n-577-3-1postmodification emission factors, #6 fuel oil nox sox co nmhc pmlo . nox: the burner...

.- .A .-

Application Review

Mark Schonhoff March 8, 1995

....

Number:

m e :

d d r a

N-577-3-1 N-577-4-1

NIA

Newark Sierra Paperboard Corporation

800 W. Church Street Stockton, CA 95203

Michael Rogge

(209) 466-5251

I. prowsal: Issue an Au-.xity To Construct to-install --w NOx burners on two . existing boilers.

In the past, Newark Sierra utilized #6 fuel oil as the primary fuel in the boilers. They are now proposing to install low NOx burners and utilize natural gas as the primary fuel for both boilers. They have requested to have their #6 fuel oil usage limited to seven days per quarter.

n.

Rule 2010: Permits Required Rule 2201: Rule 4001: Rule 4101: Visible Emissions Rule 4102: Nuisance Rule 4301: Fuel Burning Equipment

New & Modified Stationary Source Review (October 21, 1993) New Source Performance Standards (Subpart Db)

,

m. Street Address: 800 W. Church Street

Stockton, CA

Newark Sierra is in the business of making paperboard from waste paper. They also operate a cogeneration plant which utilizes steam from these two boilers. Presently the turbines are not being operated and 100% of the steam produced is being utilized by the paperboard operation. If the turbines are brought back into operation they would utilize approximately 1/3 of the steam produced. None of the electricity generated when the turbines are in operation is sold.

. . Iv.

. . V. 1- Present: 2 Babcock and Wilcox Model # 62222-37, NB 10950 Boilers equipped with:

Boiler 1: 3 Coen CPF Parallel Flow Burners.

Boiler 2: 3 Coen DAZ-22 circular register burners.

Each boiler is rated at 113 MMBTUlhr while firing on . natural gas and 11 1 MMBTU/hr while firing on #6 fuel oil.

Proposed: The new burners will be Todd Variflame low NOx burners rated at 45 MMBTUlhr each. There will be three burners per boiler (135 MMBTU/hour per boiler).

VI. ontrol Tec-

The burners utilize low excess air combustion, multi-stage combustion, and flue gas recirculation to control NOx:

1 . Low Excess Air Combustion: The combustion process will take place with a minimum amount of air which minimiies the amount of free oxygen available to form NOx.

2

2. Multi-Stage Combustion: Fuel and air are injected at various stages within the flame envelope. This helps to optimize combustion and NOx levels.

Exhaust gas is introduced into the combustion process, lowering the combustion temperature, and reducing the amount of excess air available for NOx formation.

3. Flue Gas Recirculation:

VII. Calculations:

A. Emission Factors:

Premodification Emission Factors (Natural Gas):

CARB tested both boilers for NOx and CO on .12/11/85, however only the gas usage of boiler #2 was logged. It will be assumed that the NOx and CO emission factors derived from the source test results can be used for both boilers.

Gas usage: 2.676 MMCF in boiler #2 on the day of the test (From application package, page 3-8). Assuming that the usage was uniform on an hourly basis the hourly usage was:

(2.676 MMCF/24 hr)(lOOO BTU/CF) = 111.5 MMBTU/hr

The maximum capacity of the boiler, while fring on natural gas, is 113 MMBTU/hr therefore the boiler was firing at an acceptable rate for the test.

The following equation will be utilized to calculate the NOx and CO emission factors:

EF(lb/MMBTU) = (PPM)(MW)(2.59 X 10-9)(F-Factor)[20.9/(20.9 - %O,)]

Where: PPM is the average tested concentration (Application Pkg., Appendix D) M W is the molecular weight 2.59 X 10.’ is a constant F-Factor is 8740 (From F-Factor Manual)

NOx: Average Tested Concentration: 170 PPM (Application Pkg. App. D)

EF(N0x) = (170)(46)(2.59 X 10-9)(8740)[20.9/(20.9 - 3)] = 0.21 IblMMBTU

3

CO: Average Tested Concentration: 490 PPM

EF(C0) = (490)(28)(2.59 X 10'3(8740)[20.9/(20.9 - 3)] = 0.36 1WMMBTU

4

NMHC and PMlO were not tested for and the SOX emissions were reported to be negligible therefore estimates will be made using AP-42 emission concentrations.

NMHC Concentration: 1.41 lb/MMCF (AP-42,.Table 1.4-3)

EF (NMHC) = (1.41 lb/MMCF)(l CF/1000 BTU) = 0.0014 lb/MMBTU

SOX Concentration (as SOz): 0.6 Ib/MMCF (AP-42, Table 1.4-2)

EF (SOX) = (0.6 Ib/MMCF)(l CF/1000 BTU) = 0.0006 Ib/MMBTU

PMlO Concentration: 5 Ib/MMCF (AP-42, Table 1.4-1)

EF (PMlO) = (5 Ib/MMCF)(l CFllOOO BTU) = 0.005 Ib/MMBTU

Premodification Emission Factors, #6 Fuel Oil:

Each boiler was source tested. Boiler #1 was tested by the California Air Resources Board on 12/11/85 and #2 was tested by BCA on 9/10/91. The fuel oil burned during the 1991 test on boiler #2 was Kern Oil And Refining Company Oil which is the same blend (Sulfur content of 0.74 to 1.0% and a nitrogen content of between 0.34 and 0.96%) as the fuel oil burned during the baseline period (Quarter 4 of 1989 through Quarter 3 of 1991). The fuel oil burned during the 1985 test on boiler #1 was a different blend. Since the boilers are similar it will be assumed that the emission factors for NOx, SOX and PM10, derived from the data from the 9/10/91 test, can be applied to both boilers. NMHC emissions were not tested, therefore the AP-42 emission factor will be utilized. CO was tested and the emission rate was found to be 0.25 Ib/hr which equates to approximately 4 PPM. This does not seem realistic therefore the CO emission factor will be estimated utilizing AP-42.

#6 fuel usage: 308 barrels (12,936 gallons @ 42 gal/bbl) during the entire day of the source test. Assuming that the usage was uniform throughout the day the hourly usage was 539 gallons. (Application Package, Page 3-9)

#6 fuel oil heating value: #6 fuel usage: (150,000 BTU/ga1)(539 gal/hr) = 80.85 MMBTUhr Sulfur Content: 0.91 % Nitrogen Content: 0.83 %

NOx emission rate:

150,000 BTU/gal (AP-42, A-4)

50.2 Ib/hr (Application Package, Appendix D)

5

..

EF(N0x) = (50.2 lb/hr)(l hr180.85 MMBTUlhr) = 0.62 lb/MMBTU

CO emission concentration: 5 lb/103 gal (AP-42 table 1.3-1)

EF(C0) = (5 lb/103 gal)(l ga1/150,000 BTU) = 0.033 lb/MMBTU

SOX Emission Rate:

EF (SOX) = (84.7 lb/hr)(l hd80.85 MMBTU) = 1.0 lb/MMBTU

NMHC emission Concentration:

EF(NMHC) = (0.76 lb/103 gal)(l ga1/150,000 BTU) = 0.005 lb/MMBTU

TSP Emission Rate: PMlO Fraction: 0.87 (PM10 manual)

PMlO Emissionhte = (12.74 lb/hr)(0.87) = 11.1 lb/hr

EF(PM10) = (11.1 lb/hr)(l hrBO.85 MMBTU/hr) = 0.14 1 b M T U

Postmodification Emission Factors, Natural Gas

NOx: c o : NMHC:

84.7 lb/hr (Application Package, Appendix D)

0.76 lb/103 gal (AP-42, Table 1.3-1)


0.0365 lb/MMBTU (Vender Guarantee, Application Package, appendix F) 0.15 IblMMBTU (Vender Guarantee, Application Package, appendix F) AP-42 emission concentration was guaranteed (Application Package, Sect. 3):

Emission concentration: Natural Gas Heating Value: EF(V0C) = (1.41 lb/MMCF)(l CF/1000 BTU) = 0.0014 lb/MMBTU

AP-42 emission rate was guaranteed:

Emission concentration: Natural Gas Heating Value: EF(S0x) = (0.6 lb/MMCF)(l CF/1000 BTU) = 0.0006 lb/MMBTU

1.41 Ib/MMCF (AP-42 table 1.4-3) 1000 BTU/SCF

SOX:

0.6 Ib/MMCF (AP-42 table 1.4-2) lo00 BTUISCF

PM10: AP-42 emission concentration was guaranteed:

Emission concentration: Natural Gas Heating Value:

5 Ib/MMCF (AP-42 table 1.4-2) 1000 BTU/SCF

6

EF(PM10) = (5 lb/MMCF)(l CF/1000 BTU) = 0.005 lb/MMBTU

Postmodification Emission Factors, #6 Fuel Oil

NOx

sox co

NMHC

PMlO .

NOx: The burner manufacturer has guaranteed an emission concentration of 265 to 540 PPM (0.33 to 0.69 Ib/MMBTU) depending on the type of fuel used. The applicant has proposed 0.62 1bMMBTU (Application Package, table 4-1).

