Permit Application Review Summary

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. The LPG engine at Cummings Hall was replaced with EG13 in 2006. The Gerry Pent. LPG engine was removed. The mobile generator is still located at Dartmouth but is considered a non-road engine which is exempt from stationary source permitting. The Thompson engine (6.5 kW LP unit) has been replaced. A complete description of the emergency generators and their history is contained in the Application Review Summary for permit TP-0037 issued December 2, 2011 and amended concurrent to this permitting project in 2012. An inventory of the furnaces and small boilers located throughout campus (excluding EU01-EU04 in the central Heating Plant) was submitted by Dartmouth on June 12, 2012. None of these devices are greater than the Env-A 607.01(a) permitting applicability thresholds. However, the small boilers which meet the applicability of 40 CFR 63, Subpart JJJJJJ, National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources , are considered significant activities and are listed as EU12 in the Title V permit. The list of insignificant furnaces and small boilers contained in Appendix A, Attachment 1 of TP-OP-022 has been replaced with Appendix D for those that are now considered significant activities subject to NSPS Subpart JJJJJJ. The gasoline service station consists of the gasoline dispensing facility and the gasoline storage tank located at the Oil Facility, Central Stores. The gasoline dispensing facility was listed as a significant activity in the previous Title V permit because it was regulated by Env-A 1205. Since the issuance of the previous Title V permit in 2000, the regulations have changed and are now located in the Waste Management regulations Env-Wm 1404 Volatile Organic Compounds (VOCs): Gasoline Dispensing Facilities, Bulk Gasoline Plants, and Cargo Trucks and are no longer included in Title V permits. Emissions from the gasoline dispensing facility which includes splash filling the underground tank, the underground tank breathing and emptying, the vehicle refueling operations and spillage are calculated using tank throughput and emission factors from United States Environmental Protection Agency (USEPA) AP-42 (6/2008), Section 5.2 Transportation and

3 Applicability date in 40 CFR 60, Subpart IIII. 4 Units that commenced construction or reconstruction prior to June 4, 2010 are considered existing units under 40 CFR 63, Subpart JJJJJJ. 5 Applicability date in 40 CFR 60, Subpart JJJJ. 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 5 of 21

Marketing of Petroleum Liquids . Actual throughput in 2010 from Central Stores was 63,496 gallons per year at an estimated 182.5 hours per year (0.5 hours per day; 365 days per year) which resulted in actual VOC emissions of 1,270 lbs per year which is greater than 1,000 lbs per year of all regulated air pollutants in aggregate thereby making this device a significant activity included in Table 2, above. LIST OF INSIGNIFICANT ACTIVITIES Table 3 - Insignificant Activities Manufacturer Date Construction Maximum Design Emission Unit ID Device Identification Model Number Commenced/ Capacity and Fuel Serial Number Start-Up Date Type(s) Previously EU06 Tank #1 NA 1991 125,000 gallons #6 fuel oil (AST) Previously EU07 Tank #2 NA 1991 125,000 gallons #6 fuel oil (AST) Previously EU09 Water Chillers A. Psychology A. Trane electric A. 1998 A. 80 ton using R-22 Building Backup chiller CCAD060 (Class II Water Chiller refrigerant) B. Water Chiller Plant B. York electric chiller B. 1997 B. 650 ton using R- 134A (Class I refrigerant substitute) C. Webster Hall C. McQuay electric C. 1998 C. Uses R-22 (Class II Backup Water chiller refrigerant) Chiller D. Gilman Building D. Carrier electric D. 1998 D. 75 ton using R-22 Backup Water chiller (Class II Chiller refrigerant)

NA (listed in Appendix Furnaces/Small Boilers See Appendix G See Appendix G See Appendix G A, Attachment 1 of old that are not subject to 40 TV-OP-022) CFR 60, Subpart JJJJJJ NA (listed in Appendix Fuel Storage Tanks See Appendix H See Appendix H See Appendix H A, Attachment 1 of old TV-OP-022) 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 6 of 21

