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
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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
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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
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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.
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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
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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 EU11 Diesel-fired Emergency See Appendix C Manufactured Diesel-fired Generators Installed after after April 1, 2006 See Appendix C January 1, 1985 that are subject to 40 CFR 60, Subpart IIII EU12 Boilers subject to 40 CFR 63, See Appendix D Prior to June 4, #2 fuel oil Subpart JJJJJJ 2010 See Appendix D EU13 LPG-fired Emergency See Appendix E Manufactured LPG-fired Generators Installed after after January 1, See Appendix E January 1, 1985 that are 2009 subject to 40 CFR 60, Subpart JJJJ EU14 LPG-fired Emergency See Appendix F Manufactured LPG-fired Generators Installed after prior to January 1, See Appendix F January 1, 1985 that are not 2009 subject to 40 CFR 60, Subpart JJJJ
NHDES observed the four main boilers (EU01 through EU04). Also observed were the emergency generator located in the Visual Arts building (EU13/EG25) and emergency generator located in New Hampshire Hall (EU14/EG46). Neither generator was in operation during the inspection. The remaining emergency generators and smaller boilers, which are spread throughout the campus, were not observed. The only devices in operation were EU01 and EU03, which were operating on #6 Fuel Oil, and supplying hot water for the facility. Dartmouth has added one emergency generator since the last evaluation.
During the inspection, Dartmouth presented hour meter data records. Only the emergency generator located in the Visual Arts building (EU13/EG25) and emergency generator located in New Hampshire Hall (EU14/EG46) were observed. See Appendix J for hour meter data. The hour meter readings listed in the table in Appendix J are from non-resettable hour meters on each engine and show the total hours on each engine from initial start-up. Each emergency generator is limited to 200 hours of operation during any consecutive 12-month period. The emergency generators did not operate more than 200 hours per year between the last inspection in 2015 and the 2017 inspection. Dartmouth has a log that contains data on each time each emergency generator was operated. Dartmouth presented documentation that the total time each emergency generator ran for maintenance and testing was less than 100 hours per year.
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Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017
Insignificant Activities
The table below lists the current insignificant activities identified by Dartmouth and contained in the NHDES Engineering Summary for permit application FY05-0028. These activities were confirmed by NHDES during the inspection. Since the issuance of Permit TV-0022, Dartmouth has made no changes to the insignificant activities.
Insignificant Activities Manufacturer Date Construction Maximum Design Device Identification Model Number Commenced/ Capacity and Fuel Serial Number Start-Up Date Type(s) Tank #1 NA 1991 125,000 gallons #6 fuel oil (AST) Tank #2 NA 1991 125,000 gallons #6 fuel oil (AST) Water Chillers A. Psychology A. Trane electric A. 1998 A. 80 ton using R- Building Backup chiller CCAD060 22 (Class II Water Chiller refrigerant)
B. Water Chiller B. York electric B. 1997 B. 650 ton using R- Plant chiller 134A (Class I refrigerant substitute)
C. Webster Hall C. McQuay electric C. 1998 C. Uses R-22 (Class Backup Water chiller II refrigerant) Chiller
D. Gilman Building D. Carrier electric D. 1998 D. 75 ton using R- Backup Water chiller 22 (Class II Chiller refrigerant) Furnaces/Small Boilers See Appendix G See Appendix G See Appendix G that are not subject to 40 CFR 60, Subpart JJJJJJ Fuel Storage Tanks See Appendix H See Appendix H See Appendix H
The table below lists the facility’s reported annual emissions for the review period.
Facility Reported Annual Emissions (tpy)
TSP PM10 SO2 NOx CO VOC Permitted Limits --- — ------2016 19.60 15.97 235.98 83.02 9.89 1.83 2015 20.06 16.11 241.06 86.40 10.60 5.47
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Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017
III. Control Equipment
There is no air pollution control equipment required for the devices listed in Table 1.
IV. Stack Criteria
Table 2 below, taken from Permit TV-0022, lists the permitted stack requirements for the facility. During the evaluation, NHDES observed that the stack was vertical and unobstructed, with no modifications noted by the facility.
Table 2 - Stack Criteria Minimum Height Maximum Exit Diameter Stack # Emission Unit # (feet above ground surface) (feet)
Stack 1 EU01, EU02, EU03 & EU04 175 10.0
V. Compliance with Operating and Emission Limitations
Please note that throughout this report, the columns labeled ”Regulatory Citation” may often refer to previous permits versus regulatory rules.
Table 3 below, taken from Permit TV-0022, lists the State-only operation and emission limitations for the facility, and any deficiencies noted during the evaluation.
Table 3 - State-only Enforceable Operational and Emission Limitations Item Applicable Regulatory Applicable Requirement Compliant # Emission Unit Citation 1 24-hour and Annual Ambient Air Limit Facility Wide Env-A 1400 The emissions of any Regulated Toxic Air Pollutant (RTAP) shall not cause an exceedance of its associated 24-hour Yes or annual Ambient Air Limit (AAL) as set forth in Env-A 1450.01, Table Containing the List Naming All Regulated Toxic Air Pollutants.
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Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017
Table 3 - State-only Enforceable Operational and Emission Limitations Item Applicable Regulatory Applicable Requirement Compliant # Emission Unit Citation 2 Revisions of the List of RTAPs Facility Wide RSA 125-I:5 IV In accordance with RSA 125-I:5 IV, if the Division revises the list of RTAPs or their respective AALs or classifications under RSA 125-I:4, II and III, and as a result of such revision the Owner or Operator is required to obtain or modify the permit under the provisions of RSA 125-I or Not Applicable RSA 125-C, the Owner or Operator shall have 90 days following publication of notice of such final revision in the New Hampshire Rulemaking Register to file a complete application for such permit or permit modification. Finding: The permitted devices at Dartmouth are boilers and engines burning virgin fuels which are exempt from the requirements of Env-A 1400. An Env-A 1400 review is not required. 3 Activities Exempt from Visible Emission Standards EU01, EU04, Env-A The average opacity shall be allowed to be in excess of EU05, EU10, 2002.04(c) those standards specified in Env-A 2002.02 for one EU11, EU12, (Effective 4-23- Yes period of 6 continuous minutes in any 60 minute period EU13 & EU14 2005) during startup, shutdown, malfunction, soot blowing, grate cleaning, and cleaning of fires. 4 Activities Exempt from Visible Emission Standards EU01, EU04 & Env-A Exceedances of the opacity standard in Env-A 2002 shall EU12 2002.04(d), (e), not be considered violations if the Owner or Operator and (f) demonstrates to NHDES that such exceedances: (Effective 4-23- 2005) a) Were the result of the adherence to good boiler operating practices which, in the long term, result in the most efficient or safe operation of the boiler; b) Occurred during periods of cold startup of a boiler over a continuous period of time resulting in efficient heat-up and stabilization of its operation and the expeditious achievement of normal operation of the Yes unit; c) Occurred during periods of continuous soot blowing of the entire boiler tube section over regular time intervals as determined by the operator and in conformance with good boiler operating practice; or d) Were the result of the occurrence of an unplanned incident in which the opacity exceedance was beyond the control of the operator and in response to such incident, the operator took appropriate steps in conformance with good boiler operating practice to eliminate the excess opacity as quickly as possible.
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Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017
Table 4 below, taken from Permit TV-0022, lists the Federal enforceable operation and emission limitations for the facility, and any deficiencies noted during the evaluation.
Table 4 – Federally Enforceable Operational and Emission Limitations Applicable Item Applicable Requirement Emission Rule Citation Compliant # Unit 1 Annual Emission Limitations for the Installation of Boiler #3 in EU01, EU03 Env-A 1995: & EU04 618.02(b)(11) The annual emissions of criteria pollutants from the heating & plant shall be limited as specified below during any consecutive Env-A 606.04 12-month period: & TP-B-0545 Annual Emission Limitations (tpy) for Criteria Pollutants Yes
Device CO NOx PM PM10 SO2 VOCs Boilers #1, #3 and #4 51.1 158.2 61.1 51.1 531.9 4.4 Combined
Finding: See Appendix I for compliance results. 2 Annual Emission and Fuel Usage Limitations for the Installation EU01 & Env-A of Boiler #2 in 2008: EU04 618.02(b)(11)(g)(2) & a) The annual SO2 emission limitation from Boilers #1 and #4 (EU01 & EU04) shall be limited to 378 tons per year during 40 CFR Yes any consecutive 12-month period; and 52.21(b)(23)(i) & TP-B-0545 b) The annual fuel consumption for Boiler #2 (EU02) shall be EU02 Env-A limited such that NOx emissions do not exceed 39.8 tons 618.02(b)(11)(g)(2) during any consecutive 12-month period: & The following equation will be used to determine 40 CFR compliance: 52.21(b)(23)(i) & 39.8≥*(0.0435 * gal No. 6a) + (0.0465 * gal No. 6b) + (0.0585 * TP-B-0545 gal No. 6c) + (0.0168 * gal No. 2 fuel oil)]/2,000 Where: 6a is No. 6 fuel oil containing ≤0.34% fuel bond nitrogen (FBN); Yes 6b is No. 6 fuel oil containing 0.34%
Device CO NOx PM PM10 SO2 VOCs Boiler #2 33.6 39.8 24.2 14.2 70.0 0.8
Finding: See Appendix I for compliance results.
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Table 4 – Federally Enforceable Operational and Emission Limitations Applicable Item Applicable Requirement Emission Rule Citation Compliant # Unit 3 Maximum Sulfur Content Allowable in Gaseous Fuels Facility 40 CFR 52 Gaseous fuels shall contain no more than 5 grains of sulfur per Wide Yes 100 cubic feet of gas, calculated as hydrogen sulfide at standard conditions. 4 Maximum Sulfur Content Allowable in Liquid Fuels EU02, EU05, Env-A 1604.01(a) The sulfur content of No. 2 oil shall not exceed 0.40 percent by EU10 & (Formerly Env-A Yes weight; EU12 402.02) The sulfur content of No. 6 oil shall not exceed the following EU01, EU02, Env-A sulfur content in percent sulfur by weight: EU03 & 618.02(b)(11) Applicable Emission Sulfur Content of No. 6 Fuel EU04 & Unit (weight % sulfur) 40 CFR 52.21(B)(23)(i) EU01 1.0 Yes EU02 0.5 & EU03 0.5 40 CFR 60.42c(d) (Subpart Dc) EU04 1.0 & TP-B-0545 The sulfur content of diesel fuel burned in the emergency EU11 40 CFR 60.4207 generators subject to 40 CFR 60, Subpart IIII (EU11) shall not (Subpart IIII) Yes exceed 15 ppm (0.0015 percent sulfur by weight).
5 NSPS Subpart Dc – Standards for SO2 EU02 & 40 CFR 60.42c(d), a) No Owner or Operator of an affected facility (EU02 & EU03) EU03 (g),(h) and (i) that combusts oil (No. 2 oil & No. 6 oil) shall cause to be (Subpart Dc) discharged into the atmosphere from that affected facility any gases that contain SO2 in excess of 0.50 lb/MMBtu heat input; or as an alternative, no Owner or Operator of an affected facility that combusts oil shall combust oil in the affected facility that contains greater than 0.5 weight percent sulfur. b) Except as provided in Table 4 Item 5(c), compliance with the fuel oil sulfur limits and emission limits listed in Table 4, Yes Item 5(a) shall be determined on a 30-day rolling average basis. c) For distillate oil-fired affected facilities with heat input capacities between 10 and 100 MMBtu/hr (EU02), compliance with the emission limits or fuel oil sulfur limits listed in Table 4, Item 5(a) may be determined based on a certification from the fuel supplier, as described in Table 6, Item 5, as applicable. d) The SO2 emission limits and fuel oil sulfur limits apply at all times, including periods of startup, shutdown, and malfunction. Finding: Dartmouth retains fuel oil delivery slips.
