Collins Pine Company

29100 SW Town Center Loop W • Suite 300 Et4~.. : ~Di1 ii:is Wilsonville, OR

CollinsWood.com

8 October, 2015 Transmitted via E-mail

Mr. Gerardo Rios

Chief, Permits Office

San Francisco, CA 94105 OCT 14 ~15

RE: Collins Pine Company Chester, California Sawmill

Application for an Amendment to Prevention of Significant Deterioration Permit

Conditions

Dear Mr. Rios:

Enclosed please find an application for an amendment to permit conditions contained in the

Prevention of Significant Deterioration (PSD) Permit (NSR 4-4-4, SAC 84-02) for the Collins Pine

Company (Collins) facility in Chester, California.

One of the emission units covered by the PSD permit is a 242.3 MMBtu/hr wood-fired boiler abated

by an electrostatic precipitator (ESP). The requested amendment will allow Collins to replace the

existing wet ESP with a new dry ESP. This will eliminate a process wastewater stream and reduce

water consumption at the facility without affecting compliance with any permit limit. This change is

requested so that Collins can respond to specific requests from the community for the company to

reduce water consumption and process wastewater discharges from the mill.

All of the applicable federal Environmental Protection Agency (EPA) and the Northern Sierra Air

Quality Management District (NSAQMD or District) regulations will continue to be met. There will be

no emission increase; no new air quality regulatory requirements will be triggered for this facility.

Neither the nature nor the size of the boiler is being altered.

The proposed permit amendment will have no impact on emissions or air quality.

Collins requests that EPA determine that the amendments are administrative in nature and not

subject to public review requirements.
Gerardo Rios

October 8, 2015

Our Chester Sawmill facility contact is:

Mr. Chris Verderber

Chester Sawmill Operations Manager

500 Main Street

P.O. Box 796

Chester, CA 96020

530-248-4422

If you have any questions regarding this application, please contact Gary Rubenstein or Steve Hill

with Sierra Research via email at GRubenstein~sierraresearch.com or shill(ä~sierraresearch.com,

respectively or by phone at (916) 444-6666.

Sincerely

CIollins Pine Company

Jess Brown

Environmental Manager

sh/jab

enclosures

cc: Chris Verderber (w/enclosure)

Thomas Wood, Stoel Rives LLP (w/enclosure)

Joe Fish, NSAQMD (w/enclosure)

Steve Hill, Sierra Research (wlo enclosure)

File

i:\portland\shared folders\environmental\public\chester\air post-2014 sec 114 response\regulatory agency corresponctence\written\201 5-10-

08jsd_application_cover_Ietter.docx
©

Application to the Federal

Environmental Protection

Agency for an Amendment to

PSD Permit Conditions

prepared for:

Collins Pine Company

October 2015

prepared by:

Sierra Research

1801 J Street

Sacramento, California 95811

(916) 444-6666
APPLICATION TO THE FEDERAL ENVIRONMENTAL

PROTECTION AGENCY FOR AN AMENDMENT TO PSD PERMIT

CONDITIONS

Submitted on behalf of:

Collins Pine Company

Chester Sawmill

P.O. Box 796

500 Main Street

Chester, CA 96020

October 2015

Prepared by:

Sierra Research

1801 J Street

Sacramento, CA 95811

(916) 444-6666
APPLICATION TO THE FEDERAL ENVIRONMENTAL

PROTECTION AGENCY FOR AN AMENDMENT TO PSD PERMIT

CONDITIONS

Table of Contents

1. Summary 1

2. Overall Project Description 2

2.1 Applicant’s Name and Business Description 2

2.2 Type ofApplication 3

2.3 Description of Facility 3

2.4 Description of Proposed Project 5

2.5 Proposed Emissions 6

3. Compliance with Applicable Rules and Regulations 8

3.1 New Source Review and Prevention of Significant Deterioration 8

3.2 Federal New Source Performance Standards 9

4. Ambient Air Quality Standards 10
List of Figures

Figure

Figure 2-1 Facility Location 4

List of Tables

Table f~gç

Table 2-1 Collins Pine No. 4 Boiler Specifications 5

—11—
1. SUMMARY

Collins Pine Company (“Applicant”) is requesting that EPA PSD Permit NSR 4-4-4,

SAC 84-02, for construction and operation of the Boiler No. 4 wood-fired cogeneration

plant at its facility in Chester, California, be amended. The requested amendments are as

follows:

The existing permit requires the use ofa wet electrostatic preczpitator (“ESP’9

for control ofparticulate emissions (Condition XB. 1). Applicant requests that

this requirement be amended to allow the use ofa dry ESF capable ofmeeting the

control requirements.

