VERMONT AGENCY OF NATURAL RESOURCES



VERMONT AGENCY OF NATURAL RESOURCESDepartment of Environmental ConservationAir Quality & Climate DivisionTECHNICAL SUPPORT DOCUMENT FOR PERMIT TO CONSTRUCT AND OPERATE#AOP-14-006August 2, 2018Prepared By: Tony Mathis, Environmental EngineerAPPLICANT:Summit Ventures NE, LLC1840 Sugarbush Access RoadWarren, Vermont 05674SOURCE:Snowmaking and Space Heating OperationsSugarbush Resort at Lincoln Peak and Mt. EllenWarren (Lincoln Peak) and Fayston (Mt. Ellen), VermontThis Technical Support Document details the Agency of Natural Resources, Department of Environmental Conservation, Air Quality & Climate Division (“Agency”) review for the combined Air Pollution Control Permit to Construct and Operate and is intended to provide additional technical information, discussion and clarification in support of the Permit. It is not intended to provide a comprehensive review of the Facility or permit process or duplicate the information contained in the Permit. 1.0INTRODUCTIONSummit Ventures NE, LLC (also referred to herein as "Permittee") owns and operates Sugarbush Resort located in the towns of Warren and Fayston, Vermont (also referred to herein as "Facility"). The Facility includes the downhill ski areas located on Lincoln Peak in Warren and Mount Ellen in Fayston as well as various other resort support operations and facilities such as ski lodges, restaurants, lodging facilities and a golf course. Winter ski area operations consist of snow making, trail grooming, and ski lift operations. The snowmaking operations at the Lincoln Peak area utilize both electric utility run snowmaking compressors and have the potential to use diesel engine powered snowmaking compressors. The snowmaking operations at the Mount Ellen area rely solely on snowmaking compressors that operate on power from the electric grid. Table 1-1 summarizes the Facility’s allowable emissions: Table 1-1: Facility-Wide Allowable Air Contaminant Emissions tons/year1PM/PM10/PM2.5CONOxSO2 3VOCsHAPs2GHGs3.229.149.40.5<5<110,7341PM/PM10/PM2.5 – total particulate matter, total particulate matter of 10 micrometers in size or smaller and total particulate matter of 2.5 micrometers in size or smaller, respectively. Unless otherwise specified, all PM is assumed to be PM2.5; SO2 - sulfur dioxide; NOx - oxides of nitrogen measured as NO2 equivalent; CO - carbon monoxide; VOCs - volatile organic compounds; HAPs - hazardous air pollutants as defined in §112 of the federal Clean Air Act.2A stationary source with potential emissions of 10 tons per year or greater of any single HAP or 25 tons per year or greater of all HAPs combined is considered a major source of HAPs under §112 of the federal Clean Air Act. Any stationary source with potential emissions of 8 tons per year or greater of any single HAP or 20 tons per year or greater of all HAPs combined is considered a synthetic minor source. The Facility is limited by the Permit herein to less than thresholds for a synthetic minor source. Actual total combined HAPs from the Facility are estimated at <1 tpy. This Permit does not explicitly authorize emissions up to this level since any increase in actual HAP emissions may be subject to §5-261 and 5-501 of the Regulations as applicable.3CO2e ‘at the stack’ – includes emissions from biogenic sources. See section 3.3 for details. This is not a facility limit.2.0FACILITY LOCATION AND DESCRIPTIONThe Facility is a mountain resort located in the towns of Warren and Fayston, Vermont. The area surrounding the Facility is primarily recreational resort businesses and forest. The Facility is located less than 100 kilometers from the Lye Brook Wilderness area in Manchester, Vermont and greater than 100 kilometers from the Great Gulf and Dry River Wilderness areas in New Hampshire. The Facility is a mountain resort listed under the Standard Industrial Classification ("SIC") Codes #7011, Hotels and Motels, and under the North American Industrial Classification System Code #721110 (Hotels, except Casino Hotels) and Motels, as well as SIC Code #7999, Amusement Recreation Services, Not Elsewhere Classified, and NAICS Code #713920 (Skiing Facilities). The primary permitted sources of air emissions at the Facility include the permitted use of a fleet of leased diesel engine powered air compressors at the Lincoln Peak ski area, with the aggregate rated power of the engines limited to a maximum of 4,500 hp. This engine fleet has typically consisted of approximately six (6) trailer mounted diesel engine powered air compressors used in the snow making process. The Facility is not currently operating this fleet of engines but intends to retain them in the Permit to allow for future operational flexibility of the Facility. The Facility also operates several diesel-fueled engines at various locations on the Facility for emergency back-up power in the event of a power outage or electrical drive failure. These units are used strictly for failure conditions and not used for any peak shaving or load shedding activities. Table 2-1 provides a summary of the Facility’s regulated equipment: Table 2-1 Regulated Equipment at FacilityUnitMake and