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Table 4 – Federally Enforceable Operational and Emission Limitations Applicable Item Applicable Requirement Emission Rule Citation Compliant # Unit 6 NOx RACT Requirements for Boiler #1 (EU01) EU01 Env-A a) Dartmouth College shall operate and maintain low NOx 1305.13(a)(2) burners; & b) The NOx emission rates of Boiler #1 shall be limited to the Env-A following: 1305.10(b)(1) (Effective 10-31- NOx Emission Limits 2010) (Formerly Yes EU NOx % Fuel Bound % Excess Env-A Emissions Nitrogen (FBN) Air 1211.05(d)(3)a.2. (lb/MMBtu) (Effective 08-21- EU01 0.31 ≤0.39 15.0 1995)) 0.39 0.39 Finding: During the evaluation period, Dartmouth did not burn #2 fuel oil in EU02. NOx RACT Requirements for Boiler #3 (EU03) EU03 Env-A f) Dartmouth College shall operate and maintain low NOx 1305.06(b)(2) burners; & g) The NOx emission rates of Boiler #3 shall be limited to the Env-A following: 1305.04(b)(1) NOx Emission Limits (Effective 10-31- EU NOx % Fuel Bound % Excess 2010) (Formerly Yes Emissions Nitrogen (FBN) Air Env-A (lb/MMBtu) 1211.05(c)(2)b.2. EU03 0.29 ≤0.39 15.0 (Effective 08-21- 0.39 0.39 Page 13 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 4 – Federally Enforceable Operational and Emission Limitations Applicable Item Applicable Requirement Emission Rule Citation Compliant # Unit NOx RACT Requirements for Boiler #4 (EU04) EU04 Env-A h) Dartmouth College shall operate and maintain low NOx 1305.06(b)(2) burners; & i) The NOx emission rates of Boiler #4 shall be limited to the Env-A following: 1305.04(b)(1) NOx Emission Limits (Effective 10-31- EU NOx % Fuel Bound % Excess 2010) (Formerly Yes Emissions Nitrogen (FBN) Air Env-A (lb/MMBtu) 1211.05(d)(3)a.2. EU04 0.31 ≤0.39 15.0 (Effective 08-21- 1995)) 0.39 0.39 Page 14 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 4 – Federally Enforceable Operational and Emission Limitations Applicable Item Applicable Requirement Emission Rule Citation Compliant # Unit Finding: The emergency generator located at Hopkins Hall (EU05/EG1) was removed from the facility on April 25, 2012. Dartmouth did not notify NHDES of the removal of the generator prior to the issuance of the Title V Permit. 9 Visible Emission Standard for Fuel Burning Devices Installed After EU01, EU02, Env-A 2002.02 May 13, 1970 EU03, EU04, (Effective 4-23- EU10, EU11, 2005) (Formerly The average opacity from fuel burning devices installed after No May 13, 1970 shall not exceed 20 percent for any continuous 6- EU12, EU13 Env-A 1202 minute period. & EU14 (Effective 08-21- 1995)) Findings: During the inspection, the opacity from EU01 and EU03 were in compliance with the requirement. The opacity from EU02 and EU04, and EU10 through EU14 could not be verified because the devices were not in operation. At the time the permit was issued, NHDES had sufficient information to indicate that under normal operating conditions, these devices are capable of meeting the opacity standards. During the evaluation period, the facility reported a total of six permit deviations for opacity exceedances. See Section IX. “Permit Deviation Reporting Requirements” for details. 10 NSPS Subpart Dc - Visible Emission Standards EU02 & Env-A 2002.05 In addition to the opacity standards and exemptions specified in EU03 (Effective 4-23- Env-A 2000, those fuel burning devices meeting the applicability 2005) (Formerly requirements of 40 CFR 60 shall meet the opacity standards Env-A 1202 specified therein. Boilers #2 and #3 meet the applicability (Effective 08-21- requirements of 40 CFR 60, Subpart Dc and therefore shall meet 1995)) the following opacity standards: 40 CFR 60.43c(c) a) On and after the date on which the initial performance test is and (d) (Subpart completed or required to be completed under §60.8, Dc) No whichever date comes first, no Owner or Operator of an affected facility that can combust coal, wood, or oil and has a heat input capacity of 8.7 MW (30 MMBtu/hr) or greater shall cause to be discharged into the atmosphere from that affected facility any gases that exhibit greater than 20 percent opacity (6-minute average), except for one 6-minute period per hour of not more than 27 percent opacity. b) The opacity standard applies at all times, except during periods of startup, shutdown, or malfunction. Findings: During the evaluation period, the facility reported a total of six permit deviations for opacity exceedances. See Section IX. “Permit Deviation Reporting Requirements” for details. 11 Particulate Emission Standards for Fuel Burning Devices Installed EU04 & Env-A 2002.06 on or Prior to May 13, 1970 EU05 (Effective 4-23- 2005) (Formerly The particulate matter emissions from fuel burning devices Yes installed on or prior to May 13, 1970 shall not exceed 0.41 Env-A 1202) lb/MMBtu for EU04 and 0.60 lb/MMBtu for EU05. (Effective 08-21- 1995)) Finding: Compliance with particulate emission standards can only be verified through stack testing, which has not been required for EU04, to date. However, at the time the permit was issued, NHDES had sufficient information to Page 15 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 4 – Federally Enforceable Operational and Emission Limitations Applicable Item Applicable Requirement Emission Rule Citation Compliant # Unit indicate that under normal operating conditions, these devices are capable of meeting the particulate matter standard. EU05 has been removed from the facility. 12 Particulate Emission Standards for Fuel Burning Devices Installed EU02, EU03, Env-A on or After January 1, 1985 EU10, EU11, 2002.08(c)(1) The particulate matter emissions from fuel burning devices EU12, EU13 (Effective 4-23- installed on or after January 1, 1985 shall not exceed 0.30 & EU14 2005) (Formerly Yes lb/MMBtu for devices with the maximum gross input rate less Env-A 1202 than 100 MMBtu/hr. (Effective 08-21- 1995)) Finding: Compliance with particulate emission standards can only be verified through stack testing, which has not been required for EU02, EU03, EU10, EU11, EU12, EU13, or EU14, to date. However, at the time the permit was issued, NHDES had sufficient information to indicate that under normal operating conditions, these devices are capable of meeting the particulate matter standard. 13 Particulate Emission Standards for Fuel Burning Devices Installed EU01 Env-A on or After January 1, 1985 2002.08(c)(2) The particulate matter emissions from fuel burning devices (Effective 4-23- installed on or after January 1, 1985 shall not exceed 0.15 2005) (Formerly Yes lb/MMBtu for devices with the maximum gross input rate equal Env-A 1202 to or greater than 100 MMBtu/hr but less than 250 MMBtu/hr. (Effective 08-21- 1995)) Finding: Compliance with particulate emission standards can only be verified through stack testing, which has not been required for EU01, to date. However, at the time the permit was issued, NHDES had sufficient information to indicate that under normal operating conditions, this device is capable of meeting the particulate matter standard. 14 Limitations on Operating Scenarios for Emergency Generators EU05, EU10, Env-A 1302.15 Each emergency generator shall only operate: EU11, EU13 (Formerly Env-A a) As a mechanical or electrical power source only when the & EU14 1211.02(o) primary power source for a facility is not available during an (Effective 08-21- emergency such as a power outage; or 1995)) b) During normal maintenance and testing. & No Env-A 101.671 No emergency engine shall operate as a load-shaving or peaking (Formerly Env-A power production unit. 101.661) & TP-0037 Finding: In 2016, Dartmouth operated the Life Sciences Building emergency generator (EU11/EG20) under an Emergency Demand Response contract. This was done in compliance with 40 CFR 63, Subpart IIII. However, Dartmouth did not operate the emergency generator in compliance with this permit condition. See Other Findings. 15 Operating Limitations for Emergency Engines EU05, EU10, 40 CFR §60.4211(f) EU11, EU13, (Subpart IIII), In addition to the operating hours limitation in Table 4, Item 6(j), No the owner or operator of each emergency engine shall operate & EU14 40 CFR the emergency engine for any combination of the purposes §60.4243(d) & (e) Page 16 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 4 – Federally Enforceable Operational and Emission Limitations Applicable Item Applicable Requirement Emission Rule Citation Compliant # Unit listed below for a maximum of 100 hours per calendar year: (Subpart JJJJ) a) Emergency engines may be operated for maintenance & checks and readiness testing, provided that the tests are 40 CFR §63.6585(f) recommended by federal, state or local government, the & manufacturer, the vendor, the regional transmission 40 CFR §63.6640(f) organization or equivalent balancing authority and (Subpart ZZZZ) transmission operator, or the insurance company associated with the engine; b) The owner or operator may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the owner or operator maintains records indicating that federal, state, or local standards require maintenance and testing of emergency engine beyond 100 hours per calendar year; c) All emergency engines at the facility shall be limited to only the operating scenarios limited in Table 4, Item 14; and d) The owner or operator of an emergency engine that is natural gas fired may operate their engines using propane for a maximum of 100 hours per year as an alternative fuel solely during emergency operations, but must keep records pursuant to Table 6, Item 7(b). Findings: See Finding for Table 4, Item 14 above. 16 Work Practice Standards for Industrial/Commercial/Institutional EU01, EU02, 40 CFR 63.11196 Boilers EU03, EU04 Subpart JJJJJJ a) No later than the compliance date established in 40 CFR & EU12 63.11196, the Owner or Operator shall conduct a tune-up of each boiler as specified in Table 5, Item 25; and Yes b) No later than the compliance date established in 40 CFR 63.11196, the Owner or Operator shall conduct a one-time energy assessment. 17 NESHAP General Provisions EU01, EU02, 40 CFR 63.11205 At all times, the Owner or Operator must operate and maintain EU03, EU04 Subpart JJJJJJ the boiler(s) in a manner consistent with safety and good air & EU12 pollution control practices for minimizing emissions. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required Yes by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Division that may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. Page 17 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 4 – Federally Enforceable Operational and Emission Limitations Applicable Item Applicable Requirement Emission Rule Citation Compliant # Unit 18 NSPS General Provisions EU01, EU02, 40 CFR 60.11(d) & a) At all times, including periods of startup, shutdown, and EU03, EU11 (g) malfunction, owners and operators shall, to the extent & EU13 practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, opacity observations, review of Yes operating and maintenance procedures, and inspection of the source. b) For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any standard in this part, nothing in this part shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. 19 Accidental Release Program Requirements Facility wide CAAA 112(r)(1) The quantities of regulated chemicals stored at the facility are less than the applicable threshold quantities established in 40 CFR 68.130. The facility is subject to the Purpose and General Duty clause of the 1990 Clean Air Act Amendments, Section 112(r)(1). General Duty includes the following responsibilities: Yes a) Identify potential hazards which result from such releases using appropriate hazard assessment techniques; b) Design and maintain a safe facility; c) Take steps necessary to prevent releases; and d) Minimize the consequences of accidental releases that do occur. 20 Protection of Stratospheric Ozone Facility wide 40 CFR 82 Subpart If the Owner or Operator performs maintenance on, or services, F repairs, or disposes of appliances containing regulated ozone Yes depleting substances, the Owner or Operator shall comply with the standards for Recycling and Emissions Reduction pursuant to 40 CFR 82, Subpart F. 21 Permit Deviations Facility Env-A 911.03 In the event of a permit deviation, the Owner or Operator of the Wide (Effective date 4- affected device, process, or air pollution control equipment shall 21-2007) Yes investigate and take corrective action immediately upon discovery of the permit deviation to restore the affected device, Page 18 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 4 – Federally Enforceable Operational and Emission Limitations Applicable Item Applicable Requirement Emission Rule Citation Compliant # Unit process, or air pollution control equipment to within allowable permit levels. VI. Compliance with Monitoring and Testing Requirements Table 5 below, taken from permit TV-0022, lists the monitoring and testing requirements for the facility, and any deficiencies noted during the evaluation. Table 5 - Monitoring/Testing Requirements Applicable Rule Item # Parameter Method of Compliance Frequency Compliant Emission Unit Citation 1 Sulfur Content Conduct testing to determine the sulfur Upon written Facility Wide Env-A of Gaseous content in grains of sulfur per 100 cubic request by 806.03 Not Fuels feet, of gaseous fuels. USEPA or (Effective Applicable NHDES 10-31- 2010) Finding: Neither USEPA nor NHDES has requested testing to determine the sulfur content of the gaseous fuel. 2 Sulfur Content Conduct testing in accordance with For each Facility Wide Env-A of Liquid Fuels appropriate ASTM test methods or retain delivery of except for 806.02 & delivery tickets in accordance with Table fuel oil/diesel EU02 & EU03 Env-A 6, Item 8 in order to demonstrate to the facility when burning 806.05 Yes compliance with the sulfur content No. 6 fuel oil (Effective limitation provisions specified in this 10-31- permit for liquid fuels. 