartmouth College located in Hanover, New Hampshire. The purpose of the evaluation was to determine compliance with its Title V Permit (Permit number TV-0022) and the N.H. Code Admin. Rules Env-A 100 et seq. The compliance evaluation included an on-site inspection completed on April 6, 2017. 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. The results of the compliance evaluation have been forwarded to the Enforcement Section for further review. If you have any questions, please do not hesitate to give me a call at (603) 271-6797 or by email at [email protected]. Sincerely, Alan H. Moulton Compliance Assessment Engineer Air Resources Division cc: Town Manager, Town of Hanover, PO Box 483, Hanover, NH 03755 www.des.nh.gov 29 Hazen Drive PO Box 95 Concord, NH 03302-0095 Telephone: (603) 271-1270 Fax: (603) 271-1381 TDD Access: Relay NH 1-800-735-2964 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Abbreviations and Acronyms AAL Ambient Air Limit ASTM American Society of Testing and Materials Btu British thermal units CAS Chemical Abstracts Service cfm cubic feet per minute CFR Code of Federal Regulations CO Carbon Monoxide CO2e Carbon dioxide equivalents DER Discrete Emission Reduction Env-A New Hampshire Code of Administrative Rules – Air Resources Division ERC Emission Reduction Credit FBN Fuel Bound Nitrogen ft foot or feet ft3 cubic feet gal gallon GHG greenhouse gases HAP Hazardous Air Pollutant as defined in Section 112 of the 1990 Clean Air Act Amendments hp horsepower hr hour HVAC heating, ventilation, and air conditioning kW kilowatt lb pound LPG Liquefied Petroleum Gas MM million MW megawatt NAAQS National Ambient Air Quality Standard NHDES New Hampshire Department of Environmental Services NOx Oxides of Nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate Matter < 10 microns ppm parts per million psi pounds per square inch PSD Prevention of Significant Deterioration RACT Reasonably Available Control Technology RICE Reciprocating Internal Combustion Engine RSA Revised Statues Annotated RTAP Regulated Toxic Air Pollutant scf standard cubic foot SDS Safety Data Sheet SO2 Sulfur Dioxide TSP Total Suspended Particulate Page 2 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 tpy tons per year ULSD Ultra-Low Sulfur Diesel fuel USEPA United States Environmental Protection Agency Page 3 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 I. Facility Description NHDES conducted an On-Site Full Compliance Evaluation of Dartmouth College (Dartmouth) on April 6, 2017, and the results are presented herein. The compliance evaluation covers the period calendar year 2015 to April 6, 2017. Dartmouth is an educational institution located in Hanover, NH. The college campus is composed of educational facilities, including several academic buildings and residential units owned and operated by the college. In addition, Dartmouth owns and operates a cogeneration facility at its Hanover campus. Emission sources associated with the power plant include four boilers, an emergency diesel generator, two #6 fuel oil storage tanks, and a gasoline dispensing facility utilized by service vehicles on the Hanover campus. Emission sources at the college’s educational facilities include furnace and boiler units for building heating and hot water, several small and large capacity emergency generators for emergency lighting, and running special HVAC units in libraries, for historic record and book preservation, several small space heating units, chillers, small capacity fuel storage tanks, and HVAC systems for each of the buildings. Dartmouth has 43 emergency generators located throughout the campus. The emergency generators have been grouped into categories based the applicability of the Federal Regulations, the type of fuel used, the installation date, etc. Each emergency generator is labeled with a unique EG number. See Appendices A through F in the back of this report. Table 1 of the permit has given each category an EU number. Dartmouth is a major source of NOx, SO2, and GHG emissions. Therefore, it requires a Title V Operating Permit. The facility is considered an existing major source of SO2 under the federal PSD program, as historical SO2 