### Collins Pine Company 29100 SW Town Center Loop W • Suite 300 

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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) forthe Collins Pine Company (Collins) facility in Chester, California. One ofthe emission units covered bythe PSD permit is a 242.3 MMBtu/hrwood-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 wastewaterstream 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 communityforthe company to reduce water consumption and process wastewaterdischarges from the mill. All ofthe 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 forthis facility. Neitherthe nature northe size ofthe 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 Ifyou 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\airpost-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 behalfof: Collins Pine Company Chester Sawmill P.O. Box 796 500 Main Street Chester, CA 96020

October2015

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 ofContents

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 ofFacility 3 2.4 Description ofProposed Project 5 2.5 Proposed Emissions 6 3. Compliance with Applicable Rules and Regulations 8 3.1 New Source Review and Prevention ofSignificant Deterioration 8 3.2 Federal New Source Performance Standards 9 4. Ambient Air Quality Standards 10List ofFigures

Figure Figure 2-1 Facility Location 4

List ofTables
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 ofthe BoilerNo. 4wood-fired cogeneration plant at its facility in Chester, California, be amended. The requested amendments are as follows: The existingpermit requires the use ofa wet electrostaticpreczpitator (“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 amendmentwill allow Applicant to replace the existing wet ESP with a new dry ESP. This will eliminate awastewater stream and reducewaterconsumption at the facility, without affecting compliance with any permit limit. This change is requested so that Collins can respond to specific requests from the communityforthe companyto reduce water consumption and discharge atthe mill. All ofthe applicable federal Environmental Protection Agency (EPA) and the Northern SierraAir Quality Management District (NSAQMD or District) regulations will continue to be met. There will be no emission increase; no new airquality regulatoryrequirements will be triggered forthis facility. Neitherthe nature northe size ofthe boiler is being altered. The proposed permit amendment will have no impact on emissions or air quality. Relevant EPA guidance indicates thatthe proposed pennit amendment should be classified as an administrative change: “An administrative change involves no increase in either emissions orambient impacts and no fundamental change in eitherthe source or one ofthe emission units at that source.” Applicant requests that EPA determine thatthe amendments are administrative in nature and not subjectto public review requirements.

Guidance DocumentforPrevention 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 ofApplicant: 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 copyto: 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 ofApplication

This is an original application for an administrative change to the PSD permit (NSR 4-4- 4, SAC 84-02), issued forthe construction ofCollins Pine BoilerNo. 4 wood-fired cogeneration boiler, as most recentlyamended on September 11, 1997. This application is made to the U.S. EPA, Region IX, San Francisco, CA.


### 2.3 Description ofFacility 2.3.1 Location The Collins Pine Company lumberproduction 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 nearestfederal Class I area is the Lassen Volcanic National Park/Caribou Wilderness Area. The facility is located 13.7 kilometers south ofthe southeastern corner ofthe park. The onlyother Class I area located within 100 kilometers ofthe facilityis the Thousand Lakes Wilderness Area, which is approximately47 kilometers north ofthe 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 powerproduction plant at Collins Pine consists ofthe No. 4 boiler, awoodwaste-fired watertube steam boilerthat is rated for 140,000 pounds per hour (lbs/br) ofhigh pressure steam, and aturbine generator set capable ofgenerating 12 MW ofelectricity. Boiler exhaust gases are ducted in series tbrough a rotary fuel dryer, a cyclone collection system, and awet ESP. Equipment specifications forthe 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 BoilerType Stoker-spreaderwith over-fire air Manufacturer Keeler/Dorr-OliverTyp “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 Underthis 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 amendmentwill not increase the maximum daily or annual rate ofsteam production orfuel 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 affectthe air quality demonstration made in support ofthe original PSD pennit. This amendment is needed in orderto eliminate the wastewater stream currently generated byoperating awet ESP. Applicant has committed to eliminating this wastewaterstream as part ofa settlement agreementwith local community groups over alleged effluent discharge permitviolations.

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

The PSD permit did not specifythat the ESP had to be dryorwet. 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 relevantto the 1997 amendments and was not carried through otherparts ofthe permit (see, e.g., PSD Permit Condition X.G.2 which refers onlyto “ESP”). This amendment requests removal ofthe word “wet” priorto the term “electrostatic precipitator” in PSD Permit Condition X.B. 1. No otherchanges are requested to the permit. 2.4.2 Description ofProposed Dry ESP The proposed dry ESP and stack is to replace an existing wet ESP and stack. The ESP follows an existing airpreheater, multiple cyclone particulate collectorand induced draft fan. Fuel will continue to be hogged wood and barkwith an average moisture content of 30-40% byweight. 

