the state of new hampshire department of … · emissions, the boiler is equipped with a...

The State of New Hampshire

DEPARTMENT OF ENVIRONMENTAL SERVICES

NHDES Thomas S. Burack, Commissioner

June 11, 2010

Mr. Ronald Guerin - Plant Engineer Tillotson Rubber Co., Inc. One Spur Road Dixville Notch, NH 03576

RE: Full Compliance Evaluation Report

Dear Mr. Guerin:

The New Hampshire Department of Environmental Services, Air Resources Division ("DES") completed an Off-site Full Compliance Evaluation at your facility on June 11, 2010. Enclosed is a copy of the Full Compliance Evaluation Report for your records.

The following deficiency was identified during the inspection, and is detailed in the enclosed report:

Tillotson failed to report calendar day fuel usages for EU1 and EU2 in the 2008 and 2009 Annual Emission Reports. This information was promptly submitted upon request. To remain in compliance with the Title V Permit, Tillotson must report calendar day fuel usages for EU1 and EU2 in the Annual Emisson Reports. No additional action is necessary at this time.

If you have any questions, please contact me by telephone at (603) 271-4625 or by email at [email protected] .

Sincerely,

Margaret Bastien, P.E. Compliance Assessment Section Supervisor Air Resources Division

Enclosure: Full Compliance Evaluation Report cc: Board of Selectmen, Dixville

DES Web Site: www.des.nh.gov P.O. Box 95,29 Hazen Drive, Concord, New Hampshire 03302-0095

Telephone: (603) 271-1370 Fax: (603) 271-1381 TDD Access: Relay NH 1-800-735-2964

NEW HAMPSHIRE DEPARTMENT OF rEnvilr( Services nmental

OFF-SITE COMPLIANCE EVALUATION FULL RECORDS REVIEW

Tillotson Rubber Co., Inc. One Spur Road

Dixville Notch, NH 03576 Coos County

(603) 255-4572

AFS# 3300700006

Final Report: June 11, 2010

Inspected and Report Prepared by:

New Hampshire Department of Environmental Services Air Resources Division

29 Hazen Dr., P.O. Box 95 Concord, New Hampshire 03302-0095 .

9-a-- (-.q 4 ~ ~Z &:: g ~ , Margait Bastien, P.E. Compliance Assessment Section Supervisor

Tillotson Rubber Co., Inc. Report Date: 0611112010 2009 Off-Site Compliance Evaluation

Inspection

On June 11, 2010, the New Hampshire Department of Environmental Services, Air Resources Division ("DES") completed an Off-Site Full Compliance Evaluation ("FCE") of the Tillotson Rubber Co., Inc. ("Tillotson") facility ("the Facility"), located in Dixville Notch, NH, Coos County. The Facility was targeted for inspection based on DES inspection criteria, which requires that a major source with a Title V Permit be inspected once every two years. DES's off-site records review was conducted in accordance with EPA's Compliance Monitoring Strategy. On July 24, 2008, DES performed an on-site inspection of the Facility. These inspection results are summarized in the report dated October 17, 2008.

Date of Inspection: June ii, 2010 Type of Inspection: Off-Site Full Compliance Evaluation Inspected by: Margaret Bastien, Compliance Assessment Section Supervisor Source Contact: Ronald Guerin, Plant Engineer, (603) 255-4572 Last compliance inspection conducted at facility:

July 24, 2008

Last Inspection Result: No deficiencies were observed during the Facility inspection Permit Number: TV-OP-026 Effective: March 10, 2006

Amended: March 30, 2007 Expires: March_31,_2011

Facility Description

Tillotson owns and operates four fuel-burning devices to produce steam and electricity for the Balsams Resort and for Healthco International, LLC, a latex and nitrile glove manufacturer. The Wickes Type A Wood-Fired Boiler, with one end only firing and an air-type stoker, burns greenwood sawdust and green hardwood bark. To remove particulate matter from the boiler's emissions, the boiler is equipped with a multi-cyclone dust collector without ash reinjection. The other Wickes Type A Boiler and two Dillon Boilers burn a combination of No. 4 and No. 6 fuel oils. The power plant is operated 24 hours per day and 365 days per year.

