S. Kingsley MacomberSierra Research

1801 J Street

Sacramento, CA 95814

Dear Mr. Macomber:

This is in response to your letter dated August 19, 1997, submitted by Sierra Research on

behalf of the Collins Pine Company, requesting the amendment of the July 18, 1997 PSD permit

(NSR 4-4-4, SAC 84-02) issued to Collins Pine revising their emission limits and authorizing the

use of a bypass stack at the No. 4 boiler at Collins Pine’s facility in Chester, California.

Collins Pine has requested that the opacity monitoring protocol be revised to take into

account weather conditions and to allow more flexibility on when they have to conduct a formal

visible emissions observation.

After reviewing the Collins Pine amendment request, EPA has determined that the

proposed permit revisions changing the opacity monitoring requirements are justified and willhave no impact on emissions or air quality. For this reason, EPA considers the permit

amendments to be administrative in nature and not subject to public review requirements.

Therefore, EPA hereby amends the July 18, 1997 permit as requested. This amendment to the

permit shall take effect immediately.

Should you have any questions regarding this matter, please contact Bob Baker of our

Permits Office at (415) 744-1258.

Sincerely,

David P. Howekamp

DirectorAir Division

Enclosure

cc: CARE

Northern Sierra AQMD

Murf Kams, Collins Pine Co.

Earl Withycombe, Sierra Research

Printed on Recycled Paper
and operation of power and steam production facilities at the Collins Pine lumber productionfacility located in Chester, California, is hereby amended as follows:

The EPA hereby amends Special Condition X.I.2., to read as follows:

2. Collins Pine shall conduct the following visual monitoring procedures for

determining continuous compliance with the applicable opacityrequirements:

a. Once per operating day, weather permitting, a Collins Pine

representative with visible emissions training shall observe the ESP

stack and determine if actual visible emissions are greater than the

maximum emission limit set forth in Special Condition X.G.3. If

actual visible emissions appear to be less than or equal to the

maximum emissions limit, the date, time, and observation reading

shall be recorded and no further action is required.

b. If actual visible emissions appear to be greater than the allowable

limit, then Collins Pine shall conduct by the next business day, a

formal visible emissions observation using EPA Method 9 and

conducted by a certified visible emissions reader. If the formal

visible emission readings show that the allowable limit is not

exceeded the readings shall be recorded and no further action is

required. If weather conditions do not permit a reading, then theformal reading will be conducted as soon as coditions allow. If the

readings do exceed the allowable limit or if there is no certified

visible emissions reader available, Collins Pine shall record theobservation as an exceedance of the opacity limit and shall report it

in the excess emissions report as required in Condition X.I.5.

below.
SAC 84-02

S. Kingsley Macomber

Sierra Research

1801 J Street

Sacramento, CA 95814

Dear Mr. Macomber:

In accordance with provisions of the Clean Air Act, as amended (42 U.S.C. 7401 et

seq.), the Environmental Protection Agency has reviewed the application for an Authority to

Construct submitted by Sierra Research on behalf of the Collins Pine Company, for the amendment of permit conditions in the original PSD permit, revising the emission limits and

authorizing the use of a bypass stack at the No. 4 boiler at Collins Pine’s facility in Chester, California.

A request for public comment regarding EPA’s proposed action on the above

application has been published. Enclosed is a copy of the EPA’s response to those significant comments received. After consideration of the expressed view of all interested

persons (including State and local agencies), and pertinent Federal statutes and regulations, the EPA hereby issues an Approval to Construct/Modify for the facilities described above.This action does not constitute a significant change from the proposed action set forth and offered for public comment.

The Consolidated Permit Regulations (40 CFR Part 124) which were promulgated by the Environmental Protection Agency require that we notify interested parties of the permit issuance and advise them that they may petition the Administrator of the Environmental

Protection Agency permit decision.

The petition shall include a statement of the reasons supporting that review, including

a demonstration that any issues being raised were raised during the public comment period to the extent required by these regulations and when appropriate, a showing that the condition in question is based on:

(1) A finding of fact or conclusion of law which is clearly erroneous;(2) An exercise of discretion or an important policy consideration which the

Administrator should, in his or her discretion, review.

Printed on Recycled Paper
Headquarters Hearing Clerk (A-I 10)

Room M3708

U.S. Environmental Protection Agency

401 M Street, SW

Washington, DC 20460

This amendment to the Approval to Construct/Modify shall take effect thirty (30) days from the date it is received by the Collins Pine Company.

If you have any questions regarding this matter, please contact Bob Baker of our

Permits Office at (415) 744-1258.