2010) Finding: Dartmouth retains delivery slips and tests each delivery of #6 fuel oil for sulfur content. 3 No. 6 Fuel Oil NSPS Requirements for Emission Fuel oil EU02 & EU03 40 CFR Sampling Monitoring for Sulfur Dioxide sampling with when burning 60.46c(a), The Owner or Operator of an affected every No. 6 No. 6 fuel oil (d)(1) & fuel oil (d)(2) facility subject to the SO2 emission limits under §60.42c (EU02 & EU03) shall: delivery (Subpart a) Install, calibrate, maintain, and combusted in Dc) EU02 or EU03 operate a CEMS for measuring SO2 concentrations and either O2 or CO2 Yes concentrations at the outlet of the steam generating unit, and shall record the output of the system; or b) Determine the average SO2 emission rate by sampling the fuel prior to combustion and using Method 6B of 40 CFR 60, Appendix A. Fuel Page 19 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 5 - Monitoring/Testing Requirements Applicable Rule Item # Parameter Method of Compliance Frequency Compliant Emission Unit Citation sampling shall be conducted pursuant to one of the following methods: i. For affected facilities combusting oil, oil samples shall be collected daily in an as-fired condition at the inlet to the steam generating unit and analyzed for sulfur content and heat content according to 40 CFR 60, Appendix A, Method 19. 40 CFR 60, Appendix A, Method 19 provides procedures for converting these measurements into the format to be used in calculating the average SO2 input rate; or ii. As an alternative fuel sampling procedure, oil samples may be collected from the fuel tank for each steam generating unit immediately after the fuel tank is filled and before any oil is combusted. The Owner or Operator of the affected facility shall analyze the oil sample to determine the sulfur content of the oil. If a partially empty fuel tank is refilled, a new sample and analysis of the fuel in the tank would be required upon filling. Results of the fuel analysis taken after each new shipment of oil is received shall be used as the daily value when calculating the 30-day rolling average until the next shipment is received. If the fuel analysis shows that the sulfur content in the fuel tank is greater than 0.5 weight percent sulfur, the Owner or Operator shall ensure that the sulfur content of subsequent oil shipments is low enough to cause the 30-day rolling average sulfur content to be 0.5 weight percent sulfur or less. Page 20 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 5 - Monitoring/Testing Requirements Applicable Rule Item # Parameter Method of Compliance Frequency Compliant Emission Unit Citation 4 Fuel Bound Fuel Oil Sampling Fuel oil EU02 Env-A Nitrogen Fuel oil sampling performed according to sampling with 618.02(b) Content of No. Table 5, Item 3 shall include an analysis of every No. 6 (11)(g)(2) 6 Fuel Oil fuel oil fuel bound nitrogen. Results of the fuel & oil analysis taken after each new delivery Yes shipment of oil is received shall be used combusted in TP-B-0545 in calculating the 12-month rolling EU02 average NOx emissions until the next shipment is received. 5 NOx NSPS Requirements for Continuous Continuous EU01 40 CFR Emission Monitoring (CEMS) for Nitrogen 60.48b(b), Oxides (c), (d), (e) The Owner or Operator of an affected & (f) facility subject to a NOx standard under (Subpart §60.44b (Table 4, Item 7) shall install, Db) calibrate, maintain, and operate CEMS for measuring NOx and O2 (or CO2) emissions discharged to the atmosphere, and shall record the output of the system. The CEMS shall be operated and data recorded during all periods of operation of the affected facility except for CEMS breakdowns and repairs. Data is recorded during calibration checks, and zero and span adjustments. The 1-hour average NOx emission rates measured by the continuous NOx Yes monitor shall be expressed in ng/J or lb/MMBTU heat input and shall be used to calculate the average emission rates under §60.44b. The 1-hour averages shall be calculated using the data points required under §60.13(h)(2). The procedures under §60.13 shall be followed for installation, evaluation, and operation of the continuous monitoring systems. For affected facilities combusting oil, the span value for NOx is determined using one of the following procedures: a) For oil, the NOx span values shall be 500 ppm; or b) As an alternative to (a) above, the Owner or Operator of an affected facility may elect to use the NOx span values determined according to Page 21 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 5 - Monitoring/Testing Requirements Applicable Rule Item # Parameter Method of Compliance Frequency Compliant Emission Unit Citation section 2.1.2 in appendix A to 40 CFR 75. When NOx emission data are not obtained because of CEMS breakdowns, repairs, calibration checks and zero and span adjustments, emission data will be obtained by using standby monitoring systems, Method 7, Method 7A, or other approved reference methods to provide emission data for a minimum of 75 percent of the operating hours in each steam generating unit operating day, in at least 22 out of 30 successive steam generating unit operating days. 6 NOx RACT Compliance Stack Testing for Stationary Every 3 years EU02, EU03 & Env-A 802 testing Sources EU04 (Effective Performance testing required in Table 5, 10-31- Item 7 shall be planned and carried out in 2010) accordance with the following schedule: a) A pre-test protocol shall be submitted to the Division at least 30 days prior to the commencement of testing; The Owner or Operator and any contractor retained by the Owner or Operator to conduct the test shall meet with a Division representative in person or by telephone at least 15 Yes days prior to the test date to finalize the details of the testing; A pre-test meeting may be held less than 15 days prior to the test date so long as implementation of any testing or operation changes resulting from the meeting can be carried out prior to the scheduled test date and the scheduled test integrity is not jeopardized; and b) The test report shall be submitted to the Division within 60 days after the completion of testing. Finding: See Finding for Table 5, Item #7 below. Page 22 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 5 - Monitoring/Testing Requirements Applicable Rule Item # Parameter Method of Compliance Frequency Compliant Emission Unit Citation 7 NOx Periodic Compliance Stack Testing for Every 3 years EU02, EU03 & Env-A NOx RACT EU04 803.03 The Owner or Operator shall conduct (Effective periodic compliance stack testing in 10-31- accordance with Env-A 802 to 2010) demonstrate compliance with the emission limitations stated in Table 4, Yes Item 6(d), (e), (g), and (i). Testing shall be conducted in accordance with Table 5, Item 8. The periodic compliance stack testing shall be conducted at least once every 3 years, or within 12 calendar quarters, after the date of the initial compliance stack test. Finding: On February 18, 2015, NOx RACT testing was conducted on EU02. Previous test was conducted on February 8, 2012. Therefore, the facility conducted the test within three years of the last test. Results indicated that EU02 met the NOx RACT emission limit of 0.29lb/MMBtu, with the FBN less than 0.34. On February 19, 2015, NOx RACT testing was conducted on EU03. Previous test was conducted on February 8, 2012. Therefore, the facility conducted the test within three years of the last test. Results indicated that EU03 met the NOx RACT emission limit of 0.29 lb/MMBtu, with FBN less than 0.39. On March 1, 2017, NOx RACT testing was conducted on EU04. Previous test was conducted on February 28, 2014. Therefore, the facility conducted the test within three years of the last test. Results indicate that EU04 met the NOx RACT emission limit of 0.39 lb/MMBtu, with the FBN between 0.39 and 0.60. 8 NOx Compliance Stack Testing for NOx RACT For each EU02, EU03 & Env-A The following test methods, or Division required stack EU04 803.04 approved alternatives, shall be used for test (Effective the compliance stack testing required in 10-31- Table 5, Item 7, above, as applicable: 2010) a) Method 7, 7A, 7C, 7D or 7E as described in 40 CFR 60, Appendix A, to determine NOx concentrations in stack gases; b) Method 10 as described in 40 CFR 60, Appendix A, to determine CO concentrations in stack gases; Yes c) Methods 1 and 2, 2C, 2F, 2G, or 2H, as described in 40 CFR 60, Appendix A, to determine the exit flow rate of stack gases; d) Method 3 or 3A as described in 40 CFR 60, Appendix A, to determine carbon dioxide, oxygen, excess air and molecular weight (dry basis) of stack gases; and e) Method 4 as described in 40 CFR 60, Appendix A, to determine the Page 23 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 5 - Monitoring/Testing Requirements Applicable Rule Item # Parameter Method of Compliance Frequency Compliant Emission Unit Citation volume fraction of water vapor in stack gases. 9 Opacity NSPS Requirements for Continuous Continuous EU02 & EU03 40 CFR Opacity Monitoring System (COMS) 60.47c(a) & The Owner or Operator of an affected (b) facility combusting oil that is subject to (Subpart the opacity standards under §60.43c shall Dc) install, calibrate, maintain and operate a & COMS for measuring the opacity of the TP-B-0511 emissions discharged to the atmosphere & Yes and record the output of the system. All TP-B-0545 COMS shall be operated in accordance with the applicable procedures under Performance Specification 1 of appendix B of 40 CFR 60. The span value of the opacity COMS shall be between 60 and 80 percent. 10 Opacity NSPS Compliance and Performance Test As requested EU02 & EU03 40 CFR Measurement Methods and Procedures for Particulate by the 60.45c(a) Matter Administrator (Subpart The Owner or Operator of an affected Dc) facility subject to the opacity standards under §60.43c shall conduct subsequent performance tests as requested by the Administrator, to determine compliance with the standards using Method 9 of 40 CFR 60, Appendix A-4. An owner or operator of an affected facility subject to an opacity standard may submit, for compliance purposes, continuous opacity monitoring system (COMS) data results produced during any performance test Yes required under §60.8 in lieu of Method 9 observation data. If an owner or operator elects to submit COMS data for compliance with the opacity standard, he shall notify the Administrator of that decision, in writing, at least 30 days before any performance test required under §60.8 is conducted. Once the owner or operator of an affected facility has notified the Administrator to that effect, the COMS data results will be used to determine opacity compliance during subsequent tests required under §60.8 until the owner or operator notifies the Page 24 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 5 - Monitoring/Testing Requirements Applicable Rule Item # Parameter Method of Compliance Frequency Compliant Emission Unit Citation Administrator, in writing, to the contrary. Finding: EU02 and EU03 exhaust to the same stack, which has a COMS. On October 13-15, 2009, opacity testing was conducted on EU02, while it operated on #2 fuel oil and #6 fuel oil. Results indicated that EU02’s opacity while operating on #2 fuel oil and #6 fuel oil met the limit of 20%. This test also certified the COMS. 11 Opacity NSPS Optional Monitoring Requirement N/A EU02 & EU03 40 CFR 60, Measurement An owner or operator of an affected Subpart A – facility subject to an opacity standard General may submit, for compliance purposes, Provisions continuous opacity monitoring system (COMS) data results produced during any performance test required under §60.8 in lieu of Method 9 observation data as required in Table 5 Item 10. If an owner or operator elects to submit COMS data for compliance with the opacity standard, Yes he shall notify the Administrator of that decision, in writing, at least 30 days before any performance test required under §60.8 is conducted. Once the owner or operator of an affected facility has notified the Administrator to that effect, the COMS data results will be used to determine opacity compliance during subsequent tests required under §60.8 until the owner or operator notifies the Administrator, in writing, to the contrary. Finding: See Finding for Table 5, Item #10 above. 12 Opacity Testing for Opacity from Stationary Upon request EU01, EU02, Env-A Measurements Sources by EU03 & EU04 807.02 The Owner or Operator shall conduct NHDES/USEPA (Effective opacity measurements for a stationary 10-31- source, by using either of the following: 2010) a) 40 CFR 60, Appendix A, Method 9, Yes Visual Determination of the Opacity of Emissions from Stationary Sources; or b) A certified opacity CEM system installed on the stack for which the opacity is being measured. Finding: The stack has a certified opacity CEM system or COMS. 13 Minimum Minimum Specifications for CEM Systems N/A EU01, EU02 & Env-A Specifications The Owner or Operator shall ensure that EU03 808.01 & for CEM each gaseous (CEMS) or opacity CEM 808.03 Yes Systems system (COMS) meets the following (Effective 10-31- Page 25 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 5 - Monitoring/Testing Requirements Applicable Rule Item # Parameter Method of Compliance Frequency Compliant Emission Unit Citation minimum specifications, as applicable: 2010) a) Each gaseous CEMS shall average and record the data for each calendar hour; b) Each COMS shall average the opacity data to result in consecutive, non- overlapping 6-minute averages; c) All opacity and gaseous CEM systems shall; i. Include a means to display instantaneous values of percent opacity and gaseous emission concentrations; and ii. Complete a minimum of one cycle of operation, which shall include measuring, analyzing, and data recording for each successive 5-minute period for systems measuring gaseous emissions and each 10-second period for systems measuring opacity, unless a longer time period is approved in accordance with Env-A 809. d) A valid hour of gaseous or opacity CEM system emission data means a minimum of 42 minutes of gaseous or opacity CEM system readings taken in any calendar hour, during which time the CEM is not in an out of control period as defined in Env-A 808.01(g), and the facility on which the CEM is installed is in operation. 