In addition to the four boilers, Tillotson operates a 400 KW and a 600 KW Caterpillar Diesel Generator as emergency generators for backup electricity.

Page 2 of 17


HI. Emission Unit Identification and Operatiniz Conditions

Table 1 - Emission Unit Identification, Operating Restrictions and Fuel Usage Data i .-. ' ,--,,--.---

EniissioiiUiiit •7•___ --,

Permitted Operatioiial. Reported Qperational '& Fuel Dscripiion Restrictiàñs Usge Data

EUI Wickes Type A Wood- Maximum firing rate of 40.8 2008:19,384 tons wood chips Fired Boiler MMBtu/hr gross heat input, 2009: 17,729 tons wood chips Serial number NB2884 equal to 22,000 pounds of Installed - 1978 steam per hour;

For 2008 and 2009, in 120 tons of wood/bark at 50% compliance with fuel use moisture during any calendar limitation. day

Opacity limited to 20%

EU2 Wickes Type A Boiler Maximum firing rate of 2008: 22,954 gals No. 4 & 6 F.O.

No. 4 and 6 F.O. 33.2MMBthfhr gross heat 2009: 30,395 gals No. 4 & 6 F.O.

Serial number NB2480 input;

Installed - 1978 5,300 gallons per calendar day For 2008 and 2009, in compliance with fuel use

of #4 and/or #6 fuel oil limitation. Sulfur content of No. 4 and 6 F.O. limited to 0.5% by weight


EU3 150 HP Dillon Boiler #1 Maximum firing rate of

No. 4 and 6 F.O. 8.2MMBtu/hr gross heat input 2008: 1,248 gals No. 4 & 6 F.O. Serial No. for each unit 32.6 hrs operated annually 2RLHCO24880 Combined fuel consumption 2009: 1,404 gals No. 4 & 6 F.O.

Installed - 1914 rate of 2,088 gallons per 41.8 hrs operated annually EU4 150 HP Dillon Boiler #2 calendar day of #4 and/or #6

No. 4 and 6 F.O. fuel oil; or

Serial No. HCO269 Combined unit maximum of EU4

Installed - 1914 38 hours of operation per 2008: 1,298 gals No. 4 & 6 F.O.

consecutive 24-hour period. 35.2 hrs operated annually

Sulfur content of No. 4 and 6 2009: 1,684 gals No. 4 & 6 F.O.

F.O. limited to 0.5% by 47.5 hrs operated annually weight

Opacity limited to 40% For 2008 and 2009, in compliance with fuel use and hours of operations limitations. -

Page 3 ofl7

Tillotson Rubber Co., Inc. Report Date. 0611112010 2009 Off-Site Compliance Evaluation

Table i - Emission Unit Identification,_Operatirg_Restrictions _ and Fuel Usage Data

Emission unit Permitted Operational Reported Operational & Fuel

Description Restrictions Usage Data .

EU5 400KW Caterpiller a) Maximum firing rate of 4.84 2008: 1,054 gals diesel fuel -

Diesel Generator MMBttr/r

59 hrs operated annually Serial No. 7613415 Rated output— 610 HP

2009: 617 gals diesel fuel Installed - 1960 Limited to 500 hours of

operation per any consecutive 43 hrs operated annually

12-month period.

Sulfur content of No. 2 F.O. For 2008 and 2009, in limited to 0.40% by weight compliance with hours of

Opacity limited to 40% operation limitation.

EU6 600 KW Caterpiller Maximum firing rate of 5.74 2008: 3,307 gals diesel fuel

Diesel Generator MMBtu/hr 185 hrs operated annually

Serial No. 81Z08025 Rated output— 890 HP 2009: 3,158 gals diesel fuel Installed - 1993 Limited to 500 hours of 200 hrs operated annually

operation per any consecutive 12-month period. For 2008 and 2009, in

Sulfur content of No. 2 F.O. compliance with hours of

limited to 0.40% by weight operation limitation.


Facility emissions for calendar years 2008 and 2009 are included in Table 2.