The vender has guaranteed 200 PPM (0.15 IWMMBTU) CO:

~~~

NaturalGas . #6Fuel Oil Natural Gas # 6 Fuel Oil (lb/106 B W (lb/106 BTU) (lb/106 BTU) (lb/106BTU) ,

0.21 0.62 0.0365 0.62

0.0006 1.0 0.0006 1 .o 0.36 0.033 0.15 0.15

0.001'4 0.005 0.0014 0.005

0.005 0.14 0.005 0.11

VOC: The applicant has proposed the AP42 emission concentration (Application Package, Table 4-1).

NMHC emission Concentration: EF(NMHC) = (0.76 lb/103 ga1)(539 gal/hr)(l hd80.85 MMBTU) = 0.005 Ib/MMBTU

SOX: The applicant is proposing an emission factor of 1.0 IblMMBTU based on their expectation that they can match the SOX emission rate achieved during the 9/10/91 source test (Application Package, table 4-1). Newark Sierra stated in the application that'they would be limited to a fuel oil sulfur content of 0.9% by weight.

0.76 lb/103 gal (AP-42 Table 1.3-1)

PM10: The applicant is proposing an emission factor of 0.1 1 Ib/MMBTU.

Summery Of Emission Factors I

I1 Before Modification I After Modification II

8

B. Assumptions Made:

1. . Emission Factors for a source test from one boiler may be applied to the other.

C. Emission Calculations:

1. Maximum Proposed Emissions: Newark Sierra requested to have their emissions limited such that offsets and public notice are not triggered. Additionally they requested to be limited such that BACT for fuel oil combustion emissions is not triggered. In order to achieve that, there must be no Increase In Permitted Emissions of NOx, NMHC, SOX or PMlO and the NSR balance for CO must be less than 550 pounds per day.

Both boilers are prebaseline units. Boiler #2 has not been modified since the baseline date and in 1985 Newark Sierra modified boiler #I. That modification resulted in a SOX NSR balance of 150 pounds per day, a CO NSR balance of 11.5 pounds per day and a PMlO NSR balance of 12.5 Iblday. Therefore, in order to avoid exceeding any of the above mentioned threshold levels each boiler must be limited to no more than the following:

PEPM (Oil): NOx = (111 MMBTU/hr)(24 hr/day)(0.62 Ib/MMBTU) = 1651.7 lblday CO = (111 MMBTU/hr)(24 hr/day)(0.033 Ib/MMBTU) = 87.9 lb/day NMHC = (111 MMBTU/hr)(24 hr/day)(0.005 IblMMBTU) = 13.3 Ib/day SOX = (1 11 MMBTU/hr)(24 hr/day)(l .O Ib/MMBTU) = 2664.0 lblday PMlO = (111 MMBTU/hr)(24 hr/day)(0.14 Ib/MMBTU) = 373.0 Ib/day

.

PEPM (Gas): NOx = (113 MMBTU/hr)(24 hr/day)(0.21 IblMMBTU) = 569.5 Ib/day CO = (113 MMBTU/hr)(24 hr/day)(0.36 Ib/MMBTU) = 976.3 Ib/day NMHC = (113 MMBTU/hr)(24 hr/day)(0.0014 Ib/MMBTU) = 3.8 Ib/day SOX = (113 MMBTU/hr)(24 hr/day)(0.0006 Ib/MMBTU) = 1.6 Ib/day PMlO = (113 MMBTU/hr)(24 hr/day)(0.005 Ib/MMBTU) = 13.6 Ib/day

Worstcase PEPM: NOx = 1651.7 lblday CO = 976.3 Ib/day NMHC = 13.3 Ib/day SOX = 2664 Ib/day PMlO = 373 Ib/day

9

...

Maximum.Proposed Emissions:

Newark Sierra has proposed no change in the NOx, CO, NMHC or SOX emission concentrations and a decrease in the PMlO emission concentration while firing on #6 fuel oil. Therefore, in order to ensure no increase in emissions while firing on #6 fuel oil the boilers will be limited to their premodification #6 fuel oil burning capacity which is:

(1 11 MMBTU/hr)(24 hr/day) = 2664 MMBTU/day

PE (Oil): NOx = (2664 MMBTU/day)(0.62 IblMMBTU) = 1651.7 Ib/day CO = (2664 MMBTU/day)(O.lS Ib/MMBTU) = 399.6 lblday NMHC = (2664 MMBTU/day)(O.OOS Ib/MMBTU) = 13.3 Ib/day SOX = (2664 MMBTU/day)(l.O Ib/MMBTU) = 2664.0 Ib/day PMlO = (2664 MMBTU/day)(O.ll IWMMBTU) = 293.0 Ib/day

NOx = (135 MMBTU/hr)(24 hr/day)(0.0365 IblMMBTU) = 118.3 Ib/day CO = (135 MMBTU/hr)(24 hr/day)(0.15 Ib/MMBTU) = 486.0 lblday ,NMHC = (135 MMBTU/hr)(24 hr/day)(0.0014 Ib/MMBTU) = 4.5 Ib/day SOX = (135 MMBTU/hr)(24 hr/day)(0.0006 Ib/MMBTU) = 1.9 Ib/day PMlO = (135 MMBTU/hr)(24 hr/day)(0.005 Ib/MMBTU) = 16.2 Ib/day

PE (Gas):

Worst Case PE: NOx.= 1651.7 Ib/day CO = 486.0 lblday NMHC = 13.3 Ib/day . SOX = 2664.0 Ib/day PMlO = 293.0 Ib/day

The Potential To Emit is less than or equal to the Potential To Emit Prior to The Modification.

Daily Emission Limits:

Conditions Will Be The Same For Both Boilers: Equipment Description: 135 MMBTU/HR Boiler

1.

2.

The boiler shall be fired on natural gas or #6 fuel oil only.

The NOx emission concentration shall not exceed 0.0365 Ib/mmbtu while firing on natural gas.

10

3.

4.

5 .

6.

7.

8.

9.

10.

11 .

12.

13.

The CO emission concentration shall not exceed 0.15 lblmmbtu while firing on natural gas.

The NMHC emission concentration shall not exceed 0.0014 lblmmbtu while firing on natural gas.

The SOX emission concentration shall not exceed 0.0006 Iblmmbtu while firing on natural gas.

The PMlO emission concentration shall not exceed 0.005 Iblmmbtu while firing on natural gas.

The #6 fuel oil usage shall not exceed 2664 mmbtulday.

If #6 fuel oil is burned at any time during the day then the combined heat input from natural gas and #6 fuel oil shall not exceed 2664 mmbtulday.

The NOx emission concentration shall not exceed 0.62 lblmmbtu while firing on #6 fuel oil.

The CO emission concentration shall not exceed 0.15 lblmmbtu while firing on #6 fuel oil. The NMHC emission concentration shall not exceed 0.005 Ib/mmbtu while firing on #6 fuel oil.

The SOX emission concentration shall not exceed 1 .O Ib/mmbtu while firing on #6 fuel oil.

The PMlO emission concentration shall not exceed 0.11 lblmmbtu while firing on #6 fuel oil.

14. The #6 fuel oil usage shall not exceed 18,648 mmbtu's per calendar quarter*

* The applicant originally requested to be limited to 7 days per year of fuel oil usage. It was not certain which quarter the fuel usage would take place in therefore they will be allowed 7 days per quarter. Refer to the AER section of this application review for further information:

(2,664 MMBTUlday)(7 dayslqtr) = 18,648 mmbtulqtr

11

Natural Gas EF's (IblMMBTU) #6 Fuel Oil EF's (IblMMBTU)

HAPE (Natural Gas, Per Boiler):

NOx = (113 MMBTU/hr)(24 hr/day)(0.21 lb/MMBTU)(l-0.826) = 99.1 Ib/day CO = (1 13 MMBTU/hr)(24 hr/day)(0.36 lb/MMBTU)(1-0.583) = 407.1 Ib/day NMHC = (1 13 MMBTU/hr)(24 hr/day)(0.0014 Ib/MMBTU)(l-0.0) = 3.8 Ib/day SOX = (113 MMBTU/hr)(24 hr/day)(0.0006 Ib/MMBTU)(l-0.0) = 1.6 lblday

PMlO = (113 MMBTU/hr)(24 hr/day)(0.005 Ib/MMBTU)(l-0.0) = 13.6 Ib/day

NOx

co NMHC

s o x

PMlO

WE (Natural Gas, Per Boiler):

NOx = 118.3 Ib/day - 99.1 Ib/day = 19.2 Ib/day CO = 486.0 Ib/day - 407.1 Ib/day = 78.9 Ib/day NMHC = 4.5 Ib/day - 3.8 Ib/day = 0.7 lblday

0.21 0.0365, 0.826 0.62 0.62 0.0

0.36 0.15 0.583 0.033 0.15 0.0'

0.0014 0.0014 0.0 0.005 0.005 0.0

0.0006 0.0006 0.0 1 .o 1 .o 0.0

0.005 0.005 0.0 0.14 . 0.11 0.214

12

SOX = 1.9 Ib/day - 1.6 Ib/day = 0.3 Ib/day

PMlO = 16.2 Ib/day - 13.6 Ib/day = 2.6 lblday HAPE (Fuel Oil, Per Boiler):

(Rounds to zero because it is iess than 0.5 Ib/day per District policy)

NOx = (111 MMBTU/hr)(24 hr/day)(0.62 lb/MMBTU)(l-0.0) = 1651.7 lblday CO = (111 MMBTU/hr)(24 hr/day)(0.033 Ib/MMBTU)(l-0.0) = 87.9 lblday NMHC = (111 MMBTU/hr)(24 hr/day)(0.005 Ib/MMBTU)(l-0.0) = 13.3 Ib/day SOX = (111 MMBTU/hr)(24 hr/day)(l.O Ib/MMBTU)(l-0.0) = 2664.0 Ib/day PMlO = (111 MMBTU/hr)(24 hr/day)(0.14 Ib/MMBTU)(1-0.214) = 293.1 Ib/day

IPE (Fuel Oil, Per Boiler): . NOx = 1651.7 lblday - 1651.7 Ib/day = 0.0 Ib/day CO = 399.6 lblday - 87.9 Ib/day = 311.7 lblday NMHC = 13.3 Ib/day - 13.3 Ib/day = 0.0 lb/day SOX = 2664.0 Ib/day - 2664.0 Ib/day = 0.0 Ib/day PMlO = 293.0 Ib/day - 293.1 lblday = 0.0 Ib/day'

1. Does not equal zero because of emission factor calculation round off.

13

I .

Pollutant

NOx

co

IPE For Inclusion In The NSR Balance (Each Boiler):

PEPM (#6 Fuel Oil) PEPM (Nat. Gas) PEPM (Worst Case) (lblday) (Ib/day) (Iblday)

1651.7 569.5 1651.7

87.9 976.3 976.3

Where PE,,,, = PEPM And PEAR, = PE

NMHC

sox PMlO

13.3 3.8 13.3

2664.0 1.6 2664.0

373.0 13.6 ' 373.0

Worst Case PE: NOx = 1651.7 Ib/day CO = 486.0 lb/day NMHC = 13.3 lblday SOX = 2664 lb/day PMlO = 293.0 lb/day

IPE (NSR Inclusion): NOx = 1651.7 Ib/day - 1651.7 lb/day =.O.O lb/day CO = 486.0 lb/day - 976.3 lb/day = 0.0 Ib/day' NMHC = 13.3 lb/day - 13.3 lb/day = 0.0 lblday SOX = 2664 lblday - 2664 lblday lb/day = 0.0 lblday PMlO = 293.0 lblday - 373.0 lb/day = 0.0 lblday'

1. P E ' s calculated to be less than 0.5 lb/day are set equal to zero (3/12/92 District policy)

14

1 .

3,267,562 (326,756.2 X 107

4

NOx: 202,589 SOX: 326,756 CO: 10,783 NMHC: 1,634 PM10: 45,746 :

3. Actual Emission Reductions (AER):

1,833,790 (183,379.0 X 107

AER = (HAE X CE) where:HAE = (EF)(Fuel Usage)

NOx: 113,695 SOX: 183,379 CO: 6,052 NMHC: 917 PM10: 25,673

T;

1,615,796 161,579.6 X 107

Natural Gas Usage Therms/Qtr (BTUIQtr)

(App. Pkg. Table 3-1)

NOx: 100,179 SOX: 161,580 CO: 5,332 NMHC: 808 PM10: 22,621

1,142,238 (114,223.8 X 109

15,234 (1,523.4 X lo6)

1,236,341 (123,634.1 X lo6)

1,707,673 (170,767.3 X lo6)

le Of Quarterly Avc

Natural Gas HAE (lb/Qtr)

NOx: 23,987 SOX: 69 '

CO: 41,121 NMHC: 160 PM10: 571

NOx: 320 s o x : 1 CO: 548 NMHC: 2 PM10: 8

NOx: 25,963 sox: 74 CO: 44,508 NMHC: 173 PM10: 618

NOx: 35,861 sox: 102 CO: 61,476 NMHC: 239 PM10: 854

;e HAE's

Fuel Oil Usage ThermslQtr (BTU/QW


2,277,880 (227,788.0 X 107 /

NOx: 141,229 SOX: 227,788 CO: 7,517 NMHC: 1,139 PMIO: 31.890

Baseline period is the forth quarter of 1989 through the third quarter of 1991

15

Newark Sierra will be installing a control device to control emissions while firing on natural gas. They will be reducing #6 fuel oil combustion contaminant emissions by reducing it's use. Therefore AER will be calculated utilizing the following equations:

AER (Natural Gas): HAE * CE (Rule 2201 Section 6.5.2)

AER (#6 Fuel Oil): HAE-PE (Rule 2201 Section 6.5.1)

Newark Sierra has stated that they wish to retain the right to burn #6 fuel oil seven days per year for emergency purposes (application package, Section 4). It is not known which quarter the fuel oil will be burned in therefore all four quarters will be corrected to reflect seven days of fuel oil usage.

PE for 7 days of oil use in both boilers combined is:

BTU Rating: Each boiler will be limited to 2664 MMBTU/day of #6 fuel oil usage therefore the combined allowable #6 fuel oil usage, for both boilers combined, will be 5328 MMBTUlday.

PENo,(fuel oil) = (7 days/qtr)(5328 MMBTU/day)(0.62 1blMMBTU) = 23,123.5 lb/qtr PEso,(fuel oil) = (7 days/qtr)(5328 MMBTU/day)(l .O Ib/MMBTU) = 37,296.0 lblqtr PEco(fuel oil) = (7 days/qtr)(5328 MMBTU/day)(O. 15 IWMMBTU) = 5,594.4 lb/qtr PENMHc(fuel oil) = (7 days/qtr)(5328 MMBTU/day)(O.O05 lb/MMBTU) = 186.5 lblqtr PE,,,,(fuel oil) = (7 days/qtr)(5328 MMBTU/day)(O. 11 Ib/MMBTU) = 4102.6 Ib/qtr

AER = (HAE * C E ) N ~ ~ G ~ ~ + (HAE - PE)n~ueioIi

Quarter 1:

AER (SOX) = (69 lb)(O) + (227,788 lb - 37,296.0 Ib) = 190,492 Ib AER (CO) = (41,121 1b)(0.583) + (7,517 Ib - 5,594.4 Ib) = 25,896 Ib AER (NMHC) = (160 Ib)(O)'+ (1,139 Ib - 186.5 lb) = 953 lb AER (PM10) = (571 Ib)(O) + (31,890 Ib - 4,102.6 lb) = 27,787 Ib

Quarter 2:

AER (SOX) = (1 Ib)(O) + (326,756 lb - 37,296.0 lb) = 289,460 Ib AER (CO) = (548 lb)(0.583) + (10,783 lb - 5,594.4 Ib) = 5,508 Ib AER (NMHC) = (2 lb)(O) + (1,634 Ib - 186.5 Ib) = 1,448 lb AER (PM10) = (8 Ib)(O) + (45,746 lb - 4,102.6 lb) = 41,643 lb

AER (NOX) = (23,987 lb)(0.826) + (141,229 Ib - 23,123.5 lb) = 137,919 lb

AER (NOX) = (320 1b)(0.826) + (202,589 lb - 23,123.5 lb) = 179,730 Ib

16

Quarter 3: AER (NOX) = (25,963 1b)(0.826) + (113,695 Ib - 23,123.5 lb) = 112,017 lb AER (SOX) = (74 lb)(O) + (183,379 Ib - 37,296.0 Ib) = 146,083 Ib AER (CO) = (44,508 1b)(0.583) + (6,052 Ib - 5,594.4 lb) = 26,406 lb AER (NMHC) = (173 Ib)(O) + (917 Ib - 186.5 Ib) = 731 lb AER (PM10) = (618 lb)(O) + (25,673 - 4,102.6 lb) = 21,570 lb

NOx

sox

Quarter 4: AER (NOX) = (35,861 1b)(0.826) + (100,179 Ib - 23,123.5 lb) = 106,677 lb AER (SOX) = (102 lb)(O) + (161,580 lb - 37,296.0 lb) = 124,284 Ib AER (CO) = (61,476 1b)(0.583) + (5,332 Ib - 5,594.4 lb) = 35,578 lb AER (NMHC) = (239 lb)(O) + (808 Ib - 186.5 lb) = 622 lb AER (PM10) =.(854 lb)(O) + (22,621 - 4,102.6 lb) = 18,518 lb

Summery o f AER'S:

Quarter 1 Quarter 2 Quarter 3 Quarter 4 (lbs) ( W ( W ' (lbs)

137,919 179,730 112,017 106,677

190,492 289,460 146,083 124,284

NMHC

PMlO

953 1,448 731 622.

27,787 41,643 21,570 18,518

17