14 QA/QC Plan Quality Assurance/Quality Control Plan Review EU01, EU02 & Env-A Requirements Requirements annually and EU03 808.06 The Owner or Operator of a source revise as (Effective required to install, operate, and maintain necessary 10-31- an opacity or gaseous CEM system shall 2010) prepare, submit, and maintain a quality assurance/quality control (QA/QC) plan Yes as specified below: a) The QA/QC plan shall contain written procedures for implementation of a QA/QC program that meets the criteria specified in 40 CFR 60, Appendix F, Procedure 1, section 3 for each CEM system; Page 26 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 5 - Monitoring/Testing Requirements Applicable Rule Item # Parameter Method of Compliance Frequency Compliant Emission Unit Citation b) The Owner or Operator shall file the QA/QC plan with NHDES no later than 45 days after conducting the performance specification test of the gaseous or opacity CEM system in accordance with Env-A 808.05(c) or (d); c) The Owner or Operator shall review the QA/QC plan and all data generated by its implementation at least once each year; d) The Owner or Operator shall revise or update the QA/QC plan, as necessary, based on the results of the annual review, by: i. Documenting the replacement of any damaged or malfunctioning CEM system components in order to maintain the collection of valid CEM data and to maximize data availability; ii. Documenting any changes made to the CEM system, other than those in (i) above, or changes to any information provided in the monitoring plan submitted in accordance with Env-A 808.04; iii. Including a schedule of, and describing, all maintenance activities that are required by the CEM manufacturer or that might have an effect on the operation of the system, including a summary of the results of any performance specification testing that was performed in accordance with Env-A 808.05(e) or (f); iv. Describing how the audits and testing required by Env-A 808 will be performed; and v. Including examples of the reports that will be used to document the audits and tests required by Env-A 808; e) The Owner or Operator shall make the revised QA/QC plan available for Page 27 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 5 - Monitoring/Testing Requirements Applicable Rule Item # Parameter Method of Compliance Frequency Compliant Emission Unit Citation on-site review by NHDES at any time; and f) No later than April 15 of each year, the Owner or Operator shall either: i. Submit to NHDES the revised QA/QC plan and the reasons for each change, and certify in writing that the Owner or Operator is implementing the revised QA/QC plan; or ii. Certify in writing that no changes have been made to the plan and that the Owner or Operator will continue to implement the existing QA/QC plan. If NHDES requests a revision to the QA/QC plan, the Owner or Operator shall submit a revised plan within 45 days of the date of the request. 15 General Audit General Audit Requirements for All Quarterly EU01, EU02 & Env-A Requirements Gaseous and Opacity CEMS EU03 808.07 for All Gaseous The Owner or Operator shall conduct (Effective and Opacity required quarterly audits anytime during 10-31- Yes CEMS each calendar quarter, provided that 2010) successive quarterly audits shall occur no more than 4 months apart. 16 CEMS Audit Audit Requirements for Gaseous CEM Quarterly EU01 Env-A Requirements Systems 808.08 Gaseous CEMS audits shall be conducted (Effective Yes in accordance with 40 CFR 60, Appendix F 10-31- and Env-A 808.08. 2010) 17 COMS Audit Audit Requirements for Opacity CEM Quarterly EU02 & EU03 Env-A Requirements Systems 808.11 The Owner or Operator shall perform (Effective audits for COMS in accordance with 10-31- Yes procedures described in Env-A 808.11 2010) and 40 CFR 60, Appendix B, Performance Specification 1. 18 Data Availability Data Availability Requirements N/A EU01, EU02 & Env-A Requirements a) The Owner or Operator shall operate EU03 808.12 (Effective the CEM at all times during operation Yes of the source, except for periods of 10-31- CEM breakdown, repairs, calibration 2010) checks, preventive maintenance, and Page 28 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 5 - Monitoring/Testing Requirements Applicable Rule Item # Parameter Method of Compliance Frequency Compliant Emission Unit Citation zero/span adjustments; b) The percent CEM data availability shall be maintained at a minimum of 90% on a calendar quarter basis for all opacity monitors, gaseous concentration monitors, and stack volumetric flow monitors; c) The percent CEM data availability shall be calculated as follows: (VH CalDT)x100 PercentDataAvailability (OH AH ) where: “VH” means the number of valid hours of CEM data in a given time period for which the data availability is being calculated when the plant is in operation; “OH” means the number of facility operating hours during a given time period for which the data availability is being calculated; “AH” means the number of hours during facility operation when the performance of quarterly audits as required by those procedures specified in Env-A 808.08 through Env-A 808.11, as applicable, require that the CEM be taken out of service in order to conduct the audit; “CalDT” means the number of hours, not to exceed one hour per day, during facility operation when the CEM is not operating due to the performance of the daily CEM calibrations as required in 40 CFR 60, Appendix F. 19 Requirement Requirement for Substitute Emission Data N/A EU01 Env-A for Substitute Any facility that uses the emissions data 808.13 Emission Data collected by a gaseous CEM system to (Effective calculate and report its annual emissions 10-31- in accordance with Env-A 900 shall 2010) Yes comply with the following: a) For any facility operating hour during which the gaseous CEM system has not collected a valid hour of CEM Page 29 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 5 - Monitoring/Testing Requirements Applicable Rule Item # Parameter Method of Compliance Frequency Compliant Emission Unit Citation system data, the Owner or Operator shall submit to NHDES substitute emission data for those hours which has been generated using one of the following methods: i. The missing data substitution procedures specified in 40 CFR 75, Subpart D; ii. If the missing data occurred during a period of steady-state operation, and not during a period of start-up, shutdown, or malfunction: 1. An average of the emissions data for the hours prior to and after the period of missing data during which valid CEM data was collected, or 2. Representative emissions data for the device at the same heat input rate, electric generating rate, or steam load; iii. If the missing data occurred during a start-up, shutdown, or malfunction of the device, substitute data collected by the CEM during a similar period of start-up, shutdown or malfunction, respectively; or iv. An alternative method of data substitution that meets the following criteria: 1. The alternative method was included in the monitoring plan submitted pursuant to Env-A 808.04; 2. The alternative method provides for representative emissions for the conditions of operation of the device during the period of missing data equivalent to the substitution methods described in (i) through (iii), above; and 3. The alternative method was Page 30 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 5 - Monitoring/Testing Requirements Applicable Rule Item # Parameter Method of Compliance Frequency Compliant Emission Unit Citation approved by NHDES as part of its approval of the monitoring plan pursuant to Env-A 808.04. b) For CEM systems and emissions not subject to the missing data substitution procedures of 40 CFR 75 Subpart D, sources shall include substitute emissions data in the calculation of total daily, monthly, quarterly, and annual emissions generated by the permitted device to quantify total actual emissions; c) Substitute emission data shall not be used in the calculation of emissions totals or averages in order to determine or demonstrate compliance with emissions standards; d) Substitute data shall not be included in the calculation of data availability. 20 Valid averaging Valid Averaging Period N/A EU01 Env-A period The number of hours of valid CEM system 808.17 data required for the calculation of a (Effective valid averaging period and for the 10-31- Yes determination of compliance with a 24- 2010) hour emission standard period shall be 18 hours of valid data. 21 Operation of Fuel Flow Meters Daily EU01, EU02, 40 CFR 70.6 fuel flow meters A flow meter shall be continuously EU03 & EU04 (a)(3)(i)(B) operated on the fuel inlet line to each of Yes the four boilers to measure the total amount of fuel oil consumption in each of the boilers. 22 Periodic Fuel Flow Meters Operation and Annually EU01, EU02, 40 CFR 70.6 Monitoring Maintenance EU03 & EU04 (a)(3)(i)(B) The Owner or Operator shall operate and & TP-B- maintain fuel metering devices required 0511 in Table 4, Item 21 in accordance with manufacturer’s recommended Yes specifications. Calibration shall be conducted at least once a year in accordance with manufacturer’s specifications and following manufacturer’s recommended procedures or in a manner and/or Page 31 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 5 - Monitoring/Testing Requirements Applicable Rule Item # Parameter Method of Compliance Frequency Compliant Emission Unit Citation frequency approved by the Division. 23 Operations of Steam Flow Monitor As specified EU01, EU03 & 40 CFR 70.6 steam flow Operate and maintain a continuous EU04 (a)(3)(i)(B) monitor steam flow rate monitoring system for & measuring steam production in pounds TP-B-0511 per hour from each of the boilers which meets the following requirements: a) The steam flow rate monitoring system shall meet all applicable ASME specifications; b) The steam flow transducer shall be calibrated at least once annually in accordance with manufacturer’s Yes specifications; and c) If adequate straight length of piping is not available, then in lieu of a measuring system that meets ASME specifications, the Owner or Operator may use a steam flow rate monitoring system that can be calibrated by instruments installed, maintained and calibrated per ASME specifications or by other methods approved by the NHDES. 24 Hours of a) The emergency generators listed in Continuous EU11 40 CFR Operation Appendix C (EU11) shall be 60.4209(a) Yes equipped with a non-resettable (Subpart hour meter. IIII) b) The emergency generators listed in Continuous EU13 40 CFR Appendix E (EU13) shall be equipped 60.4237 Yes with a non-resettable hour meter. (Subpart JJJJ) c) If you own or operate an existing Continuous EU05, EU10 & 40 CFR emergency stationary RICE located EU14 63.6625(f) at an area source of HAP emissions, (Subpart Yes you must install a non-resettable ZZZZ) hour meter if one is not already installed. Page 32 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 5 - Monitoring/Testing Requirements Applicable Rule Item # Parameter Method of Compliance Frequency Compliant Emission Unit Citation 25 Boiler Tune-up NESHAP for Area Sources: Industrial, By the EU01, EU02, 40 CFR Commercial, and Institutional Boilers compliance EU03, EU04 & 63.11223 The biennial tune-up of the boiler(s) shall date EU12 Subpart consist of the following: established in JJJJJJ a) As applicable, inspect the burner, 40 CFR and clean or replace any components 63.11196 and of the burner as necessary; every 5-years b) Inspect the flame pattern, as thereafter applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer’s specifications if available; c) Inspect the system controlling the Yes air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly; d) Optimize total emissions of carbon monoxide, consistent with the manufacturer’s specifications, if available; and e) Measure the concentration in the effluent stream of carbon monoxide in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made. Findings: For EU01 – EU04, the tune-up frequency in the Method of Compliance column is incorrectly stated as biennial. EU01 – EU04 have Oxygen trim, therefore, the correct frequency is once every five years. For EU01 – EU04, boiler tune-ups were conducted as follows: EU01 – November 26, 2013; EU02 – October 15, 2013; EU03 – November 11, 2013; and EU04 – April 11, 2013. They were all conducted prior to the March 21, 2014 deadline. The next boiler tune-up for these boilers will be in 2018. For EU12, the tune-ups were conducted late, on September 11, 2014, and the documentation was completed on September 22, 2014. The tune-ups were due to be completed by March 21, 2014. This was addressed in the previous inspection report. 26 To Be When conditions warrant, the Division Upon request Facility Wide RSA 125- Determined may require the Owner or Operator to by the Division C:6, XI conduct stack testing in accordance with & Not USEPA or other Division approved TP-0037 Applicable methods. Finding: During the evaluation period, NHDES has not required additional testing. Page 33 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 VII. Compliance with Recordkeeping Requirements Table 6 below, taken from permit TV-0022, lists the recordkeeping requirements for the facility, and any deficiencies noted during the evaluation. Table 6 - Recordkeeping Requirements Applicable Rule Item # Applicable Requirement Frequency Emission Compliant Citation Unit 1 Record Retention Retain for a Facility Wide 40 CFR The Owner or Operator shall retain records of minimum of 70.6(a)(3)(i all required monitoring data, recordkeeping 5 years i)(B) and reporting requirements, stack testing Yes results and support information for a period of at least 5 years from the date of origination. 