Table 2: Facilit\'-Wide Emissions

-

Sulfur Carbon Particulate Nitrogen

Dioxide Monoxide Matter VOCs (tPyT - i ftudcs (tpv)

t) (tpy) (P\bjo) (tpv)

!PEt-1nr11ni;`i`o11(1l 49.9 75.3 360 64 4.28

Limits J 2009 14.55 3.20 156.33 15.75 1.40

1_2008 j 15.65 3.06 170.90 17.18 1.52

Facility emissions are calculated using the facility's fuel usage data and the EPA's AP-42 emission factors. Emission limits for sulfur dioxide, carbon monoxide, particulate matter and VOCs are based on potential calculations presented in the Engineering Summary dated January 17, 2006. Sulfur dioxide emissions from EU2 are limited to 39.9 tons during any consecutive 12-month period. Tillotson is in compliance with its emission limits.

Page 4 of 17

PCE 1 Multi-cyclone dust collector without ash re- EU 1 injection - particulate control

Stack Criteria

- g l ji

'.: •

inii.sion \1 inimum SLick Ikiht (feet) \1airnum Stack Diameter Stack No. tuit # - .thocCroundLceI' orDiniensions(feet

Stack #1 EUI 55.0 4.0

Stack #2 EU2 56.63 3.5

Stack #3 .EU3 & EU4 51.17 3.17

These stacks must discharge vertically without obstruction and meet the criteria in Table 4.

CompliancewithPermittingRefluirements

CHAPTER Env-A 300 Ambient Air Quality Standards

See Part Env-A 606 below.

CHAPTER Env-A 500 - Standards Applicable to Certain New or Modified Facilities and Sources of Hazardous Air Pollutants

Tillotson's boilers are not subject to the New Source Performance Standards ("NSPS") subpart Dc - Small Industrial, Commercial, Institutional Steam Generating Units, as specified in Env-A 503.01 or 40 CFR 60. Emission units EU3 and EU4 do not meet the heat input rating threshold. Emission units EU1 and EU2 do meet the heat input rating threshold but were installed before the applicability date of June 9, 1989.

Tillotson's emergency generators are not subject to the NSPS subpart 1111 - Stationary Compression Ignition Internal Combustion Engines, as specified in Env-A 503.01 or 40 CFR 60.

1 The EU 1 stack height is referenced to the base elevation at the end of the building where the stack is located. If referenced from the west end of the building (the same base elevation as that of EU2, EU3, and EU4), the stack height is 38 feet above ground surface.

Page5 ofl7


Emission units EU5 and EU6 were manufactured and installed before the applicability date of July 11, 2005 and have not been modified after that date.

Tillotson is not a major source of hazardous air pollutants ("HAPs"), does not emit any of the HAPs listed in 40 CFR 61 and, therefore, is not subject to any of the National Emission -. Standards for Hazardous Air Pollutants ("NESHAP") specified in Env-A 504.01 and 40 CFR 61.

Tillotson is not subject to the NESHAP for Source Categories (Maximum Achievable Control Technology ("MACT") Standards), subpart DDDDD - Industrial/Commercial/Institutional Boilers & Process Heater, as specified in Env-A 505.01 or 40 CFR 63. Tillotson is not a major source of HAPs and, therefore, is exempt from this MACT.

CHAPTER Env-A 600 - Statewide Permit System

Tillotson is a major source of carbon monoxide ("CO") and, therefore, requires a Title V Operating Permit. Permit # TV-OP-026 ("the Permit") was issued by DES on March 10, 2006 and administratively amended on March 30, 2007 for the operation of a wood-fired boiler, three oil-fired boilers, and two emergency generators. The Permit expires on March 31, 2011.

On April 6, 2010, DES received a permit application for two new wood-fired boilers, a new oil-fired boiler and an emergency generator. Tillotson plans to replace the wood-fired boiler, the three oil-fired boilers, and the two emergency generators with these new combustion devices. DES issued an administrative letter of completeness on June 2, 2010. DES is in the process of drafting a new temporary State Permit to Operate for the construction of the new devices.

Part Env-A 606 Air Pollution Dispersion Modeling Impact Analysis Requirement

Modeling for this facility, conducted in November 2005, determined that in order not to exceed the AAQS for particulate matter (PM10) the fuel amount for EU1 must be limited to 120 tons per day of wood and the fuel oil usage rate of 87ga1/hr must be retained for EU2, EU3 and EU4.