Tanks #1 and #2 which are used to store #6 fuel oil do not have actual emissions of VOCs greater than or equal to 10 tpy and therefore do not meet the applicability of Env-A 607.01(g). They also don’t meet the applicability of Env-A 607.01(h) due to the vapor pressure of #6 fuel oil. Tanks #1 and #2 were considered significant activities in the previous Title V permit TV-OP-022 because it was determined at the time of permit issuance that 40 CFR 60, Subpart Kb was applicable to them which resulted in these devices being listed in the Significant Activity Identification table. Upon further analysis, Subpart Kb does not apply to storage vessels with a capacity greater than or equal to 151 m 3 (39,890 US gal) storing a liquid with a maximum true vapor pressure less than 3.5 kPa (0.5 psia). Tanks #1 and #2 are each 125,000 gallon tanks which store #6 fuel oil but the true vapor pressure is less than 0.1 psia at 70°F. In addition, actual emissions from the tanks in 2010 were 4.25x10 -04 lb/yr combined (calculated from TANKS 4.0 using actual throughput in gallons per year) which is less than the applicability level in Env-A 609.04 of 1,000 lbs per year of all regulated air pollutants in aggregate. Therefore, Tanks #1 and #2 are insignificant devices and will be categorized as such in the proposed permit. In addition, on June 12, 2012 Dartmouth submitted a complete list of diesel, #2 fuel oil, gasoline, kerosene, mineral oil and boiler fuel additive tanks located at Dartmouth. None of these tanks meet the permitting requirements of Env-A 607.01(g) or (h) and all of them have emissions less than 1,000 lbs per year of all regulated air pollutants in aggregate. Therefore, they are all considered insignificant activities and are listed in Appendix H of the application review summary. There are four chillers subject to 40 CFR Part 82 using Class I and Class II refrigerants located at Dartmouth: Water Chiller Plant (York Electric Chiller), Webster Hall Backup Water Chiller (McQuay), Psychology Building Backup Water Chiller (Trane), and Gilman Building Backup Water Chiller (Carrier). There are no actual emissions from the chillers provided when the Owner or Operator performs maintenance on, or services, repairs, or disposes of appliances containing regulated ozone depleting substances, the Owner or Operator complies with the standards for Recycling and Emissions Reduction pursuant to 40 CFR 82, Subpart F. In addition, they are not subject to any of the permitting requirements of Env-A 607.01. Therefore, the chillers are insignificant devices and will be categorized as such in the proposed permit. The list of insignificant furnaces and small boilers contained in Appendix A, Attachment 1 of TP-OP-022 has been replaced with Appendix G of the application review summary for those that are still considered insignificant activities not subject to NSPS Subpart JJJJJJ. Dartmouth has disconnected the supplemental fuel line, removed the door from its latches, and placed lockout tag on the startup switch for the pathological waste incinerator (previously listed as an insignificant activity under Appendix A, Attachment 1 of TP-OP-022). Since the device has been effectively dismantled and deemed inoperable, it has been removed from this Title V permit. All insignificant activities must be included in the annual emissions report for the quantification of emissions and for the payment of emission-based fees. POLLUTION CONTROL EQUIPMENT Dartmouth does not operate any add-on pollution control equipment on the boilers. They have low NOx burners on all four boilers. In addition, only one of the emergency generators located at Dartmouth operates with add-on pollution control equipment. The new Life Sciences Building Caterpillar engine (EG20) is an EPA certified Tier 2 engine that is equipped with a Steuler Selective Catalytic Reduction (SCR) for NOx control. Dartmouth was not required under any regulation, to date, to install the SCR. Instead, Dartmouth chose to install the add-on controls in order to minimize NOx emissions as part of their voluntary efforts to stay below the 25 tpy applicability threshold for NOx RACT (Env-A 1301.02(j)), including a reduction in the allowable hours of operation of the emergency generators as they install more of these devices to support new campus buildings. At this time, Dartmouth has chosen to not take credit for the installation of the SCR for PTE or actual emission calculations and therefore, no monitoring or stack testing requirements will be included in the permit. The SCR is projected to have an ammonia slip of less than 5 ppm. Dartmouth demonstrated compliance with the Regulated Toxic Pollutants requirements of Env-A 1400 by using calculations to show de minimis amounts of ammonia emissions emitted based on Table 1450-1 at the time of issuance of TP-0037. 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 7 of 21

EMISSION CAPS There are multiple emission caps contained in various Dartmouth permits. The following is a description of the cap, its origin and the devices upon which the emission cap pertains: Boiler #3 NSR Avoidance Cap: Condition VIII.B. Table 4, Item 6 of the previous TV-OP-022 limits Boilers #1, #2 (old), #3, #4 plus all emergency generators located at Dartmouth at the time of the Title V permit issuance to 175.0 tons of actual NOx emissions during any consecutive 365 day period for purposes of NSR/PSD avoidance, which was the result of the construction of the new Boiler #3 conducted in 1996. Upon further review, the Temporary Permit issued to Dartmouth for the installation of the new Boiler #3 (TP-B-387) specifically listed the following devices which are subject to the 175.0 tpy NOx limit: a. Boiler #1 (EU01); b. Boiler #2 (old EU2 which has been removed); c. New Boiler #3 (EU03); d. Boiler #4 (EU04); e. Onan/Cummings 300 kW emergency diesel generator (EG2 listed in Appendix B under the listing of emergency generators attributed to EU10 in TP-0037); f. Allis Chalmer 200 kW emergency diesel generator (which has been removed); g. Cummings 230 kW emergency diesel generator (which was the old Medical School emergency generator that was replaced with EG19 Vail-Remsen which is listed in Appendix C under the listing of emergency generators attributed to EU11); and h. Caterpillar Model 3508 emergency diesel generator covered by TP-B-332 which is EG3 listed in Appendix B under the listing of emergency generators attributed to EU10 in TP-0037 and is located at the Electric/Heating Plant. Therefore, this emission cap should only be applicable to the following devices that are still located at Dartmouth: EU01, EU03, EU04, EG2 (EU10), and EG3 (EU11). In addition to this cap, Condition V. Table 3, Item 12 of TP-B-0545 limits Boilers #1 (EU01), #3 (EU03) and #4 (EU04) to 158.2 tons of NOx per year on a 12-month rolling average. This limit was established in TP-B-0511 in 2006 as part of a PSD avoidance calculation when the Boiler #1 - #4 short-term steam limits were removed. In addition, Condition V. Table 3, Item 1 of Temporary Permit TP-0037 limits emergency generators listed in Appendices A, B and C of TP-0037 to 200 hours during any consecutive 12-month period. This 200 hour per year limit restricts potential NOx emissions from EG2 and EG3 to 3.65 tons of NOx per 12-month rolling average. Therefore, combined NOx emissions from EU01, EU03, EU04, EG2 (EU10), and EG3 (EU11) are limited to 161.9 tons of NOx during any consecutive 12-month period. As a result, the 175.0 tpy NOx cap can be removed from Dartmouth’s Title V permit because the other two conditions which will be incorporated in the new Title V permit result in a more restrictive NOx cap for the devices listed above. The calculations for this limit are shown below using AP-42 Section 2.4 Large Stationary Diesel Engines (10/96) emission factor for NOx and 137,000 BTU/gal of diesel fuel: EG2 has a maximum fuel firing rate of 20.8 gallons/hr. EG3 has a maximum fuel firing rate of 62.4 gallons/hr. (20.8 + 62.4) gal/hr * 200 hr/yr * 3.2 lb NOx/MMBtu * 0.137 MMBtu/gal / 2000 lb/ton = 3.65 tpy NOx from EG2 & EG3 EU01, EU03 & EU04 NOx emission limit = 158.2 tpy 158.2 + 3.65 = 161.85 tpy NOx limit < 175.0 tpy NOx limit Boiler #2 PSD/NSR Avoidance Caps: TP-B-0545 issued in 2008 was for the installation of the new Boiler #2. The emission units identified in TP-B-0545 included Boiler #1 (EU1), new Boiler #2 (EU02), Boiler #3 (EU3), Boiler #4 (EU4) and two temporary boilers (EUA and EUB). The temporary boilers were removed from the facility in October, 2008. This permitting exercise included several emission caps as well as fuel switching and the shutdown of the old Boiler #2 for PSD/NSR avoidance. Boiler #1 (EU01) 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 8 of 21