2 General Recordkeeping Requirements Monthly Facility Wide Env-A For each fuel burning device at the facility, 903.03 the Owner or Operator shall keep records of (Effective fuel utilization in accordance with the 4-21-2007) following: & TP-B-0511 a) Monthly and calendar year total fuel Yes consumption; & b) Fuel type (e.g. #6 or #2 fuel oil, diesel, TP-B-0545 LPG); and & c) Hours of operation of each device to be TP-0037 used to apportion fuel use between multiple devices. 3 NSPS Subpart Db Recordkeeping Continuously EU01 40 CFR Requirements 60.49b(d) The Owner or Operator shall record and (1) & (g) maintain records of the amounts of each fuel (Subpart combusted during each day and calculate the Db) annual capacity factor individually for residual oil for the reporting period. The annual capacity factor is determined on a 12- month rolling average basis with a new annual capacity factor calculated at the end Yes of each calendar month. The owner or operator of an affected facility subject to the nitrogen oxides standards under §60.44b shall maintain records of the following information for each steam generating unit operating day: a) Calendar date; b) The average hourly nitrogen oxides emission rates expressed as NO2 (lb/million Btu heat input) measured or Page 34 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 6 - Recordkeeping Requirements Applicable Rule Item # Applicable Requirement Frequency Emission Compliant Citation Unit predicted; c) The 30-day average nitrogen oxides emission rates (lb/million Btu heat input) calculated at the end of each steam generating unit operating day from the hourly nitrogen oxide emission rates for the preceding 30 steam generating unit operating days. d) Identification of the steam generating unit operating days when the calculated 30-day average nitrogen oxides emission rates are in excess of the nitrogen oxides emissions standards under §60.44b, with the reasons for such excess emissions as well as a description of corrective actions taken; e) Identification of the steam generating unit operating days for which pollutant data have not been obtained, including reasons for not obtaining sufficient data and a description of corrective actions taken; f) Identification of the times when emission data have been excluded from the calculation of average emission rates and the reasons for excluding data; g) Identification of "F" factor used for calculations, method of determination, and type of fuel combusted; h) Identification of the times when the pollutant concentration exceeded full span of the CEMS; i) Description of any modifications to the CEMS that could affect the ability of the CEMS to comply with Performance Specification 2 or 3; and j) Results of daily CEMS drift tests and quarterly accuracy assessments as required under appendix F, Procedure 1. 4 NSPS Subpart Dc Recordkeeping Continuously EU02 & EU03 40 CFR Requirements 60.48c(e), The Owner or Operator shall keep record of (g)(1) & the following information: (g)(2) Yes a) Calendar dates covered in the reporting (Subpart period; Dc) b) Each 30-day average sulfur content Page 35 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 6 - Recordkeeping Requirements Applicable Rule Item # Applicable Requirement Frequency Emission Compliant Citation Unit (weight percent), calculated during the reporting period, ending with the last 30- day period; reasons for any noncompliance with the emission standards; and a description of corrective actions taken; c) Each 30-day average percent of potential SO2 emission rate calculated during the reporting period, ending with the last 30- day period; reasons for any noncompliance with the emission standards; and a description of the corrective actions taken; d) Identification of any times when emissions data have been excluded from the calculation of average emission rates; justification for excluding data; and a description of corrective actions taken if data have been excluded for periods other than those during which oil was not combusted in the steam generating unit; e) Identification of whether averages have been obtained based on CEMS rather than manual sampling methods; f) If fuel supplier certification is used to demonstrate compliance, records of fuel supplier certification or laboratory analyses pursuant to Table 6, Item 5, below; and g) A certified statement signed by the Owner or Operator of the Facility that the records of fuel supplier certifications submitted represent all of the fuel combusted during the reporting period. The Owner or Operator shall record and maintain records of the amount of each fuel combusted during each operating day. As an alternative to daily records, the Owner or Operator of an affected facility that combusts only fuels using fuel certification pursuant to Table 6, Item 5 to demonstrate compliance with the SO2 standard, may elect to record and maintain records of the amount of each fuel combusted during each calendar month. Page 36 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 6 - Recordkeeping Requirements Applicable Rule Item # Applicable Requirement Frequency Emission Compliant Citation Unit 5 NSPS Subpart Dc Requirements for Fuel Maintain Up- EU02 & EU03 40 CFR Supplier Certificates or Laboratory Analyses to-Date Data 60.48c(f) Maintain the following records for Boilers #2 (Subpart and #3: Dc) a) For distillate oil (#2 fuel oil), copies of fuel supplier certificates which include: i. The name of the oil supplier; ii. A statement from the oil supplier that the oil complies with ASTM D396-78, 89, 90, 92, 96, or 98, Standard Specifications for Fuel Oils, for distillate oil; and iii. The sulfur content or maximum sulfur content of the oil. b) For residual oil (#6 fuel oil), the fuel Not supplier certificate or laboratory analyses Applicable shall include: for a); i. The name of the oil supplier; Yes for b) ii. The location of the oil when the sample was drawn for analysis to determine the sulfur content of the oil, specifically including whether the oil was sampled as delivered to the affected facility, or whether the sample was drawn from oil in storage at the oil supplier’s or oil refiner’s facility, or other location; iii. The sulfur content of the oil from which the shipment came (or of the shipment itself); and iv. The method used to determine the sulfur content of the oil. Finding: For #2 fuel oil: During the evaluation period, Dartmouth has not burned #2 fuel oil in EU02. For #6 fuel oil: Dartmouth is in compliance. 6 NESHAP Subpart JJJJJJ Recordkeeping Maintain Up- EU01, EU02, 40 CFR Requirements to-Date Data EU03, EU04 63.11225 The Owner or Operator shall maintain the & EU12 (Subpart following records: JJJJJJ) a) A copy of each notification and report that the Owner or Operator submitted Yes to comply with 40 CFR 63, Subpart JJJJJJ and all documentation supporting any Initial Notification or Notification of Compliance Status submitted; b) Records to document conformance with Page 37 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 6 - Recordkeeping Requirements Applicable Rule Item # Applicable Requirement Frequency Emission Compliant Citation Unit the work practices required by §63.11214 and as specified below: i. Records must identify each boiler, the date of tune-up, the procedures followed for tune-up, and the manufacturer’s specifications to which the boiler was tuned; ii. For units that combust non- hazardous secondary materials that have been determined not to be solid waste pursuant to §241.3(b)(1), the Owner or Operator must keep a record which documents how the secondary material meets each of the legitimacy criteria under §241.3(d)(1); iii. For units that combust a fuel that has been processed from a discarded non-hazardous secondary material pursuant to §241.3(b)(4), the Owner or Operator must keep records as to how the operations that produced the fuel satisfies the definition of processing in §241.2 and each of the legitimacy criteria in §241.3(d)(1); iv. For fuel that has received a non- waste determination pursuant to the petition process submitted under §241.3(c), the Owner or Operator must keep a record that documents how the fuel satisfies the requirements of the petition process; v. For units that combust non- hazardous secondary materials as fuel per §241.4, the Owner or Operator must keep records documenting that the material is a listed non-waste under §241.4(a); vi. For each boiler required to conduct an energy assessment, the Owner or Operator must keep a copy of the energy assessment report. c) Records of the occurrence and duration of each malfunction of the boiler; Page 38 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 6 - Recordkeeping Requirements Applicable Rule Item # Applicable Requirement Frequency Emission Compliant Citation Unit d) Records of actions taken during periods of malfunction to minimize emissions in accordance with the general duty to minimize emissions, including corrective actions to restore the malfunctioning boiler to its normal or usual manner of operation; e) The records must be in a form suitable and readily available for expeditious review. The Owner or Operator must keep each record for 5 years following the date of each recorded action. The Owner or Operator must keep each record on-site or be accessible from a central location by computer or other means that instantly provide access at the site for at least 2 years after the date of each recorded action. The Owner or Operator may keep the records off site for the remaining 3 years; and f) If the Owner or Operator switches fuels or makes a physical change to the boiler, and the fuel switch or change results in the applicability of a different subcategory or a switch out of 40 CFR 63, Subpart JJJJJJ due to a switch to 100 percent natural gas, the Owner or Operator shall provide notice of the date upon which the Owner or Operator switched fuels or made the physical change, within 30 days of the change. The notification must identify: i. The name of the owner or operator of the affected source, the location of the source, the boiler(s) that have switched fuels or were physically changed, and the date of the notice; ii. iii. The date upon which the fuel switch or physical change occurred. 7 Gaseous Fuel Recordkeeping Requirements Whenever Facility Wide Env-A Maintain one of the following: there is a 903.03 a) Sulfur content as percent sulfur by change in (Effective weight or in grains per 100 cubic feet of gaseous fuel 4-21-2007) Yes fuel; supplier but & b) Documentation that the fuel source is at least TP-0037 annually Page 39 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 6 - Recordkeeping Requirements Applicable Rule Item # Applicable Requirement Frequency Emission Compliant Citation Unit from a utility pipeline; or c) Documentation that the fuel meets state sulfur limits. Finding: Dartmouth maintains documentation that indicates the propane meets the state sulfur limits. 8 Liquid Fuel Oil Recordkeeping Requirements For each EU01 & EU04 Env-A In lieu of sulfur testing pursuant to Table 5, delivery of #6 806.05 Item 2, the Owner or Operator may maintain fuel oil to the (Effective the following information: facility date 10- 31-2010) a) For #6 fuel oil, except for #6 fuel oil & which meets the requirements of Table TP-B-0511 5, Item 3, the Owner or Operator may maintain: i. Records showing the maximum weight percentage sulfur and quantity of each fuel delivery shipment received; and ii. Records showing either: 1. The analytical method used and the specific fuel analysis results of the shipment or consignment Yes from which the shipment came; or 2. Delivery records sufficient to allow for traceability of the analytical results corresponding to each shipment received by the stationary source, showing: A. The date of delivery; B. The quantity of delivery; C. The type of fuel; D. The maximum weight percentage sulfur; and E. The name, address, and telephone number of the company making the delivery. b) For #2 fuel oil or diesel fuel oil, the Whenever Facility Wide Env-A Owner or Operator shall maintain either there is a 806.05 the records required by a. above, or a change in (Effective written statement from the fuel supplier fuel supplier date 10- Yes that the sulfur content of the fuel as but at least 31-2010) delivered does not exceed state or annually & federal standards for that fuel. TP-0037 Page 40 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 6 - Recordkeeping Requirements Applicable Rule Item # Applicable Requirement Frequency Emission Compliant Citation Unit 9 NOx Emission Statements Recordkeeping Maintain Up- Facility Wide Env-A Requirements to-Date Data 905.02 If the actual annual NOx emissions from the & Facility are greater than or equal to 10 tpy, TP-0037 then record the following information: a) Identification of each fuel burning device; b) Operating schedule during the high ozone season (June 1 through August 31) for each fuel burning device identified in Table 6, Item 9.a, above, including: i. Typical hours of operation per day; ii. Typical days of operation per Yes calendar month; iii. Number of weeks of operation; iv. Type and amount of each fuel burned; v. Heat input rate in MMBtu/hr; vi. Actual NOx emissions for the calendar year and a typical high ozone day during that calendar year; and vii. Emission factors and the origin of the emission factors used to calculate the NOx emissions. 