Env-A 609.04 Insignificant Activities

Tillotson has identified the following insignificant activities:

• Hot air furnace using distillate oil rated at 0.39 MMbtu/hr and located in truck maintenance garage,

• Furnace using distillate oil rated at 0.101 MMbtulhr and located in the hydro building, • Boiler pilots using propane and located in the power plant, • Parts cleaner containing 30 gallons of cleaner and located in the power plant, and • Parts cleaner containing 34 gallons of cleaner and located in the truck maintenance garage.

Emissions from the insignificant activities for 2008 and 2009 were included in the respective emission reports.

Page 6 of 17


Env-A 609.08 Apilication Shield

For a discussion of the permit renewal and application shield, see Chapter 600 above.

Part Env -A 618 - Additional Requirements in Non-Attainment Areas and the New Hampshire Portion of the Northeast Ozone Transport Region

Tillotson is an existing major source located in Coos County of New Hampshire and is in the Northeast Ozone Transport Region. Tillotson is not a new major stationary source nor has it made any major modifications. Therefore, Tillotson is not subject to this part.

On April 6, 2010, Tillotson submitted a permit application to replace its current devices with two wood fired boilers, one oil fired boiler, and an emergency generator. As proposed, the planned devices will not constitute a major modification. Once these devices are fully operational, Tillotson will become a minor source for CO and no longer require a Title V permit.

Compliance with Permit Fee System

CHAPTER Env-A 700 - Permit Fee System

Env-A 705.04 - Payment of Emission-Based Fee

Emission-based fees are due by April 15 of the year following the emissions year.

Tillotson submitted timely payment of its emission-based fees for calendar years 2008 and 2009.

Source Testing and Monitoring

CHAPTER Env-A 800 - Testing and Monitoring Procedures

Tillotson is subject to the monitoring and testing requirements as contained in Table 5 below (taken from Table 5 of the Title V permit).

Table 5 - Monttormg/Testing Rc!u1I ements

Item Frequency of Applicable Coinpliaiice Parameter Method of Compliance Method Device Status

Sulfur content The operator shall conduct testing in accordance with For each Facility Tillotson is in of liquid fuels appropriate ASTM test methods or retain delivery delivery of Wide compliance.

tickets, which certify the weight percent of sulfur for fuel oil to the Sulfur content each delivery of fuel oil to determine compliance facility

of fuel with the sulfur content limitation provisions specified delivered is in this permit for liquid fuels. reported in the

TV Semi- Annual Permit Deviation and

Page 7 of 17


Table 5 - Monitoring/Testing Rec nirements

Iteni Frequency of Applicable Compliance P ii umetci Method f/l1Iuuu1t1 Meliod Device L_t ilus

Monitoring Repurts -

Upon request, Tillotson

provided fuel delivery slips for #2 and #6

fuel oil to verifv sulfur

content.

Particulate All equipment, facilities, and systems installed and At startup, Facility Tillotson is in Matter used to achieve compliance with the terms and during Wide compliance.

conditions of this Permit, shall be operated as operation, and Tillotson efficiently as possible so as to minimize air pollutant during certifies on an emissions and meet all applicable air pollution shutdown annual basis emission limits, in the TV

Annual Compliance

Certifications.

Particulate The pollution control equipment (PCE1) shall be: As specified in EU1 & Tillotson is in Matter

i Maintained regularly, n accordance with the the facility compliance

PCE1 Dates that

compliance.

maintenance schedule submitted to the division plan submitted maintenance on May 29, 2000. May 29, 2000 occurred is

Fully operational upon startup and shall not be At startup, reported in the

bypassed during the startup, operation, or during TV Semi-

shutdown of EU 1. operation and Annual Permit and Deviation

during and shutdown Monitoring

Reports.

