0UNITEDSTATESENVIRONMENTALPROTECTIONAGENCYREGIONIX75HawthorneStreetSanFrancisco,CA94105-3901September11,1997INREPLYAIR-3REFERTO:NSR4-4-4SAC84-02S.KingsleyMacomberSierraResearch1801JStreetSacramento,CA95814DearMr.Macomber:ThisisinresponsetoyourletterdatedAugust19,1997,submittedbySierraResearchonbehalfoftheCollinsPineCompany,requestingtheamendmentoftheJuly18,1997PSDpermit(NSR4-4-4,SAC84-02)issuedtoCollinsPinerevisingtheiremissionlimitsandauthorizingtheuseofabypassstackattheNo.4boileratCollinsPine’sfacilityinChester,California.CollinsPinehasrequestedthattheopacitymonitoringprotocolberevisedtotakeintoaccountweatherconditionsandtoallowmoreflexibilityonwhentheyhavetoconductaformalvisibleemissionsobservation.AfterreviewingtheCollinsPineamendmentrequest,EPAhasdeterminedthattheproposedpermitrevisionschangingtheopacitymonitoringrequirementsarejustifiedandwillhavenoimpactonemissionsorairquality.Forthisreason,EPAconsidersthepermitamendmentstobeadministrativeinnatureandnotsubjecttopublicreviewrequirements.Therefore,EPAherebyamendstheJuly18,1997permitasrequested.Thisamendmenttothepermitshalltakeeffectimmediately.Shouldyouhaveanyquestionsregardingthismatter,pleasecontactBobBakerofourPermitsOfficeat(415)744-1258.Sincerely,DavidP.HowekampDirectorAirDivisionEnclosurecc:CARENorthernSierraAQMDMurfKams,CollinsPineCo.EarlWithycombe,SierraResearchPrintedonRecycledPaper0

C)PERMITMODIFICATIONCOLLINSPINECOMPANY(NSR4-4-4,SAC84-02)TheJuly18,1997ApprovaltoConstructissuedtoCollinsPineCompanyfortheconstructionandoperationofpowerandsteamproductionfacilitiesattheCollinsPinelumberproductionfacilitylocatedinChester,California,isherebyamendedasfollows:TheEPAherebyamendsSpecialConditionX.I.2.,toreadasfollows:2.CollinsPineshallconductthefollowingvisualmonitoringproceduresfordeterminingcontinuouscompliancewiththeapplicableopacityrequirements:a.Onceperoperatingday,weatherpermitting,aCollinsPinerepresentativewithvisibleemissionstrainingshallobservetheESPstackanddetermineifactualvisibleemissionsaregreaterthanthemaximumemissionlimitsetforthinSpecialConditionX.G.3.Ifactualvisibleemissionsappeartobelessthanorequaltothemaximumemissionslimit,thedate,time,andobservationreadingshallberecordedandnofurtheractionisrequired.b.Ifactualvisibleemissionsappeartobegreaterthantheallowablelimit,thenCollinsPineshallconductbythenextbusinessday,aformalvisibleemissionsobservationusingEPAMethod9andconductedbyacertifiedvisibleemissionsreader.Iftheformalvisibleemissionreadingsshowthattheallowablelimitisnotexceededthereadingsshallberecordedandnofurtheractionisrequired.Ifweatherconditionsdonotpermitareading,thentheformalreadingwillbeconductedassoonascoditionsallow.Ifthereadingsdoexceedtheallowablelimitorifthereisnocertifiedvisibleemissionsreaderavailable,CollinsPineshallrecordtheobservationasanexceedanceoftheopacitylimitandshallreportitintheexcessemissionsreportasrequiredinConditionX.I.5.below.n0EDST47, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION1X 75 Hawthorne Street San Francisco,
CA 941 05-3901 July 18, 1997
IN REPLY AIR-3 REFER TO: NSR 4-4-4 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-2- An appeal

to the Administrator

for review of the permit decision along with an. original and one copy must be filed not later than thirty (30) days from the date the fmal permit

is issued with the Headquarters Hearing Clerk
at the following address: 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 Divisionn

p APPROVAL

TO CONSTRUCT/MODIFY 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 Division0 Permit conditions Permit Expiration This approval

to Construct/Modify

shall become invalid (1) if construction

is not commenced (as defined

in 40 CFR 52.21(b)(8)) within
18 months after the approval takes effect, (2) if construction

is discontinued

for
a period of 18 months
or more, or (3) if construction

is not 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:

and1; -2- C.

to inspect any equipment, operation,

or method required

in this Approval

to Construct/Modify;

and D.

to sample emissions from the source. 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 Pine Company.0

C) -3- B. Air Pollution ControL Equipment Collins Pine shall install, continuously operate and maintain the following
air pollution controls

to minimize boiler No.
4 emissions. Controls listed below shall be fully operational

on and after the effective date of this permit. 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 through the 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 PM 10 , NOR, CO. and opacity on the exhaust gases from the ESP stack, and for PM 10 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 PM 10 , 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 PM 10 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 forfl