### 2.5 Proposed Emissions Applicant proposes to retain all ofthe emission limits in the existing PSD permit. Those limits are summarized below. Becausethe combustion process is not being altered, no changeto combustion emissions is expected, and no change to combustion limits is requested. Becausethe dry ESP is expected to perform at least as effectivelyas the wet ESP, no change to particulate emissions is expected, and no changeto particulate limits is requested. 2.5.1 Operating limits Operation ofBoilerNo. 4 is limited to 8,592 hours peryear. Operation in transient mode (startup, shutdown, and malfunctions) is limited to 500 hours peryear. Exceptwhere noted below, emission limits are 3-hour averages. 2.5.2 Particulate Matter (PM10) The existing PSD permit limits io emissions from the ESP stackto 13.0 lbs/hror 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 stackto 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 stackto 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 amendmentto 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 boilerNo. 4 emissions. Controls listed below shall befully operational on and after the effective date ofthis permit. 1. Collins Pine shall operate an we~ electrostaticprecipitator (WEP~~) for control ofparticulate emissions. Exceptforperiods ofupset, breakdown, orpre-scheduled washing, all exhaustgasesfrom the boilershall be vented through the WEP~. 2. Collins Pine shall operate and maintain a multiclone dust collector. All exhaustgasesfrom 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 airquality standards (40 CFR 52.21). The NSAQMD, where the Collins Pine Company facility is located, is designated as attainment or unclassified for national ambient airqualitystandards for all the pollutants covered bythe PSD program (criteria pollutants). In the NSAQIvID, EPA has retainedjurisdiction overthe PSD program; the NSAQMD has not been delegated authorityto administerthe program for EPA. The PSD requirements applyon a pollutant-specific basis to anyprojectthat is a new major stationary source or a majormodificationto an existing major stationary source. The determination ofapplicabilityto Collins Pine is based on evaluation ofthe proposed changes to the PSD permit conditions. The PSD regulations define a majorsource as any source type belonging to a list of28 source categories that emits orhas the potential to emit 100 tons peryear, or any other source type that emits orhas the potential to emit250 tons peryear or more on apollutant specific basis. The Collins Pine facility does not fall into one ofthe listed 28 source categories; however, because boiler emissions ofCO exceed 250 tons peryear, it is an existing major stationary source forthis pollutant. The PSD regulations define a modification as anyphysical change orchange in the method ofoperation that results in an increase in emissions ofa regulated pollutant. A major modification is one thatwill result in both a significant increase and a significant net increase in emissions ofthe regulated pollutant. As indicated above, the onlypollutant forwhich Collins Pine facility is “major” is CO. The proposed change, replacement ofone particulate control device with another, equally effective, particulate control device, is not expected to affect CO emissions at all. Operation ofthe boiler in the future is expected to continue as it has in the past. The proposed change will not increase the boiler’s design capacityorits potential to emit any regulated pollutant. Applying the “Actual-to-projected-actual” applicabilitytest for projects that only involve existing emission units, therewill be no increase in emissions ofanypollutant as a result ofthis change. The Applicantwill continueto meetthe

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

pollutants. Because the changewill not result in a significant increase ofany PSD pollutant or any increase in a BestAvailable Control Technology (BACT) emission rate, orhave any effect on air quality, the PSD permit can be amended administrativelyto implement the proposed change. In the NSAQMD, where the facility is located, the NAAQS have not been exceeded for any ofthe criteriapollutants. Therefore, NSR regulations do notapplyto the requested permit amendment. 

### 3.2 Federal New Source Performance Standards The Standards ofPerformance forNew Stationary Sources (NSPS) are source categoryspecific federal regulations, limiting the allowable emissions ofcriteria pollutants (i.e., those that have a national ambient airquality standard). NSPS applyto sources that have been constructed, reconstructed, or modified afterthe applicability data forthe standard. Replacement ofthe BoilerNo. 4 wet ESP with a dry ESP does not constitute reconstruction ormodification ofthe affected facility as thoseterms are defined in NSPS regulations. Even assuming thatthe ESP is part ofthe affected facility, replacement of the ESP will not cost more than 50 percent ofthe cost ofa new affected facility. Also, replacement ofthe ESP will not result in an increase in the hourlycapacityto emit any pollutants regulated underthe Boiler NSPS.

-9-

### 4. AMBIENT AIR QUALITY STANDARDS

EPA PSD regulations also prohibitthe granting ofa permitthatwould prevent the attainment and maintenance ofambient air quality standards. Becausethe proposed amendmentwill not result in a change in emissions, the proposed amendmentwill not prevent attainment ormaintenance ofambient air quality standards. No impact analysis was performed forthis application.