4. NSR Balance:

For this project, pursuant to District Rule 2201 Section 6.6, the NSR balance is the sum of the IPE's authorized by valid o i implemented ATCs. For units modified prior to September 19, 1991 the Net Emission Increase as determined pursuant to the NSR rule in effect at the time of modification shall be the NSR contribution as a result of that modification.

In 1985 the burners in boiler #2 were replaced with burners that were identical to those previously in use. This was classified by the SJCAPCD as a repair and no ATC was required. There will be no NSR balance contribution as a result of that repair.

In 1985 boiler #1 was retrofitted with new burners. The net emission increase as a result of the 1985 modification to boiler #1 was determined to be 150 pounds per day of SOX and 150 pounds per day of NOx.

In order to determine the worst case NSR balance contribution of CO and PMlO the potential emissions while burning each fuel will be calculated.

The SOX increase was stated, in the EE, to be 150 Ib/day. In order to determine the ' PMlO and CO increases the quantity of oil required to produce 150 lblday of SOX

emissions will be calculated and the CO and PMlO NSR increases while burning oil will be calculated based on the increased fuel usage.

In order to determine the increase in emissions due to the burning of natural gas the quantity of natural gas required to produce 150 lblday of NOx emissions will be calculated and the CO and PMlO NSR balance increases will be determined based on this fuel usage.

Increase In SOX Emissions: 150 lblday (from EE for 1985 retrofit) SOX EF: 152.29 lb/103 gal (from EE for 1985 retrofit)

Max increase in #6 Usage = (150 lblday) / (152.29 lb/103 gal) = 985 gallday

NOx Emissions: NOx EF:

Max Nat. Gas Usage = (150 lb/day) / (522.5 Ib/MMCF) = 0.287 MMCF/day

150 lb/day (from EE for 1985 retrofit) 522.5 Ib/MMCF (From EE for 1985 retrofit)

Potential Increase From #6 Fuel Oil (All EF's from the 1985 EE):

SOX = 150 lblday CO = (985 gal/day)(5 lb/103 gal) = 4.9 Ib/day

18

5

PMlO = (985 gal/day)(12.7 lb/103 gal) = 12.5 lblday

19

Potential Increase From Natural Gas (All EFs from the 1985 EE):

CO = (0.287 MMCF/day)(40 Ib/MMCF) = 11.5 lblday SOX = (0.287 MMCF/day)(0.6 IWMMCF) = 0.2 lblday PMlO = (0.287 MMCF/day)(5 IblMMCF) = 1.4 Ib/day

Worst Case Net Increase In Emissions Resulting From The 1985 Retrofit Of Boiler #1, Considering Both Fuels:

SOX = 150 Ib/day CO = 11.5 lblday PMlO = 12.5 Ib/day

Worst Case IPE's, from the proposed retrofit, for inclusion in the NSR Balance:

CO (Ib/day) SOX (lb/day)

CO = 0.0 lb/day (Per Boiler) SOX = 0.0 Ib/day (Per Boiler) PMlO = 0.0 Ib/day (Per Boiler)

PMlO (Ib/day) Permit Number

N-577-1-0 (Board & Trim Line

0.0

N-577-2-0, (Board & Trim Line

N-577-3-1

(Boiler #2) 0.0 0.0

Total 11.5 150 12.5

I I 0.0' II 0.0 0.0

11.5 150 12.5

1. The Board & Trim Lines are pre-NSR units that have been modified since the baseline date, however, the modifications resulted in no increase in emissions.

20

5. Stationary Source Potential To Emit (SSPE):

This modification will result in no increase in emissions of VOC or NOx therefore SSPE will not be calculated.

VIII.

Rule 2201: New & Modified Stationary Source Review (October 21, 1993)

BACT (Natural Gas): The Increase In Permitted Emissions of NOx and PMlO are each greater than two pounds per day therefore BACT is triggered for NOx and PM10. The Increase in permitted emissions of NMHC and SOX is less than two pounds per day and the CO NSR balance (CO attainment area) is less than 550 pounds per day therefore BACT is not triggered for NMHC, SOX or CO.

.

NOx: Newark Sierra is proposing a NOx emission rate of less than 30 ppm while firing on natural gas which is BACT.

PM10: The combustion of natural gas is BACT.

BACT (#6 Fuel Oil): There is no increase in NOx, SOX, NMHC or PMlO emissions while firing on #6 fuel oil and the CO NSR balance is less than 550 Ib/day (CO attainment area) therefore BACT while firing on #6 fuel oil is not triggered.

Offsets: Offsets are not triggered.

Rule 4001:

Not subject to this subpart because Newark Sierra did not commence construction, modification or reconstruction (as defined in CFR 40 Part 60). after June 19, 1984.

New Source Performance Standards (Subpart Db)

Rule 4101: Visible Emissions

As long as the equipment is properly operated and maintained emissions should be less than 20% opacity.

Rule 4102: Nuisance

21

._ . , ( I

,.

U n l w orherwise indiwed or ohviour fim the name of thc'~~,mtiw.l, rhc information contained in chis W s h i l c message is confidoltial information inrended for the use ofine individual ot entitynamod below. Lfth~ this mossage is not tho inruldcd rcciplenk or the employee nr mponsible to deliver il 10 the intended rccipien$ you are hwcby nodfied thnt my dissnniuatiun, distribution or copying of this communication is strictly prohibited. If yuu have reccivcd lhii communication in enor, please notify us ai the telephone number listed. Thank you.

B' C A L D W E L r,

A

May 29,1998

I FAX TRANSMITTAL COVER SHEET I PLEASE DELIVER THE FOLLOWING PAGES TO:

Name: Mark Schonhoff Company: San Joaquin Unified Air Pollution Control District

City/State: Modesto, CA FAX NO: (209) 545-8652

THIS TRANSMITTAL IS BEING SENT FROM

Y e s a No No S Name: Wilma Dreessen Return originals: Yes Employce No: 8 1 10 Stamp: Project No: 6090 Staple: Y e s m N o 0 TaSkC;/L: 16.5

SPECIAL INSTRUCTIONSREMARKS:

Per your request, attached are the purchase orders for burner installation on Boiler #I and Boiler #2 at Newark Sierra Paperboard Corporation.

SAN JOA UIN VALLEY UNlFlE a A.P.C.D.

NO. REGION

NUMBER OF PAGES BEJNG TRANSMITTED INCLUDING COVER SHEET: 7 Envimnmontal Enwneedng And Consumng

SUITE 150.3460 B U S M F X A W ~ , PLEASANTHILL. Ch~wPMA94523.4342 PHONE: (s10)937-9010 FAX: (510)937-9026

I H3Wd

-~ ..I..__.. . -t I

Furnish a l l o f the necessary labor, materials, tools, equipaent and supenision required to Install three (3)

new Coen Parallel Flm Low Excess Air Burners in the -- -- _.- - - --I.-.I---__- I-___- ... ...___. . #I Boiler a t W d Bond's StocJcton, CA plmt in

1 .

____. - . . . . . . . ..

. . , .._--- .----______ . ...

. - ..._... -- ....- _ _ _ - ...- . _, ____,_ . ._ .

accordance with Qld Bond's instructions. 6old Bond's

Section IV Specifications for work order 5118 and

. . - -- . _______ ._ ..

I -- .__-. . - _---. . ... ._ -

-.- ... . Ward-Schmid proposal 8185-0181-PN. DTD 8/22/85. . -. .. .. . . .. ...- .

.--.... .. .--...--- . -. - , , ____.._--_

_--_. -. . . Yard-%hid is t o colsplete the above mrk for the

total I m p ~urn of I _ - .--... . -...-_- ..__._I__..._

$16,440.00 .-._I_. . - .- . _ - .- - ... -. . _ _ . . _ _

'I . . -- - .._. . . . Furnish a l l of the engineering. drawings, speclficatlm:;,

r. V d ;labor, materials, toots. equipment and supehfslon 9 .0 0

-required to furnish and install a ccdnplete flame t -safeguard system for the three (3) burners on the

#I Boiler at Sold Bond's Stocktton. CA D l U t i n

.. -. - ._ . -

Go'd Bond 2001 Rrxfard Rood 810142-R-51 ORDER &uif /...... Products 1 Charlotre, NC 28.71 1

-PURCHASE .

CONTINUATION SHEET 4 Na-" ,?"Po", o*u

P A G E _ 3 O F - September 20. 1985 DATE

TO

IT. - -

I :

Inc.

accordance *iith &Id Bond's instructions, Gold OeSCRlPTlON

Bond's Section IV Specifications for work order 5118

and Ward-Schid proposal #8S-Oi83-PW. D I U 8/28/85.

Completed system shall be operational and F. M. or

I.R.I. Insurance approval, of the manual type per NFPA-85 B d D.

Hard-Schmld shall suhit three (3) copies of sy- wiring and Piping diagrams, operating Instructions

and certif fed p r i n t and instructions of individual components as applicable.

. Ward-khmfd is to complete the above *ark for the

total IW sum of

No insulattm is to be removed rithout prior

permission from R. J. Piasecki (Gold Bond's

Designated Field Representative)

Ward-Schmid is to coordinate all work with

R. J. Piasecki (Gold Bond's Desfgnated Field

Representative) and Mr. 0. J. Vaccaru (&Id Bondls

flanager of Construction) AUTHORIZED BY;

- PPI -

64,189.

I

1 *uRcn*SC O R D ~ R WMW I 810142-R-5118

S E E MTRUCnONS ELCW

2001 Rerfcvd Road /hi/ding 1 Cberlorr.. NC 2821 I

PURCHASE ORDER Producrs

1 N w 0 r . w D*luo CONTlNU~TlON SHEET

D*fE September 20, 1985 P A G E A O F

0 Yard-Schmid to., Inc.

t

QUANTITY lUNi CODE DESCRIPTDN

.Terms o f Payment: Net 10th of month follwlng date

of 1 nvo 1 ce . Confinnation telephone conversation Mr. Kent Flaherty

91 18/85.

Certificate o f Insurance required prlor to wrlr

caamencing.

.. . . . . . . .

Accounting Codes: 12-51-18-58 $77341.00 . . .. . . . .. . . .

12-51-18-97-50 53288.00 I _ _ ,

.. .. . . .. .

AUIHOWED BI: n

PRICE

-

brf lurchds ing - QS - G O L D B O N O B U l L O l N G P R O D U C T S

DIVISION OF N4rlON4L SY?SUY C-AYV Accts. Payable

Cost Engineer

E . Miller-Prpp. Acctg. . n. J . Rogge-STK., Plt. flgr ?UIl PIYFOPD ROAD -- ELQ w cnAmtorrf iy c :U:TI

File CONSTRUCTION CHANGE ORDER

8 1 0 1 42- 1 D * l E March 3 , 1986

TOWARD-SCHMID CO., I N C . P . 0 . B o x 459 Cere;, C A 95307

S t o c k t o n Plant PLANT

W.O. 51 18

. O E S C R l P T l O N

T h i s Construction Change Order i s i s sued t o furnish labor, . - materia:^. t o o l s . equipment and supervis ion required to remova anc c;aan pane l s . renove asbestos f r o0 o l d windbox per a p p l i c a b l e g o v s r n l o a codes, fabr ica te and I n s t a l l new i n s u l a t i o n and new metal Panels i n the new windbox a t t o t a l cos t o f . . . . $5,756.74

-- REASONS FOR CHANGE:

Was not included in t h e or ig inal contract .

5

- ...

9206LC6015:aI 11ana1 U

TO Yafd-SclPId Campanp 2132 Pine skpet . ceres, a95307 (209) 537-5094 .

- I ---I--.---,

--t--.---t----

, -

. I .

SHIPIIHO. 2132 PINE ST

CERES. CALIF. V5307

1 N . 'O I C N? 208,

OATE July 31, 1985

YOUR ORDER NO. PO # 812760-R-5118 W/S # 50634

r 1 Gold Bond Building Products

800 West Church Street

Stockton, CA 95203 9-3A- 85-

L -I

QUAN. I D E S C P ~ P ~ I O N

Furnish all necessary labor, materials and equipment required to complete the boiler # 2 burner installation contract at Gold Bond.

Project Completed

Holiday and weekend installation

/-I--,. .-.+"+I

TLll"! <IN.* A""" PLEASE PAV FROM INVOICE. NO STATEMENT WILL BE RENDERED UNLESS REOU€SlED

L 3 3 W d szasL&sats:a1 . 7 7 3 A L l 1 W ( J NAOXB

U N l l PQlCe W O N '

8.745.00

! ,000.00 ~ ,745.00

- I . ,* ' )I' -'. , . . . ..

Unless othmist indicated or obvious from the nature of rhe -mid, the information eontaincd in this facsimile rnessllgc is confidantid information intended for the ux of ulc individual or entity named below. If the r d e r of this mwgc is nat the intended neipicnt, or he cmp~oyce or agent responsible to dehvw it to the intcnded recipient, you me hereby notifed rhat any discmination. distribution or copying of this communimiion is strictly prohibited. If you hsve received this wmmunicntioo in error, plea% notify us at (he telephone number listed. Thank you.

' A

C A L D W E L L

May 15,1998

I FAX TRANSMllTAL COVER SHEET I PLEASE DELIVER THE FOLLOWING PAGES TO:

Name: Mark Schonhoff Company: San Joaquin Unified Air Pollution Control District

Ciiy/State: Modesto, CA FAX NO: (209)545-8652

THIS TRANSMITTAL IS BEING SENT FROM:

Name: Wilma Dreessen Return originnals: N o 0 Employee No: 8 1 10 Stamp: NO 0 Project No: 001 1 Staple: N O R TaskG/L: 05.7

SPECIAL LNSTRUCTXONS/REMARK%

Attached are records h m Corn Compauy regarding the Newark Sicrra Paperboard Corporation boilers beforc and after 1985. The project did not meet the definition of modification or reconstruction in 4OCFR60.14-15. Thc boilers are not subject to NSPS subpart Db (40CFR60).

If you have additional questions, plcase call me at (925) 210-2289.

MAY 1 9 1998 SAN JOA UIN VALLEY

UNlFlE 8 A.P.C.D. NO. REGION

NUMBER OF PAGES BEING TRANSMITTED INCLUDING COVER SHEET f - 7 Envimnmenlai Engheuring And Consulling

SlmE 150,3480 BLSKRK AVENU+ PLWhhT H U CALFORNLA 945234352 PHONE: (510) 937-9010 FAX: (510)937-9026

I 3 3 W d

Corn Company, Inc. 1 5 10 Tanforan Avenue Wodmd, CA. 95716 ph: 530-668-2156 &: 530668-2171