Sincerely,

Enclosures

cc: CARB

Northern Sierra AQMD

Muff Karns, Collins Pine Co.

Earl Withycombe, Sierra Research

Air Division
A STATIONARY SOURCE

In compliance with provisions of the Clean Air Act, as amended (42 U.S.C. 7401 et seq.),

the Collins Pine Company is granted approval to construct and operate power and steam

production facilities at the Collins Pine lumber production facility located in Chester,

California, in accordance with the plans submitted with the applications and with the Federal

regulations governing the Prevention of Significant Air Quality Deterioration (40 CFR 52.21)

and other conditions attached to this document and made a part of this approval.

Failure to comply with any condition or term set forth in this approval will be considered

grounds for enforcement action pursuant to Section 113 of the Clean Air Act.

This Approval to Construct/Modify a stationary source grants no relief from the

responsibility for compliance with any other applicable provision of 40 CFR Parts 52, 60 and

61 or any applicable federal, state, or local air quality regulations.

This approval shall become effective 30 days after receipt of the Approval to

Construct/Modify by the Collins Pine Company.

Dated: ‘7

Air Division
completed within a reasonable time.

II. Notification of Commencement of Construction and Startup

The Regional Administrator shall be notified in writing of the anticipated data of initial startup

(as defined in 40 CFR 60.2(o)) of each facility of the source not more than sixty (60) days

nor less than thirty (30) days prior, to such date and shall be notified in writing of the actual

data of commencement of construction and startup within fifteen (15) days after such date.

ifi. Facilities Operation

All equipment, facilities, and systems installed or used to achieve compliance with the terms

and conditions of this Approval to Construct/Modify shall at all times be maintained in

good/working order and be operated as efficiently as possible so as to minimize air pollutant emissions.

IV. Malfunction

The Regional Administrator shall be notified by telephone within 48 hours following any failure of air pollution control equipment, process equipment, or of a process to operate in a normal maimer which results in an increase in emissions above any allowable emissions limit

stated in Section IX of these conditions. In addition, the Regional Administrator shall be

notified in writing within fifteen (15) days of any such failure. This notification shall include

a description of the malfunctioning equipment or abnormal operation, the date of the initial failure, the period of time over which emissions were increased due to the failure, the cause

of the failure, the estimated resultant emissions in excess of those allowed under Section IX of

these conditions, and the methods utilized to restore normal operations. Compliance with this malfunction notification provisions shall not excuse or otherwise constitute a defense to any violations of this permit or of any law or regulations which such malfunction may cause.

V. Right to Entry

The Regional Administrator, the head of the State Air Pollution Control Agency, the head of the responsible local Air Pollution Control Agency, and/or their authorized representative,

upon the presentation of credentials, shall be permitted:

A. to enter upon the premises where the source is located or in which any records are required to be kept under the terms and conditions of this Approval to

Construct/Modify; and

B. at reasonable times to have access to and copy any records required to be kept under the terms and conditions of the Approval to Construct/Modify: and
VI. Transfer of Ownership

in the event of any changes in control or ownership of facilities to be construction or

modified, this Approval to Construct/Modify shall be binding on all subsequent owners and

operators. The applicant shall notify the succeeding owner and operator of the existence of

this Approval to Construct/Modify and its conditions by letter, a copy of which shall be

forwarded to the Regional Administrator and the State and local Air Pollution Control

Agency.

VII. Severability

The provisions of this Approval to Construct/Modify are able, and, if any provision of this

Approval to Construct/Modify is held invalid, the remainder of this Approval to

Construct/Modify shall not be affected thereby.

VIII. Other Applicable Regulations

The owner and operator of the proposed project shall construct and operate the proposed stationary source in compliance with all other applicable provisions of 40 CFR Parts 52, 60

and 61 and all other applicable federal, state and local air quality regulations.

IX. Paperwork Reduction Act

Any requirements established by this permit for the gathering and reporting of information are

not subject to review by the Office of Management and Budget (“0MB”) under the Paperwork Reduction Act because this pennit is not an “information collection request” within the meaning of 44 U.S.C. 3502(4) & (11), 3507, 3512, and 3518. Furthermore, this permit and

any information gathering and reporting requirements established by this permit are exempt from 0MB review under the Paperwork Reduction Act because it is directed to fewer than ten

persons. 44 U.S.C. 3502(4), (11), 5 C.F.R. 1320.5(a).

X. Special Conditions

A. Certification

Collins Pine shall notify the EPA in writing of compliance with Special Conditions

X.B. and X.I. and shall make such notification within (15) days of such compliance. This letter must be signed by a responsible representative of the Collins PineCompany.
1. Collins Pine shall operate a wet electrostatic precipitator (WEP) for control of

particulate emissions. Except for periods of upset, breakdown, or pre

scheduled washing, all exhaust gases from the boiler shall be vented throughthe WEP.