4.. Fuel Usage The Permittee shall perform the following: Daily EU2 Tillotson is in compliance.

a) For EU2:

Monitor fuel oil usage on a calendar day For 2008 and

basis along with the hours of operation; 2009,

The fuel flow meter/recorder will be calendar day

operated and maintained to monitor fuel oil fuel oil usage

usage; and . submitted on

The fuel flow meter shall be calibrated in June 7, 2009

accordance with the manufacturer's upon request.

specifications. Fuel flow meters are

factory sealed so calibration

is unnecessary. Fuel usages fluctuations

Page 8 ofl7


1tni Trejuenc of Apjliible Coniphancc # Paianuter Metliwl of Cornphanee Mcthoc1 Dc ice Sttis

due to temperature

changes accounted for in Appendix

A of the Annual

Emission Reports.

b) For EU3 and EU4: Daily EU3 & EU4 Tillotson is in I. Monitor fuel oil usage on a calendar day compliance.

basis; Fuel flow Fuel flow meters/recorders will be operated meters are and maintained to monitor individual fuel oil factory sealed usage; and so calibration Fuel flow meters shall be calibrated in is accordance with the manufacturer's unnecessary. specifications. Fuel usages

fluctuations due to

temperature changes

accounted for in Appendix

A of the Annual

Emission Reports

Fuel Usage The wood usage for EU I shall be monitored on a Monthly EU! Tillotson is in monthly basis along with the hours of operation. compliance.

Wood usage is reported on a monthly and annual basis in the Annual

Emission Reports.

Periodic Steam Production Monitoring Continuously EU! Tillotson is in Monitoring Steam production shall be monitored on a 24-

compliance.

hour block average usmg a steam flow meter; Maximum

calendar day and average steam The steam flow meter shall be calibrated and production is maintained according to manufacturer's reported in the specifications. TV Semi-

Annual Permit Deviation and

Monitoring

Page 9 of 17


I I)lC " - wIon1u)rlil(,,,/ I esling tcC( UIFCHICIJ IS

Itun Fi eqlleII\ of Apphcabk Compliance # Parameter Method_ofCompliinc. Method Device Status

Reports.

7. Stack Testing Compliance Stack Testing Within the 5 PCE 1/EU 1 Tillotson has for Total

Suspended Compliance stack testing shall be planned and

year term of this permit,

not performed a

Particulate carried out at the frequency specified. and within 90 stack test to

Matter a) The pre-test protocol must be submitted to the days of the date. division by the facility at least 30 days prior to anniversar' of Stack testing the commencement of testing. the last stack is planned for

b) The pre-test protocol shall contain the following test Fall 2010 or

information: Winter 2011.

Calibration methods and sample data sheets; Description of the test methods to be used; Pre-test preparation procedures; Sample collection and analysis methods; Process data to be collected; and Complete test program description.

c) At least 30 days prior to the commencement of source testing, the Permittee shall notif' the division of the date(s) of the planned compliance stack testing;

d) At least 15 days prior to the test date, the facility and any contractor that the facility retains for performance of the test, shall participate in a pre-test conference with a division representative.

e) Emission testing shall be carried out under the observation of a division representative. Upon commencement of any performance test, the performance test shall not be aborted unless approved by the division.

f) The Permittee shall submit the stack test report to the division within 60 days of completion of the actual test.

8. Periodic If the indicator ranges specified in Table 5A Continuous PCEI Tillotson is in Monitoring accumulate exceedances over 5% of the rolling 12- compliance.

month total operating time for PCE 1, the Permittee To date, no shall prepare and submit a Quality Implementation events Plan (QIP) in accordance with Table 6 Item 5, and triggering this implement the plan. requirement

have occurred.

VIII. Compliance with Recordkeeping and Reporting

Page 10 of 17

Tillótson Rubber Co., Inc. Report Date: 0611112010 2009 Off-Site Compliance Evaluation

CHAPTER Env-A 900 - Owner or Operator Recordkeeping and Reporting Obligations

The Full Compliance Evaluation Records Review is included in Appendix A to this report. The appendix lists all the reports that were received and reviewed in order to complete this compliance evaluation. The records review attachment includes a determination of each report's timeliness with regard to the required submittal date.

