Permit Application Review Summary
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New Hampshire Department of Environmental Services Air Resources Division PERMIT APPLICATION P.O. Box 95, 29 Hazen Drive REVIEW SUMMARY Concord, NH 03302-0095 Phone: 603-271-1370 Fax: 603-271-7053 Facility: Dartmouth College Engineer: Cathy Beahm Location: 6111 McKenzie Hall, Hanover, NH 03755-3552 AFS #: 3300900020 Application #: FY05-0028 Date: 01/02/13 Page 1 of 21 PROJECT DESCRIPTION Dartmouth College (Dartmouth) submitted this application (FY05-0028) for the renewal of the Title V permit TV-OP-022 which expired February 28, 2005. Since the application was received six months prior to the expiration date, application shield provisions apply. A completeness letter was sent May 11, 2005. Other applications have been submitted in the interim and have been completed (see Permit History below). The intent of this project is to incorporate all existing permits into one Title V permit for Dartmouth. CHANGES FROM PREVIOUS PERMIT • Remove references to old Boiler #2 (EU2) and pathological waste incinerator (Old Title V Permit TP-OP-022, Insignificant Activities – Appendix A); • Update Table 1 – Significant Activity Identification to accurately reflect those devices which should be listed there based on regulatory applicability; • Include requirements from TP-B-0511 for the removal of short-term steam limits on Boilers #1 – #4; • Include requirements from TP-B-0545 for the new Boiler #2; • Include requirements from TP-0037 for the emergency generators; • Include 40 CFR 60, Subpart JJJJ emergency generator requirements for gas-fired emergency generators and 40 CFR 63, Subpart ZZZZ language for applicable emergency generators; • Include 40 CFR 63, Subpart JJJJJJ boiler requirements; • Dartmouth has requested that the opacity limit for Boiler #4 be 20% instead of the regulatory requirement of 40% (Env-A 2002.01) in order to streamline the opacity language in their permit and because there is one continuous opacity monitor (COM) that is on the common stack for Boilers #1, #2, #3 and #4. This was included in past permits but needs to be clarified in this one. FACILITY DESCRIPTION Dartmouth is an educational institution located in Hanover, New Hampshire. The college campus is composed of educational facilities, including several academic buildings and residential units owned and operated by the college. In addition, the college 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 service station utilized by service vehicles on the Hanover campus. Emission sources at the college’s educational facilities include furnace/boiler units for building heating and hot water, several small and large capacity emergency generators for emergency lighting and running special heating, ventilation, and air conditioning (HVAC) units in libraries for historic record and book preservation, several small space heating units, several chillers, several small capacity fuel storage tanks, and several HVAC systems for each of the buildings. Dartmouth is a major source for Title V for nitrogen oxides (NOx), sulfur dioxide (SO 2) and greenhouse gasses (GHG). The facility is considered an existing major source of SO 2 under the federal Prevention of Significant Deterioration (PSD) program, as historical SO 2 emissions have been greater than the PSD major source threshold of 250 tons per year. The facility is considered an existing major source of NOx under the Nonattainment New Source Review (NSR) program, as historical NOx emissions have been greater than 100 tons per year. Potential GHG emissions are greater than 100,000 tons per year of carbon dioxide equivalents (CO 2e). The facility is an area source for hazardous air pollutants (HAPs). PERMIT APPLICATION REVIEW SUMMARY Facility: Dartmouth College Engineer: Cathy Beahm Location: 6111 McKenzie Hall, Hanover, NH 03755-3552 AFS #: 3300900020 Application #: FY05-0028 Date: 01/02/13 Page 2 of 21 PERMIT HISTORY Table 1 - Permitting History Permit # Application Description Issue Date Expiration # Date TV-OP-022 FY96-TV019 Initial Title V Operating Permit issued 02/07/2000 02/28/2005 Minor Amendments to Title V Operating Permit based on comments TV-OP-022 NA 05/23/2000 02/28/2005 in a letter from Dartmouth to DES. TV-OP-022 FY03-0024 Minor Amendments to Title V Operating Permit 10/21/2002 02/28/2005 TV-OP-022 FY05-0028 Renewal of Title V Operating Permit TBD TBD Temporary Permit for the Heating Plant to remove steam limitations on boilers based on the results of an updated air quality impacts TP-B-0511 FY05-0029 06/09/2006 12/31/2007 analysis that demonstrates compliance with the NAAQS; PSD/NSR avoidance caps put in place as a result. Temporary Permit for installation