and Boiler #4 (EU04) were limited to an emission cap of 378 tons of SO 2 and required to reduce the sulfur content of #6 fuel oil burned in the boilers from 1.5% to 1%. In addition, the emission caps established in TP-B-0511 as described above, were clarified to be applicable to Boiler #1 (EU1), Boiler #3 (EU3) and Boiler #4 (EU4) since the old Boiler #2 was removed during the new Boiler #2 installation. The caps are listed in Table 4 below: Table 4 – Boiler #2 PSD/NSR Avoidance Caps Annual (Consecutive 12-month period) Emission Limitations (tpy) for Criteria Pollutants Device CO NOx PM PM 10 SO 2 VOCs New Boiler #2 (EU02) 33.6 39.8 24.2 14.2 70.0 0.8 Boilers #1, #3 & #4 Combined (EU01, EU03 & EU04) 51.1 158.2 61.1 51.1 531.9 4.4 Boilers #1 & #4 (EU01 & EU04) 378 NOx RACT Avoidance Cap for Emergency Generators: Dartmouth has remained exempt from the requirements of Env-A 1311 for the emergency generators since the implementation of NOx RACT in 1995. In the most recent permit (TP-0037), Dartmouth has taken a 200 hours per any consecutive 12-month period to keep all emergency generators located at Dartmouth (listed in Appendices A, B, C, E and F) to less than 25 tpy of NOx. Appendix I (attached) shows the potential emissions from all the emergency generators currently located at Dartmouth based on the 200 hours per 12-month period operating limit. MODELING An air dispersion modeling analysis was last conducted for the Dartmouth heating plant in 2008 when the facility replaced Boiler #2. The results of the modeling showed compliance for all four boilers at 100% load under the permitted conditions and can be found in a memo dated January 11, 2008. CONTINUOUS EMISSIONS MONITORING (CEM/COMS) AND EMISSION TESTING REQUIREMENTS The following table illustrates the required emission testing and CEM systems required to be conducted or installed at Dartmouth along with the corresponding regulatory requirement: Table 5 – Emission Test and CEM System Requirements Device CEMS/Emission Regulatory Requirement Frequency Regulatory Cite Test Boiler #1 NOx CEMS The owner or operator of an affected facility subject to a Continuous 40 CFR 60 Subpart NOx standard under §60.44b shall install, calibrate, Db §60.48b(b)(1) maintain and operate CEMS for measuring NOx and O 2 emissions discharged to the atmosphere, and shall record the output of the system. Boilers NOx Stack Test Owners and operators of all sources subject to Env-A 1300 Initially and Env-A 802 & 803 #2, #3 & shall conduct an initial and periodic compliance stack test every 3 years #4 in accordance with Env-A 802 to demonstrate compliance with the applicable NOx RACT emission standards and control options specified in Env-A 1300. 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. Boilers Compliance The owner or operator subject to the opacity standards Initially and as 40 CFR 60 Subpart #2 & #3 Testing for under §60.43c shall conduct an initial performance test as requested by Dc §60.45c(a)(8) Opacity required under §60.8, and shall conduct subsequent the performance tests as requested by the Administrator, to Administrator determine compliance with the standards using Method 9 of Appendix A-4 of 40 CFR 60. 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 9 of 21

Table 5 – Emission Test and CEM System Requirements Device CEMS/Emission Regulatory Requirement Frequency Regulatory Cite Test Boilers Opacity COMS The owner or operator of an affected facility combusting Continuous 40 CFR 60 Subpart #2 & #3 oil that is subject to the opacity standards under §60.43c Dc §60.47c(a) shall install, calibrate, maintain, and operate a continuous opacity monitoring system (COMS) for measuring the opacity of the emissions discharged to the atmosphere and record the output of the system.

Boilers An owner or operator of an affected facility subject to an opacity standard may submit, for 40 CFR 60, Subpart #2 & #3 compliance purposes, continuous opacity monitoring system (COMS) data results produced during A – General any performance test required under §60.8 in lieu of Method 9 observation data. If an owner or Provisions 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 Administrator, in writing, to the contrary. 6