- ~~~

Envirommlal Engineering and Consulhg 3480 Buskirk Avaue, Ste 150 Pleasant Hill, CA 94523

. . , ./ Attention: ._ .-

Reference: 1. Ncwark Sierra P aboard (formerly Gold Bond Building Products), Stockron, CA. 2. Coen Co. pro'cc&es 20D-9470-1 and 2OD.9494-1 for the retdit of two

1937 vintage !I3 abcock BE WiIcox m d F-22 steam boilers. # Dear Wilma:

In reference to your letter of 5/7/98, attache4 is a boiler efficiency a d assessment re R fmm tho Fiberboard Co oration dated 5/2/77. This report clearly shows that the original E iler design

new Coea bumcrs were provided io the 3' quarter of 1985. Our records indicate that the new Coen burners are designed to f i e these boilen to the same design capacity.

So the answer toyour qucstion is; since the Caen bumer retrofits did not change the boiler desi capacity, the dcswn fuel gas and fucl oil consumption rates haw not chauged and should be t!$ same as in &e onginal design

Ifauy questions, just call.

Sincerely,

capacity i s 95, 7 DO pounds per hour of 445 psig / 650 degree F main steam, for each unit. The

, Matthew Hall Application Engineer

CC: Lou Bri7mlara, Caul Company Sales Representative, San Ramon, CA.

2 3 3 W d

:. : ._

MJ-200-9494-1 Paste 2 Of 4 OD391a

b 3 3 W d

. . I L .. i .

?T35RW>. RD CO3P. STOCICTON, CA. . .

. ' h e f nUow ing is' a report of the e f f i c i ency tests inr-de January' 25 fc 26, 197'7 by I w . M. P. Wieszczylc of the Babcock t: :i!ilcox Co. on both of t h e ncbcock & Wilcoa bo i l e r s at Tibe rbos rd Corp., S t o c k t m CA. 'are i n c l u d e d i n t h i s report .

.'. ' p *. . . . .,.

The c!ata, p r i n c i p a l resu l t s , and recommendations of these tests, .!.

1lE:SCRIPTIOIU OF IWELERS ,<".3

---=/ T+.go ( 2 ) - 95,000 1B/hr, F-type, Babcock g: W l l c o x h i t s

T h e b o i l e r s are equipped w i t h t h r e e (3) Cocn type o i l and gas . :: .. '

. bUi-ncr:.. ular air hezter. . .

! h h u n i t is a l so equipped w i t h a.Babcock k I\rilcox tub- . . ,. . . . . . I. .

GE'!.]EI&L . ' I 8':

These t e s t s were conducted in accordance w i t h the ASME short . t e s t form.

w:as taken at the normal operating load.

w.t:; reaclic!d.

The test po ln t , for each: boiler and f o r both fuels, . . -

Rcaci5,nqs wcre taken a f t e r a Gtaady Stztc? zt.coin rl6w conciition

. thoi-inoco~1~1e w i ~ r c pozsihle . Flue.&as aanqlcs were takon from the ' I

h e 1 oil iind natural gas samples were liaken and analysis was handled by the customer.

The b j r i t c r wishes io express thrinka a t t h i s time i n behalf of' Ch?. 13;lI)cnck i; W L ~ C O Y Co. TO? the Courtesy and cooperation extended l r i i t i w h i l e st , th i : j plant.

!l'!;ii+eraturc r o a d i n p . were vcrcrierl by mean5 o f a I.,

L w i l e r o u L l e L z i i u wcre anolyzcc! by. me;\.ris or an orsat. I ..

. .

..

E 3 3 W d

TO . A. H. Herrill &Associates, Inc. .

. 45 @ail @ut%, suite 204 _ _ ........ .-- ' . * .. : .. W l W t C m k , CA 945% - . '

I I I I

- . . . . -

. . . . . . .

I

Quotation #W585-4, dated 5/31/85 for the 1-

Closed specificatfon. No substitutions alicwed.

vendor t o furnish (3) sets uf prints for approval.

I I I I I

A':. Ub3U P.7411

BnJ-2 OD-9470-1 Page 2 Of.3 ooien

9 S3Wd 11SMa1W3 B NMOBE'WOBJ IE'II E6-6I-AWW

' . . . ! ' , I '+Q-as-ss 1 2 ~ 1 ~ FROM:BROWN a CALDWELL 10:5109379026 PAGE 1

Unless athewkc indicated or obyiw from the name ofdx vannnina~. the information conaind in this facsimile mesragc b confidential infomarion intended for the usc of (hc Individual or entity MI& below. If the d e r of &is me*ugc is not me hda mipicnt, or the employee or agent mponsible to delivu it to he mtmM Rcipims you M hmby notified that any disminatiolL dimibmion or copying of this communication is nricUy prohibited. If you have received mis aommunica~on in ermr, please notify us at the telephone number listed. ltmk you.

A C A L D W E L L

May 26,1998

I FAX TRANSMITTAL COVER SHEET I PLEASE DELIVER THE FOLLOWING P A G B TO:

Name: Mark Schoahoff Company: San Joaquin Urdied Au Pollution Control District

Cityfitate: Modesto, CA F A X NO: (209) 545-8652


Name: Wilma Dreessen Return origiuak Yes Employee No: 8110 Stamp: Yes

( ProjectNo: 6090 Staple: Yesa No TaskCk, 16.5

SPECIAL INSTRUCTIONS/REMARKS:

Attached is an estimate of $560,OOO for the cost of a new 95,000 PPH steam boiler in 1985. This is for a standard boiler with no special NOx emission reductions. The actual burner replacements at the Newark Sierra Paperboard Corporation faciity for boiler 1 and boiler 2, respectively, are 8.6 percent and 3.9 percent of the fixed capital cost that would be required to construct a comparable entirely new facility. Thus, the 1985 project did not meet the definition of reconstruction in 40CFR60.15. The boilers are not subject to NSPS subpart Db (4OCFFt60).

If you have additional questionS, please call me at (925) 210-2289.

NUMBER OF PAGES BEING TRANSMITTED INCLUDING COVER SHEET:

l 5 l v h n n a . n m ~ ~ r i n g M ~ *

sum 150,3480BvsruaKAmPucwurrHnSCAUR)PNU945214342 (510) 937-9010 FAX: (510)937-5026

’ , .MA?;26-98 1 2 : 1 8 FR0M:BROWN E CALDWELL .._ ,

I D : 5109379026 PAGE 2

May 26, 1998 i

MEMO

TO: Wilma Dreessen FROM: Jim Schettler

SUBECT: Replacement Steam Boiler Cost, for a 95,000 PPH steam boiler

This memo is reference to the 1985 replacement capital cost of an installed 95,000- pound per hour (PPH), 45O-psig, 650 F steam boiler equipped for firing with either natural gas or No. 6 diesel fuel oil.

Cost inflation in this =ea of Northern California, including Stockton, has averaged about 3 to 4 percent per year for the 13 years since 1985. Thus the 1985 steam boiler equipment cost will be about 60 to 68 percent of the 1998 steam boiler equipment cast.

~

The capital cost will include removing the old boiler, possibly by removing a section of ~

wall, along with installing the new boiler. Installation also includes removing and reattaching the piping and electrical, dong with setting the boiler on the foundation. Per the ‘‘ R S Means” mechanical cost estimator guidebook, large mechanical equipment such as steam boilers have an installation cost typically about 30 to 50 percent of the bare equipment cost These installation costs do not include any specialty costs such as

I

asbestos removal and disposal, or a replacement exhaust stack. i

~

For simplicity, I’ve use a 1985 cost factor of 64% (for 3.5 % annual inflation) and an equipment installation cost factor of 40?? (between 30 and SVh)). Thus the 1985 cost, in 1985 dollars, will be about:

AAA x 0.64 x 1.4 = 0.90 x AAA where AAA is the quoted 1998 equipment cost ,‘/

I

1-

i _ ,

Attached is a cost quote for S620,OOO kom Cleaver Braoks for the May 1998 cost of a

boiler cost of an equivalent boiler, in 1985 dollars is therefore approximately $560,000. e+- This value is the fixed capital cost of the new components.

The suppliers’ invoiced cost for the burner replacements, in 1985, were approxjmately ,v~f- %48,000 and $22,000 for boilers 1 and 2 respectively. These 1985 burna replacement

prices are substantially less than 50% of the fixed capital cost, or $280,000 in 1985 dollars, for a mmparable, entirely new, replacement steam boiler.

Thus, the two 1985 burner replacements do not meet the 40 CFR 60.15 definition of

dual fuel, 95,000-PPH, 45O-psig, steam boiler. The 1985 installed replacement steam

:+b( I

i

DJ !

j !

“reconstmiion” of an existing Fdcility. I

IDz5109379026 ' . "e1;:26-98 12: 19 FROM:BROWN 8 CALDWELL Phone 51s 784-01 i o m.r.mawunam uompany

25920 Eden Landmg Road HaywamCa. 9 4 ~ F ~ u 510-764-1004

- Fax Cover Sheet -

Date: 5/26/98

Pages:

To:

Fax Phone: ,

From: Dale Yager

Subject: Cleaver-Brooks Boiler

Jim:

Please see attached data sheets for the 95,000 #/hr. boiler per your request.

Also the budget price does not include freight or start UP- Advise if I can be of further help.

Thank you,

.......-....... Dale Yager

( 1

MAY:^^-98 1Z:lS FROMsBROWN B CALDWELL PAGE 4

-4

cUSTONER:BROW 6 CALWELL

DATE:05-22-1998 LOCATION:---, --- BURNER: 200-CT BOILER H6DEL:DLL)K-110-S SUPERHWER: 764 Sg. Fp. DESIGN PRBSS.2 550 PSIG

ALT.: 500 FT. (HG): 29.38 BOIWiR B.S.: 6114 SQ.FF. Pc: 1-01 PRO$. W.W.: 1172 sp.

ECONOMIZER (SQ- FT.): FVPmCE VoLUm: 1890 N.m.