10 Additional Monitoring and Testing Records For each EU02, EU03 40 CFR The Owner or Operator shall maintain stack test & EU04 70.6(a)(3)(i records of monitoring and testing conducted ii)(A) & requirements as specified in Table 5 of this Env-A 906 Yes Permit including: & TP-B- 0511 a) Stack test results for Boilers #2, #3, and #4 pursuant to Table 5, Items 6, 7 and 8; b) Summary of maintenance, calibration, Maintain Up- EU01, EU02, 40 CFR and repair of the steam flow measuring to-Date Data EU03 & EU04 70.6(a)(3)(i device and fuel oil metering device(s). ii)(A) & Yes Env-A 906 & TP-B- 0511 11 Additional Recordkeeping Requirements Maintain Up- EU02 Env-A The Owner or Operator shall maintain the to-Date Data 618.02 following additional records: (b)(11)(g)( a) For Boiler #2 (EU02), calculate and 2) Yes record monthly NOx emissions using the & equation in Table 4, Item 2(b); data TP-B-0545 collected according to Table 5, Item 4; Page 41 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 6 - Recordkeeping Requirements Applicable Rule Item # Applicable Requirement Frequency Emission Compliant Citation Unit and data collected according to Table 6, Item 2; b) For Boilers #1, #2, #3 and #4, maintain Maintain Up- EU01, EU02, Env-A 906 12-month rolling emissions for to-Date Data EU03 & EU04 (Effective compliance with limits specified in Table 4-21-2007) Yes 4, Items 1 and 2; & TP-B-0545 c) For each CEM system at the facility, the Maintain on As specified Env-A 808 Owner or Operator shall keep the a continuous (Formerly records of emission data recorded by the basis Env-A 805 CEM system, including: Effective i. Calendar daily averages of NOx part 10-31- per million (ppm) dry whether or 2010) not an excess emissions has & Env-A occurred for EU01; 903.04(a) ii. Calendar daily averages of & Yes percentage of O2 on a wet basis for TP-B-0511 EU01; iii. Calendar daily averages of percentage of opacity for EU01, EU02, EU03 and EU04; iv. Calendar daily averages of steam generation rate for EU01, EU02, EU03 and EU04; and v. CEM system availability data. 12 Regulated Toxic Air Pollutants (RTAPs) Update prior Facility Wide Env-A Maintain records documenting compliance to process 902.01 with Env-A 1400. changes and Compliance was demonstrated at the time of within 90 permit issuance as described in the Division’s days of each Application Review Summary for application revision of #FY05-0028. The source must update the Env-A 1400 compliance demonstration using one of the methods provided in Env-A 1405 if: a) There is a revision to the list of RTAPs Not lowering the AAL or de minimis emission Applicable levels for any RTAP emitted from the Facility; b) The amount of any RTAP emitted is greater than the amount that was evaluated in the Application Review Summary (e.g., use of a coating will increase); c) An RTAP that was not evaluated in the Application Review Summary will be Page 42 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 6 - Recordkeeping Requirements Applicable Rule Item # Applicable Requirement Frequency Emission Compliant Citation Unit emitted (e.g., a new coating will be used); or d) Stack conditions (e.g. air flow rate) change. Finding: The permitted devices at Dartmouth are boilers and engines burning virgin fuel and are exempt from the requirements of Env-A 1400. An Env-A 1400 review is not required. 13 Additional Recordkeeping Requirements for Maintain Up- EU05, EU10, 40 CFR Emergency Engines Subject to NOx RACT, to-Date Data EU11, EU13 §60.4211 NSPS and NESHAP Regulations & EU14 & The owner or operator shall maintain the 40 CFR following records: §60.4214 (Subpart a) The operation of the engine in IIII) emergency (i.e. loss of power) and non- 40 CFR emergency situations (i.e. maintenance §60.4243 & testing). The owner or operator must & record the time of operation of the 40 CFR Yes engine and the reason the engine was in §60.4245 operation during that time. (Subpart b) Documentation of the federal, state or JJJJ) local standard(s) that require the owner 40 CFR or operator to conduct maintenance and §63.6655 testing for more than 100 hours per (Subpart calendar year if the owner or operator is ZZZZ) exercising the option listed in Table 4, & Item 15. Env-A 906 Finding: Dartmouth maintains records on the amount of time each emergency generator operates and the reason why each emergency generator ran. 14 Recordkeeping for Permit Deviations Maintain Up- Facility Wide Env-A 911 Recordkeeping of deviations from Permit to-date Data (Effective Yes requirements shall be conducted in date 4-21- accordance with Section XXVIII of the Permit. 2007) Page 43 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 VIII. Compliance with Reporting Requirements Table 7 below, taken from permit TV-0022, lists the reporting requirements for the facility, and any deficiencies noted during the evaluation. Table 7 - Reporting Requirements Applicable Item Applicable Requirements Frequency Emission Rule Citation Compliant # Unit 1 Any report submitted to the NHDES and/or USEPA As specified Facility 40 CFR shall include the certification of accuracy in Section Wide 70.6(c)(1) statement outlined in Section XXI.B. of the Permit XXI. B. Yes and shall be signed by the responsible official. 2 Annual Emissions Report Annually Significant Env-A 907.01 The Owner or Operator shall submit an annual (Received by & emissions report which shall include the following NHDES no TP-B-0511 information: later than & th a) Actual calendar year emissions from each April 15 of TP-B-0545 device of NOx, CO, SO , TSP, VOCs and HAPs; the following 2 Yes b) The methods used in calculating such year) emissions in accordance with Env-A 705.02, Determination of Actual Emissions for Use in Calculating Emission-Based Fees; and c) All information recorded in accordance with Table 6, Item 2. 3 Annual Compliance Certification Annually Facility wide 40 CFR Annual compliance certification shall be (Received by 70.6(c)(1) submitted in accordance with Section XXI.A. of the NHDES no Permit. later than Yes April 15th of the following year) 4 Semi-Annual Permit Deviation and Monitoring Semi- Facility 40 CFR Report annually Wide 70.6(a)(3)(iii) The Owner or Operator shall submit a semi- (Received by (A) annual permit deviation and monitoring report, NHDES no which contains: later than Yes a) Summaries of all monitoring and testing July 31st and requirements contained in this permit; and January 31st b) A summary of all permit deviations and of each excursions that have occurred during the calendar reporting period. year) Page 44 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 7 - Reporting Requirements Applicable Item Applicable Requirements Frequency Emission Rule Citation Compliant # Unit 5 General Audit Requirements for All Gaseous and Quarterly EU01, EU02 Env-A 808.07 Opacity CEM Systems & EU03 (Effective 10- a) Subject to (c), below, within 30 calendar days 31-2010) following the end of each quarter, the Owner or Operator shall submit to NHDES a written summary report of the results of all audits required by Table 5, Item 15, that were performed during that quarter, in accordance with the following: i. For gaseous CEM audits, the report format shall conform to that presented in 40 CFR 60, Appendix F, Procedure 1; and ii. For opacity CEM audits, the report format shall conform to that presented in EPA-600/8-87-025, April 1992, Yes “Technical Assistance Document: Performance Audit Procedures for Opacity Monitors”. b) The Owner or Operator shall notify NHDES: i. At least 30 days prior to the performance of a RATA; and ii. At least 2 weeks prior to any other planned audit or test procedure required under Env-A 808. c) The Owner or Operator shall file with NHDES a written summary of the results of the RATA testing required by Table 5, Item 16 by the earlier of 45 calendar days following the completion of the RATA test or the date established in the section of 40 CFR 60 that requires performance of the RATA. 6 Data Availability Requirements As specified EU01, EU02 Env-A If the Owner or Operator of the source discovers & EU03 808.12(e) & that it has failed to meet the percent data Env-A 911.04(c) availability requirement in the previous calendar quarter or in the calendar quarter in which it currently is operating, the Owner or Operator of the source shall, in addition to the permit Yes deviation reporting required by Env-A 911: a. Notify NHDES by telephone, fax, or e-mail ([email protected]) within 10 days of discovery of the permit deviation; b. Submit a plan to NHDES, within 30 days of discovery, specifying in detail the steps it Page 45 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 7 - Reporting Requirements Applicable Item Applicable Requirements Frequency Emission Rule Citation Compliant # Unit plans to take in order to meet the availability requirements for future calendar quarters; and c. Implement the plan to meet the data availability requirements no later than 30 days after the end of the quarter of failure. 7 Quarterly Emission Report Quarterly EU01, EU02 Env-A 808.14, Submit to NHDES emission reports containing the (received by & EU03 Env-A 808.16 & following information: NHDES no Env-A 808.18 a. Excess emission data recorded by the CEM later than 30 (Effective system, including: days 10-31-2010) i. The date and time of the beginning and following the ending of each period of excess emission; end of each ii. The actual emissions measured by the quarterly CEM system during the excess emission; reporting iii. The total amount of emissions above the period) emissions limit, or percent above the emissions limit, during the period of excess emissions; iv. The specific cause of the excess emission; and v. The corrective action taken; b. If no excess emissions have occurred, a statement to that effect; c. For gaseous measuring CEM systems, the daily averages of the measurements made Yes and emission rates calculated; d. A statement as to whether the CEM system was inoperative, repaired, or adjusted during the reporting period; e. If the CEM system was inoperative, repaired, or adjusted during the reporting period, the following information: i. The date and time of the beginning and ending of each period when the CEM was inoperative; ii. The reason why the CEM was inoperative; iii. The corrective action taken; f. For all “out of control periods” the following information: i. Beginning and ending times of the out of control period; ii. The reason for the out of control period; and iii. The corrective action taken. Page 46 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 7 - Reporting Requirements Applicable Item Applicable Requirements Frequency Emission Rule Citation Compliant # Unit g. The date and time of the beginning and ending of each period when the source of emissions which the CEM system is monitoring was not operating; h. The span value, as defined in Env-A 101.176, and units of measurement for each analyzer in the CEM system; i. When calibration gas is used, the following information: i. The calibration gas concentration; ii. If a gas bottle was changed during the quarter: 1. The date of the calibration gas bottle change; 2. The gas bottle concentration before the change; 3. The gas bottle concentration after the change; and iii. The expiration date for all calibration gas bottles used. j. The percent data availability calculated in accordance with Table 5, Item 18 for each gaseous, opacity, and flow rate monitor in the CEM system; k. Even if sufficient valid hours have been measured by the CEM system necessary for calculation of a valid averaging period as defined in Env-A 808.17, the Owner or Operator shall still report for any invalid hours that occurred during the emission standard period the substitute data, as approved in accordance with Env-A 808.13, that will be used to determine the source's total emissions; l. All information required above shall be clearly indicated, labeled, and formatted such that compliance with all emissions standards to which the source is subject, can be determined and any periods of excess emissions, substitution of missing or invalid CEM data, CEM calibration, CEM maintenance, or startup, shutdown, or malfunction can be easily identified. 8 NOx Emission Statements Reporting Requirements Annually Facility Env-A 909 If the actual annual NOx emissions from all (Received by Wide & Yes devices located at the Facility are greater than or NHDES no TP-0037 equal to 10 tpy, then include the following later than Page 47 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 7 - Reporting Requirements Applicable Item Applicable Requirements Frequency Emission Rule Citation Compliant # Unit information with the annual emission report: April 15th of a) A breakdown of NOx emissions reported the following pursuant to Table 7, Item 2 by month; and year) b) All data recorded in accordance with Table 6, Item 9. 