ModelRatingFuel Type2Date InstalledLincoln Peak Area Emergency Reciprocating Internal Combustion Engines 4Valley House Quad – Cummins QSB6.7 Serial # 73862239190 bhpB20 Biodiesel / ULSD2015Super Bravo Express Quad - Cummins NTA855-P Serial # 11775835500 bhp1995Heaven’s Gate Triple – Cummins NTA855C Serial # 11197299450 bhp1984Castlerock Double – Cummins B3.9-P Serial # 46120376116 bhp2001Gate House Express Quad – Cummins NTA855P Serial # 11773937360 bhp1995North Lynx Triple – Cummins NTA855C Serial # 11197300400 bhp1984Village Quad – Kubota V1505-T Serial # 1HD089617 bhp20171 Size, number, make and model of engines subject to change however, total combined capacity required to remain below 4,500 bhp. 2 As required in 40 CFR Part 60 Subpart IIII, engines subject to this subpart shall only fire fuels with a maximum sulfur content not to exceed 0.0015 percent by weight (15 ppm). 3 BHP – brake horsepower rated output as specified by the manufacturer. 4 Lincoln Peak emergency engines sum to a total combined rating of 2,033 bhp. 5 Mount Ellen emergency engines sum to a total combined rating of 2,528 bhp. 6 Since the emergency generators are used for emergency purposes only and are not operated more than 100 hours per year each, they are considered insignificant activities under Subchapter X of the Regulations. However, estimated emissions from the units have been calculated assuming 200 hours of operation per year and are included in the facility-wide allowable emission estimates. Table 2-1 Regulated Equipment at Facility - (Continued)UnitMake and ModelRatingFuel Type2Mount Ellen Area Emergency Reciprocating Internal Combustion Engines 5 Sunshine Quad – Kubota V1505-T Serial # 1HK177317 bhpB20 Biodiesel / ULSDGreen Mountain Express Quad Primary – Cummins VTA28P Serial # 25173367 900 bhpGreen Mountain Express Quad Evacuation – Cummins B3.9-P Serial #46227161 116 bhpNorth Ridge Express Quad –Cummins 6BT5.9-P Serial # 44314014 160 bhpSummit Quad – Cummins NTA855P Serial # 11601988 335 bhpInverness Quad – Cummins NTA855P Serial # 16601081 400bhpSlide Brook Express Quad – Cummins KTA19-P Serial # 37157795600 bhpClay Brook Hotel Emergency Reciprocating Internal Combustion EnginesClay Brook Hotel Fire Suppression System – John Deere 4045TF Serial # PE4045T569818220 bhpB20 Biodiesel / ULSDClay Brook Hotel Emergency GeneratorIveco/FPT SD0130 EngineSerial # 2086753198 bhpGate House Base LodgeGate House Lodge Emergency GeneratorCaterpillar C4.4 Serial # RJ51155NT744805157 bhpDiesel Engines for Snowmaking OperationsCummins Model N14-C475 Tier III or equivalent - Lincoln Peak Base Area Leased Units Varies 1B20 Biodiesel / ULSDClay Brook Hotel boilersTwo (2) Buderus / Riello, Model G 615/144.1 MMBtu/hr (each)-LPGSugarbush Administration BuildingH.A. Smith Co. Model 20400,000 MMBtu/hrB20 Biodiesel / No. 2 Fuel OilOther Fuel Combustion Sources for Space Heating including but not limited to:Indoor fireplaces and outdoor fire pitsN/AWoodVarious non-road diesel engine powered equipment including but not limited to those powering snow grooming and materials handling equipment. VariesVariesB20 Biodiesel / ULSD1 Size, number, make and model of engines subject to change however, total combined capacity required to remain below 4,500 bhp and all engines must be certified to EPA Tier 3 or better. 2 As required in 40 CFR Part 60 Subpart IIII, engines subject to this subpart shall only fire fuels with a maximum sulfur content not to exceed 0.0015 percent by weight (15 ppm). Biodiesel blends not exceeding 20 percent biodiesel (B20) and Ultra-Low Sulfur Diesel (ULSD) with a sulfur content not to exceed 0.0015% (15 ppm) by weight both satisfy this requirement. 3 bhp – brake horsepower rated output as specified by the manufacturer. 4 Lincoln Peak emergency engines sum to a total combined rating of 2,033 bhp. 5 Mount Ellen emergency engines sum to a total combined rating of 2,528 bhp. Although not required for determining applicability with Subchapter X, quantifiable emissions from “insignificant activities” must be included for the purposes of establishing whether or not a source is subject to other air pollution control requirements, including, but not limited to: reasonably available control technology, major source status, and Title V operating permit applicability.Additionally, guidance provided by the U.S. EPA (entitled “White Paper for Streamlined Development of Part 70 Permit Applications”) lists activities which are considered as “trivial” sources of air contaminants and may be presumptively omitted from operating permit applications.Table 2-2 lists activities at the Facility which were considered negligible or exempt sources of air contaminant emissions, and therefore were not considered as emission sources as part of the Operating/Construction Permit review. Table 2-2: Sources of Negligible Contaminant EmissionsEquipmentDescription/LocationNumerous small space heating unitsHeating units are at various locations around Lincoln Peak and Mount Ellen areas, and are fired with liquified petroleum gas (LPG). All units rated at less than three (3) MMBtu/hr1. Three (3) diesel fuel storage tanks.The three (3) diesel fuel storage tanks were installed in 1987 and are rated at 12,000 gallons each. Two are located at Lincoln Peak and one is located at Mount Ellen. 