Table 6 lists reporting requirements of Tillotson pursuant to Condition VIILF., Table 7 of the Permit and indicates if reporting requirements were met.

jll

Applicable Item Frequency of Emission Compliance

44 i?.nnt ti n(y 1?pniiirprnpntc Rpiinrtitw 1 mit StAtII

1. The Permittee shall submit a summary report of all Every 6 months Facility Wide Tillotson is in permit deviations, and testing and monitoring data as (no later than compliance. specified in Tables 5 and 5A of this permit the 30th day of These items including: the following were reported in

Summary of testmg andlor delivery ticket month of each calendar half

2008 and2009 TV Semi-

certifications for fuel sulfur content limitation year) Annual Permit provisions; Deviation and Summary of maintenance and repair records for Monitoring PCE1; Reports.

Summary of maintenance, calibration, and repair records for the fuel flow meters associated with EU2, EU3, and EU4;

Summary of fuel usage for EU 1, EU2, EU3, and EU4;

Summary of calendar day average steam production for EU 1;

0 Summary of maintenance, calibration and repair records for the steam flow meter associated with EU1;

Summary of maintenance records for the magnehelic gauge and connecting lines on PCE1;

Summary information on the number, duration, and cause of excursions from CAM permit conditions and corrective actions taken;

Description of the actions taken to implement a QIP during the reporting period;

Documentation that the implementation of the QIP has been completed and reduced the likelihood of similar levels of excursions occurring if applicable.

Page 11 of 17


Table 6 - Applicable Reporting Requirements

API) I iCa I) Ic Iteni Frequency of Eniissioii Coitiplia nec

Rtpoitiiig Reguirement Reporting Unit Status

2, The Permittee shall submit an annuaiThel usage iiiiã1T5T(ii' EUTTEU2'T For EW and report indicating consecutive calendar day and later than April EU3 & EU4 EU4, these items consecutive 12 month rolling totals of fuel utilization 151h of the were reported in for the four boilers and corresponding fuel following year) 2008 and 2009 information as outlined in Table 6, Items 6, 7, 9, and Annual

10. Emission Reports.

See discussion following this

table.

The Permittee shall submit an annual fuel usage Annually (no EU5, & EU6 Tillotson is in report indicating consecutive 24-hour period and later than April . compliance. consecutive 1 2-month rolling totals of fuel 151h of the These items utilization for each of the two emergency generators following year) were reported in and corresponding fuel information as outlined in 2008 and 2009

Tab.le 6, Item 11. Annual Emission Reports.

The Permittee shall notify the division if submittal of As PCEI Tillotson is in the QIP required in Table 6, Item 5 will exceed 180 expeditiously as compliance. days from the day the source becomes subject to the possible Tillotson has not permit condition. had any events

that would trigger

preparation of a Quality

Implementation Plan (QIP)

NOx Reporting Requirements: Annually (no Facility Wide Tillotson is in

For fuel burning devices, including boilers, and later than April

151h of the compliance.

engines, as well as miscellaneous sources, the owner following year) These items

or operator shall submit to the division, annually (no were reported in

later than April 15th of the following year), reports of 2008 and 2009 the data required by Table 6 item 13, including total Annual annual quantities of all NO emissions. Emission

Reports.

Prompt reporting of deviations from Permit Prompt Facility Wide Tillotson is in requirements shall be conducted in accordance with reporting compliance. Section XXVIII of this Permit. (within 24 hours Tillotson had no

of an permit occurrence) deviations to

report.

Page 12 of 17


Aplièable Item

: Frequency of lEniissioii Compliance Repqj Unit Sttims

Any report submitted to the division and/or EPA As specified Facility Wide Tillotson is in shall include the certification of accuracy statement compliance. outlined in Section XXI.B of this Permit and shall be Submitted signed by the responsible official.

reports included certification of

accuracy statement.

Annual reporting and payment of emission based Annually (no Facility Wide Tillotson is in fees for pollutants, including but not limited to SO2, later than April compliance. NO CO, TSP, and VOCs, shall be conducted in 151h of the See Appendix accordance with Section XXIII of this Permit. following year)

A.

Annual compliance certification shall be submitted Annually (no Facility Wide Tillotson is in in accordance with Section XXI of this Permit. later than April compliance.

15th of the followmg year)

See Appendix A.