STM E X T W P Y (BTU/#): 1332.49 mAL H.S.: 7286 SQ. IT. WATER ENTflALPY (BTU/#) : 290.279 DEG. SUPERWEAT: lS2

USE ANPERSON SgPAilATORs FOR L-OPK

STWCFLOW LES/HR PERCENT QF MX. LOAD CONT. BWDOWN LBS/IIR

4 EXCESS ATR NRN. + BOILER

SUPERHER'PER PRESS. DROP PSIG DRVM OPERATING PRESS. PSIG S.H. OUTLET S T W TEKP. DEG. E. NRNACE EXIT CAS TEHP. DEC-P FLUE GAS LV. BOILER l'm. D S F WATER T W . ENTER. BOILER DE6.-P AWBXENT X R TQ@- DEG-F

TYPE oe NEL FIRED

STEAH PRESS. e S.H. OUTLET FSIG

21750. 25.

712. # I OIL

so. 4.50. ~~

2. 452. 596.

1338. 476. 320.

B O .

4'1500. so.

1425. LIS OIL

20. 450.

9. 1159. 618.

1670. 511. 320.

80.

71250. 7s.

2137. $2 OIL 1s.

450. 20. ,

31 O:/ 635. 1876.

554. 320. 80.

35.' !

4 8 5 . 650.

2019. 603. 320. BO. 100.

I I HEW OVTPU" * 1000 BTU/UR 24089. 48815. 73950. 99488. EUIT I N W 1000 BTU/MI 29991. 60069. 91312. 124316. 12qfi 6!'16Mym DRY GAS ?LOSS S 9.02 9.04 9.53 10.52

UNACCOUNTED i'oR LOSS 4 1.00 1.00 1.00 1.00 2.11 1.04 0.69 0 .51

H2 6 H Z O IN !i"EL LOSS 6 7.34 7-43 7.55 7.69 MOISTURE IN A I R LOSS E 0.22 0.22 0.24 0.26

RADIATION LOSS e TCVPAl XEAT Loss. 4 19.69 10.74 19.01 19.93 EfffCIENCS OF uPIT BASED ON (HRVl 0 80.3). 81.26 80.99 80.01

W n FIRED LBS/BR FUEL FIRED GAbL/ER HlW OF F W L BTU/LB

FLVE GAS NRW. C BoILER IBS/HR FLUE GAS TO STACK LBS/HR M k EOR CCX4iWSTIdN LBSIER CUXBUSTfON AIR Cm

DRAFT LOSS FURN. 4 BOILER M W.G. DrtAf i LOSS IN BREEQIING IN W.G. PRESSORE IN N R N A C t IN W.G. D R L T LOSS TIIRV BURNER DRAFT LOSS TN . U A DUCT NET RESISTANCE 1% W.G.

ETW. HT- RE., B T l l / f t R / C U ~ .FUVRN.WT.RE., Bl'U/IiR/SQff,PROJ,W.W.

PSV-1%-15-33 S T m R E D ARRO'T

IN W.G. IN W.G.

nzm ABS. RAZE B T U / H R / S Q ~

1ss9 .. 213.

19300.

30616. 30616. 29062.

6700.

0.58 0.02 0.60 0.53 0.00 1-13

15866. 25594. 2969.

3112. ~~ ~

426. ,19300.

56833. 56893. $3721. 12385.

2.19 0 . 0 7 2.26 1.83 0.02 4.11

31712. 512S4. 5978.

4731.

19300. 648.

82990. 82990.

18042, 78258.

4 .90

3.91

0.16 5.06

0.05 9.02

48297. 77910. 8967.

112987. 112987. + e.% 106546. 115069, 24564. 27512.

i 9.27 0.30 9 . 5 1 7.26 0.10 +17.% I

16-93 19.74 i

65754. 106072, 1195s.

i

. -,. . MAYy26-98 12:19 FRDM:BRDWN a CALDWELL ID:5109379026 PAGE 5

CUSTOHZR:BROU?l 6 CkLBUlELL tow1ON : --- , --- WE: 05-22-1998

SURHER: ZOO-CT BOILER HODEL:DLDR-l10-S SUPSUHLATER: 764 SQ, m. BofzeR DESXW PRI?SS.; 550 PSIG

UT.: 5 0 0 Et. (HG) : 2 9 . 3 ~ BOILER H.J.: 6114 S Q . ~ . Fc: 1.01 PRCIJ. W.W.? 1172 Sg, fi S T n ENTHALPY (BTVIR): 1332-49 T@AZ H.5.: 7286 SQ. fF. WATER ENTRALE'Y (BW/#1 : 290.279 DEG. SUPEMHEAT: 182

ZCONOIQIZER ISQ. m.): FURNACE W L m : 1090 Cv.m.

USE ANDERSON SEPARATORS FUR l-PPH

S T W FLOW LBS/XR 23750. PERCENT O€ MRX. LOA0 25. C W . BLOWDOWN IBS/HR 712. TYPZ OF WSL FIRE3 NAT.oAs B EXCESS AIR m. + a o x m 30. STEAM PRESS. C 9.R. OUTLEI PSIG 450. SVPERIIEATER PRESS. DROP PSt6 2 . DRUM OPERATING PRESS. PSIG 452. 5 . 8 . OUTLET STPAPI TEMP. DCC. F. 596. NRUASE EXIT GAS TEMP- DSG-F 1391. FLUE GAS LV. BOILER TEKP. DEC-P 472. WATER T W . W E R , EOILBR DEG.-P 320. AMBIENT AIR T m . DEG-r eo.

HEAT OUTPUT * 1000 BrV/I lR 24089. INPUT 1000 STUlllR 311634

PRY GAS LOSS % 0 .43 6 820 IN PUEL LOSS P 11 .44

WITTURE IN AIR to99 % 0.22 UNACCOUNTED FOR LOSS S 0.50 RRPIATION LOSS B 2.11 TOTAL HEAT LOSS 0 22.70 EFFICIEXCY OF UNIT W E D OM (W) % 71-30

EuEL FIRED SBSIIIR 1471: NEL PIxm SCRi 31163. HIN OF RteL BW/LB 21100.

aW W RTEN. 6 BOILER LBS/BR 31236. FLUE GAS TO STACK LBS/HR 31236. AZR FOR COMBUSTION LBS/EIR 29754. COMBUSTION A I R CPM 6861.

BRAfi LOSS PVRN. 6 DOILER I N W.C. 0.65 DPAFT MS5 IN W E C H I N G M W.C. 0 .02 PRESSURe I N -E I N W.6. 0.67 DPAZT LOSS THRU BVPNER IN W.G. 0.53 D W LOSS IN ASR IxrCT IN W . G . 0 .00 NET RESISTANCE ZN R.G. 1.20

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. - . . M A Y - ~ s - ~ ~ 12120 FROM-BROWN H CALDWELL ID:5103379026

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srd. optins w B o k .

start-up Field Service

I I I I

. .. . . . . . . _. .. . . . . . . .

. . . , . . .. .: , .

S N JOA UlN VALLEY UNlFlE B A.P.C.D.

B R 0 w N N2m'ON Unless othenrirs indieatcd or obvious from the name of rhe msmittal, rhe informstion contained in rhis facrimllc mcssagc is confidmtial information intended for the use of the individual or cntity m c d below. lfths reader or this message is no1 the inrcndcd recipient. or the employee or agent responsible 10 deliver it IO du intcndcd recipient, you are hereby notifcd that any dissemination, distribution or copying of this communimion is strictly prohibited. If you have received this communication in error, plcasc notify us a1 the telephone number listed. Thank you.

C A L D W E L L

May 15,1998

1 FAX TRANSMITTAL COVER SHEET I PLEASE DELIVER THE FOLLOWING PAGES TO:

Name: Mark Schonhoff Comoanv: San Joaauin Unified Air

City/State: Modesto, CA

- - Pollution Control District I

FAX NO: (209)545-8652


Name: Wilma Dreessen Return originals: Yes No 0 Employee No: 81 10 Stamp: YesW N o m Project No: 001 1 Staple: Yesm N o 0 Tark.G/L: 05.7

SPECIAL INSTRUCTIONSAWMARKS

Attached are records from Coen Company regarding the Newark Sierra Paperboard Corporation boilers before and after 1985. Thc project did not meet tlic definition of modification or reconstruction in 40CFR60.14-15. The boilers are not subject to NSPS subpart Db (40CFR60).

If you have additional questions, please call me at (925) 210-2289

M E R OF PAGES BEING TRANSMIMITTED INCLUDING COVER SHEET: 2 Emimnmenial Enprneenng And CunSuMng

S u m 150,3480 BUSKIRK AvGNU6, PWsANr HILL, chLIfORNI4 94523-4342 mom (510)937-9010 FAX. (510)937-9326

t 3 3 W d

. ._ . .

SAN JOA UIN VALLEY UNlNE A.P.C.D. NO. s REGION

... . .. . . _., Attention: .~.-

Reference: 1. Newark

1 Dear Wilma:

In reference to your letter of 5/7/98, awhed is a boiler Fiberboard Co oration dated 5/2/77. This repon

new Coen burners were provided in rhe 3 quarter of capacity is 95, 7 00 pounds per hour 0f445~psig / 650

capacity, the design fuel gas and fuel oil wnsumption rates have not changed and should be ti%" e

Coen burners are designed to tire these boilers to the same design capacity.

So rhe answer to your qucnion is; since the Coen brrrnn retrofits did naz change the boiler desi

same as in the original design.

If any questions, just call.

Sincerely,

I

Matthew Hall Application Engineer

CC: Lou Brimlara, Coen Company Sales Representative, Sau Ramon, CA.

2 3 3 W d

. .. . .. :I'

. TI19 followin[: is' d report of the eff ic lency t e s t s mxde January'

on both of tlie 5,2-.bcock -& Wilcos b o i l e r s a t 7ib'erboard Corp., S t o c A t m CA. 'Phc (lata, p r i i i c i p a l r e s u l t s , , aad recomnendst ions of these tests. 'are included i n this report .

,.'; : ."i 25 k 2 s 2 1977 by l W v M. P. LJieszczylc of t h e Bibcock P; 'ililcox Co. .,. .

.,'.

. . DESCi7IPTIOli 01' 130XL.ERS ..:. :: , \ - . . . 'Pdo -(2) -~ $?s~,OOO lB/hr, F--type, Babcock & Milcox U n i t s

The b o i l ' e r s *.re equipped- with th ree ( 3 ) Coen type o i l a n d gas , . '

.. .. .~ ~. ~.

.I I

147 7 burnera. Each u n i t is a l so equipped w i t h a,BabcocR Milcox tub- ._ .)

. . .. .. , . . . - . . u l a r air heater .

These t e s t . ? wore 'conducted i n a w o r d a n c e w i t h the RSME shor t I ' test form. The t e s t p o i n t , f o r each, b o i l e r and f o r both fuels,

VZG tzken at tlie normal operating load. , . -

Rr!acij,nr;s w e ~ c taken i l f ce r il .-.Leady ,state st.:cain fl& c o n e i t i o n I.I,-.L"I r e x r i c d . 'T!:n,iwrntutc roadinEz, were vcrcf ie i l by incans of a ..

. eh~rinocoirplc whcrc por,sihle, Flue. &TI :ani?ler. were t a k e n from the . . . L d l e r uuL.lcL i : b i J wcre uimlytec! by. inems of air, orsat.

N e 1 o i l :And n a k u r a l gas samples were &.ken and a n a l y s i s was handled by the customer.

The r j r i t o r wj.ahes to express tlizinks n t t h i s t ime i n h e h c l f of .' t h e . U a b c o c k L: Gii:lcox Co. for t h e cour tesy and cooperat ion extended - ,

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furnished In accordance *lth A-H-.Mewl!l's Quotation #w585-4, dated 5/31/85 for the 1-

Closed specification, NO S u b S t i t U t i M S ali-d. .

. . . - . - . .. . .. . .- .. .. -. . . .. . . . - . , . , ..

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I . - Vendor t o fumlsh ,(3) sets of prints for approval.

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TO . A. H. Nerrlll I ASSOC. Inc, c/o c m coapanr Ualnut cwek, CA 94596

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c UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX

75 Hawthorne Street San Francisco, CA 94105-3901

March 11,1998

Seyed Sadredin Director of Permit Services San Joaquin Valley

1999 Tuolumne Street, Suite 200 Fresno, CA 93721

Unified Air Pollution Control District SAN JbA UII\ V i - i ~ ~ d

UNlFlE A.P.C.D. NO. REGION

8

Subject: Draft Emission Reduction Credit for Newark Sierra Paperboard Corporation (project # 970384)

Dear Mr. Sadredin:

EPA appreciates the opportunity to review this draft Emission Reduction Credit (ERC) for Newark Sierra Paperboard Corporation (NSPC). NSPC retrofit two boilers with low-NOx burners, increased their capacity to 135 MMbtulhr, and was restricted to burning primarily natural gas instead of fuel oil. The District proposed issuing approximately 341’tons per year of .sulfur dioxide (SOX) credits; 244 tons per year of nitrogen oxides (NOx) creditsYS0 tons per year of fine particulate (PM,,) credits; 42 tons per year of carbon monoxide (CO) credits; and 2 tons per year of volatile organic compound (VOC) credits.