1 MMBtu/hr – Maximum rated heat input in million British thermal units per hour. It should be noted that a process or piece of equipment which is considered a “negligible activity” does not relieve the owner or operator from the responsibility of complying with any applicable requirements associated with said process or equipment. 3.0quantification of pollutantsThe quantification of emissions from a stationary source is necessary in order to establish the regulatory review process necessary for the operating permit application and to determine applicability with various air pollution control requirements. These determinations are normally based upon allowable emissions. Allowable emission is defined as the emission rate calculated using the maximum rated capacity of the source and, if applicable, either: (a) the applicable emission standard contained in the Regulations, if any, or (b) the emission rate or design, operational or equipment standard specified in any order or agreement issued under the Regulations that is state and federally enforceable. An applicant may impose in its application an emission rate or design, or an operational or equipment limitation which may be incorporated in the Permit to restrict operation to a lower level. Such limitations may include fuel restrictions or production limits. The regulated sources of air contaminants at the Facility include fourteen (14) emergency diesel engines, three (3) stationary emergency generators with diesel engines two (2) Buderus/Riello LPG-fired boilers, various other LPG fired heating equipment at the Facility, one (1) No. 2 fuel oil-fired boiler, the combustion of wood fuel in the fireplaces and outdoor firepits at the Facility, operation of non-road equipment such as snow grooming and materials handling equipment and provisions for the operation of approximately six (6) leased diesel engine powered compressors used in snowmaking operations. The estimated emissions from the combustion sources identified above are summarized below: Emission factors are based on emission factors for the various combustion categories as presented in AP 42, Fifth Edition, Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources (AP-42). Estimated combustion emissions from the liquified petroleum gas (LPG) fired heating units at the Facility, including but not limited to the two (2) Buderus/Riello LPG-fired boilers were based on the permit limitation for LPG combustion at the Facility of 900,000 gallons per year. Table 3-1: Liquefied Petroleum Gas (LPG)1 Fired Boilers – Allowable EmissionsPollutantEmission FactorAllowable Emissions (ton/year)FactorUnits 2ReferenceSO2 0.1 S 3lb/1000 galAP-42, LPG Combustion, Table 1.5-1, 7/080.45NOx135.85PM0.70.32CO7.53.38VOC10.45HAPs 40.169AP 42, Natural Gas Combustion, Tables 1.4-3 & 1.4-4 (7/98)0.0761 LPG – liquefied petroleum gases also known as propane, but butane and other liquefied petroleum gases may be present in the mixture.2 lb/1,000 gallons: pounds of pollutant emitted per 1,000 gallons of LPG combusted. 3 S represents the sulfur content expressed in gr/100 standard cubic feet (scf) of gas vapour. The sulfur content of HD-5 propane is 10 gr/100scf, so S=10.4 HAP emissions from propane combustion assumed to be the same as from natural gas combustion Estimated combustion emissions from the No. 2 oil fired heating units at the Facility administrative building were estimated based on the permit limitation for No. 2 fuel oil combustion at the Facility of 25,000 gallons per year, with the No. 2 fuel oil having a sulfur content not greater than of 0.0015% (15 ppm) by weight Table 3-2: Oil Fired Boilers - Allowable EmissionsPollutantEmission FactorAllowable Emissions(tons per year)FactorUnits 2ReferenceSO2142S 1lb/1000 galAP-42, Fuel Oil Combustion, Table 1.3-1 (9/98)0.003NOx200.25PM3.3AP-42, Fuel Oil Combustion, Tables 1.3-1 and 1.3-2 (9/98)0.04CO5AP-42, Fuel Oil Combustion, Table 1.3-1 (9/98)0.06VOC0.34AP-42, Fuel Oil Combustion, Table 1.3-3 (9/98)0.004HAPs0.062AP-42, Fuel Oil Combustion, Tables 1.3-8 to 1.3-10 (9/98)0.0011 S represents the weight % of sulfur in the oil. For example, if the fuel is .0015% sulfur, then S=0.00152 lb/1000 gal: pounds of pollutant emitted per 1000 gallons of fuel input to the boiler.Emissions from the fleet of emergency engines at the Facility, which includes both emergency evacuation engines, and emergency generators and fire pump engines serving various buildings at the Facility were estimated using emission factors from AP-42, Section 3.3 for gasoline and diesel engines less than 600 bhp. Some of the emergency engines are greater than 600 bhp, but the AP-42 emission factors for engines less than 600 bhp are higher than those for engines greater than 600 bhp, so the higher emission factors were used to provide a conservative estimate. Emissions were estimated based on 200 hours of operation per year for an engine fleet with an aggregate rated engine horsepower of 5,136 bhp, and an estimated engine efficiency of 38.9 percent, resulting in an