of Vail-Remsen (EG19 – Medical TP-B-0522 FY06-0036 08/23/2006 02/28/2008 School) emergency generator Installation of emergency generators at McLaughlin Rauner (EG17 – TP-0037 FY07-0067 McLaughlin), Cummings (EG13 – MacLean), Kemeny (EG16 – 12/02/2011 06/30/13 Kemeny-Haldemen), and Fahey (EG14 – Tuck Residence) buildings. Temporary Permit for #2 Replacement Boiler & Two Temporary Boilers - Installation of new Boiler #2, utilization of 2 temporary boilers for 180 days, and for PSD/NSR avoidance: limit the fuel TP-B-0545 FY07-0251 usage of the new Boiler #2; require the removal of the existing Boiler 07/01/2008 01/31/2010 #2; limit the fuel usage of existing Boilers #1 and #4; and reduce the sulfur content of the fuel being combusted in Boiler #1 and Boiler #4. Installation of emergency generators at Hitchcock (LPG engine) and Floren Varsity (EG15) buildings and a request to limit emergency TP-0037 FY07-0263 generators to 200 hours per year to limit NOx emissions to 25 TPY 12/02/2011 06/30/13 and to opt Dartmouth out of the requirements of NOx RACT for emergency generators. Additional information for installation of emergency generators at TP-0037 FY05-0028 Tuck LLC (EG18 – Achtmeyer-Tuck LLC) and New Hampshire 12/02/2011 06/30/13 (LPG engine – New Hampshire Residence) TP-B-0545 09-0265 Permit TP-B-0545 reissuance. 01/08/10 01/31/11 TP-0037 Installation of emergency generator at Life Science Building (EG20) 12/02/2011 06/30/13 10-0195 AND modification to TP-B-0545 for Boiler #2 sulfur content for #2 TP-B-0545 fuel oil. 01/31/11 01/31/11 Amendment to TP-0037 to include LPG emergency generators and TP-0037 12-0192 12/21/12 06/30/13 make minor corrections to prepare for Title V permit issuance. PERMIT APPLICATION REVIEW SUMMARY Facility: Dartmouth College Engineer: Cathy Beahm Location: 6111 McKenzie Hall, Hanover, NH 03755-3552 AFS #: 3300900020 Application #: FY05-0028 Date: 01/02/13 Page 3 of 21 PROCESS/DEVICE DESCRIPTION Table 2 - Significant Activities Manufacturer Date Construction Emission Maximum Design Capacity and Device Identification Model Number Commenced/ Unit ID Fuel Type(s) Serial Number Start-Up Date EU01 Boiler #1 Zurn Industries 1986 1 112.2 MMBtu/hr 12196 sq ft MultiPass #6 fuel oil – equivalent to 748 gal/hr 100978 1.0% sulfur EU02 Boiler #2 Babcock & Wilson 2008/2009 97.5 MMBtu/hr (FM103-79) #6 fuel oil – equivalent to 650 gal/hr #201-3530 0.5% sulfur 99.97 MMBtu/hr #2 fuel oil – equivalent to 714 gal/hr 0.40% sulfur EU03 Boiler #3 Nebraska Boiler Co. 1995/1996 95.5 MMBtu/hr NS-E-65SH #6 fuel oil – equivalent to 637 gal/hr D-3461/E-3462 0.5% sulfur EU04 Boiler #4 Combustion 1967 97.3 MMBtu/hr Engineering #6 fuel oil – equivalent to 649 gal/hr VP-12W; 20628 1.0% sulfur EU05 Diesel-fired Emergency See Appendix A 1961 Diesel-fired Generators Installed on or See Appendix A prior to May 13, 1970 EU08 Gasoline Service Station NA 1991 10,000 gallons gasoline storage tank including the Gasoline Dispensing Facility and the Gasoline Storage Tank EU10 Diesel-fired Emergency See Appendix B After January 1, 1985 Diesel-fired Generators Installed after See Appendix B January 1, 1985 that are not subject to 40 CFR 60, Subpart IIII 2 1 Construction of Boiler #1 commenced on July 31, 1985. 2 January 1, 1985 was the date set in this table because Env-A 2000 particulate matter standards change after that date. 40 CFR 60, Subparts IIII and JJJJ have their own set of applicability dates for regulatory requirements. PERMIT APPLICATION REVIEW SUMMARY Facility: Dartmouth College Engineer: Cathy Beahm Location: 6111 McKenzie Hall, Hanover, NH 03755-3552 AFS #: 3300900020 Application #: FY05-0028 Date: 01/02/13 Page 4 of 21 Table 2 - Significant Activities Manufacturer Date Construction Emission Maximum Design Capacity and Device Identification Model Number Commenced/ Unit ID Fuel Type(s) Serial Number Start-Up Date EU11 Diesel-fired Emergency See Appendix C Manufactured after Diesel-fired Generators Installed after April 1, 2006 3 See Appendix C January 1, 1985 that are subject to 40 CFR 60, Subpart IIII EU12 Boilers subject to 40 CFR See Appendix D for Prior to June 4, 2010 4 #2 fuel oil 60, Subpart JJJJJJ boiler locations See Appendix D EU13 LPG-fired Emergency See Appendix E Manufactured after LPG-fired Generators Installed after January 1, 2009 5 See Appendix E January 1, 1985 that are subject to 40 CFR 60, Subpart JJJJ EU14 LPG-fired Emergency See Appendix F Manufactured prior to LPG-fired Generators Installed after January 1, 2009 See Appendix F January 1, 1985 that are not subject to 40 CFR 60, Subpart JJJJ The list of emergency generators contained in Appendix B, Attachment 2 of TP-OP-022 has been replaced with Appendices A, B, C, E and F of the new Title V permit.