Boilers SO 2 CEMS The Owner or Operator of an affected facility subject to the For every #6 fuel oil 40 CFR 60 Subpart #2 & #3 SO 2 emission limits under §60.42c (EU02 & EU03) shall: delivery combusted Dc §60.46c(a), a. Install, calibrate, maintain, and operate a CEMS for in Boiler #2 & #3 (d)(1) & (d)(2) measuring SO 2 concentrations and either O 2 or CO 2 concentrations at the outlet of the steam generating unit, and shall record the output of the system; or Determine the average SO2 emission rate by sampling the fuel prior to combustion and using Method 6B of 40 CFR 60, Appendix A. Dartmouth is currently complying with this requirement by conducting the oil sampling as described in 40 CFR 60.46c(d)(2) and as described in Condition VI. Table 4, Item 4 of TP-B-0545. Dartmouth conducted a RATA for Boiler #1’s NOx CEM and COM on February 7, 2012. The results indicated that the Rosemount O 2 and the Thermo Environmental NOx analyzer were operating within their required accuracy criteria both on an individual and system basis. The opacity monitor was also found to be in conformance with the opacity drift test limit contained in PS 1, 40 CFR 60, Appendix B. For calendar year 2011, Dartmouth reported seven (7) opacity deviations: Boiler #1 (2/1/11 and two on 3/28/11), Boiler #2 (11/3/11), Boiler #4 (4/20/11, 7/26/11 and 12/16/11). The opacity COM satisfies the Dc requirements for Boilers #2 and #3. Dartmouth is required by TV-OP-022 and TP-B-0545 to do stack testing for Boilers #2, #3 and #4 every three years to verify compliance with the NOx limits in the Title V permit. The following table shows the most recent stack test for each of the boilers and the results:

6 Dartmouth requested in their pre-test protocol to use COMS data during the October 13 – 15, 2009 stack test thus satisfying this requirement in 40 CFR 60, Subpart A. Therefore, Condition VI. Table 4, Item 2 of TP-B-0545 will be clarified in the new Title V permit to apply only if the owner or operator notifies the Administrator, in writing, that they are no longer electing to submit COMS data for compliance with the opacity standard in lieu of Method 9 observation data. 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 10 of 21

Table 6 – Most Recent NOx Stack Test Results Date of Most Fuel Bound Emission Level Average Fuel Boiler Recent Stack Emission Limit Nitrogen (FBN) (Average of 3 Opacity Type Test Content (wt%) test runs) Reading (%) 0.29 lb/MMBtu ( ≤0.34% FBN) February 8, #6 oil 0.31 lb/MMBtu ( ≤0.39% FBN) 0.29 wt% 0.228 lb/MMBtu 6.8 2012 #2 0.39 lb/MMBtu ( ≤0.60% FBN) October 13 – #2 oil 0.12 lb/MMBtu 0.04 wt% 0.073 lb/MMBtu 1.2 15, 2009 0.29 lb/MMBtu ( ≤0.39% FBN) #3 02/08/12 #6 oil 0.29 wt% 0.246 lb/MMBtu 8.5 0.39 lb/MMBtu ( ≤0.60% FBN) 0.31 lb/MMBtu ( ≤0.39% FBN) #4 02/22/11 #6 oil 0.46% 0.326 lb/MMBtu 12 0.39 lb/MMBtu ( ≤0.60% FBN)

Dartmouth conducts sampling of each #6 fuel oil delivery in order to comply with 40 CFR 60, Subpart Dc (60.46c(a), (d)(1) & (d)(2). This requirement was not included in previous permits for Boiler #3 (EU03) but was applicable. Therefore, the Title V permit will include both EU02 and EU03 as applicable emission units for this requirement. In the Quarterly Excess Emission and Fuel Usage Report, Dartmouth submits daily and 30 day (monthly) average sulfur and nitrogen content (weight %) in the fuel. In the Semi-Annual Permit Deviation and Monitoring Report, Dartmouth submits a representative certificate of analysis and bill of lading from the analysis and the delivery of the fuel. They keep the remaining records on site for review and inspection. COMPLIANCE STATUS Emission Testing Dartmouth will continue to be required to do stack testing every 3 years for NOx RACT as well as an annual RATA for Boiler #1’s NOx CEM and COM per the existing Title V permit requirements. Inspections DES last conducted an on-site inspection of Dartmouth on June 22, 2011. Issues related to the permitting of emergency generators and incorrect reporting of the gasoline throughput of the Gasoline Distribution Facility in the 2010 annual emission report were noted and corrected. A permit for the emergency generators (TP-0037) was issued December 2, 2011. Reports The following table lists the reports that Dartmouth is required to submit to DES and the date the last report was submitted. Table 7 – Reporting Requirements in Existing Permits TV-OP-022 Permit Condition Type of Report Due Date Date Received by DES Condition VIII. F. Table 7, Item 1 of TV- VOC Report (Env-A 901.07(b)) Required in Title V permit when actual OP-022 emissions exceed 10 tpy but Dartmouth has not submitted one since actual emissions have been less than 10 tpy since 1994 when inventories were first tracked. Condition VIII. F. Table 7, Item 2 of TV- NOx Emission Statements Report April 15, 2012 April 13, 2012 OP-022 and Condition VIII. Table 6, Item 2 of TP-B-0545 Condition VIII. F. Table 7, Item 3 of TV- Quarterly CEM Excess Emissions 1st Quarter 2012 – April 30, 2012 OP-022 and Condition IX. Table 6, Items 5 Report (Boiler #1) April 30, 2012 & 8 of TP-B-0511 Condition VIII. F. Table 7, Item 4 of TV- Quarterly NOx Emissions Report 1st Quarter 2012 – April 30, 2012 PO-022 (Boiler #1) April 30, 2012 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 11 of 21

