From: Spenillo, Justin

To: Spenillo, Justin

Subject: Klamath Falls: Stationary Source Controls - Docket

Date: Monday, March 16, 2015 12:53:23 PM

Phone Interview w/ ODEQ – 6/17/2014

OEA/R10,  Basic technical analysis, Cursory Review – 3/25/2014

From: Hedgpeth, Zach

Sent: Tuesday, March 25, 2014 1:24 PM

To: Spenillo, Justin

Subject: RE: Klamath Falls: Stationary Source Controls

Justin,

See below for the results of my cursory review of the PM, NOx, VOC, and SO2 controls at

the five stationary sources you identified in Klamath Falls.  These reviews are based

solely on the Title V permits you provided, due to time constraints.  Please let me know

if anything further is needed.

Masco Bath Corporation:

This facility is a bathware manufacturer.  The air pollutant emitting processes at the

facility include fiberglass laminate manufacturing, paint booths, and misc activities.  The

paint booths have filters to control for PM, but no control for VOC.  This is a common

level of control for paint booths.  The facility as a whole is uncontrolled for VOC and is

permitted to emit about 200 tons per year.  Emissions of NOx and SO2 are limited to 39

tons per year.  The facility has no controls for NOx or SO2 other than using natural gas, a

relatively clean fuel.

Klamath Energy LLC:

This facility is a power plant fired on natural gas.  The facility has six natural gas

combustion turbines which are all equipped with SCR; 5 of the 6 also are equipped with

water injection and CO catalyst.  SCR with or without water injection reflects a high level

of control for NOx.  Natural gas turbines are generally clean emitters with respect to PM

and SO2.

JELD-WEN Inc:

This facility includes a variety of business types such as wood products and chrome

plating.  The facility has a large number of emission units, some of which are equipped

with higher level air pollution control devices such as baghouses and ESPs.  A more
rigorous review would be necessary to examine the level of control in more detail due to

the number and complexity of plant processes and emission units.  The facility is

permitted to emit relatively low levels of PM, SO2, CO, and NOx, but almost 300 tons per

year VOC.

Collins Products Inc:

This facility is a reconstituted wood products facility.  Most of the larger emission units

appear to be controlled via fabric filters for PM.  The hardboard bake oven is also

controlled by an RTO/RCO for VOC control.  These two control technologies reflect

generally higher level control.  There are a large number of smaller emission units for

which a more rigorous review would be necessary in order to fully understand the level

of control.  The facility is permitted to emit almost 400 tons per year PM and more than

200 tons per year PM-10.  This suggests there may be opportunity to enhance PM

controls at the facility.  The facility is also permitted to emit over 1,200 tons per year

VOC, which also suggests potential for improved air pollution control.  Emissions of NOx

and SO2 are relatively low.

Columbia Forest Products, Inc:

This facility is a plywood manufacturer.  The facility has two wood fired boilers, one of

which is equipped with a multiclone for PM control while the other is uncontrolled.  This

reflects a low level of PM control with significant opportunity to further reduce

emissions through implementation of modern air pollution control technology.  The

boilers are also uncontrolled for other pollutants.  The facility also has veneer dryers

and plywood presses which are uncontrolled, again reflecting a low level of control for

VOC/HAP.  Significant opportunity exists for reduced emissions through installation of

modern VOC controls on the veneer dryers and plywood presses.  The facility is

permitted to emit around 100 tons per year PM-10 and 150 tons per year VOC.

Zach Hedgpeth, PE

Air Pollution Control Technology & Emission Testing

Office of Environmental Assessment

EPA Region 10 -- Seattle

hedgpeth.zach@epa.gov

206-553-1217