The requested amendment will allow Applicant to replace the existing wet ESP with a

new dry ESP. This will eliminate a wastewater stream and reduce water consumption at

the facility, without affecting compliance with any permit limit. This change is requested

so that Collins can respond to specific requests from the community for the company to

reduce water consumption and discharge at the mill.

All of the applicable federal Environmental Protection Agency (EPA) and the Northern

Sierra Air Quality Management District (NSAQMD or District) regulations will continue

to be met. There will be no emission increase; no new air quality regulatory requirements

will be triggered for this facility. Neither the nature nor the size ofthe boiler is being

altered.

The proposed permit amendment will have no impact on emissions or air quality.

Relevant EPA guidance indicates that the proposed pennit amendment should be

classified as an administrative change: “An administrative change involves no increase

in either emissions or ambient impacts and no fundamental change in either the source or

one ofthe emission units at that source.”

Applicant requests that EPA determine that the amendments are administrative in nature

and not subject to public review requirements.

Guidance Documentfor Prevention ofSign~flcant Deterioration Permit Mod~/Ications, June 1991, p. 3-2.

—1—
2. OVERALL PROJECT DESCRIPTION

2.1 Applicant’s Name and Business Description

Name of Applicant: Collins Pine Company

Address: 500 Main Street

P.O. Box 796

Chester, CA 96020

Plant Contact: Mr. Chris Verderber

Chester Sawmill Operations Manager

530-248-4422

Mailing Address for Permits and Correspondence:

Same as above with copy to:

Sierra Research

1801 J Street

Sacramento, CA 95811

General Business Description: Lumber Mill

Submitting Officer: Mr. Chris Verderber

Consultants:

Sierra Research

1801 J Street

Sacramento, CA 95811

Contact: Steve Hill

(510) 684-3671

-2-
2.2 Type of Application

This is an original application for an administrative change to the PSD permit (NSR 4-4-

4, SAC 84-02), issued for the construction of Collins Pine Boiler No. 4 wood-fired

cogeneration boiler, as most recently amended on September 11, 1997. This application

is made to the U.S. EPA, Region IX, San Francisco, CA.

2.3 Description of Facility

2.3.1 Location

The Collins Pine Company lumber production facility is located at 500 Main Street in

Chester, California. Chester is in Plumas County, within the Northern Sierra Air Quality

Management District, within the Mountain Counties Air Basin.

The nearest federal Class I area is the Lassen Volcanic National Park/Caribou Wilderness

Area. The facility is located 13.7 kilometers south of the southeastern corner of the park.

The only other Class I area located within 100 kilometers of the facility is the Thousand

Lakes Wilderness Area, which is approximately 47 kilometers north of the facility. A

map showing the facility and the surrounding area is presented as Figure 2-1.

-3-
Figure 2-1

Facility Location

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2.3.2 Existing Facility

The existing steam and power production plant at Collins Pine consists of the No. 4

boiler, a woodwaste-fired water tube steam boiler that is rated for 140,000 pounds per

hour (lbs/br) of high pressure steam, and a turbine generator set capable of generating 12

MW of electricity. Boiler exhaust gases are ducted in series tbrough a rotary fuel dryer, a

cyclone collection system, and a wet ESP. Equipment specifications for the boiler are

presented in Table 1. Continuous emission monitoring (CEM) systems for monitoring

CO and NOx were installed in 1991.