Table 7 – Reporting Requirements in Existing Permits TV-OP-022 Permit Condition Type of Report Due Date Date Received by DES Condition VIII. F. Table 7, Item 5 of TV- Quarterly Opacity Excess Emissions 1st Quarter 2012 – April 30, 2012 OP-022 and Condition IX. Table 6, Item 6 Report (Boiler #3 and new #2) April 30, 2012 of TP-B-0511 and Condition VIII. Table 6, Item 6 of TP-B-0545 Condition VIII. F. Table 7, Item 6 of TV- Quarterly Fuel Oil Sulfur Content January 31 st and January 26, 2012 OP-022 superseded by Condition IX. Table (Boiler #3) – Changed to semiannually July 31 st each year 6, Item 7 of TP-B-0511 in TP-B-0511 but Dartmouth continues to submit this information quarterly. Condition VIII. F. Table 7, Item 7 of TV- NOx RACT Stack Testing Results 60 days after March 14, 2012 OP-022 superseded by Condition IX. Table completion of 6, Item 2 of TP-B-0511 stack testing Condition VIII. F. Table 7, Item 8 of TV- Annual Fuel Usage Report April 15 for Dartmouth is submitting OP-022 previous year these quarterly instead of annually – 1 st Quarter 2012 – April 30, 2012 Condition VIII. F. Table 7, Item 9 of TV- Individual Permit Deviation Report Within 24-hrs of Last one submitted OP-022 an occurrence 12/16/11 for opacity issue on Boiler #4 Condition VIII. F. Table 7, Item 10 of TV- Semi-Annual Permit Deviation and January 31 st and January 26, 2012 OP-022 Monitoring Report July 31 st each year Condition VIII. F. Table 7, Item 12 of TV- Annual Emission Report and Emission April 15, 2012 April 13, 2012 OP-022 superseded by Condition IX. Table Based Fees 6, Item 4 of TP-B-0511 and Condition VIII. Table 6, Item 1 of TP-B-0545 Condition VIII. F. Table 7, Item 13 of TV- Annual Compliance Certification April 15, 2012 April 13, 2012 OP-022

Condition VIII. Table 6, Item 3 of TP-B- NSPS Construction and Startup Initial startup: Notification: 0545 Notifications (Boiler #2) July 30, 2009 August 24, 2009 Condition VIII. Table 6, Item 5 of TP-B- NSPS Fuel Reports for Small Steam January 31 st and January 26, 2012 0545 Generating Units (Boiler #2) July 31 st each year Fees Dartmouth submitted their emission based fees for 2011 on April 13, 2012. REVIEW OF REGULATIONS State Regulations The currently adopted state rule is cited with the SIP approved rule citation in parenthesis under each individual rule heading. The rule citation that is used in the permit as the regulatory basis is either the SIP approved rule, or a newer rule that is as stringent or is more stringent than the SIP approved rule or has becoming Federally Enforceable through the listed Temporary Permit. 7 Env-A 100 – Organizational Rules • 101.671 Definition of emergency generator – Applicable (formerly Env-A 101.661 & TP-0037)

7 Based on the EPA document “White Paper Number 2 for Improved Implementation of the Part 70 Operating Permits Program”, March 5, 1996 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 12 of 21

Env-A 400 – Acid Deposition Control Program – Applicable (effective 12-24-1990 (SIP approved 08-14-92))

• 403.01 (Class B Major Source) – Regulation limits the facility to 1.6 lbs/MMBtu of SO 2 which is equivalent to #6 oil with 1.5 wt% sulfur. Dartmouth’s Temporary Permit TP-B-0545 limits the sulfur to 1.0 wt% in Boilers #1 and #4 and 0.5 wt% in Boilers #2 and #3 for PSD avoidance as well as 40 CFR 60, Subpart Dc compliance. Therefore, more restrictive limits are already included in the Temporary Permit and will be carried over into the renewed Title V permit. Env-A 500 – Standards Applicable to Certain New or Modified Facilities and Sources of Hazardous Air Pollutants • 503.01(d) – Applicable to Boiler #1 [40 CFR 60, Subpart Db] [See Federal Regulations below] • 503.01(e) – Applicable to Boilers #2 and #3 [40 CFR 60, Subpart Dc] – Not Applicable to Boiler #4 because it was manufactured in 1967 which is before the applicability date for Subpart Dc (June 9, 1989) • 503.01(aw) – Applicable to diesel-fired internal combustion engines listed in EU11 [40 CFR 60, Subpart IIII] • 503.01(ax) – Applicable to 3 new gas-fired internal combustion engines listed in EU13 [40 CFR 60, Subpart JJJJ] • 505.01(cb) → Applicable to EU11 & EU13 – A stationary RICE located at an area source of HAP emissions is new if you commenced construction of the stationary RICE on or after June 12, 2006 pursuant to §63.6590(a)(2)(iii). A new or reconstructed stationary RICE located at an area source must meet the requirements of 40 CFR 63, Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart IIII, for compression ignition engines or 40 CFR 60, Subpart JJJJ, for spark ignition engines. No further requirements apply for such engines under 40 CFR 63, Subpart ZZZZ. → Applicable to EU05, EU10 & EU14 – Existing institutional emergency stationary RICE located at an area source of HAP emissions are exempt from 40 CFR 63, Subpart ZZZZ pursuant to §63.6590(b)(3) provided they meet the definition of an emergency generator pursuant to 40 CFR 63.6640(f). Env-A 600 – Permitting (effective 12-21-10 (SIP approved 02-06-2012)) • 606 – NOT Applicable – No new or modified devices; therefore, no modeling required. • 607.01(a) – Applicable – Boiler #2 has a design rating greater than or equal to 10 MMBtu/hr and burns #2 fuel oil (EU02). • 607.01(c) – Applicable – Boilers #1, #2, #3 and #4 each have design ratings greater than or equal to 2 MMBtu/hr and burn #6 fuel oil (EU01 – EU04). • 607.01(d)(1) – Applicable – The internal combustion engines which combust liquid fuel oil and have a gross heat input greater than 150,000 BTUs per hour individually have combined total design gross heat input greater than 1,500,000 BTUs per hour (EU05, EU10 & EU11). • 607.01(d)(2) – NOT Applicable – None of the internal combustion engines which combust liquid propane gas have a gross heat input greater than 1,500,000 BTUs per hour individually nor do they have a combined total design gross heat input greater than 10,000,000 BTUs per hour. • 607.01(g) – NOT Applicable – See List of Insignificant Activities section above. • 607.01(h) – NOT Applicable – See List of Insignificant Activities section above. • 607.01 (n) – Applicable – Dartmouth has taken various emission limitations (see Emission Caps above). As a result of the installation of the new Boiler #2, Dartmouth has a permit limit for fuel usage in Boiler #2 which is found in Condition V. Table 3, Item 10 of TP-B-0545. In addition, the facility is limited in Condition V. Table 3, Item 1 of TP-0037 to 200 hours per year of operation of the internal combustion engines to limit their potential to emit of NOx. • 607.01(t) – NOT applicable – See Pollution Control Equipment section above. • 607.01(v) – Applicable – NOx RACT