aggregate fuel consumption of 240 gallons per hour. It was assumed the engines would be fueled with ultra-low sulfur diesel (ULSD) fuel containing not greater that 0.0015% (15 ppm) by weight sulfur. Table 3-3: Emergency Engines – Estimated EmissionsPollutantEmission FactorAllowable Emissions (ton/year)FactorUnitsReferenceSO21.01S1lb/MMBtu 2AP-42, Chapter 3, Stationary Internal Combustion Sources, Large Stationary Diesel and All Stationary Dual-fuel Engines, Table 3.4-1 (10/1996)0.01PM0.13AP-42, Chapter 3, Stationary Internal Combustion Sources, Gasoline and Diesel Industrial Engines, Table 3.3-1 (10/1996)1.04NOX2.1714.82CO2.683.19VOC0.101.21HAPs0.00157AP-42, Chapter 3, Stationary Internal Combustion Sources, Gasoline and Diesel Industrial Engines, Table 3.3-2 (10/1996)0.011 S represents the weight % of sulfur in the oil. For example, if the fuel is 0.0015% sulfur, then S=0.0015 2 lb/MMBtu represents pounds of pollutant emitted per million British thermal units of heat input to the engine. Emissions from the leased engine fleet were estimated based on the emission limits for Tier 3 engines contained in 40 CFR Part 89 with an estimated engine efficiency of 37.2 percent, and the combustion of 300,000 gallons of ultra-low sulfur diesel (ULSD) fuel containing not greater that 0.0015% (15 ppm) by weight sulfur. Emissions of VOCs and HAPs were not estimated for these engines. Table 3-4 Leased Snowmaking Engines – Estimated EmissionsPollutantEmission FactorAllowable Emissions (ton/year)FactorUnitsReferenceSO21.01S1lb/MMBtu 2AP-42, Chapter 3, Stationary Internal Combustion Sources, Large Stationary Diesel and All Stationary Dual-fuel Engines, Table 3.4-1 (10/1996)0.03PM0.13g/bhp-hr 3Tier 3 Emission Limits from 40 CFR, Part 891.01NOX2.1720.29CO2.6817.591 S represents the weight % of sulfur in the oil. For example, if the fuel is 0.0015% sulfur, then S=0.0015 2 lb/MMBtu represents pounds of pollutant emitted per million British thermal units of heat input to the engine. 3 g/bhp-hr equals grams of pollutant emitted per brake horsepower hour at rated load and speed.Allowable emissions from combustion of wood in the fire pits and fireplaces at the Facility were estimated using AP42 factors for combustion of wood residue. To provide a conservative estimate of emissions, it was assumed that the heat value of wood used at the Facility was 8,000 Btu/pound. Registration information from the Facility indicates that approximately 17 cords of wood were combusted in 2016. A fuel limit was established for wood fuel that was approximately three times that of the 2016 usage. Assuming cordwood weighs 5,300 pounds per cord, this results in a wood fuel combustion limit of 150 tons, or approximately 58 cords of wood. Table 3-5: Wood Combustion - Allowable EmissionsPollutantEmission FactorAllowable Emissions (ton / year)FactorUnits ReferenceSO20.025lb/MMBtu 1AP-42, Wood Residue Combustion in Boilers, Table 1.6-2 (9/03)0.03NOx0.49AP-42, Wood Residue Combustion in Boilers, Table 1.6-2 (9/03)0.59PM 0.417AP-42, Wood Residue Combustion in Boilers, Table 1.6-1 (9/03) Includes both filterable and condensable fractions0.50CO0.6AP-42, Wood Residue Combustion in Boilers, Table 1.6-2 (9/03)0.72VOC0.017AP-42, Wood Residue Combustion in Boilers, Table 1.6-3 (9/03)0.02HAPs0.0387AP-42, Wood Residue Combustion in Boilers, Tables 1.6-3 and 1.6-4 (9/03)0.051 lb/MMBtu represents pounds of pollutant emitted per million British thermal units of wood fuel combusted. A variety of non-road equipment is used at the Facility for grooming and snow management. The Permittee has indicated that estimated combustion of ULSD in this equipment during 2017 was approximately 55,407 gallons of diesel and 7,488 gallons of gasoline. The aggregate rated horsepower of the non-road equipment fleet at the Facility has been estimated by the Agency as 3.500 bhp. It is likely that the emissions certifications of the non-road engines at the Facility range from uncertified engines to Tier 4 engines. Equipment used during construction operations would not be included in this total, as they are a temporary emissions source and not part of the equipment used during normal Facility operations. Equipment registered for on-highway usage, regardless of the owner/operator of this equipment, would not be considered as part of the equipment associated with the Facility. Allowable emissions for the non-road equipment fleet used for operations at the Facility were estimated by assuming the emissions for a diesel engine powered non-road fleet, on average, would correspond to Tier 2 emission standards. A fuel consumption limit for the non-road equipment was established at 70,000 gallons per year, which approximates the current fuel usage for the non-road fleet. This limit was not set to a higher value to avoid exceeding the 50-ton threshold for NOx emissions, which would have exceeded the threshold criteria for NOx. These engines were assumed to be fueled with ultra-low sulfur diesel fuel containing a maximum of 0.0015% by weight sulfur with a heating value of 140,000 Btu per gallon. The engine efficiency for the non-road engine fleet was assumed to be 37.4%, which results