Table 2-1

Collins Pine No. 4 Boiler Specifications

Parameter Specification

Equipment Description Hogged woodwaste-fired boiler

Boiler Type Stoker-spreader with over-fire air

Manufacturer Keeler/Dorr-Oliver Typ “MKB”

Firing Rate (HHV) 242.3 MMBtu!hr

Rated Steam Output 140,000 lbs/br

Electric Generator Set 12 MW

Ancillary Equipment Conveyors, Classifiers, Rotary Fuel Dryer

Abatement Device Multiclone Dust Collector, Cyclone Collector, wet ESP

. . Steam Flow Meter, Carbon Monoxide CEM, Nitrogen Momtoring Systems Oxides CEM, CO2 CEM, Stack Flow Rate Monitor

2.4 Description ofProposed Project

2.4.1 General Description

Under this amendment, Applicant requests authorization to replace its existing wet ESP

with a dry ESP. No change to allowable emission levels or rates is requested. The new

dry ESP will continue to meet all emission limits applicable to the existing wet ESP. The

proposed amendment will not increase the maximum daily or annual rate of steam

production or fuel consumption, or increase any regulated compound’s emission rates

above its significance tbreshold, as defmed in the PSD regulations and the facility’s PSD

permit. Further, these changes will not affect the air quality demonstration made in

support of the original PSD pennit.

This amendment is needed in order to eliminate the wastewater stream currently

generated by operating a wet ESP. Applicant has committed to eliminating this

wastewater stream as part of a settlement agreement with local community groups over

alleged effluent discharge permit violations.

-5-
The original 1984 PSD permit concluded that installation of an ESP constituted BACT.

The PSD permit did not specify that the ESP had to be dry or wet. When the PSD permit

was amended in 1997, the word “wet” was inserted before the term “electrostatic

precipitator” in PSD Permit Condition X.B. 1. This change was not relevant to the 1997

amendments and was not carried through other parts of the permit (see, e.g., PSD Permit

Condition X.G.2 which refers only to “ESP”). This amendment requests removal of the

word “wet” prior to the term “electrostatic precipitator” in PSD Permit Condition X.B. 1.

No other changes are requested to the permit.

2.4.2 Description of Proposed Dry ESP

The proposed dry ESP and stack is to replace an existing wet ESP and stack. The ESP

follows an existing air preheater, multiple cyclone particulate collector and induced draft

fan. Fuel will continue to be hogged wood and bark with an average moisture content of

3 0-40% by weight.

2.5 Proposed Emissions

Applicant proposes to retain all of the emission limits in the existing PSD permit. Those

limits are summarized below.

Because the combustion process is not being altered, no change to combustion emissions

is expected, and no change to combustion limits is requested.

Because the dry ESP is expected to perform at least as effectively as the wet ESP, no

change to particulate emissions is expected, and no change to particulate limits is

requested.

2.5.1 Operating limits

Operation ofBoiler No. 4 is limited to 8,592 hours per year. Operation in transient mode

(startup, shutdown, and malfunctions) is limited to 500 hours per year.

Except where noted below, emission limits are 3-hour averages.

2.5.2 Particulate Matter (PM10)

The existing PSD permit limits io emissions from the ESP stack to 13.0 lbs/hr or

0.0265 gr/dscf @ 12% C02 (3-hour average). No change to these limits is requested.

2.5.3 Nitrogen Oxides (NOx)

The existing PSD permit limits NOx emissions from the ESP stack to 55 lbs/hr or 145

ppm @ 12% CO2 (3-hour average) during normal operations and 85 lbs/hr or 165 ppm

-6-
or 145 ppm @ 12% CO2 (3-hour average) during transient conditions. No change to

these limits is requested.

2.5.4 Carbon Monoxide (CO)

The existing PSD permit limits CO emissions from the ESP stack to 220 lbs/hr during

normal operations (3-hour average) and 975 lbs/hr during transient conditions (3-hour

average), and 575 lbs/hour during transient conditions (8-hour average). No change to

these limits is requested.

15i Proposed Amendment to Existing PSD Permit

Collins Pine requests an amendment to PSD Permit Condition X.B. 1, as indicated in the

italicized underline/strike-out text below.