• 609.01(a)(1) – Applicable – Dartmouth is a major source for SO 2, NOx and GHG and is therefore required to obtain a Title V Operating Permit. • 609.04 – Applicable – See List of Insignificant Activities above. 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 13 of 21

• 618 – Additional Requirements in Non-Attainment Areas and the NH Portion of the Northeast Ozone Transport Region – Applicable to the installation of Boiler #3 in 1996 and Boiler #2 in 2008 – Dartmouth took limits to avoid NSR review. • 619 – Prevention of Significant Deterioration (PSD) of Air Quality Permit Requirements – Applicable to the installation of Boiler #2 in 2008 – Dartmouth took limits to avoid PSD review. Not applicable to the installation of Boiler #3 in 1996 pursuant to Section 169(I) of the CAA and 40 CFR 52.21. Env-A 700 – Permit Fee System – Applicable (effective 12-24-1990 (SIP approved 08-14-1992)) Env-A 800 – Testing and Monitoring Procedures – Applicable (effective 08-21-1995 (SIP approved 03-21-1998)) • 802 – Applicable – stack testing requirements (Env-A 802 effective 10-31-2010 is more stringent) • 803 – Applicable – NOx stack testing (effective 10-31-2010; SIP approved rule does not have NOx stack testing requirements) • 806.02 & 806.05 (404.01) – Applicable – sulfur content testing and recordkeeping of liquid fuels (806.02 & 806.05 are more stringent) • 806.03 & 806.05 (404.01) – Applicable – sulfur content testing and recordkeeping of gaseous fuels (806.03 & 806.05 are more stringent) • 806.05 – Applicable to all fuel burning devices at Dartmouth, however, EU02 and EU03 which are subject to 40 CFR 60, Subpart Dc, have similar requirements. Therefore, 40 CFR 60.48c(f) applies to Boilers EU02 & EU03 and 806.05 (effective 10-31-2010 and cited in TP-0037) applies to the remaining fuel burning devices. • 807.02 – Applicable – opacity testing (effective date 10-31-2002 is more stringent (SIP approved rule does not have opacity testing requirements), rule effective date updated to 10-31-2010) Env-A 900 – Owner or Operator Recordkeeping and Reporting Obligations – Applicable (effective 08-21-1995 (SIP approved 03-10-1998) Env-A 900 effective 04-21-2007 is more stringent) Env-A 1300 – Nitrogen Oxides (NOx) Reasonably Available Control Technology (RACT) • 1301.02(a) – Applicable • 1301.02(d) and 1305.10(b)(1) – Applicable to Boiler #1 (formerly Env-A 1211.05(d)(3)a.2. and established in TP- B-351. • 1301.02(d) and 1305.04(b)(1) – Applicable to Boilers #2, #3 and #4 (formerly Env-A 1211.05(c)(2)b.2. and Env- A 1211.05(d)(3)a.2. and established in TP-B-0545, TP-B-387 and TP-B-352. • 1301.02(d) and 1305.06(a) – Applicable to Boiler #2 when firing #2 fuel oil (formerly Env-A 1211.05(c)(2)a. and established in TP-B-0545. • 1301.02(j)(1) and (j)(2) – Applicable to EU05, EU10, EU11, EU13 & EU14 (formerly Env-A 1211.01(j)(1) and (j)(2) and established in TP-0037) Env-A 1400 – Applicable – Regulated Toxic Air Pollutants • See Pollution Control Equipment section above. Env-A 1600 – Fuel Specifications – Applicable – Note that Env-A 400, NSPS and PSD avoidance limits are more stringent than the state requirement of 2% for #6 fuel oil. #2 fuel oil is limited to 0.4 wt% (which is more stringent than 40 CFR 60, Subpart Dc), LPG for all gas-fired emergency generators (EU13 & EU14) is limited to 5 grains per 100 ft 3 (See 40 CFR 52 below) and the emergency generators subject to 40 CFR 60, Subpart IIII (EU11) are limited to 15 ppm (0.0015 wt%). Therefore, the sulfur limitations in the proposed Title V permit will reflect the most stringent requirements. Env-A 1900 – Not Applicable – Pathological Waste Incinerator has been effectively dismantled and deemed inoperable. Env-A 2000 – Applicable – Fuel Burning Devices (effective 04-23-2005, not SIP approved) [Previously Env- A 1200 – Prevention, Abatement, and Control of Stationary Source Air Pollution (effective 08-21-1995 (SIP approved 07-23- 2002))]