in a total fuel consumption rate for the entire non-road fleet of 170 gallons per hour. These emissions from non-road engines have always been present at the Facility but have not been accounted for in previous estimates of allowable emissions. Accordingly, these emissions have been included in the allowable emissions for the Facility but are not considered a modification. Table 3-6– Estimated Emissions from Non-Road Engines -PollutantEmission FactorAllowable Emissionstons per yearFactorUnitsSourceSO21.01S1lb/MMBtu2AP-42, Chapter 3, Stationary Internal Combustion Sources, Section 3.3 Stationary Internal Combustions Sources, Section 3.3 –Gasoline and Diesel Industrial Engines Table 3.3-1 (10/1996)0.007NOx4.8g/bhp-hr 340 40 CFR Part 89, Subpart B, Section.112 - Oxides of nitrogen, carbon monoxide, hydrocarbon, and particulate matter exhaust emission standards7.63PM0.150.24CO2.64.13VOC---4---HAPs6.45E-03lb/MMBtu2AP-42, Chapter 3, Stationary Internal Combustion Sources, Section 3.3 Stationary Internal Combustions Sources, Section 3.3 –Gasoline and Diesel Industrial Engines, Table 3.3-2 (10/1996)0.0321 S represents the weight % of sulfur in the oil. For example, if the fuel is 0.0015% sulfur, then S=0.0015 2 lb/MMBtu represents pounds of pollutant emitted per million British thermal units of heat input to the engine. 3 g/bhp-hr represents grams of pollutant emitted per each brake horsepower-hour of engine operation. 4 VOC emissions for Tier 2 included in NOx emission factor. Total estimated emissions from the Facility and the Facility allowable emissions are summarized in Table 3-7. Table 3-7 Summary of Estimated and Allowable Air Contaminant Emissions (tons/year)1SourcePM/PM10/PM2.5CONOxSO2 VOCsHAPs2LPG Combustion0.323.385.850.4500.4500.076Boilers - No. 2 Fuel Oil Combustion0.040.060.250.0030.0040.001Emergency Engines1.043.1914.820.0051.2100.005Leased Diesel Engines for Snowmaking1.0117.5920.290.032------Wood Combustion0.500.720.590.0300.0200.046Non-road Engines0.244.137.630.007---0.032Sum of Estimated Emissions3.1529.0749.420.5271.6840.160Allowable Emissions3.229.149.40.5<5<11PM/PM10/PM2.5 – total particulate matter, total particulate matter of 10 micrometers in size or smaller and total particulate matter of 2.5 micrometers in size or smaller, respectively. Unless otherwise specified, all PM is assumed to be PM2.5; SO2 - sulfur dioxide; NOx - oxides of nitrogen measured as NO2 equivalent; CO - carbon monoxide; VOCs - volatile organic compounds; HAPs - hazardous air pollutants as defined in §112 of the federal Clean Air Act.2A stationary source with potential emissions of 10 tons per year or greater of any single HAP or 25 tons per year or greater of all HAPs combined is considered a major source of HAPs under §112 of the federal Clean Air Act. Any stationary source with potential emissions of 8 tons per year or greater of any single HAP or 20 tons per year or greater of all HAPs combined is considered a synthetic minor source. The Facility is limited by the Permit herein to less than thresholds for a synthetic minor source. Actual total combined HAPs from the Facility are estimated at <1 tpy. This Permit does not explicitly authorize emissions up to this level since any increase in actual HAP emissions may be subject to §5-261 and 5-501 of the Regulations as applicable.As may be noted in Table 3-7 above:The Facility has allowable emissions of all air contaminants in the aggregate of ten (10) or more tons per year: The Facility is therefore subject to Subchapter X of the Regulations and is designated as a Subchapter X Major Source.The Facility does not have allowable emissions of any contaminant which would classify the source as a “Major Source” and therefore is not subject to the new source review requirements of §5-502 of the Regulations. The Facility does not have allowable emissions of any contaminant which would classify the source as a "Title V Subject Source" and therefore is not subject to the federal operating permit requirements of 40 C.F.R. Part 70 or 71.3.3 – Estimating Potential Green House Gas EmissionsAPPLICABLE REQUIREMENTS DISCUSSION4.1Vermont Air Pollution Control Regulations and StatutesSection 5-201, 5-202, and 5-203 – Prohibition of Open Burning. The Facility is not anticipated to engage in any open burning activities except in conformity with the provisions of Section 5-201, 5-202, and 5-203 of the Regulations. Section 5-211(2) - Prohibition of Visible Air Contaminants. Installations constructed subsequent to April 30, 1970. These emission standards apply to all installations at the Facility. The applicant is anticipated to comply with these emission standards based on proper equipment design, operation and maintenance. Section 5-221(1)(a) - Prohibition of Potentially Polluting Materials in Fuel. This regulation applies to all the stationary fuel burning equipment at the Facility. Based on the application submittal, the applicant is anticipated to comply with this regulation based on the use of diesel fuel certified by the supplier to contain no more than 0.0015% sulfur by weight (15 ppm). Section 5-221(2) - Waste Oil. Based on the application submittal and past