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

exhaust gases from the boiler must always be directed through the multiclone.

C. Steam Production Limit

Steam production from boiler No. 4 shall not exceed 140,000 pounds per hour on a

daily average. During bypass stack use, steam production shall not exceed 70,000

pounds per hour. Collins Pine shall maintain apermanent log of the temperature,

pressure and mass flow rate of steam produced at boiler No. 4. These records shall

be maintained in a convenient location for a period of not less than two years in a

form suitable for inspection.

D. Fuel Usage

Collins Pine shall burn only wood, bark, and wood residues in boiler No. 4.

E. Boilers No. 1,2, and3

Except during brief periods of start-up, existing boilers No. 1, 2, and 3 shall not

operate concurrently with boiler No. 4.

F. Performance Tests

1. Within 60 days after achieving the maximum production rate, but no later than

90 days after issuance of the final permit, and at such times as may be

specified by the EPA, Collins Pine shall conduct or cause to be conducted

performance tests (as defined in 40 CFR 60.8) for PM10,NOR, CO. and

opacity on the exhaust gases from the ESP stack, and for PM10 on the exhaust

gases from the bypass stack, and shall furnish the EPA (Attn: AIR-5) a

written report of the results of such tests. The tests for PM10,NOR, CO, and opacity at the ESP stack shall be conducted on an annual basis and at the

maximum operating capacity of the facilities being tested. The test for PM10

at the bypass stack shall be conducted every third year following the initial

test at the maximum allowable operating capacity stated in Special Condition

X.C. Upon written request and with supporting justification from Collins

Pine, EPA may waive a specific annual or triennial test and/or allow for
conducted and results reported in accordance with the test methods set forth in

40 CFR 60, Part 60.8 and Appendix A. The following test methods shall be

used:

a. Performance tests for emissions of NO shall be conducted using EPA

Methods 1-4 and 7e.

b. Performance tests for emissions of PM10 shall be conducted using EPA

Methods 1-5 for the ESP stack and EPA Methods 1-4 and 201a for the

bypass stack.

c. Performance tests for emissions of CO shall be conducted using EPA

Methods 1-4 and 10.

d. Performance tests for opacity shall be conducted using EPA Method 9.

The EPA (Attn: AIR-5) shall be notified in writing at least 30 days prior to

such test to allow time for the development of an approvable performance test

plan and to arrange for an observer to be present at the test.

Such prior approval shall minimize the possibility of EPA rejection of test

results for procedural deficiencies. In lieu of the above-mentioned test

methods, equivalent methods may be used with prior written approval from

the EPA.

3. For performance test purposes, sampling ports, platforms, and access shall be

provided by Collins Pine on the ESP and bypass exhaust systems in

accordance with 40 CFR 60 Part 60.8(e).’

G. Emission Limits

1. NO,, and CO Emission Limits

On and after the effective date of this permit, Collins Pine shall not discharge,

or cause the discharge into the atmosphere from the ESP and bypass stacks

pollutants in excess of the more stringent of the following specified limits:

Pollutant Mode Emission Limits

NO Normal 55 lb/hr or 145 ppm @ 12% CO2(3-hr avg)

Transient 85 lb/hr or 165 ppm @ 12% CO2(3-hr avg)
2. PM10 Emission Limits

On and after the effective date of this permit, Collins Pine shall not discharge,

or cause the discharge into the atmosphere from the following stacks any

gasses which contain particulate matter in excess of the more stringent of the

following specified limits:

a) ESP Stack Limits

Pollutant Maximum Emission Limit

PM10 13 lb/hr or 0.0265 gr/dscf @ 12% CO2(3-hr avg)

b) Bypass Stack Limits

Pollutant Maximum Emission Limit

PM10 38.4 lb/hr or 0.20 gr/dscf @ 12% CO2(3-hr avg)

3. Opacity Limits

On and after the effective date of this permit, Collins Pine shall not discharge

or cause the discharge into the atmosphere from the boiler exhaust stacks

gases which exhibit an opacity of 20% or greater for any period of periods aggregating more than three minutes in any one hour.

4. Revision of Emission Limits

If the emission limit for any of the above pollutants is revised, the difference

between the pollutant emission limit set forth above and the lower pollutant emission limit shall not be allowed as a emission offset for future constructionor modification.