We believe that NSPC may qualify for reduced ERCs for PM,, and sulfur oxides SOX. EPA’s New Source Performance Standard (40 CFR subpart Db) SOX and par t iha te emission limits were triggered by increases in NSPC’s emission rate. However, we believe that the District could show that some of the reductions of S o x and PM,, emissions are surplus to the reductions required by the NSPS. We would like to work with the District to establish the appropriate baselines for these pollutants.

We recommend not issuing NOx ERCs because all of the emission reductions at boilers I and 2 are mandated by District regulations and part of the emission reductions are also required by NSPS subpart Db. Both the Clean Air Act (section 173(a)) and District rule 2201 (section 3.2.1) prohibit offsets for emission decreases that are not surplus. Therefore, none of the proposed NOx ERCs could be used to comply with ‘my federally enforceable offset requirement under the Clean Air Act (CAA), including offset requirements under Rule 209.1 of the San Joaquin County State Implementation Plan.

We also recommend that the District not issue the proposed CO ERCs. NSPC’s post- modification emissions will decrease under certain circumstances, but the modification generally allows NSPC to increase their emission rate and total emissions. We estimate that the allowable post-modification emissions are about 100 tons per year more than the actual pre-modification

. .

+ emissions. In addition, the baseline emissions are higher than allowed by District rule 4305.

We would also like in opportunity to comment on the District’s ATC for the modifications to these boilers. According to the District’s evaluation (dated March 8, 1995, see page 7) the District did not provide the public notice required for projects in non-attainment areas. This may have been due to a misunderstanding of the EPA non-attainment designation in effect when NSPC increased CO emissions. We are providing you with preliminary comments based on copies of the permits and evaluation provided by your staff. However, we recommend that the District provide public notice to meet the requirements of Rule 2201 section 5.1.3 that were triggered by the modification.

Our detailed comments on this project are enclosed. We request that you not take further action on this project until we have reached agreement that the credits have been revised to comply with all federally enforceable requirements. Please call me at (415) 744-1254 or have your staff call Ed Pike of the Permits Office at (415) 744-121 1 if you have questions regarding this letter.

Sincerely,

Matt Haber Chief, Permits Office

Enclosures

cc: Anthony Mendes, Permits Services Manager, Northern Region Ray Menebroker, California Air Resources Board Mark Vincent, Newark Sierra Paperboard Company

Enclosure A EPA Comments on Newark Sierra Paperboard Corporation (project # 970384) Draft ERC

and Preliminary Comments on Final ATCs (N-577-3-1 and N-577-4-1)

1. Surplus Test for NOx

The District has proposed granting Emission Reduction Credits based on a finding that the source complies with District rule 2201 section 3.2.3. However, compliance with this section alone is not adequate to qualify for Emission Reduction Credits. District rule 2201 section 3.2.1 also requires that reductions used for Emission Reduction Credits “Shall be real, enforceable, quantifiable, surplus, and permanent.” Boilers 1 and 2 at this facility are prohibited from emitting more than 30 ppm NOx by District rule 4305. In addition, NOx emission reductions were required by NSPS subpart Db (40 CFR section 60.44b). Therefore, the reduction is not surplus and the source is not eligible for NOx ERCs.

2. NSPS SOX and Particulate Limits

As noted in the District’s evaluation of the capacity increase (dated March 8, 1995. see page one), the modified boilers are subject to NSPS subpart Db. Therefore, the sulfur dioxide and PM,, baselines must be adjusted by the amount of the reduction required by the NSPS (40 CFR sections 60.42b and 60.43b). We are available to work with the District to calculate the appropriate adjustments. For PM,,, we recommend basing the allowable emissions on the PM,, fraction of the allowable NSPS particulate limit. We understand that a more recent ATC would remove the emission limits that exceed the NSPS allowable emissions. We recommend revising all permits for this source, including operating permits, to prohibit emissions in excess of the NSPS emission limit.

3. PM,, baseline

We would like an opportunity to review and comment on the basis for the PM,, baseline emission estimates. This data was referenced as attachment D to the original ATC application. We appreciate the information that District staff has provided us, and would like to receive this information as well.

Calculations for Carbon Monoxide and Other Pollutants 4.

The District has proposed granting Emission Reduction Credit for CO. However, the post-modification allowable emission rates (in Itdmmbtu and Ibs/hr) and total allowable emissions are higher than the average pre-modification emission rates and total premodification emissions. While the pre-modification emission rate was occasionally higher than the posthodification rate, the calculations for CO and all other pollutants

1

must consider both the emission decreases and increases that occurred due to the modification. The allowable post-modification CO emissions are about 100 tpy higher than NSPC’s past actual emissions (based on source test data)’. These calculations indicate that NSPC made a title I modification and was required by EPA regulations to offset this emission increase.

There are several reasons for the discrepancy between EPA’s calculations and the District’s. First,, the District’s calculation gives credit for burning less fuel oil without considering the emissions increase that will occur from burning natural gas with a higher CO emission rate instead. Second, the District calculation does not include the emission increases that occurred due to the modification of the boiler capacity from 1 1 1 - 1 1.3 MMbtu/hr each to 135 MMbtu/hr each. While’this discrepancy has the largest impact on CO calculations, all proposed credits must be recalculated to account for the emissions from natural gas replacing fuel oil and the emission increase allowed due to the capacity increase. We recommend recalculating all proposed credits based on the pre-project actual emissions (adjusted for all required reductions) minus the post-modification allowable emissions,

5. Public Notice for 1995 Authority to Construct

The District calculated (March 8, 1995 evaluation, see pages 10 and 11) an “IPE” for CO of 79 and 3 12 Ibdday for two operating scenarios. The IPE for the typical premodification operating scenario (fuel oil) and post-modification operating scenario (natural gas) is 398 Ibs/day or more2. Therefore, the IPE exceeded the 100 Ibs CO/day threshold for public notice in non-attainment areas (District Rule 2201 section 5.1.3.4). We understand that the lack of public (including EPA) notice for the 1995 permits authorizing the modification may have been due to a misunderstanding of the EPA non- attainment designation for Stockton at the time of permit issuance. We,recommend working with EPA to ensure that the permit meets all District and EPA requiremenis and then providing the public notice triggered by the emission increase.

As you know, EPA’s proposed redesignation for Stockton may be finalized soon.

’ See enclosure B for calculations. The emission increase is higher if baseline emissions are reduced based on rule 4305 compliance limits.

According to the District evaluation @IO-I I), the Historic Adjusted Potential Emissions ( H U E ) is 87.9 Ibs/day and the post-modification potential to emit is 486 Ibs/day under typical operating conditions. The Increase in Permitted Emissions (IPE) is the post-modification Permitted Emissions minus the HAPE, or 486 Ibs/day - 87.9 Ibs/day = 398 Ibs/day. The IPE is greater when using actual source test data instead of District emission estimates to calculate the HAPE or reducing the baseline for reductions required by District rule 4305.

2

However, we believe that NSPC should comply with the requirements that were triggered at the time of the emission increase rather than the EPA PSD program that would apply after a final redesignation.

6. BACT for Carbon Monoxide

Although EPA and District rules vary in their applicability test, we believe that the NSPC triggered review under both. District rule 2201 (section 6.1 . I . 1) requires state BACT (which should be equivalent to EPA LAER) for an Increase in Permitted Emissions (“IPE) for CO of two pounds per day in non-attainment areas. EPA has calculated that the increase is a title I modification that also exceeds the EPA LAER thresholds. Therefore, we recommend conducting a BACT review for this emission increase and providing EPA and the public with an opportunity to review your determination.

7. De-Bottlenecking

The increased capacity of the new boiler will provide NSPC with additional steam that will likely be used to increase the production rate at the facility. If the new boiler increases emissions at other units by “de-bottle necking” production, the increase in emission and potential to emit could be subject to New Source Review. If the District has not reviewed other equipment at the plant that may increase emissions due to the increase in boiler capacity, we recommend that the District perform a New Source Review applicability determination for this equipment.

3

, .

. . .:.

I

Enclosure B Carbon Monoxide Emission Calculations

1) Calculation of Annual Emission Increase A ) Past Actual CO Emissions Based on Source Test Data ' and Fuel Usage:

1) using source test results of 0.003 Ib/MMbtu for fuel oil and 0.36 IblMMbtu for natural gas:

-> 907,600 MMbtu oil/yr * 0.003 Ib CO/MMbtu + 410,000 MMbtu gas/yr * 0.36 IbslMMbtu = 2722 lbslyr + 147,600 Ibs/yr = 75.1 tpy CO

2) using source test results of 0.003 Ib/MMbtu for fuel oil and allowable rule 4305 emissions of 0.293 Ib/MMbtu for natural gas

-> 907,600 MMbtu oil/yr * 0.003 Ib CO/MMbtu + 410,000 MMbtu gas/yr * 0.293 Ibs/MMbtu = 2722 Ibs/yr + 120,130 Ibs/yr = 61.4 tpy C O

B) Potential to Emit for Modified Boiler? ,

= 0.15 Ibm COlMMbtu * (2 boiler * 135 MMbtu /boiler/hr) * 8670 hrs/yr = 175.6 tpy CO at rated capacity

C) Emission Increase Allowable Future Emissions minus Past Actual Emissions:

Allowable Future Emissions minus Past Actual Emissions Adjusted for Rule 4305:

175.6 tpy - 75.1 tpy = 100.5 tpy C O

175.6 tpy - 61.4 tpy = 114.2 tpy C O

'Note: EPA believes that actual emissions should be calculated from measured, rather than estimated emissions. The District chose not to use the 1991 source test for one pollutant, CO, when the measured emissions were substantially lower than AP-42 emission factors. When a valid source test results in an emission rate lower than AP-42, the baseline emissions must instead be based on the source test results.

2Calculations are based on permitted emission rates and rated capacity; unit may operate above rated capacity, especially for short time periods.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX

75 Hawthorne Street ,

San Francisco, CA 94105-3901

March 11,1998

Seyed Sadredin Director of Permit Services San Joaquin Valley

1999 Tuolumne Street, Suite 200 Unified Air Pollution Control District

Fresno, CA 93721

Subject: ~ ,

Draft Emission Reduction Credit for.Newark Sierra Paperboard Corporation ’

(project # 970384) i

Dear Mr. Sadredin:

EPA appreciates the opportunity to review this draft Emission Reduction Credit (ERC) for Newark Sierra Paperboard Corporation (NSPC). NSPC retrofit two boilers with low-NOx burners, increased their capacity to 135 MMbtu/hr, and was restricted to burning primarily natural gas instead of fuel oil. The District proposed issuing approximately 341 tons per year of sulfur dioxide (SOX) credits; 244 tons per year of nitrogen oxides (NOx) credits; 50 tons per year of fine particulate (PM,,) credits; 42 tons per year of carbon monoxide (CO) credits; and 2 tons per year of volatile organic compound (VOC) credits.

We believe that NSPC may qualify for reduced ERCs for PM,, and sulfur oxides SOX. EPA’s New Source Performance Standard (40 CFR subpart Db) SOX and particulate emission limits were triggered by increases in NSPC’s emission rate. However, we believe that the District could show that some of the reductions of S o x and PM,, emissions are surplus to the reductions required by the NSPS. We would like to work with the District to establish the appropriate baselines for these pollutants.

We recommend not issuing NOx ERCs because all of the emission reductions at boilers I and 2 are mandated by District regulations and part of the emission reductions are also required by NSPS subpart Db. Both the Clean Air Act (section 173(a)) and District rule 2201 (section 3.2.1) prohibit offsets for emission decreases that are not surplus. Therefore, none of the proposed NOx ERCs could be used to comply with any federally enforceable offset requirement under the Clean Air Act (CAA), including offset requirements under Rule 209.1 of the San Joaquin County State Implementation Plan.

We also recommend that the District not issue the proposed CO ERCs. NSPC’s post- modification emissions will decrease under certain circumstances, but the modification generally allows NSPC to increase their emission rate and total emissions. We estimate that the allowable post-modification emissions are about 100 tons per year more than the actual pre-modification

emissions. In addition, the baseline emissions are higher than allowed by District rule 4305.

We would also like an opportunity to comment on the District’s ATC for the modifications to these boilers. According to the District’s evaluation (dated March 8, 1995, see page 7) the District did not provide the public notice required for projects in non-attainment areas. This may have been due to a misunderstanding of the EPA non-attainment designation in effect when NSPC increased CO emissions. We are providing you with preliminary comments based on copies of the permits and evaluation provided by your staff. However, we recommend that the District provide public notice to meet the requirements of Rule 2201 section 5.1.3 that were triggered by the modification.

Our detailed comments on this project are enclosed. We request that you not take further action on this project until we have reached agreement that the credits have been revised to comply with all federally enforceable requirements. Please call me at (415) 744-1254 or have your staff call Ed Pike of the Permits Office at (4 15) 744-12 11 if you have questions regarding this letter.