operational history, the Facility does not burn waste oil and therefore is not currently subject to this regulation. The Agency will continue to assess compliance with this section in the future during any inspections of the Facility. Inspections will include inquiring into waste oil combustion practices and a review of records indicating potential types and quantities of waste oil combusted. Section 5-231(3)(a) - Prohibition of Particulate Matter; Combustion Contaminants. This emission standard applies to all stationary fuel burning equipment at the Facility. An emission limit of 0.5 lb/MMBtu applies to each of the engines used for snowmaking operations, as well as the boilers and furnaces used at the Facility. The Facility is anticipated to comply with this emission standard based on the modern design of the boilers, furnaces, and internal combustion engines used at the Facility, and with the requirement for the proper operation and maintenance of this equipment Section 5-231(4) - Prohibition of Particulate Matter; Fugitive Particulate Matter. The Facility is not anticipated to be a significant source of fugitive particulate matter. However, the Facility is required to take reasonable precautions at all times to control and minimize emissions of fugitive particulate matter from the operations at the Facility. The Agency will require use of reasonable precautions, such as the application of water or surfactants to minimize the generation of fugitive PM from roads and parking areas on-site, as necessary. Additionally, the Agency will assess compliance with this requirement during any inspections of the Facility and will require the use of additional measures if found necessary during a compliance inspection. Section 5-241(1) and (2) - Prohibition of Nuisance and Odor. Since the Facility is operating combustion equipment, the potential for odors from combustion contaminants exists. Due to the generally rural location of the Facility, odor problems have not historically been a concern and it is not anticipated there will be future violations of this Facility requirement. Section 5-271 - Control of Air Contaminants from Stationary Reciprocating Internal Combustion Engines. All stationary reciprocating internal combustion engines, such as diesel-fired engine generators, with a brake horsepower output rating of 450 bhp or greater must meet emission standards for NOx, CO, and PM. Stationary reciprocating internal combustion engines installed prior to July 1, 1999, will be subject to the emission standards summarized in the table below as of July 1, 2007. Engines installed after July 1, 1999, but before July 1, 2007 must comply with the same standards immediately upon installation. The Facility is anticipated to comply with the emission standard outlined in Section 5-271 of the Regulations based on the fact that all leased and rented engines at the Facility, excluding engines used exclusively for emergency purposes, meet the more stringent emissions standards of the Federal EPA Tier III certification for PM (0.15 g/bhp-hr), NOx (3.0 g/bhp-hr) and CO (2.6 g/bhp-hr). Section 5-402 - Written Reports When Required. This section gives the Agency authority to require the Facility to submit reports summarizing records required to be maintained by the Agency. In particular, the Facility is required to submit, prior to each ski season the following information on all engines, other than emergency units, that will be operated at the Facility for use during snowmaking operations during the approaching ski season: A listing of all engines proposed to be operated;A summary of engine specs and emission specs for each engine;A cumulative listing of the manufacture’s rated horsepower output of each engine and a statement certifying that the total capacity is in compliance with the permit; andA certification that all engine emission rates meet the respective emission limits within the permit. Section 5-403 - Circumvention. This section states no person shall build, erect, install or use any article, machine, equipment or other contrivances, the use of which, without resulting in a reduction in the total release of air contaminants to the atmosphere, reduces or conceals an emission which otherwise would constitute a violation of these regulations. Based on the application submittal, past operational history and information available to the Agency, the Facility is currently in compliance with this regulation. Subchapter VIII - Registration of Air Contaminant Source. This section states that each operator of a source which emits more than five tons of any and all air contaminants per year shall register the source with the Secretary and shall renew such registration annually. The applicant is currently in compliance and has been registering its emissions with the Agency on an annual basis. 