H. Operating Limits

Boiler No. 4 Operating Limit

Total annual hours of operation of Boiler No. 4 shall not exceed 8,592 hours

per year.
3. ESP Bypass Operating Mode

The boiler is limited to operate in the bypass mode to no more than 125 hoursper year. This mode is defined as the period in which the ESP is under

maintenance and boiler no. 4 exhaust gas is directed through the bypass stack

instead of the ESP stack. During bypass mode, Collins Pine shall not operate

the fuel dryer, will reduce steam production to no more than 70,000 pounds

per hour, and shall operate the boiler in a manner that minimizes particulate

emissions.

Continuous Emission Monitoring and Recordkeeping

1. Prior to the date of startup and thereafter, Collins Pine shall install, maintain

and operate the following continuous monitoring systems in the boiler exhaust

stack:

a. A continuous monitoring system to measure stack gas NO and CO

concentrations. The system shall meet EPA monitoring performance

specifications (40 CFR 60.13 and 40 CFR 60, Appendix B, Perfor

mance Specifications 2, 3, and 4).

b. A continuous monitoring system to measure stack gas volumetric flow

rates. The system shall meet EPA performance specifications (40

CFR Part 52, Appendix E).

2. Collins Pine shall conduct the following visual monitoring procedures for

determining continuous compliance with the applicable opacity requirements:

a. During the annual performance test, using EPA Method 9, Collins

Pine shall determine the baseline visible emission level for the ESP

stack. (baseline visible emissions can not be greater than theallowable limit).

b. Once per operating day, a Collins Pine representative with District

approved visible emissions training shall observe the ESP stack and

determine if actual visible emissions are greater than the baseline

visible emission level. If actual visible emissions appear to be less

than or equal to baseline visible emissions, the date, time, andobservation reading shall be recorded and no further action is

required.
exceeded, the readings shall be recorded and no further action is

required. If the readings do exceed the allowable limit or if there is

no certified visible emissions reader available, Collins Pine shallrecord the observation as an exceedance of the opacity limit and shall

report it in the excess emissions report as required in Condition X.I.5.

below.

3. Collins Pine shall maintain a file of all measurements and visibility

observations, including continuous monitoring systems evaluations; all

continuous monitoring systems or monitoring device calibration checks;

adjustments and maintenance performed on these systems or devices; total

annual hours of operation; hours operated in the transient or bypass mode;

performance and all other information required by 40 CFR 60 recorded in a

permanent form suitable for inspection. The file shall be retained for at least

• five years following the date of such measurement, maintenance, reports and records.

4. Collins Pine shall notify EPA (Attn: AIR-5) of the date on which

demonstration of the continuous monitoring system performance commences

• (40 CFR 60.13 (c)). This date shall be no later than 60 days after startup.

.5. Collins Pine shall submit a written report of all excess emissions to EPA

(Attn: AIR-5) for every calendar quarter. The report shall include the

following: V

• a. The magnitude of excess emissions computed in accordance with 40

CFR 60.13(h), any conversion factors used, and the date and time of

commencement and completion of each time period of excess

emissions.

b. Specific identification of each period of excess emissions that occurs

during start-ups, shutdowns, and malfunctions of the boiler systems. The nature and cause of any malfunction (if known) and the correctiveaction taken or preventive measures adopted shall also be reported.

c. The date and time identifying each period during which the continuous

monitoring system was inoperative, repaired, or adjusted. Such information shall be stated in the report.

d. When no excess emissions have occurred or the continuous monitoring

system has not been inoperative, repaired, or adjusted, such information shall be stated in the report.
6. Excess emissions indicated by the CEM system shall be considered violations

of the applicable emission limit for the purposes of this permit.

7. Not less than 90 days prior to the date of startup of the facility, Collins Pine

shall submit to the EPA (Attn: AIR-5) a quality assurance project plan for the

certification and operation of the continuous emission monitors. Such a plan

shall conform to the EPA document “Guidelines for Developing a Quality

Assurance Project Plan” (QAMS 005/80). Continuous emission monitoring

may not begin until the QA project plan has been approved by the EPARegion 9.

XL Agency Notifications

All correspondence as required by this Approval to Construct/Modify shall be forwarded to:

A. Director, Air Division (Attn: AIR-5)

EPA Region IX

75 Hawthorne Street.

San Francisco, CA 94105

B. Chief, Stationary Source Division

California Air Resources Board

P.O. Box 2815

Sacramento, CA 95814

C. Air Pollution Control Officer

Northern Sierra AQMD

200 Litten Drive, Suite 320.

Grass Valley, CA 95945
solicited comments from the public as to its proposal to grant conditional approval, in

accordance with 40 CFR 52.21, to the Collins Pine Company for the amendment of permit

conditions in the original PSD permit, revising the emission limits and authorizing the use of

a bypass stack at the No. 4 boiler at their facility in Chester, California. During the

comment period EPA received comments from Sierra Research, on behalf of Collins Pine,

and from the Northern Sierra Air Quality Management District. The following is EPA’s

response to the significant issues raised.