• 2002.01 (1202.01) – Applicable – Visible emissions from Boiler #4 is limited to 40%. Dartmouth has asked to streamline the permit and make all boiler opacity limits equally restrictive at 20%. Visible emissions from the Hopkins emergency generator (EU05) are limited to 40%. • 2002.02 (1202.02) – Applicable – Visible emissions from Boilers #1, #2, and #3 (EU01, EU02 & EU03) all small boilers subject to JJJJJJ (EU12) and the emergency generators (EU10, EU11, EU13 & EU14) are limited to 20%. • 2002.04(a) – Applicable – Exemptions for Boilers #2 and #3 which are subject to 40 CFR 60, Subpart Dc. However, Dartmouth has asked that these exemptions not be included in the permit since they conflict with 40 CFR 60.43c(c) and (d). • 2002.04(c) – Applicable for Boiler #1 and #4 (EU01 & EU04) and all small boilers subject to JJJJJJ (EU12) – Opacity may exceed 20% for six continuous minutes in any 60- minute period during startup, shutdown, malfunction, soot blowing, grate cleaning and cleaning of fires. Applicable for emergency generators (EU05, EU10, EU11, EU13 & EU14) – Opacity may exceed 20% for six continuous minutes in any 60- minute period during startup, shutdown, and malfunction. [State Only Requirement] • 2002.04 (d), (e) and (f) – Applicable for all boilers – Activities Exempt from Visible Emission Standards. [State Only Requirement] • 2002.05 – Applicable for Boilers #2 and #3. [40 CFR 60, Subpart Dc 60.43c(c) and (d)] • 2002.06 (1202.05) – Applicable for Boiler #4 (TSP emissions are limited to 0.41 lb/MMBtu) and emergency generator (EU05) – 0.60 lb/MMBtu. • 2002.08 (1202.07) – Applicable for Boilers #1, #2, and #3 – TSP emissions are limited to 0.15 lb/MMBtu for Boiler #1 and 0.30 lb/MMBtu for Boilers #2 and #3. Applicable to emergency generators (EU10, EU11 and EU13) and all small boilers subject to JJJJJJ (EU12) – 0.30 lb/MMBtu.

Env-A 3500 – Hospital/Medical/Infectious Waste Incineration – NOT Applicable – Pathological Waste Incinerator has been effectively dismantled and deemed inoperable. Federal Regulations 40 CFR 52 – NH State Implementation Plan • August 3, 2006 – DES submitted a SIP submittal to EPA to remove the short-term steam limitations from Dartmouth’s boiler plant due to an updated air dispersion modeling review and issuance of TP-B-0511. • Env-A 402.02(a), effective on December 27, 1990, was adopted as part of the State Implementation Plan (SIP) on September 14, 1992 and is still considered federally enforceable until such time as the SIP is amended and approved by the EPA. The sulfur content of #2 fuel oil shall not exceed 0.40% sulfur by weight. Applicable to #2 fuel oil burned in Boiler #2 and the diesel (#2 fuel oil) fired emergency generators. • Env-A 402.03, effective on December 27, 1990, was adopted as part of the State Implementation Plan (SIP) on September 14, 1992 and is still considered federally enforceable until such time as the SIP is amended and approved by the EPA. Gaseous fuel shall contain no more than 5 grains per 100 cubic feet of sulfur, calculated as hydrogen sulfide at standard conditions. Applicable to gaseous fuel burned in the emergency generators.

40 CFR Part 60 – New Source Performance Standards

40 CFR 60, Subpart Db, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units Applicable to Boiler #1 – Dartmouth commenced construction of Boiler #1 on July 31, 1985 and has a heat input capacity from fuels combusted in the steam generating unit of greater than 100 MMBtu/hr, therefore Subpart Db applies. Pursuant to §60.40b(b)(3), Boiler #1 is subject to only the NOx standards under 40 CFR 60. Subpart Db and not the opacity, PM and SO 2 standards because of the date the construction commenced for the boiler. 40 CFR 60, Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units Applicable to Boilers #2 and #3 (EU02 & EU03). Dartmouth commenced construction of Boiler #2 in 2008 and Boiler #3 in 1995 and both boilers have maximum design heat input capacities between 10 and 100 MMBtu/hr, therefore Subpart Dc applies. Not Applicable to Boiler #4 because it was manufactured in 1967 which is before the applicability date for Subpart 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 15 of 21

Dc (June 9, 1989). 40 CFR 60, Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines – Applicable to EU11. 40 CFR 60, Subpart JJJJ, Standards of Performance for Stationary Spark Ignition Internal Combustion Engines – Applicable to EU13. 40 CFR 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984 – Not Applicable – Dartmouth’s Tanks #1 and #2 are each 125,000 gallon tanks and store #6 fuel oil with a true vapor pressure of less than 0.1 psia at 70°F. Subpart Kb does not apply to storage vessels with a capacity greater than or equal to 151 m 3 (39,890 US gal) storing a liquid with a maximum true vapor pressure less than 3.5 kPa (0.5 psia). 40 CFR Part 61 – National Emission Standard for Hazardous Air Pollutants No applicable standards 40 CFR Part 63 – National Emission Standard for Hazardous Air Pollutants for Stationary Sources

40 CFR 63, Subpart ZZZZ, National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines – Applicable – See Env-A 500 above. 40 CFR 63, Subpart DDDDD, National Emissions Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters – Not Applicable – Dartmouth is an area source of HAPs. (See calculations attached in Appendix J for both GHG and HAPs.) 40 CFR 63, Subpart JJJJJJ, National Emissions Standards for Hazardous Air Pollutants for Area Sources: Industrial, Commercial, and Institutional Boilers – Applicable EU01, EU02, EU03, EU04 & EU12 – The boilers are considered existing sources because the construction of the boilers occurred prior to June 4, 2010. Therefore, Dartmouth is subject to the biennial tune-up for all applicable units and the one time energy assessment requirements (for EU01, EU02, EU03 & EU04) of 40 CFR 63, Subpart JJJJJJ along with the applicable notifications, recordkeeping and reporting requirements. Others 40 CFR 64, Compliance Assurance Monitoring – Not Applicable – CAM rule applies to Title V sources that operate emission units with pre-controlled potential emissions at or above the major source thresholds that rely on control devices to comply with applicable requirements. This facility does not operate any control device. Therefore CAM rule is not applicable 40 CFR 68, CAA 112(r)(1), General Duty – While the facility states they do not store any chemicals above the 112(r) applicability, the facility is subject to the general duty clause (112(r)(1)) in order to ensure that they have identified potential hazards, designed and maintain a safe facility, have steps in place to prevent releases and minimize the consequences of accidental releases. 40 CFR 82, Protection of Stratospheric Ozone, Subpart F, Recycling and Emissions Reduction – Applicable to Chillers (previously EU09). 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 16 of 21