4.2Federal Air Pollution Control Regulations and the CAASection 111 of the Clean Air Act establishes New Source Performance Standards (NSPS). NSPSs apply to new sources, and are promulgated under 40 CFR, Part 60. Section 112 of the Clean Air Act establishes National Emission Standards for Hazardous Air Pollutants (NESHAPs). NESHAPs are promulgated under 40 C.F.R. Part 61 and Part 63 and may apply to new or existing sources. Potentially applicable NSPSs, NESHAPs, and other Federal air quality regulations are summarized in Table 4-1.Table 4-1: Applicable Requirements from Federal Regulations and the Clean Air Act40 CFR Part 60, Subpart Dc - Standards of Performance for Small Industrial-Commercial- Institutional Steam Generating Units. Applies to all boilers with a heat input rating of 10 MMBtu/hr or greater manufactured or modified after June 9, 1989. Units larger than 30 MMBtu per hour installed after February 27, 2005 are subject to additional particulate matter requirements. The Facility is not subject to this regulation, as the boilers at the Facility are rated at less than 10 MMBtu/hr. 40 CFR Part 60, Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (CI ICE). Applies to stationary CI RICE model year 2007 and later as well as those ordered after July 11, 2005 and with an engine manufacture date after April 1, 2006. Also applies to stationary CI RICE that are modified or reconstructed after July 11, 2005. This regulation requires engine manufacturers to certify that subject engines, with limited exceptions, comply with applicable Tier rating emission standards as established for non-road engines under 40 CFR Part 89 and/or 1039. Also requires engine operators to maintain and operate the engine according to the manufacturer’s written recommendations for the life of the engine and also limits fuel usage to diesel fuel with a maximum sulfur content of 15 ppm (ULSD). Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation. Subpart IIII is anticipated to apply to the leased engines for snowmaking and other older compression ignition emergency engines in the event the older units are replaced with newer units.40 CFR Part 60, Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. Applies to new spark ignition engines installed after June 12, 2006. Engines greater than 100 bhp firing landfill or digester gas must meet emission limits for NOx, CO and VOC and, for units 500 bhp and less, shall have a on-time compliance test and, for units greater than 500 bhp, shall have a compliance test at least once every 8.760 hours of operation or every 3 years, whichever occurs first. Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation. Subpart JJJJ not is anticipated to apply to any stationary engines at the Facility, as the Permittee has indicated that the stationary engines at the Facility are compression ignition engines. 40 CFR Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. Applies to new engines that commenced construction (installed) on or after June 12, 2006 at area sources of HAPs. Requires such engines to comply with NSPS Subpart IIII or JJJJ, as applicable. Also applies to existing engines that commenced construction (installed) prior to June 12, 2006 at area sources of HAPs. By May 3, 2013 requires engines equal and greater than 300 bhp to meet CO emission standards which may necessitate catalytic controls, must install crankcase ventilation system, and requires ULSD fuel. Engines <300 bhp need only meet maintenance requirements including changing oil & filter and, inspecting and replacing if necessary, air filter, hoses and belts. Does not apply to existing emergency units at an area source residential/commercial/institutional facility unless they are enrolled in demand response programs. Subject emergency units are subject to maintenance requirements, must install an elapsed hour meter and must use ULSD commencing January 1, 2015 if used for DR. For engines firing landfill or digester gas comprising 10% or more of the heat input, the engines are subject to management practices only (change oil & filter, inspect plugs, and inspect hoses and belts every 1440 hours or annually, whichever occurs first) as well as operating in accordance with manufacturer’s recommendations and minimizing time at idle.Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation. Subpart ZZZZ is anticipated to apply to all the engines at this Facility. The leased engines are anticipated to comply with the new engine requirements of Subpart ZZZZ by complying with Subpart IIII. The ski lift emergency evacuation engines are not exempt as residential/commercial/institutional units and are anticipated to comply with the existing emergency engine requirements of Subpart ZZZZ by complying with the maintenance standards. No existing (~pre-2006) 4Z engines are operated for non-emergency purposes. 40 CFR Part 63, Subpart JJJJJJ - National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial and Institutional Boilers. Applies to new and existing fuel oil and solid fuel fired boilers located at area sources (major sources are subject to Subpart DDDDD). Natural gas or propane fired boilers are not subject. This gas exemption allows use of backup fuel during gas curtailments and up to 48 hours of elective use. Oil fired hot water boilers less than 1.6 MMBTU/hr are not subject. The rule requires a tune-up for each boiler once every two years except boilers with oxygen trim and oil boilers less than 5 MMBTU/hr must conduct tune-ups every five years. New boilers greater than 10 MMBTU/hr are subject to PM emission limits. Boilers that commenced construction on or before June 4, 2010 are considered an existing source.Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation. Subpart JJJJJJ is not anticipated to apply to the two (2) LPG-fired Buderus/Riello, Model G 615/14, rated at 4.1 MMBtu/hr each, and located at the Clay Brook Hotel at the Facility. Since the Facility is not a major source of HAPs, the Facility is not subject to Subpart DDDDD.Clean Air Act §608 National recycling and emission reduction program; 40 CFR Part 82, Protection of Stratospheric Ozone, Subpart F – Recycling and Emissions Reductions. These requirements are applicable to any facility that owns, services, maintains, repairs, and disposes of appliances containing ozone depleting substances. Requirements of the regulation include, but are not limited to: (a) Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices specified in 40 CFR Part 82, Subpart F §82.156.(b) Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the standards for recycling and recovery equipment as specified in 40 CFR Part 82, Subpart F §82.158.(c) Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved technician certification program as specified in 40 CFR Part 82, Subpart F §82.161.(d) Commercial or industrial process refrigeration equipment must comply with the leak repair requirements specified in 40 CFR Part 82, Subpart F §82.156.(e) For each appliance normally containing fifty (50) or more pounds of refrigerant, the Permittee shall keep records of refrigerant purchased and added to such appliances as specified in 40 CFR Part 82, Subpart F §82.166.Since Vermont has not taken delegation of this federal regulation, the U.S. EPA is the implementing authority and is responsible for determining applicability of this regulation. The Facility is anticipated to have subject equipment or operations applicable to this regulation. 5.0reasonably available control technologyAt this time, the Agency has not established a Reasonably Available Control Technology ("RACT") requirement applicable to this Facility. Therefore, the source is currently in compliance with this requirement. The Agency will notify the source if any applicable RACT requirement applies to this Facility in the future. If such RACT should apply to the source in the future, the Agency will ensure that the source complies with such requirement at that time.6.0HAZARDOUS MOST STRINGENT EMISSION RATE DISCUSSIONThe sources of HAC emissions at the Facility are the combustion related emissions associated with boilers used for space heating at the Facility, diesel engines used in the snow making process, emergency diesel engines for backup fire protection and electricity, and engines used in non-road equipment necessary for the operation of the Facility, such as snow grooming and materials handling equipment. Pursuant to §5-261(1)(b)(ii) of the Regulations, fuel burning equipment that combusts virgin liquid or gaseous fuels are exempt from the requirements of §5-261. Therefore, the virgin fuel fired combustion sources identified above are exempt from §5-261 of the Regulations. Emissions from the wood-fired fireplaces and firepits at the Facility were not reviewed under §5-26, as the Agency does not typically review emissions from wood-fired units of less than 90 boiler horsepower, and the fireplaces and firepits at the Facility are likely below this threshold. 7.0MOST STRINGENT EMISSION RATE DISCUSSION (MSER):Pursuant to §5-502 of the Regulations, the owner/operator of each new major stationary source or major modification must apply control technology adequate to achieve the Most Stringent Emission Rate ("MSER") with respect to those air contaminants for which there would be a major or significant actual emissions increase, respectively, but only for those currently proposed physical or operational changes which would contribute to the increased emissions. This operating permit renewal is not subject to review under the MSER requirements in §5-502 of the Regulations. In addition, there have been no prior MSER evaluations conducted for any of the previous modifications to the Facility. 8.0AMBIENT AIR QUALITY IMPACT EVALUATION DISCUSSION (AQIE):An ambient air quality impact evaluation is performed to demonstrate whether or not a proposed project will cause or contribute to violations of the ambient air quality standards and/or significantly deteriorate existing air quality. The Agency's implementation procedures concerning the need for an ambient air quality impact evaluation under §5-406(1) of the Regulations, specifies that such analyses may be required when a project results in an allowable emission increase of ten (10) tons per year or more of any air contaminant, excluding VOCs. Additionally, the Agency may require an air quality impact evaluation where the short-term allowable emission rates will significantly increase as a result of a project. The Facility is not undergoing changes subject to new source review; therefore, this section is not applicable. ................
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