X Special Conditions

B. Air Pollution Control Equipment

Collins Pine shall install~ continuously operate and maintain thefollowing

airpollution controls to minimize boiler No. 4 emissions. Controls listed

below shall befully operational on and after the effective date ofthis

permit.

1. Collins Pine shall operate an we~ electrostatic precipitator (WEP~~)

for control ofparticulate emissions. Exceptforperiods ofupset,

breakdown, orpre-scheduled washing, all exhaust gasesfrom the

boiler shall be vented through the WEP~.

2. Collins Pine shall operate and maintain a multiclone dust collector.

All exhaust gasesfrom the boiler must always be directed through the

multiclone.

###

7..
3. COMPLIANCE WITH APPLICABLE RULES AND

REGULATIONS

3.1 New Source Review and Prevention of Significant Deterioration

EPA has promulgated PSD regulations for areas that are in compliance with national

ambient air quality standards (40 CFR 52.21). The NSAQMD, where the Collins Pine

Company facility is located, is designated as attainment or unclassified for national

ambient air quality standards for all the pollutants covered by the PSD program (criteria

pollutants). In the NSAQIvID, EPA has retained jurisdiction over the PSD program; the

NSAQMD has not been delegated authority to administer the program for EPA.

The PSD requirements apply on a pollutant-specific basis to any project that is a new

major stationary source or a major modification to an existing major stationary source.

The determination of applicability to Collins Pine is based on evaluation of the proposed

changes to the PSD permit conditions.

The PSD regulations define a major source as any source type belonging to a list of 28

source categories that emits or has the potential to emit 100 tons per year, or any other

source type that emits or has the potential to emit 250 tons per year or more on a pollutant

specific basis. The Collins Pine facility does not fall into one of the listed 28 source

categories; however, because boiler emissions of CO exceed 250 tons per year, it is an

existing major stationary source for this pollutant.

The PSD regulations define a modification as any physical change or change in the

method of operation that results in an increase in emissions of a regulated pollutant. A

major modification is one that will result in both a significant increase and a significant

net increase in emissions of the regulated pollutant.

As indicated above, the only pollutant for which Collins Pine facility is “major” is CO.

The proposed change, replacement of one particulate control device with another, equally

effective, particulate control device, is not expected to affect CO emissions at all.

Operation of the boiler in the future is expected to continue as it has in the past. The

proposed change will not increase the boiler’s design capacity or its potential to emit any

regulated pollutant. Applying the “Actual-to-projected-actual” applicability test for

projects that only involve existing emission units, there will be no increase in emissions

of any pollutant as a result of this change. The Applicant will continue to meet the

-8-
annual and hourly emission limits and there will be no significant increase in any PSD

pollutants.

Because the change will not result in a significant increase of any PSD pollutant or any

increase in a Best Available Control Technology (BACT) emission rate, or have any

effect on air quality, the PSD permit can be amended administratively to implement the

proposed change.

In the NSAQMD, where the facility is located, the NAAQS have not been exceeded for

any of the criteria pollutants. Therefore, NSR regulations do not apply to the requested

permit amendment.

3.2 Federal New Source Performance Standards

The Standards ofPerformance for New Stationary Sources (NSPS) are source categoryspecific federal regulations, limiting the allowable emissions of criteria pollutants (i.e.,

those that have a national ambient air quality standard). NSPS apply to sources that have

been constructed, reconstructed, or modified after the applicability data for the standard.

Replacement of the Boiler No. 4 wet ESP with a dry ESP does not constitute

reconstruction or modification of the affected facility as those terms are defined in NSPS

regulations. Even assuming that the ESP is part of the affected facility, replacement of

the ESP will not cost more than 50 percent of the cost of a new affected facility. Also,

replacement of the ESP will not result in an increase in the hourly capacity to emit any

pollutants regulated under the Boiler NSPS.

-9-
4. AMBIENT AIR QUALITY STANDARDS

EPA PSD regulations also prohibit the granting of a permit that would prevent the

attainment and maintenance of ambient air quality standards. Because the proposed

amendment will not result in a change in emissions, the proposed amendment will not

prevent attainment or maintenance of ambient air quality standards.

No impact analysis was performed for this application.