Sincerely,

Matt Haber Chief, Permits Office

Enclosures

cc: Anthony Mendes, Permits Services Manager, Northem Region Ray Menebroker, California Air Resources Board Mark Vincent, Newark Sierra Paperboard Company

f:\user\share\epi ke\sanjoaq\nspcerc. fin

.. ..

Enclosure A EPA Comments on Newark Sierra Paperboard Corporation (project # 970384) Draft ERC

and Preliminary Comments on Final ATCs (N-577-3-1 and N-577-4-1)

1. Surplus Test for NOx

The District has proposed granting Emission Reduction Credits based on a finding that (8 the source complies with District rule 2201 section 3.2.3. However, compliance with this 5

I,Cp section alone is not adequate to qualify for Emission Reduction Credits. District rule

2.

B

2201 section 3.2.1 also requires that reductions used for.Emission Reduction Credits “Shall be real, enforceable, quantifiable, surplus, and permanent.” Boilers 1 and 2 at this facility are prohibited from emitting more than 30 ppm NOx by District rule 4305. In addition, NOx emission reductions were required by NSPS subpart Db (40 CFR section 60.44b). Therefore, the reduction is not surplus and the source is not eligible for NOx ERCs.

NSPS SOX and Particulate Limits

As noted in the District’s evaluation of the capacity increase (dated March 8, 1995, see page one), the modified boilers are subject to NSPS subpart Db. Therefore, the sulfur dioxide and PM,, baselines must be adjusted .by the amount of the reduction required by the NSPS (40 CFR sections 60.42b and 60.43b). We are available to work with the v ’ . A*

“’ PI District to calculate the appropriate adjustments. For PM,,, we recommend basing the

allowable emissions on the PM,, fraction of the allowable NSPS particulate limit. We understand that a more recent ATC would remove the emission limits that exceed the NSPS allowable emissions. We recommend revising all permits for this source, including operating permits, to prohibit emissions in excess of the NSPS emission limit.

t Y hpv

3. PM,, baseline

We would like an opportunity to review and comment on the basis for the PM,, baseline emission estimates. This data was referenced as attachment D to the original ATC application. We appreciate the information that District staff has provided us, and would like to receive this information as well.

h~ ‘‘ p” L ~ Q P ’

4. Calculations for Carbon Monoxide and Other Pollutants

The District has proposed granting an Emission Reduction Credit for CO. However, the post-modification allowable emission rates (in Ibs/mmbtu and Ibs/hr) and total allowable emissions are higher than the average pre-modification emission rates and total premodification emissions. While the pre-modification emission rate was occasionally higher than the post-modification rate, the calculations for CO and all other pollutants

1

must consider both the emission decreases modification. The allowable post-modification CO emissions are about 100 tpy higher than NSPC’s past actual emissions (based on source test data)’. These calculations indicate that NSPC made a title I modification and was required by EPA regulations to offset this emission increase.

increases that occurred due to the

There are several reasons for the discrepancy between EPA’s calculations and the District’s. First, the District’s calculation gives credit for burning less fuel oil without considering the emissions increase that will occur from burning natural gas with a higher CO emission rate instead. Second, the District calculation does not include the emission increases that occurred due to the modification of the boiler capacity from 1 1 1-1 13 MMbtu/hr each to 135 MMbtu/hr each. While this discrepancy has the largest impact on CO calculations, all proposed credits must be recalculated to account for the emissions from natural gas replacing fuel oil and the emission increase allowed due to the capacity increase. We recommend recalculating all proposed credits based on the pre-project actual emissions (adjusted for all required reductions) minus the post-modification allowable emissions.

Public Notice for 1995 Authority to Construct

The District calculated (March 8, 1995 evaluation, see pages IO and 11) an “IPE” for CO of 79 and 312 Ibs/day for two operating scenarios. The IPE for the typical premodification operating scenario (fuel oil) and post-modification operating scenario (natural gas) is 398 Ibs/day or more2. Therefore, the IPE exceeded the 100 Ibs CO/day threshold for public notice in non-attainment areas (District Rule 2201 section 5.1.3.4). We understand that the lack of public (including EPA) notice for the 1995 permits authorizing the modification may have been due to a misunderstanding of the EPA non- attainment designation for Stockton at the time of permit issuance. We recommend working with EPA to ensure that the permit meets all District and EPA requirements and then providing the public notice triggered by the emission increase.

As you know, EPA’s proposed redesignation for Stockton may be finalized soon.

I See enclosure B for calculations. The emission increase is higher if baseline emissions are reduced based on rule 4305 compliance limits.

According to the District evaluation @lo-1 I), the Historic Adjusted Potential Emissions (HAPE) is 87.9 Ibs/day and the post-modification potential to emit is 486 Ibs/day under typical operating conditions. The Increase in Permitted Emissions (IPE) is the post-modification Permitted Emissions minus the HAPE, or 486 Ibs/day - 87.9 lbs/day = 398 Ibs/day. The IPE is greater when using actual source test data instead of District emission estimates to calculate the HAPE or reducing the baseline for reductions required by District rule 4305.

2

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However, we believe that NSPC should comply with the requirements that were triggered at the time of the emission increase rather than the EPA PSD program that would apply after a final redesignation.

6. BACT for Carbon Monoxide

Although EPA and District rules vary in their applicability test, we believe that the NSPC triggered review under both. District rule 2201 (section 6.1 . I . l ) requires state BACT

,#’ (which should be eauivalent to EPA LAER) for an Increase in Permitted Emissions (“IPE”) for CO of two pounds per day in non-attainment areas. EPA has calculated that the increase is a title I modification that also exceeds the EPA LAER thresholds. Therefore, we recommend conducting a BACT review for this emission increase and providing EPA and the public with an opportunity to review your determination.

De-Bottlenecking

The increased capacity of the new boiler will provide NSPC with additional steam that will likely be used to increase the production rate at the facility. If the new boiler increases emissions at other units by “de-bottle necking” production, the increase in emission and potential to emit could be subject to New Source Review. If the District has not reviewed other equipment at the plant that may increase emissions due to the increase in boiler capacity, we recommend that the District perform a New Source Review applicability determination for this equipment.

3

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Enclosure B Carbon Monoxide Emission Calculations

1) Calculation of Annual Emission Increase A) Past Actual CO Emissions Based on Source Test Data and Fuel Usage:

1) using source test results of 0.003 IblMMbtu for fuel oil and 0.36 IblMMbtu for natural gas:

-> 907,600 MMbtu oillyr * 0.003 Ib COlMMbtu + 410,000 MMbtu gaslyr * 0.36 IbslMMbtu = 2722 lbslyr + 147,600 lbslyr = 75.1 tpy CO

2) using source test results of 0.003 IblMMbtu for fuel oil and allowable rule 4305 emissions of 0.293 IblMMbtu for natural gas

-> 907,600 MMbtu oillyr * 0.003 Ib COlMMbtu + 410,000 MMbtu gaslyr * 0.293 IbslMMbtu = 2722 Ibslyr + 120,130 Ibslyr = 61.4 tpy CO

B) Potential to Emit for Modified Boiler? = 0.15 Ibm COlMMbtu * (2 boiler * 135 MMbtu lboilerlhr) * 8670 hrslyr = 175.6 tpy CO at rated capacity

C) Emission Increase Allowable Future Emissions minus Past Actual Emissions:

Allowable Future Emissions minus Past Actual Emissions Adjusted for Rule 4305:

175.6 tpy - 75.1 tpy = 100.5 tpy CO

175.6 tpy - 61.4 tpy = 114.2 tpy CO

'Note: EPA believes that actual emissions should be calculated from measured, rather than estimated emissions. The District chose not to use the 1991 source test for one pollutant, CO, when the measured emissions were substantially lower than AP-42 emission factors. When a valid source test results in an emission rate lower than AP-42, the baseline emissions must instead be based on the source test results.

*Calculations are based on permitted emission rates and rated capacity; unit may operate above rated capacity, especially for short time periods.

.>- ~ I &;i [

San Joaquin Valley Unified Air Pollution Control District

November 5, 1998

Matt Haber Permits Office Air Division US. E.P.A. - Region IX 75 Hawthorne Street San Francisco, CA 94105

SAh JUhyuliv V ~ L L L Y UNIFIED A.P.C.D.

NO. REGION

Dear Mr. Haber:

RE: San Joaquin Valley Unified Air Pollution Control District ERC Project 970384 (Newark Sierra Paperboard)

The District has received your comment letter dated March 11, 1998, concerning the above project and offers the following responses:

Comments:

The NOx emissions were riot surplus because the boilers were subject to both District Rule 4305 and 40 CFR Part 60, Subpart Db.

Deductions to the SOX and PMlO ERC's must be made because the boilers were subject to 40 CFR Part 60, Subpart Db during the baseline period.

The increase in boiler capacity would likely be utilized to increase the production of the facility which could trigger District New Source Review requirements for other units.

Response:

The applications for the Authorities to Construct authorizing the installation of the low NOx burners that resulted in the NOx reductions proposed for banking were deemed complete on December 10, 1991. This is prior to the date that District Rule 4305 was added to the District list of NOx control measures. Therefore, none of the reductions may be discounted for this reason.

The modifications to these two boilers did not result in an increase in heat input capacity, although it is certainly understandable why EPA thought that was the case. The Application Review for N-577-3-1 and N-577-4-1 dated March, 1995 incorrectly listed the pre-modification heat input capacities as 113 MMBtu/hr for natural gas and 11 1 MMBtulhr for #6 fuel oil. Attached are copies of the original permit applications in April, 1974 that list the heat input rating of the original burners as “Approximately 130 MMBtulhr.” Also attached is a copy of the information submitted with the application for modification in June, 1985 which lists the heat input rating of the replacement burners as 142 MMBtulhr for natural gas and 122 MMBtulhr for #6 fuel oil, and a copy of the San Joaquin County APCD application review that uses those heat input ratings in it‘s evaluation of compliance. Also note that in each application, the boiler remains rated at 95,000 pounds of steam per hour.

Newark Sierra Paperboard also submitted information showing that the cost of the retrofits did not result in either boiler becoming a reconstructed stationary source.

Since modification to the boilers did not result in an increase in heat input capacity and the boilers did not become reconstructed stationary sources as defined in Subpart Db, they were not subject to Subpart Db during the baseline period and no deduction of NOx ERC’s may be made for this reason.

Comment :

The EPA would like access to the information contained in appendix D of the ATC application for the burner retrofits pertaining to the PM10 emission estimates.

Response:

The information is included with this letter.

Comment:

The CO emission reductions were incorrectly calculated

Response:

There were two actions on Newark Sierra’s part that resulted in actual emission reductions (AER’s); reduced fuel oil usage and the installation of low NOx natural gas burners. District rule 2201 specifies the equation to be utilized to calculate the AER’s that occurred as a result of each action.

In order to calculate the reductions due to the reduced usage of fuel oil the following equation was utilized per section 6.5.1:

AER = HAE - PE, where:

HAE is the historical actual emissions calculated utilizing actual fuel oil usages and valid emission factors.

PE is the postmodification potential to emit while firing on fuel oil.

In order to calculate the reductions due to the replacement of the original natural gas burners with low NOx natural gas burners the following equation was utilized per section 6.5.2:

AER = HAE X CE, where

HAE is the historical actual emissions calculated utilizing actual natural gas usages and' valid emission factors.

CE is the control due to the new burners.

The total HAEs are therefore:

(HAE - PE),,, + (HAE X CE),,

The CO reductions were correctly calculated in accordance with District Rule 2201.

Comments:

The increase in permitted emissions of CO was greater than 100 pounds per day, therefore, the project should have been public noticed because the area in which Newark Sierra is located was not yet officially designated by the EPA as attainment for co.

The District utilized the incorrect CO BACT trigger because it incorrectly assumed that the facility was located in a CO attainment area.

Response:

The area was in compliance with Federal CO standards at the time that the application was deemed complete. Therefore, the application was evaluated as a project in a CO attainment area even though EPA still had not yet officially designated the area as attainment.

.. '.

Should you have any questions please telephone Seyed Sadredin at (209) 497-1000.

Sincerely,

Seyed adredin . .

Director of Permit Services

SS/AJ M/M JS/cl Enclosure

c: Mark Vincent - Newark Sierra Paperboard

a

. ' BCC Sac 5117-09 .. ..

OCtober 3. 1991 Page 4

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INTRODUCTION

On September 10, 1991, BC Analytical performed source testing on the exhaust of boiler number 2 at Newark Sierra Wood Products' Stockton, CA facility. This report contains all of the data and results of the sampling and analysis undertaken.

The test was performed to gather information for in-house information and engineering purposes only. The table below lists the sampling methods, number of sample replicates, sample run duration and approximate sample volume for each determination. The visible emissions testing was performed by Galson Corporation. Their report is inciuded in Appendix A.