Condition VIII.F., Table 7 of the Permit requires Tillotson to submit an annual fuel usage report indicating consecutive calendar day and consecutive 12-month rolling totals of fuel utilization for the four boilers and corresponding fuel information as outlined in Table 6, Items 6, 7, 9, and 10. For EU1 and EU2, the 12-month rolling totals of fuel usage were reported in the 2008 and 2009 Annual Emission Reports. However, the calendar day usages were not reported in the 2008 and 2009 Annual Emission Reports. Tillotson promptly provided the calendar day fuel usages for EU1 and EU2 upon request.

Tillotson failed to report calendar day fuel usages for EU1 and EU2 in the 2008 and 2009 Annual Emission Reports.

IX. Compliance with RACT

CHAPTER Env-A 1200 - Prevention, Abatement, and Control of Stationary Source Air Pollution

Part Env-A 1204 - Stationary Sources of VOCs

Tillotson has no devices or processes that are subject to Reasonably Available Control Technology ("RACT") requirements for VOCs.

Part Env-A 1211 - Nitrogen Oxides

The Permit contains a facility-wide fuel limit, which limits facility-wide NOx emissions to less

Page 13 of 17


than 50 tons per year. For 2008 and 2009, NOx annual emissions were reported as 15.65 and 14.55 tons, respectively. These NOx emissions are well below the 50 tons per year permitted limit; therefore, Tillotson is in compliance with this part.

Compliance with Toxics Regulations

CHAPTER Env-A 1400 - Regulated Toxic Air Pollutants ("RTAPs")

Fuel burning devices burning virgin fuels are exempt from an Env-A 1400 compliance determination.

Tillotson operates two parts cleaners which are listed as insignificant devices. These parts cleaners use Safety-Kleen 105 Solvent Recycled, which contains two RTAPs, petroleum distillates (CAS# 64742-47-8) and tetrachloroethylene (CAS# 127-18-4), as the parts cleaning fluid. As long as the parts cleaners are operated in accordance with manufacturer specifications, an Env-A 1400 compliance determination is not necessary.

There are no other devices at Tillotson which emit RTAPs that require an air toxics compliance determination.

Compliance with Process/Particulate/Opacity Regulations

CHAPTER Env-A 1600 - Fuel Specifications

Env-A 1603.01 - Applicable Liquid Fuels

Tillotson uses No. 2, 4 and/or 6 fuel oils in EU2, EU3, EU4, EU5 and EU6.

Env-A 1604.01 - Maximum Sulfur Content Allowable in Liquid Fuels

Env-A 1604.01 limits the sulfur content of the #4 and #6 fuel oil used in the oil-fired boilers to 0.5% sulfur by weight (44 and #6 fuel oil). Tillotson reported the sulfur content of the #6 fuel oil for each delivery in the Annual Emission Reports. For 2008 and 2009, Tillotson did not receive any #4 fuel oil.

Env-A 1604.01 limits the sulfur content of the #2 fuel oil used in the emergency generators to 0.4% sulfur by weight (#2 fuel oil). Tillotson reported the sulfur content of the #2 fuel oil for each delivery in the Annual Emission Reports.

Upon request, Tillotson provided #2 fuel oil delivery slips for deliveries on May 4, 2009 and November 17, 2009. Tillotson also provided #6 fuel oil delivery slips for a delivery received on January 19, 2009. All deliveries met the sulfur content limitation for each type of fuel oil; therefore, Tillotson provided written verification of the sulfur content of the fuel oil being used as required by Condition VIII.F., Table 6, Item 6, of the Title V permit.

Page 14 of 17


CHAPTER Env-A 2000 - Fuel Burning Devices

Env-A 2002.01 - Visible Emission Standard for Fuel Burning Devices Installed on or Prior to May 13, 1970 (eff 4123105;formerly Env-A 2003.01, eff 511197)

For the Facility, Env-A 2002.01 limits the emissions from EU3, EU4 and EU5 subject to this part to 40% opacity. Since this is an off-site inspection and the Facility does not have continuous emission monitoring systems, opacity was not verified.

Part Env-A 2002.02 - Visible Emission Standard for Fuel Burning Devices Installed After May 13, 1970 (eff 4123105; formerly Env-A 2003.02, eff 511197)

For the Facility, Env-A 2002.02 and the permit limits the emissions from EU1, EU and EU6 subject to this part to 20% opacity. Since this is an off-site inspection, opacity was not verified.