9 Payment of Emission-Based Fee Annually Significant & Env-A 705.04 Annual reporting of emission based fees shall be (Received by Insignificant conducted in accordance with Section XXIII of the NHDES no Activities Permit. later than Yes April 15th of the following year) 10 NESHAP Subpart JJJJJJ Notification Requirements As required EU01, EU02, 40 CFR Compliance Certification Report per 40 CFR EU03, EU04 63.11225(b) The Owner or Operator shall prepare a 40 CFR 63, 63.11225(b) & EU12 (Subpart JJJJJJ) Subpart JJJJJJ Compliance Certification Report (Prepared no which shall contain: later than a. Company name and address; March 1st b. Statement by a responsible official, with the following the official’s name, title, phone number, e-mail 5-yr tune-up address, and signature, certifying the truth, and accuracy and completeness of the notification submitted to and a statement of whether the source has US EPA complied with all the relevant standards and Region 1 and other requirements of 40 CFR 63, Subpart the Division JJJJJJ. The notification must include the upon following certification(s) of compliance, as request) applicable, and signed by a responsible official: Future i. “This facility complies with the Requirement requirements in §63.11223 to conduct a 5-year tune-up of each boiler.” ii. For units that do not qualify for a statutory exemption as provided in section 129(g)(1) of the Clean Air Act: “No secondary materials that are solid waste were combusted in any affected unit.” iii. “This facility complies with the requirement in §§63.11214(d) and 63.11223(g) to minimize the boiler’s time spent during startup and shutdown and to conduct startups and shutdowns according to the manufacturer’s recommended procedures or procedures specified for a boiler of similar design if manufacturer’s recommended Page 48 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 7 - Reporting Requirements Applicable Item Applicable Requirements Frequency Emission Rule Citation Compliant # Unit procedures are not available.” Finding: Dartmouth needs to write its Compliance Certification Report after it completes future tune-ups. 11 NSPS Subpart Db Reporting Requirement Semiannually EU01 40 CFR The Owner or Operator of an affected facility (Postmarked 60.49b(i) (v) & th subject to the continuous monitoring by the 30 (w) requirements for NOx under §60.48(b) shall day following (Subpart Db) submit reports containing the information the end of recorded pursuant to Table 6, Item 3. the reporting The reporting period for the reports is each 6 period) month period. unless The Owner or Operator may submit electronic reports are quarterly reports for NOx in lieu of submitting the submitted written reports. The format of each quarterly electronically electronic report shall be coordinated with the per 40 CFR permitting authority. The electronic report(s) 60.49b(w) Yes shall be submitted no later than 30 days after the end of the calendar quarter and shall be accompanied by a certification statement from the Owner or Operator, indicating whether compliance with the applicable emission standards and minimum data requirements of 40 CFR 60, Subpart Db was achieved during the reporting period. Before submitting reports in the electronic format, the Owner or Operator shall coordinate with the permitting authority to obtain their agreement to submit reports in this alternative format. 12 NSPS Subpart Dc Reporting Requirements Semiannually EU02 & 40 CFR a) The Owner or Operator shall submit excess (Postmarked EU03 60.48c(c) (d) & th mission reports for any excess emissions by the 30 (e) from Boilers #2 and #3 that occur during the day following (Subpart Dc) reporting period. the end of b) The Owner or Operator shall submit to the reporting NHDES and USEPA, Region 1, a semi-annual period) fuel certification report for fuel consumed in Boilers #1 and #2 that includes the records Yes listed in Table 6 Items 4 and 5. c) The reports shall be submitted to US EPA, Region 1 at the following address: US EPA, Region 1 Attn: Air Compliance Clerk 1 Congress Street Suite 1100 Mail Code SEA Boston, MA 02114-2023 Page 49 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Table 7 - Reporting Requirements Applicable Item Applicable Requirements Frequency Emission Rule Citation Compliant # Unit Finding: Item b: The permit incorrectly identifies Boiler #1. The correct Boiler is #3. New EPA address is: 5 Post Office Square, Suite 100 (OES04-2) Boston, MA 02109-3912 13 Additional Reporting Requirements 60 days after EU02, EU03 Env-A 910 The Owner or Operator shall submit to the completion & EU04 (Effective of testing 4-21-2007) Department the results of the compliance stack Yes emissions test required pursuant to Table 5, Item Env-A 802.11 7 no more than 60 days after completion of & testing; TP-B-0511 IX. Permit Deviation Reporting Requirements Dartmouth is aware of the recordkeeping and reporting requirements for permit deviations. During the evaluation period, Dartmouth reported six permit deviations to NHDES, as follows: On October 27, 2015, Dartmouth reported that, on October 23, 2015, it exceeded the 20% opacity limit, as stated in Table 4 of permit TV-0022. Dartmouth reported that there was a load swing and poor air control after a plant trip when it was restoring campus steam. Dartmouth stated that it checked the fuel/air tuning curve and took no action because there was a significant steam load change. Dartmouth determined that, in the future, operators should start-up a second boiler when the operating boiler approaches 100% boiler output. The average opacity during the 6-minute block was 21.8%, which exceeded the 20% opacity limit. NHDES reviewed this deviation in accordance with its procedures and no further action is required. On January 26, 2016, Dartmouth reported that, on that date, it exceeded the 20% opacity limit, as stated in Table 4 of permit TV-0022. Dartmouth reported that there was poor air control during a significant steam load change caused by a Boiler #2 (EU02) trip (flame failure). Dartmouth stated that it changed the Boiler #1 (EU01) fuel/air curve on the upper end of the firing rate to give combustion slightly more air. The average opacity during the 6-minute block was 29.6%, which exceeded the 20% opacity limit. NHDES reviewed this deviation in accordance with its procedures and no further action is required. On March 30, 2016, Dartmouth reported that, on March 29, 2016, it exceeded the 20% opacity limit, as stated in Table 4 of permit TV-0022. Dartmouth reported that there was poor air control bringing boiler online to help trim morning steam loads. The operator was reminded to keep a closer eye on the O2 levels and to use the O2 trim controller. The average opacity during the 6-minute block was 24.0%, which exceeded the 20% opacity limit. NHDES reviewed this Page 50 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 deviation in accordance with its procedures and no further action is required. On January 26, 2017, Dartmouth reported that, on that date, it exceeded the 20% opacity limit, as stated in Table 4 of permit TV-0022. Dartmouth reported that there was poor air control and not enough combustion air. The NOx monitor read a false high and the operator trimmed the air too much, resulting in an opacity spike and two six-minute averages exceeded the 20% limit. Dartmouth took Boiler #1 (EU01) offline, then found and fixed a leak in the NOx monitor sample system. The average opacity during the first 6-minute block was 21.7% and the average opacity during the second 6-minute block was 25.9%, both of which exceeded the 20% opacity limit. NHDES reviewed this deviation in accordance with its procedures and no further action is required. On February 27, 2017, Dartmouth reported that, on February 26, 2017, it exceeded the 20% opacity limit, as stated in Table 4 of permit TV-0022. Dartmouth reported that there was poor air control as Boiler #1 (EU01) load increased during early morning demand for steam and during the transition of putting a second boiler on line to meet the demand. Two six-minute averages exceeded the 20% limit. The operator placed the second boiler on line to stabilize the plant. Boiler #1 (EU01) air should have been increased prior to, during, and after the startup of the second boiler. The average opacity during the first 6-minute block was 25.9% and the average opacity during the second 6-minute block was 22.8%, both of which exceeded the 20% opacity limit. NHDES reviewed this deviation in accordance with its procedures and no further action is required. On March 2, 2017, Dartmouth reported that, on March 1, 2017, it exceeded the 20% opacity limit, as stated in Table 4 of permit TV-0022. Dartmouth reported that it lowered the air on Boiler #4 (EU04) during the NOx RACT test to see what impact less air would have on the NOx emissions. Dartmouth raised the air back up after learning that less air had a minimal effect on the NOx emissions. The average opacity during the 6-minute block was 20.6%, which exceeded the 20% opacity limit. NHDES reviewed this deviation in accordance with its procedures and no further action is required. X. Other Findings 1. Since the issuance of the Title V Operating Permit TV-0022, the requirements of 40 CFR 63, Subpart ZZZZ changed (effective January 30, 2013). The new requirements, as presented in the table below, will be included in future permits and are in addition to other federal engine regulations that are currently included in Dartmouth’s Title V Operating Permit TV-0022. In addition, clarifying requirements contained in 40 CFR 60, Subpart IIII and Subpart JJJJ are also proposed to be included in future permits and are listed below. Page 51 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 New Applicable Requirements Emission Unit Regulatory Citation Compliant New Source Performance Standards (NSPS) for Stationary CI Internal Combustion Engines Subject to Regulations Under 40 CFR Part 60, Subpart IIII: Operational Requirements for New Emergency Engines The owner or operator of an emergency engine subject to the requirements of 40 CFR Part 60, Subpart IIII shall: a. Purchase a certified emergency engine in accordance 40 CFR 60.4206, with the requirements listed in 40 CFR Part 60, Subpart EU11 40 CFR 60.4211(a) & Yes IIII; 40 CFR 60.4211(c) b. Install, configure, operate and maintain the engine (Subpart IIII) according to the manufacturer's emission-related written instructions (O&M manual) or change only the emission-related settings in a way that is permitted by the manufacturer; and c. Operate and maintain the engine to meet the emission standards over the entire life of the engine. New Source Performance Standards (NSPS) for Stationary SI Internal Combustion Engines Subject to Regulations Under 40 CFR Part 60, Subpart JJJJ: Operational Requirements for New Emergency Engines The owner or operator of an emergency engine subject to the requirements of 40 CFR Part 60, Subpart JJJJ shall: a. Purchase a certified emergency engine in accordance with the requirements listed in 40 CFR Part 60, Subpart JJJJ; and b. Operate and maintain the engine to meet the emission standards over the entire life of the engine; and 40 CFR 60.4234 & c. If the owner or operator operates and maintains the EU13 40 CFR 60.4243 Yes engine according to the manufacturer's emission- (Subpart JJJJ) related written instructions (O&M manual) or changes only the emission-related settings in a way that is permitted by the manufacturer, then you must keep records of conducted maintenance to demonstrate compliance; or d. If the owner or operator does not operate and maintain the engine according to the manufacturer's emission-related written instructions (O&M manual), the engine will be considered a non-certified engine. The owner or operator must demonstrate compliance according to §60.4243. Page 52 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 New Applicable Requirements Emission Unit Regulatory Citation Compliant NSPS Subpart IIII Recordkeeping Requirements The owner or operator shall maintain the following records: a. Documentation from the engine manufacturer 40 CFR 60.4211 EU11 Yes certifying that the engine complies with the applicable (Subpart IIII) emission standards stated in 40 CFR Part 60, Subpart IIII; and b. A copy of the manufacturer's O&M manual for the engine. Emergency Demand Response Reporting Requirements a. The owner or operator of an emergency generator that operates or is contractually obligated to be available for more than 15 hours per calendar year for the purpose of Emergency Demand Response (EU10/EG3), must submit an annual report which contains the following information: 1. Company name and address where the engine is located; 2. Date of the report and beginning and ending dates of the reporting period; 3. Engine site rating and model year; 4. Latitude and longitude of the engine in decimal degrees reported to the fifth decimal place; 5. Hours operated for the purposes of Emergency Demand Response including the date, start time, and end time for engine operation; Electric/Heating 6. Number of hours the engine is contractually 40 CFR 63.6650 Plant EG Yes obligated to be available for Emergency Demand (Subpart ZZZZ) (EU10/EG3) Response; 7. Identify the entity that dispatched the engine and the situation that necessitated the dispatch of the engine; 8. If there were no deviations from the fuel requirements (15 ppm ULSD), a statement that there were no deviations from the fuel requirements during the reporting period; and 9. If there were deviations from the fuel requirements (15 ppm ULSD), information on the number, duration, and cause of deviations, and the corrective action taken. b. The annual report must be submitted electronically using the subpart specific reporting form in the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA’s Central Data Exchange (CDX) (www.epa.gov/cdx). However, if the reporting form specific to this subpart is not available Page 53 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 New Applicable Requirements Emission Unit Regulatory Citation Compliant in CEDRI at the time that the report is due, the written report must be submitted to the Administrator and the Department at the addresses listed in Condition XXI. Finding: For the Electric/Heating Plant EG (EU10/EG3), Dartmouth submitted the required report for 2015 to USEPA on March 21, 2016. For the Electric/Heating Plant EG (EU10/EG3), Dartmouth maintained Emergency Demand Response status until May 2016. Also, in July 2016, Dartmouth entered into an Emergency Demand Response Contract for the Life Sciences Building EG (EU11/EG20) and ran the generator on three occasions under this contract. Per USEPA, the report due on March 31, 2017, is no longer required. 