-4- testing
to be done
at less than the maximum allowable operation capacity. Such request must be submitted (Attn: AIR-5)
no later than 60 days prior
to the annual test date. 2. Performance
test for the emissions

of NO, CO. PM 10 , and opacity shall be 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 PM 10 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% CO 2 (3-hr avg) Transient

85 lb/hr or 165 ppm
@ 12% CO 2 (3-hr avg)0

0 -5- Pollutant Mode Emission Limits CO Normal

220 lb/hr (3-hr avg) Transient

950 lb/hr (3-hr avg) Transient

575 lb/hr (8-hr avg) 2. PM 10 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 PM 10

13 lb/hr or 0.0265 gr/dscf

@ 12% CO 2 (3-hr avg) b) Bypass Stack Limits Pollutant Maximum Emission Limit PM 10
38.4 lb/hr or 0.20 gr/dscf

@ 12% CO 2 (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 construction or 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.n

-6- 2. Transient Operating Mode Boiler No. 4’s hours of operation

in the transient operating mode shall not exceed 500 hours per year. This mode

is defined

as startup, shutdown,

or malfunction conditions. 3. ESP Bypass Operating Mode The boiler

is limited

to operate

in the bypass mode
to no more than 125 hours per 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 the allowable 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, and observation reading shall be recorded and no further action

is required.•0.

0 -7- c.

If actual visible emissions appear

to be greater than the baseline visible emission level, then Collins Pine shall conduct within 24 hours,

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 the readings
do exceed the allowable limit or if there

is no certified visible emissions reader available, Collins Pine shall record 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 corrective action 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.fl -8- e. Excess emissions shall be defmed

as any 3-hour
or 8-hour period during which the average emissions

of NO,ç, or CO, as measured

by the CEM, exceeds the maximum emission limits set forth in Special Condition X.G. above. 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 EPA Region

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 959450

0RESPONSETOCOMMENTSCOLLINSPINECOMPANY(NSR4-4-4,SAC84-02)OnFebruary3,1997,theUnitedStatesEnvironmentalProtectionAgency(EPA)Region9,solicitedcommentsfromthepublicastoitsproposaltograntconditionalapproval,inaccordancewith40CFR52.21,totheCollinsPineCompanyfortheamendmentofpermitconditionsintheoriginalPSDpermit,revisingtheemissionlimitsandauthorizingtheuseofabypassstackattheNo.4boilerattheirfacilityinChester,California.DuringthecommentperiodEPAreceivedcommentsfromSierraResearch,onbehalfofCollinsPine,andfromtheNorthernSierraAirQualityManagementDistrict.ThefollowingisEPA’sresponsetothesignificantissuesraised.A.NorthernSierraAirQualityManagementDistrictComment:AfterreviewingthePSDmodificationsforCollinsPine,NSR4-4-4,SAC84-02,theNorthernSierraAirQualityManagementDistrictisrequestingthefollowingchange.InSectionX.F.2.b,PerformanceTests,pleaseconsiderchangingthetestforPM1OfromEPATestMethod201atoEPATestMethod5.InCalifornia,stationarysourcesarerequiredtotestforparticulatematterbyusingeitherEPATestMethod5withthebackhalf,orCaliforniaAirResourcesBoardMethod5.IfthetestmethodinthePSDpermitremainsunchanged,CollinsPinewillberequiredtoperformbothTestMethod5andTestMethod201a,whichwillcauseasubstantialincreaseinthecostofsourcetestingthisfacility.Response:AfterreviewingthecommentfromtheDistrictandasimilarcommentfromtheapplicant,EPAagreesandwillreviseSpecialConditionX.F.torequireEPATestMethod5.B.SierraResearchComment:InConditionX.C.(SteamProduction),the70,000poundperhourlimitonsteamproductionshouldapplyonlywhenthebypassstackisinuse,nottoallESPmaintenanceperiods.Similarly,thesteamproductionlimitshouldbeappliedonanhourlyaveragebasis,notadailyaveragebasis,especiallysincemostbypassperiodsarenotanticipatedtoextendbeyondfourhoursinanyoneday.Toeffectthesechanges,CollinsPineCompanyrequestthatthesecondsentenceofthisConditionread“Duringbypassstackuse,steamproductionshallnotexceed70,000poundsperhour.”C)

•0 -2- Response: EPA agrees and will revise the Condition

as requested. Comment:

In Condition X.F.

1 (Performance Tests), the requirement

for annual testing of PM1O, NOx, and CO should be limited

to the ESP stack only. NOx and 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
of total particulate and PM 10 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 PM 10 to specify the use of Method

5 for the ESP stack and that Method 201a be used to test PM 10 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.]0.

0 -3- Collins Pine Company requests that Condition X.I.5.e.
be amended

to delete the reference

to opacity pursuant

to the understandings cited above. Response: EPA agrees and will delete Condition X.I.2. and 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 PM 10 source testing of the bypass stack using EPA Method 201a and found PM 10 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 PM 10 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 PM 10 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.