A. Northern Sierra Air Quality Management District

Comment: After reviewing the PSD modifications for Collins Pine, NSR 4-4-4,

SAC 84-02, the Northern Sierra Air Quality Management District is

requesting the following change. In Section X.F.2.b, Performance

Tests, please consider changing the test for PM1O from EPA Test

Method 201a to EPA Test Method 5.

In California, stationary sources are required to test for particulate

matter by using either EPA Test Method 5 with the back half, orCalifornia Air Resources Board Method 5. If the test method in the

PSD permit remains unchanged, Collins Pine will be required to

perform both Test Method 5 and Test Method 201a, which will cause a

substantial increase in the cost of source testing this facility.

Response: After reviewing the comment from the District and a similar comment

from the applicant, EPA agrees and will revise Special Condition X.F.

to require EPA Test Method 5.

B. Sierra Research

Comment: In Condition X.C. (Steam Production), the 70,000 pound per hour limit

on steam production should apply only when the bypass stack is in use,

not to all ESP maintenance periods. Similarly, the steam productionlimit should be applied on an hourly average basis, not a daily average

basis, especially since most bypass periods are not anticipated to extend

beyond four hours in any one day. To effect these changes, Collins

Pine Company request that the second sentence of this Condition read

“During bypass stack use, steam production shall not exceed 70,000

pounds per hour.”
y

d CO concentrations at the bypass stack will be the same

as those at the ESP stack, thus malcing the testing of these pollutants at

the bypass stack redundant and unnecessary. Annual testing of PM1O

at the bypass stack is also unnecessary as the bypass stack will be used

for less than 150 hours per year. Collins Pine Company suggests

PM1O testing of the bypass stack every three years as a reasonable

schedule for compliance verification.

Also, the requirement that tests of emissions from the bypass stack be

conducted at maximum operating capacity contradicts the requirement

in Condition X.C. that steam production levels be reduced whenever

the bypass stack is used.

Response: EPA agrees and will revise Special Condition X.C. as requested.

Comment: In attempting to make compatible the testing requirements sought by

EPA and the Northern Sierra Air Quality Management District, we

proposed a test method for the bypass stack that combined portions oftotal particulate and PM10 test methods. After conversations with

EPA’s Enforcement Office, we are now recommending that a single

amendment be made to your original testing requirement for PM10 to

specify the use of Method 5 for the ESP stack and that Method 201a be

used to test PM10 emissions from the bypass stack on a schedule of

once every three years.

Response: After reviewing your request and a similar request from the District,

EPA agrees and will revise Special Condition X.F. as requested.

Comment: Collins Pine Company requests that Condition X.I.2. (opacity

monitoring) be deleted per the understanding reached between EPA

Region IX and Collins Pine in settlement of the Notice of Violation

issued by EPA on March 30, 1990. Because opacity monitoring is not

feasible due to elevated moisture levels in the ESP stack, one of these

understandings was that deletion of requirements for monitoring opacity

with transmissometer would be addressed through modification of

Collins Pine’s PSD permit. [A copy of a letter from EPA dated Dec.

9, 1993, referencing deletion of the opacity monitoring requirement

was included with the comments.]
amend Condition

X.I.5.e. as requested. However, EPA considers opacity to be a

surrogate parameter for particulate emissions and by monitoring opacity

a source can indirectly monitor particulate emission rates. Without an

opacity monitor or even an annual source test there is no way for Collins Pine to verify or document on-going compliance with opacity or particulate emission limits. For this reason, EPA is amending Condition X.F. to require opacity source testing and is adding

a new

Condition X.I.2. requiring daily observation and recordkeeping of stack opacity emissions.

Comment: Collins Pine Company recently conducted PM10 source testing of the bypass stack using EPA Method 201a and found PM10 emission rates to

be higher than those forecasted in our initial requests for bypass stack emission limits. As a result, we are requesting that the limits on PM10

emissions and allowable hours of operation for the bypass stack be amended in Collins Pine’s PSD permit to 38.4 pounds per hour and 125 hours per year, respectively.

Response: EPA has reviewed Collins Pine’s permit amendment request along with the submitted calculations. Since the modification will result in only a 0.4 ton per year increase in PM10 potential to emit, will not increase

the stack grain loading (grfdscf), and will not cause an exceedance of

the NAAQS, EPA agrees to modify the permit as requested.