emissions have been greater than the PSD major source threshold of 250 tpy. The facility is considered an existing major source of NOx under the Nonattainment NSR program, as historical NOx emissions have been greater than 100 tpy. Potential GHG emissions are greater than 100,000 tpy of CO2e. The facility is an area source for HAPs. Dartmouth College Facility name and address 6111 McKenzie Hall Hanover, New Hampshire 03755-3552 County Grafton Telephone (603) 646-2344 AFS# 3300900020 Source Type Title V Inspection Date/Time April 6, 2017; 10:10 am Inspection Type On-Site Full Compliance Evaluation Page 4 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Weather 38o F., 5 mph wind from the SE, rain Inspection Period 2015 to April 6, 2017 Inspected by Alan Moulton, NHDES Compliance Assessment Engineer Frank Roberts, P.E., Associate Vice President Abbe Bjorklund, Director, Engineering and Utilities Source Contact(s) Bill Riehl, Chief Engineer, Power Plant Dave Knox, Generator Technician Last Inspection June 25, 2015 Last Inspection Results: a) Continue to monitor the sulfur content of the #6 fuel oil received for EU01 through EU02. b) Conduct boiler tune-ups within the required time limits stated in the regulation. c) Operate boilers EU01 through EU04 such that the opacity stays below the limit of 20%, as required by Table 4, Items #9 and #10 of the Permit. d) Include the certification of accuracy statement on each document submitted to NHDES or USEPA. e) For each emergency generator Dartmouth must record the reason why it ran. Dartmouth has corrected the issues found during the last inspection except for the opacity in boilers EU01 through EU04. Dartmouth is still reporting deviations of the opacity limit for the boilers. Permitting / Application Timeline Permit TV-0022 Issued January 2, 2013 Minor Modification February 3, 2017 Expires January 31, 2018 Application FY05-0028 Submitted (Timely) August 25, 2004 Application for 16-0064 Submitted April 15, 2016 Minor Amendment 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. Dartmouth 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. Page 5 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 II. Emission Unit Identification and Facility Wide Emissions Table 1 below, taken from Permit TV-0022, lists the permitted emission units as verified during the evaluation. Table 1 - Emission Unit Identification, Significant Activities Manufacturer Date Construction Emission Description of Emission Maximum Design Capacity and Model Number Commenced/ Unit ID Unit Permitted Fuel Types Serial Number Start-Up Date EU01 Boiler #1 Zurn Industries 1986 112.2 MMBtu/hr 12,196 sq ft #6 fuel oil – 748 gal/hr MultiPass Maximum steam production rate – 100978 90,000 lbs/hr of superheated (Low NOx burners were steam at 450 psig and 700°F. installed in 1995.) EU02 Boiler #2 Babcock & 2008/2009 97.5 MMBtu/hr Wilson #6 fuel oil – 650 gal/hr (FM103-79) 99.97 MMBtu/hr #201-3530 #2 fuel oil – 714 gal/hr EU03 Boiler #3 Nebraska Boiler 1995/1996 95.5 MMBtu/hr Co. #6 fuel oil – 637 gal/hr (Equipped with low NOx NS-E-65SH Maximum steam production rate – burners and flue gas D-3461/E-3462 75,000 lbs/hr of superheated recirculation.) steam at 450 psig and 700°F. EU04 Boiler #4 Combustion 1967 97.3 MMBtu/hr Engineering #6 fuel oil – 649 gal/hr VP-12W; 20628 Maximum steam production rate – 70,000 lbs/hr of superheated (Low NOx burners were steam at 450 psig and 700°F. installed in 1995.) EU05 Diesel-fired Emergency See Appendix A 1961 Diesel-fired Generators Installed on or See Appendix A prior to May 13, 1970 The emergency generator located at Hopkins Hall (EU05/EG1) was removed from the facility on April 25, 2012. EU08 Gasoline Service Station NA 1991 NA including the Gasoline Dispensing Facility and the Gasoline Storage Tank EU10 Diesel-fired Emergency See Appendix B After January 1, Diesel-fired Generators Installed after 1985 See Appendix B January 1, 1985 that are not subject to 40 CFR 60, Subpart IIII Page 6 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 1 - Emission Unit Identification, Significant Activities Manufacturer Date Construction Emission Description
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