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 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) 8 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

8 Based on heat input of 137,000 Btu/gallon for diesel fuel.

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) 9 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)

9 Based on heat input of 137,000 Btu/gallon for diesel fuel.

APPENDIX D EU12 –BOILERS SUBJECT TO 40 CFR 63, SUBPART JJJJJJ Location Description Fuel Type Heat Input per Unit (MMBtu/hr) Vail Boiler #2 Fuel Oil 1.68 Remsen Boiler #2 Fuel Oil 1.68 Lodge Boiler #2 Fuel Oil 0.84 24 East Wheelock Boiler #2 Fuel Oil 0.37 23 East Wheelock Boiler #2 Fuel Oil 0.42 13 East Wheelock Boiler #2 Fuel Oil 0.32 11 East Wheelock Boiler #2 Fuel Oil 0.46 10 West Wheelock Boiler #2 Fuel Oil 0.49 20 West Street Boiler #2 Fuel Oil 0.37 9 Webster Boiler #2 Fuel Oil 0.23 13 Webster Boiler #2 Fuel Oil 0.32 1 & 3 Occum Ridge Boiler #2 Fuel Oil 0.40 12 Rope Ferry Boiler #2 Fuel Oil 0.23 35 North Main Street Boiler #2 Fuel Oil 0.49 36 North Main Street Boiler #2 Fuel Oil 0.23 38 North Main Street Boiler #2 Fuel Oil 0.40 Outing Club House Boiler #2 Fuel Oil 0.56 Outing Club House Boiler #2 Fuel Oil 0.32 Fuller Boat House Boiler #2 Fuel Oil 0.08 Crew Facilities Boiler #2 Fuel Oil 0.18 Crew Facilities Boiler #2 Fuel Oil 0.25 42 College Boiler #2 Fuel Oil 0.21 Hillcrest Boiler #2 Fuel Oil 0.56 Hillcrest Boiler #2 Fuel Oil 0.56 Parker House Boiler #2 Fuel Oil 0.37 Webster Cottage Boiler #2 Fuel Oil 0.08 Morton Farm Boiler #2 Fuel Oil 0.18 Hanover Country Club Boiler #2 Fuel Oil 0.14 44 College Boiler #2 Fuel Oil 0.35 13 Choate Road Boiler #2 Fuel Oil 0.42

APPENDIX E EU13 – LPG-FIRED EMERGENCY GENERATORS THAT ARE SUBJECT TO 40 CFR 60, SUBPART JJJJ

Description & Manufacturer Model Serial # kW Fuel Firing Heat Date Location (hp) Rate Input Installed (gal/hr or (MMBtu cf/hr) /hr) 10 Hanover Inn Cummins 75GGHF E120334856 75 LPG 415 1.04 2012 Kitchen (119.8) Visual Arts Kohler 100REZG GXC00826 100 LPG 511 1.28 2012 (165) 53 Commons Olympian G80LG2 2332285 80 LPG 461 1.15 2012 (128)

10 Based on heat input of 2,500 Btu/cf for LPG.

APPENDIX F EU14 – LPG-FIRED EMERGENCY GENERATORS THAT ARE NOT SUBJECT TO 40 CFR 60, SUBPART JJJJ 11 Description & Manufacturer Model Serial # kW Fuel Firing Heat Date Location Rate Input Installed (gal/hr or (MMBtu cf/hr) /hr) 12 Judge Onan 15JCL D910378387 15 LPG 82 0.14 Unknown Mass-Mid Onan 15JCL30634B I890268221 15 LPG 82 0.14 1985 Berry Gym Onan 15JCL J910431347 15 LPG 82 0.14 1988 Collis Caterpillar 3306 7404527 135 LPG 547 1.29 1992 Maxwell Onan 7.5JBFL30634D K900358543 7.5 LPG 41 0.07 1992 Rope Ferry Generac 92A02171-W 2003313 15 LPG 82 0.14 1992 Brown Onan 15JCL J920487464 15 LPG 82 0.14 1993 Byrne Onan 12.5JCG F90473495 12.5 LPG 68 0.12 1993 Sudikoff Olympian 93A02239-S 2008061 45 LPG 246 0.43 1993 Fayerweather-Mid Onan 15JCL C930501594 15 LPG 82 0.14 1994 Russell Sage Onan 15 JCB L940563972 15 LPG 82 0.14 1994 Robinson Olympian 95A04666-S 2023640 30 LPG 164 0.29 1996 Topliff Onan 15 JCL C920457588 15 LPG 82 0.14 1996 Wheeler Generac 00608-4 3048436 15 LPG 82 0.14 1997 Gilman Onan LSG-8751-6005A 17815T-18- 70 LPG 355 0.67 1999 TT Lord Onan 15JCL30634B F890248502 15 LPG 82 0.14 1999 Zimmerman Generac 99A04233-S 2049728 45 LPG 246 0.43 1999 Woodward Olympian G15U1 F3827A/001 15 LPG 82 0.14 2000 Hitchcock Onan WSG1068 07W564990 85 LPG 422 1.05 2007 New Hampshire Kohler 25RZGB 2227710 25 LPG 166 0.41 2009

11 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). 12 Fuel flow and heat input estimated based on kW rating for all except for Hitchcock and New Hampshire which are based on 2,500 Btu/cf for LPG. 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 20 of 21

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 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 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 21 of 21

Location/Description Tank Age Tank Type Product Stored Capacity (gallons) 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