2. The Emergency Demand Response contract that Dartmouth had for the Electric/Heating Plant EG (EU10/EG3) was canceled in May 2016. In July 2016, Dartmouth agreed to an Emergency Demand Response Contract for the Life Sciences Building EG (EU11/EG20). Dartmouth ran this generator on three occasions under the Emergency Demand Response contract: July 14, 2016 for 4 hours; August 11, 2016 for 7 hours; and, December 14, 2016 for 3.5 hours. Dartmouth operated the Life Sciences Building EG (EU11/EG20) under the Emergency Demand Response contract in compliance with the current Federal regulations. However, when Dartmouth operated this generator under the Emergency Demand Response Contract, it did not meet the requirements of Table 4, Item # 14 of the Permit. Findings: Dartmouth operated the Life Sciences Building EG (EU11/EG20) on three occasions under an Emergency Demand Response Contract and did not meet the requirements of Table 4, Item #14 of the Permit. In an April 24, 2017 email to NHDES, Dartmouth indicated that it will not be continuing with the Emergency Demand Response Contract for the Life Sciences Building EG (EU11/EG20). XI. Enforcement History and Status During the evaluation period, NHDES has not issued any enforcement actions against Dartmouth. XII. Compliance Assistance, Recommendations and Corrective Actions Based on the findings of this compliance evaluation, NHDES recommends the following actions to bring the facility into compliance with the identified deficiencies and future reporting requirements: Page 54 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 a) 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. b) Before operating an emergency generator under an Emergency Demand Response Contract, conduct a review to determine if it complies with all applicable federal, state, and Permit requirements. Report Prepared By Alan H. Moulton Title Compliance Assessment Engineer Signed Page 55 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 APPENDIX A EU05 – EMERGENCY GENERATORS INSTALLED ON OR PRIOR TO MAY 13, 1970 Emission Description Manufacturer Model Serial # kW Fuel Firing Heat Date Unit ID & Location Rate Input Installed (gal/hr or (MMBtu/ cf/hr) hr) EG1 Hopkins Onan 25D2C 91C667975 25 Diesel 1.7 0.23 1961 4RA/1675C Note: Emergency Generator EU05/EG1 was removed from the facility on April 25, 2012. APPENDIX B EU10 – EMERGENCY GENERATORS INSTALLED AFTER JANUARY 1, 1985 THAT ARE NOT SUBJECT TO 40 CFR 60, SUBPART IIII Emission Description & Manufacturer Model Serial # kW Fuel Firing Heat Date Unit ID Location Rate Input Installed (gal/hr or (MMBtu/ cf/hr) hr) EG2 Burke Onan 300DFCB D91038105 300 Diesel 20.8 2.85 1993 (Gen Set) 430330549 NTA-855-GA Engine Model EG3 Electric/Heating Caterpillar 3508 23Z05884 800 Diesel 62.4 8.55 1994 Plant EG EG4 Moore Caterpillar 3406 17500605 350 Diesel 26.7 3.66 1998 EG5 Webster Rauner Caterpillar 3208 54F03765 200 Diesel 13.4 1.84 1998 EG6 Berry Library Caterpillar 3412 81Z24215 668 Diesel 44.5 6.10 1999 EG7 Wilder Caterpillar 3208 5YF03999 200 Diesel 14.8 2.03 1999 EG8 Boss Tennis Olympian T4.236 959838 50 Diesel 4.73 0.65 2000 EG9 Silsby Olympian 1004TG AB50498U0 75 Diesel 5.9 0.81 2000 722 EG10 Whittemore Onan 6CT.3-G2 45949769 125 Diesel 9.9 1.36 2000 EG11 37 Dewey Field Olympian D150P1 OL00000AT 150 Diesel 13.3 1.82 2001 Rd. 00175 EG12 Thompson Onan DKAF49565 C010217562 25 Diesel 1.7 0.23 2001 Arena 60 EG13 Cummings Onan DFCC- K05085585 350 Diesel 25.3 3.47 2006 5743187 Gen 8 Spec Z Set NTA855- G3 Engine EG21 Medical School Perkins 1006-6T YB70326- 135 USLD 7.68 1.052 1999 Fire Water U620506B Bhp Pump Page 56 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 APPENDIX C EU11 – EMERGENCY GENERATORS INSTALLED AFTER JANUARY 1, 1985 THAT ARE SUBJECT TO 40 CFR 60, SUBPART IIII Emission Description Manufacturer Model Serial # kW Fuel Firing Heat Date Unit ID & Location (Tier #) Rate Input Installed (gal/hr or (MMBtu/ cf/hr) hr) EG14 Fahey Olympian D80-P4 Gen OLY00000 80 ULS 6.3 0.86 2006 (Tier 2) Set 1104C- KD4P kW Diesel 44TAG1 Engine EG15 FlorenVarsity Caterpillar C15 Gen Set C5E00672 350 ULS 25.2 3.45 2006 ( Tier 3) kW Diesel EG16 Kemeny Onan DGCB- AO6087163 60 ULS 5 0.69 2006 (Tier 1) 5747344 Gen 3 Spec T kW Diesel Set 4BT3.9- G4 Engine EG17 McLaughlin Cummins 200DGFC- BO5075093 200 ULS 18.1 2.48 2006 Rauner (Tier 1) 5108 Gen Set 2 Spec F kW Diesel 6CTAA8.3- G3 Engine EG18 Tuck LLC Onan 200 DSHAC I070107946 200 ULS 17 2.33 2008 (Tier 3) Gen Set kW Diesel EG19 Vail-Remsen Kohler S6R-Y1PTA- 19269 600 ULS 63 8.63 2008 600REOZM 4 ekW Diesel (Tier 1) EG20 Life Sciences Caterpillar C27 Engine MJE01670 750 ULS 53.5 7.30 2011 Building (Tier 2) ekW Diesel (Model Year 2009) Page 57 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 APPENDIX D EU12 –BOILERS SUBJECT TO 40 CFR 63, SUBPART JJJJJJ Emission Location Description Fuel Type Heat Input per Unit (MMBtu/hr) Unit ID EG22 Vail Boiler ULSD 1.68 EG23 Remsen Boiler ULSD 1.68 APPENDIX E EU13 – LPG-FIRED EMERGENCY GENERATORS THAT ARE SUBJECT TO 40 CFR 60, SUBPART JJJJ Description Firing Emission kW Heat Input Date & Manufacturer Model Serial # Fuel Rate Unit ID (hp) (MMBtu/hr) Installed Location (ft3/hr) Hanover Inn 75 EG24 Cummins 75GGHF E120334856 LPG 415 1.04 2012 Kitchen (119.8) 100 EG25 Visual Arts Kohler 100REZG GXC00826 LPG 511 1.28 2012 (165) 80 EG26 53 Commons Olympian G80LG2 2332285 LPG 461 1.15 2012 (128) C25 N6 GG02- 25 EG27 Wheeler Onan H150861272 LPG 125.4 0.31 2016 1519014 (43.5) Page 58 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 APPENDIX F EU14 – LPG-FIRED EMERGENCY GENERATORS THAT ARE NOT SUBJECT TO 40 CFR 60, SUBPART JJJJ Description Firing Emission Heat Input Date & Manufacturer Model Serial # kW Fuel Rate Unit ID (MMBtu/hr) Installed Location (ft3/hr) EG28 Judge Onan 15JCL D910378387 15 LPG 82 0.14 Unknown EG29 Mass-Mid Onan 15JCL30634B I890268221 15 LPG 82 0.14 1985 EG30 Berry Gym Onan 15JCL J910431347 15 LPG 82 0.14 1988 EG31 Collis Caterpillar 3306 7404527 135 LPG 547 1.29 1992 EG32 Maxwell Onan 7.5JBFL30634D K900358543 7.5 LPG 41 0.07 1992 EG33 Rope Ferry Generac 92A02171-W 2003313 15 LPG 82 0.14 1992 EG34 Brown Onan 15JCL J920487464 15 LPG 82 0.14 1993 EG35 Byrne Onan 12.5JCG F90473495 12.5 LPG 68 0.12 1993 EG36 Sudikoff Olympian 93A02239-S 2008061 45 LPG 246 0.43 1993 Fayerweather EG37 Onan 15JCL C930501594 15 LPG 82 0.14 1994 -Mid EG38 Russell Sage Onan 15 JCB L940563972 15 LPG 82 0.14 1994 EG39 Robinson Olympian 95A04666-S 2023640 30 LPG 164 0.29 1996 EG40 Topliff Onan 15 JCL C920457588 15 LPG 82 0.14 1996 LSG-8751- 17815T-18- EG41 Gilman Onan 70 LPG 355 0.67 1999 6005A TT EG42 Lord Onan 15JCL30634B F890248502 15 LPG 82 0.14 1999 EG43 Zimmerman Generac 99A04233-S 2049728 45 LPG 246 0.43 1999 EG44 Woodward Olympian G15U1 F3827A/001 15 LPG 82 0.14 2000 EG45 Hitchcock Onan WSG1068 07W564990 85 LPG 422 1.05 2007 New EG46 Kohler 25RZGB 2227710 25 LPG 166 0.41 2009 Hampshire EU46: Documentation from Kohler shows New Hampshire generator was tested by the manufacturer on 10/17/08 (pre-40 CFR 60, Subpart JJJJ applicability date of 1/1/09). Page 59 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 INSIGNIFICANT ACTIVITIES APPENDIX G FURNACES/SMALL BOILERS NOT SUBJECT TO 40 CFR 60, SUBPART JJJJJJ Location Description Fuel Type Heat Input per Unit (MMBtu/hr) Lodge Hot water heater #2 Fuel Oil 0.32 24 East Wheelock Hot water heater #2 Fuel Oil 0.08 23 East Wheelock Hot water heater #2 Fuel Oil 0.12 13 East Wheelock Hot water heater #2 Fuel Oil 0.12 11 East Wheelock Hot water heater #2 Fuel Oil 0.08 10 West Wheelock Hot water heater #2 Fuel Oil 0.08 20 West Street Hot water heater #2 Fuel Oil 0.11 9 Webster Hot water heater #2 Fuel Oil 0.08 13 Webster Hot water heater #2 Fuel Oil 0.11 12 Rope Ferry Hot water heater #2 Fuel Oil 0.11 36 North Main Street Hot water heater #2 Fuel Oil 0.08 44 College Hot water heater #2 Fuel Oil 0.11 42 College Hot water heater #2 Fuel Oil 0.11 13 Choate Road Hot water heater #2 Fuel Oil 0.11 Hanover Country Club Hot water heater #2 Fuel Oil 0.08 Roth Center Indirect boiler #2 Fuel Oil 0.3 Burnham Soccer Hot water heaters Propane 1.0 Shattuck Observatory Boiler Propane 0.16 Rugby House Furnace Propane 0.35 Rugby House Hot water heater Propane 0.11 Grounds Building Boiler Propane 0.2 Grounds Building Furnaces Propane 0.05 37 Lafayette Furnace Propane 0.2 37 Lafayette Furnace Propane 0.1 APPENDIX H TANKS Location/Description Tank Age Tank Type Product Stored Capacity (gallons) Heating Plant (Tank HP-2) 2008 AST #2 Fuel Oil 350 37 Dewey Field Road/FO&M Maintenance Building 2008 AST Diesel 500 (Tank 1B) Dewey Field Road Grounds Maintenance Building (Tank 2002 AST Diesel 500 NH451027) Floren Varsity Auxiliary (Tank 2-Florian) 2007 AST Diesel 750 Floren Varsity (Tank 471100) 2007 AST Diesel 750 Scully Field (Tank 33047) 2008 AST Diesel 142 Vail (Tank 596) 2008 AST Diesel 160 Vail (Tank Vail 2) 2002 AST Diesel 250 Medical School 1989 UST Diesel 10,000 McLaughlin/Rauner (Tank 634731) 2006 AST Diesel 366 Kemeny (Tank 641125) 2006 AST Diesel 145 Berry Baker Library (Tank B/B Lib-1) 2000 AST Diesel 200 Page 60 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Location/Description Tank Age Tank Type Product Stored Capacity (gallons) Berry Baker Library (Tank B/B Lib-2) 2000 AST Diesel 60 Grounds (Tank Grounds-B) 1994 AST Diesel 500 Heating Plant Generator (Tank EM GEN BLD) 1995 AST Diesel 500 Moore building (Tank L10032) 1999 AST Diesel 560 Hopkins (Tank M198358) 1997 AST Diesel 135 Whittemore (Tank M901255) 2000 AST Diesel 340 Whittemore (Tank Whittemore) 2000 AST Diesel 60 Silsby (Tank M93096) 2000 AST Diesel 147 Webster Rauner (Tank MH5085 201) 1998 AST Diesel 300 Morton Farm (Tank Morton) 2001 AST Diesel 275 Burke Building (Tank N968287) 2004 AST Diesel 500 Cummings (Tank N969307) 2006 AST Diesel 265 Tuck LLC (Tank OST-1) 2008 AST Diesel 275 Tuck LLC (Tank OST-2) 2008 AST Diesel 100 Fahey (Tank P250592) 2006 AST Diesel 200 Thompson Arena 2011 AST Diesel 149 Oak Hill 2011 AST Diesel 275 Boss Tennis AST Diesel 50 Wilder AST Diesel 250 Heating Plant (Tank HP-2) 2008 AST #2 Fuel Oil 350 Small #2 Oil tanks supplying fuel to boilers/furnaces Varies Varies #2 Fuel Oil Varies listed in Appendix D & G 37 Dewey Field Road/FO&M Maintenance Building 2008 AST Gasoline 500 (Tank 1A) Grounds (Tank Grounds A) 1994 AST Gasoline 500 Boathouse (Tank Boathouse) 1998 AST Gasoline 500 Heating Plant (Tank HP-1) 1999 AST Kerosene 190 FO&M Yard (Tank 522878) 1999 AST Kerosene 180 FO&M Yard (Tank T-1) 2002 AST Mineral Oil 1,028 FO&M Yard (Tank T-2) 2002 AST Mineral Oil 1,028 Heating Plant Power House (Tank OMG8500) 1993 AST Boiler Fuel Additive 390 Page 61 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 APPENDIX I: Dartmouth College Compliance Sheet Table 4, Item #1 Annual Emission Limitations for the Installation of Boiler #3 in 1995: Boilers #1, #3, #4 combined Annual Emissions (tpy) for Criteria Pollutants CO NOx PM PM10 SO2 VOCs Limit 51.1 158.2 61.1 51.1 531.9 4.4 2016 7.41 68.75 17.33 14.00 214.52 0.64 2015 7.87 71.46 17.85 14.19 218.42 0.73 Table 4, Item #2 Annual Emission and Fuel Usage Limitations for the Installation of Boiler #2 in 2008: The annual SO2 emission limitation from Boilers #1 and #4 (EU01 & EU04) shall be limited to 378 tons per year during any consecutive 12-month period; and Boilers #1, #4 combined Annual Emissions (tpy) for Criteria Pollutants SO2 Limit 378 2016 196.45 2015 126.81 The annual fuel consumption for Boiler #2 (EU02) shall be limited such that NOx emissions do not exceed 39.8 tons during any consecutive 12-month period: Page 62 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 The following equation will be used to determine compliance: 39.8≥*(0.0435 * gal No. 6a) + (0.0465 * gal No. 6b) + (0.0585 * gal No. 6c) + (0.0168 * gal No. 2 fuel oil)]/2,000 Where: 6a is No. 6 fuel oil containing ≤0.34% fuel bond nitrogen (FBN); 6b is No. 6 fuel oil containing 0.34% The annual emissions of criteria pollutants from Boiler #2 (EU02) shall be limited as specified below during any consecutive 12-month period: Boiler #2 Annual Emissions (tpy) for Criteria Pollutants CO NOx TSP PM10 SO2 VOCs Limit 33.6 39.8 24.2 14.2 70.0 0.8 2016 1.37 11.88 2.13 1.84 21.44 0.08 2015 1.31 11.37 2.04 1.76 20.52 0.07 APPENDIX J Emergency Generator Hour Meter Data Hour Meter Hour Meter Reading – Reading – Unit ID # Location Difference 2015 evaluation 2017 evaluation (hours) (hours) EU05/EG1 Hopkins Generator has been removed. EU10/EG2 Burke 523.3 541.1 17.8 EU10/EG3 Heating Plant 151.7 210.9 59.2 EU10/EG4 Moore 492 555 63 EU10/EG5 Webster Rauner 431 491 60 EU10/EG6 Berry Library 438 510 72 EU10/EG7 Wilder 508 563 55 EU10/EG8 Boss Tennis 424.1 472.4 48.3 EU10/EG9 Silsby 438.5 492.6 54.1 EU10/EG10 Whittemore 468.1 526.1 58.0 EU10/EG11 37 Dewey Field Rd 339 419 80 EU10/EG12 Thompson Arena 338.7 410.7 72.0 EU10/EG13 Cummings 291.9 351.4 59.5 EU10/EG21 Medical School Fire 166.5 170.4 3.9 Page 63 of 64 Dartmouth College Inspection Date: April 6, 2017 On-Site Full Compliance Evaluation Report Date: May 2, 2017 Hour Meter Hour Meter Reading – Reading – Unit ID # Location Difference 2015 evaluation 2017 evaluation (hours) (hours) Water Pump EU11/EG14 Fahey 289 335 46 EU11/EG15 Floren Varsity 288.4 367.7 79.3 EU11/EG16 Kemeny 286.7 357.8 71.1 EU11/EG17 McLaughlin Rauner 292 347.7 55.7 EU11/EG18 Tuck LLC 183.1 234.7 51.6 EU11/EG19 Vail-Remsen 73.3 79.9 6.6 EU11/EG20 Life Sciences Bldg. 185.4 256.4 71.0 EU13/EG24 Hanover Inn Kitchen 97.0 166.3 69.3 EU13/EG25 Visual Arts 106.4 172.8 66.4 EU13/EG26 53 Commons 153.9 230.5 76.6 Wheeler (Installed in EU13/EG27 NA 41.5 41.5 2016) EU14/EG28 Judge 378.9 405.3 26.4 EU14/EG29 Mass-Mid 349.5 366.8 17.3 EU14/EG30 Berry Gym (Sports) 460.5 502.5 42.0 EU14/EG31 Collis (Center) 542 596 54 EU14/EG32 Maxwell 601.2 625.4 24.2 EU14/EG33 Rope Ferry 327.1 369.9 42.8 EU14/EG34 Brown 386.8 436.3 49.5 EU14/EG35 Byrne 555.4 590.1 34.7 EU14/EG36 Sudikoff 720.6 850.9 130.3 EU14/EG37 Fayerweather-Mid 398.9 441.7 42.8 EU14/EG38 Russell Sage 447.6 494.7 47.1 EU14/EG39 Robinson 310.1 331.5 21.4 EU14/EG40 Topliff 388.1 434.2 46.1 EU14/EG41 Gilman 463.3 472.6 9.3 EU14/EG42 Lord 507.3 547.6 40.3 EU14/EG43 Zimmermahn 379.3 456.6 77.3 EU14/EG44 Woodward 345.1 397.4 52.3 EU14/EG45 Hitchcock 261.9 332.7 70.8 EU14/EG46 New Hampshire 162.2 217.7 55.5 Page 64 of 64