Env-A 2002.06 - Particulate Emission Standards for Fuel Burning Devices Installed on or Prior to May 13, 1970 (eff 4123105;formerlyEnv-A 2003.06, eff 511197)

Applicable particulate emission standards are based on specific requirements in the Permit and the formula presented in Env-A 2002.06. Applicable emission units are EU3, EU4 and EU5. Compliance with emission standards for the fuel burning devices can only be determined through stack testing which has not been completed, to date. Based on a conversation on June 7, 2010 with Ronald Guerin, stack testing is planned for the Fall 2010 or Winter 2011.

Env-A 2002.07 - Particulate Emission Standards for Fuel Burning Devices Installed After May 13, 1970 but Before January 1, 1985 (eff 4123105; formerly Env-A 2003.07, eff 51119 7)

Applicable particulate emission standards are based on specific requirements in the Permit and the formula presented in Env-A 2002.07. Applicable emission units are EU1 and EU2. Compliance with emission standards for the fuel burning devices can only be determined through stack testing which has not been completed, to date Based on a conversation on June 7, 2010 with Ronald Guerin, stack testing is planned for the Fall 2010 or Winter 2011.

Env-A 2002.08 - Particulate Emission Standards for Fuel Burning Devices Installed On or After January 1, 1985 (eff 4123105; formerly Env-A 2003,08, eff 511197)

Applicable particulate emission standards are based on specific requirements in the Permit and the formula in Env-A 2002.08. The applicable unit is EU6. Compliance with emission standards for the fuel burning devices can only be determined through stack testing which has not been completed, to date. Based on a conversation on June 7, 2010 with Ronald Guerin, stack testing is planned for the Fall 2010 or Winter 2011.

Page 15 of 17

Tillotson Rubber Co., Inc. Report Dale: 0611112010 2009 Off-Site Compliance Evaluation

Compliance With Applicable Federal Rules

See section Chapter Env-A 500 for a discussion of applicable Federal standards.

40 CFR 70.6 (a)(3) Permit Content, Monitoring, Record Keeping, and Reporting Requirements

Tillotson is meeting its Title V permit requirements (see the Full Compliance Evaluation Records Review, attached).

Enforcement History and Status

For 2008 and 2009, there are no past or ongoing enforcement actions against Tillotson.

Conclusions and Recommendations

The following deficiency was identified during the inspection:

Tillotson failed to report calendar day fuel usages for EU1 and EU2 in the 2008 and 2009 Annual Emission Reports. This information was promptly submitted upon request.

To remain in compliance with the Title V Permit, Tillotson must report calendar day fuel usages for EU1 and EU2 in the Annual Emission Reports.

Attachments: Appendix A - Full Compliance Evaluation Records Review.

Page 16 of 17


Appendix A Full Compliance Evaluation Records Review

Facility: Tillotson Rubber Co., Inc. Date of FCE: June 11,2010 Reviewer: Margaret Bastien

Annual Emission Renorts (md. NOx. VOC etc.: Period When Rec'd RepptOK In Database

2009 03/15/2010 Yes Yes 2008 03/13/2009 Yes Yes

Annual Emissions-Based Fee Payments:

Wkw 2009 04/02/2010 Yes, in DES Emission Section's Spreadsheet 2008 03/26/2009 Yes, in DES Emission Section's Spreadsheet

TV Annual Comnliance Certifications: Reporting Period WienRec'd Rgpp()K In Danihase

2009 03/15/2010 Yes Yes 2008 03/12/2009 Yes Yes

TV Semi-Annual Permit Deviation and Monitoring Renorts: Reporting Period ReporLQ Iii Database

2009 01/25/2010 Yes Yes 2009 07/23/2009 Yes Yes 2008 01/26/2009 Yes Yes 2008 07/21/2008 Yes Yes

Individual Permit Deviations Reports: None to report.

Quarterly Continuous Emission Monitoring Excess Emission Reports (CEM EERs): Not applicable

CEM Audits (OPAs, CGAs, RAAs, RATAs): Not applicable

Stack Tests: None to date

Other reports: Not applicable

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