Minimum Minimum Sampling Sample Sampling Sample Sample Determination Method Replicate Duration Volume

Particulate CARB 5 3 60 min. 30 ft3 Sulfate, Ammonia, HC1 NOx, CO, S02, THC

Visible Emissions EPA 9 (concurrent with C A W 5)

CAR$ 5 (determined from aliquots from particulate trains)

C02, and 0 2 CARB 100 (continuous)

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' ECC Sac 5147-09 .October 8: 1991

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DATA SUMMARY

Parameter RUN 1

Particulate Sampling, Duct Conditions:

Date 9/10/91 Time 1227-1257

Temperature, O F Abs. Press., in Hg Velocity, ft/sec Volume Flow Rate

ACFM SDCFM % H,O

Fixed Gases %O, vol.dry

%CO, vol. dry

%N2 vol.dry

425 29.99

39.6

47400 25000

10.4

9.6

7.8

82.6

Particulate Concen [ration, gr/SDCF

Total Filterable 0.067 Total Aqueous Condensable 0.022 Total Organic Condensable 0.006 Total Particulate 0.094 Sulfate 0.039 Hydrogen Chloride 0.0008 Ammonia 0.00004

Particulate Emissions, lb/hr

Total Filterable 14.36 Total Aqueous Condensable 4.63 Total Organic Condensable 1.20 Total Particulate 20. I9 Sulfate 8.40 Hydrogen Chloride 0.17 Ammonia 0.009

RUN 2

9/10/91 1422- 1522

420 29.99 35.1

42100 22300

10.5

8.1

9.2

82.7

0.019 0.015 0.003 0.037 0.014

0.0008 0.000005

3.63 2.90 0.62 7. IS 2.76 0.16

0.0009

RUN 3

9/10/91 1613-1713

392 29.99

26.8

32 100 17600

10.4

7.6

9.5

82.9

0.048 0.019 0.005 0.072 0.033

0.0008 0.000005

7.30 2.85 0.74

10.89 4.91 0.13

0.0008

AVERAGE

4 12 29.99

33.8

40533 2 1633

10.4

8.4

8.8

82.7

0.044 0.019 0.005 0.068 0.029

0.0008 0.00002

8.43 3.46 0.85

12.74 5.36 0.15

0.0036

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. BCC Sac 5147-09 . October'8. 1991

Page 6

DATA SUMMARY

RUN5 AVERAGE RUN 1 RUN 2 RUN 3 RUN 4

Date 9/10/91 9/10/91 9/10/91 9/10/91 9/10/91 Time 1123-1222 1249-1348 1415-1514 1524-1623 1632-1731

CO, pprnvd 1.6 1.8 8.3 0.0 0.5 2.4

NO,, PPrnVd 322 289 325 339 342 323 0 2 , %vd 9.2 9.9 8.1 7.2 7.6 8.4

THC, pprnvd 5.2 2.3 2.1 1.7 1.1 2.5

CO, lb/hr 0.18 0.20 0.82 0.00 0.04 0.25 NO, as NO2, lblhr 58.5 52.5 52.7 43.4 43.8 50.2 SO*, lblhr 93.6 88.3 90.7 74.8 75.9 84.7 THC as C, lb/hr 0.25 0.11 0.089 0.057 0.037 0.18

C02, %vd 8.6 8.1 9.2 9.5 9.5 9.0

SO,, ppmvd 3 70 349 402 420 426 393

Note: Emission Rates for runs 1 and 2 were calculated using 25000 SDCFM; Emission Rates for run 3 were calculated using 22300 SDCFM; Emission Rates for runs 4 and 5 were calculated using 17600 SDCFM.

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1. Owner/Opcrator Name: 2. Equipment Location: G o l d B o n d B u i l d i n g P r o d u c t s , D i v . of National Gypsu S t o c k t o n C a l i f o r n i a

3. Boiler Manufacturer, Model Number g: Serial Number: (Attncli Manufacturer 's Catalog) ( E x i s t i n q ) B & W T v D e F - 7 7 t311ilt 1 9 3 7 ( C a t a l o a n o t d v a i i a h l ~ )

13 oi 1 er Rating: 4. State Ser ia l Number o r OLkcr ld?n:ificaLion Numbcr:

5' Use: 9 5 , 0 0 0 l b / h r 6 . Gas Burner No. of ' Model No. 1Lin:xiim Rating Excess Maximum Rating Zxcess

Manufaclxxr: BurRers Pzr Giirner A i r Per Burner A i r C O E N 3 C P F 2 1 % " 8,000 c u f t / h r @ a % 48 .00Ocuf t /h r @ 10 %

B & W T y p g F - 2 2 , 9 5 , 0 0 0 I b / h r S t e a m :learn @ 4 5 0 . y s i g IIot Water Other Hot Liquld

7. Gas Bs rnc r Mode of Control: Allto mdtiC Automatic Automatic ~HigIi - Low a Full h l o d u l a t i o n m

8 . Oil Euimer No. of I\?odel No,. I.iinimurn Rating Excess Maximum Rating Excess : ~ a u d L/ On - of: 0

Manuiacturer: Burners Pa- Eurner A i r Per Burner A i r - C O E N 3 C P F 21%" 45 gal /hr 35% 2 7 0 gal/hr 1 5 %

9. Oil E x m e r Type: Sk2.m RLLary A i r Atorni.zin:: Cup Atomizing ff

If A i r Atomized, Give Feed P r e s s u r e L s i g

T Y P e o r P r i n t N m e N x n c C . F . H o w a r d , J r I n d Officizl Ti t le 3f Person S i , ~ n g Ti:l Date is D a h r o r m ? i c e P r e s i d e n t o f E n g i n e e r i n g

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. . I ' ~ A N JOAQUIN c o m w AIR POLLUTIO OL ~ ~ J T R I C T . ~

. ^ . . , . . . ' ,

.. . :: 1601::E. Hazelton Avenue, P. 0. Box 2009 , Stockton,. California 95201

Telephone: ( 2 0 9 ) 466-6781

Application for AUTIIORTTY TO CONSTRUCT an

. . i .

, Date: 4-29-74 Application Number: . .

. . An application is required for each operation described i n part B of instructions.

Owner, Partner, or Governmental Agency.

2. MAILING ADDRESS':

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6 . TYPE AND ESTIMATED COST OF BASIC EQUIPMENT:

Date Application Received:

.. .. . .

" ' '.: 1601 E. X 2009, S tockton ,.,..Caiifo Telephone: (209) 466-6781

. . . . . .

Application for AIJTIIORITY TO CONSTRUCT and&UUT I .: . . I

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Date: 4-29-74 Application Number: T.

.~

An application i s requlred for each operation described i n p a r t B of instructions.

Owner, Partner, or Governmental Agency.

Fibreboard .Corporation

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Operation: 241hr., 7/day, 360 daylyr.

TITLE OF SIGNE

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ERC Application Evaluation Project #: 970384

Application #'s: N-130-1, N-130-2, N-130-3, N-I304 & N-130-5

Engineer: Mark Schonhoff Date: February 3,1998

Company Name: Newark Sierra Paperboard Mailing Address: 800 W. Church Street

Stockton, CA 95203

Contact Name: Mark Vincent Phone: (209) 466-7088

Date Application Received: June 16,1997 Date Application Deemed Complete: June 30, 1997

1. Summary:

The applicant is proposing to receive emission reduction credits (ERC's) for reductions that occurred as a result of retrofitting two boilers with low-NOx burners and reducing their permitted potential to burn #6 fuel oil. The bankable emission reductions. as shown in this analysis, are:

The modifications that resulted in the reductions were Derformed under District )li , , ation numbers N-577-3-1 and N-57741. The applicant subsequently applied for, and received Authorities to Construct to discontinue the use of #6 fuel oil and to lower the CO emission limits. Those reductions will not be considered in this application.

UODI icable Rules;

Rule 2201: Rule 2301:

New and Modified Stationary Source Review (June 15, 1995) Emission Reduction Credit Banking (December 17, 1992)

111. Location Of Reduction 5:

800 W. Church Street Stockton, CA

IV. Method Of Genera tina Reduct ions;

Installation of low-NOx burners and reductions in the quantity of #6 fuel oil that may be burned. The modifications were performed under District application numbers N-577-3-1 and N-5774-1.

V. ER C Calculat ions;

A. Assumptions and Emission Factors:

Emission Factors:

The derivation of the following emission factors is shown in the application review for the Authorities to Construct that authorized these reductions. The application numbers are N-577-3-1 and N-577-4-1.

6. Baseline Period Determination and Data:

Per District Policy NSWERC 10-1 the baseline period will be the two years immediately prior to the Authority to Construct (ATC) application for the modification that resulted in the reductions. The application was received on December 5, 1991. Since ERCs are issued on a quarterly basis the baseline period will be the 8 complete calendar quarters immediately preceding the ATC application. That period is the fourth quarter of 1989 through the third quarter of 1991.

2

Baseline period fuel usages:

The fuel usages are from table 3-1 of the application for ATC’s N-577-3-1 & N-577- 4-1.

1989 1990 1991 Average

Natural Gas:

Qtr. 1 natural gas (therms) (therms) (therms) (therms)

Qtr 2 natural gas Qtr 3 natural gas Qtr 4 natural gas

_I - - 28,784 17,736 72 1,958,831 3,386,562

2,266,740 30,397 513,850 - 1,142,238 15,235 1,236,341 1,707,673

1989 1990 1991 Average

Fuel Oil:

Qtr. 1 fuel oil (therms) (therms) (therms) (therms)

3,415,713 3,354,455 1,107,234 0 1,140,048 3,180,669 2,722,350 - 2,277,881 3,267,562 1,914,792 1,615,796

Qtr 2 fuel oil Qtr 3 fuel oil

- 3,231,592

Qtr 4 fuel oil

- -

Qtr. 1: (1,142,238 therms)(O.l MMBtultherm) = 114,223.8 MMBtu Qtr. 2: (15,235 therms)(O.l MMBtultherm) = 1,523.5 MMBtu Qtr. 3: (1,236,341 therms)(O.l MMBtuItherm) = 123,634.1 MMBtu Qtr. 4: (1,707,673 therms)(O.l MMBtu/therm) = 170,767.3 MMBtu

Fuel Oil:

Qtr. 1: (2,277,881 therms)(O.l MMBtunherm) = 227,788.1 MMBtu Qtr. 2: (3,267,562 therms)(O.l MM Btunherm) = 326,756.2 MMBtu Qtr. 3: (1,914,792 therms)(O.l MMBtukherm) = 191,479.2 MMBtu Qtr. 4: (1,615,796 therms)(O.l MMBtultherm) = 161,579.6 MMBtu

3

C. Historical Actual Emissions:

Quarter 1 :

HAE (Natural Gas)

NOx: (1 14,223.8 MMBtu)(0.21 IblMMBtu) = 23,987 Ib CO: (1 14,223.8 MMBtu)(0.36 IblMMBtu) = 41,121 Ib VOC: (1 14,223.8 MMBtu)(0.0014 IblMMBtu) = 160 Ib SOX: (1 14,223.8 MMBtu)(0.0006 IblMMBtu) = 69 Ib PMIO: (1 14,223.8 MMBtu)(0.005 IblMMBtu) = 571 Ib

HAE (Fuel Oil):

NOx: (227,788.1 MMBtu)(0.62 IblMMBtu) = 141,229 Ib CO: (227,788.1 MMBtu)(0.033 IblMMBtu) = 7,517 Ib VOC: (227,788.1 MMBtu)(O.OOS IblMMBtu) = 1,139 Ib SOX: (227,788.1 MMBtu)(l .O IblMMBtu) = 227,788 Ib PMIO: (227,788.1 MMBtu)(O.l4 IblMMBtu) = 31,890 Ib

Quarter 2

HAE (Natural Gas)

NOx: (1,523.5 MMBtu)(0.21 IbMMBtu) = 320 Ib CO: (1,523.5 MMBtu)(O.36 IblMMBtu) = 548 Ib VOC: (1,523.5 MMBtu)(0.0014 IblMMBtu) = 2 Ib SOX: (1,523.5 MMBtu)(0.0006 IblMMBtu) = 1 Ib PMIO: (1,523.5 MMBtu)(O.OOS IblMMBtu) = 8 Ib

HAE (Fuel Oil):

NOx: (326,756.2 MMBtu )(0.62 IblMMBtu) = 202,589 Ib CO: (326,756.2 MMBtu)(0.033 IblMMBtu) = 10,783 Ib VOC: (326,756.2 MMBtu)(0.005 IblMMBtu) = 1,634 Ib SOX: (326,756.2 MMBtu)(l .O IbMMBtu) = 326,756 Ib PMIO: (326,756.2 MMBtu)(O.l4 IblMMBtu) = 45,746 Ib

4

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Quarter 3:

HAE (Natural Gas):

NOx: (123,634.1 MMBtu)(0.21 IblMMBtu) = 25,963 Ib CO: (123,634.1 MMBtu)(O.36 IblMMBtu) = 44,508 Ib VOC: (123,634.1 MMBtu)(0.0014 IblMMBtu) = 173 Ib SOX: (123,634.1 MMBtu)(0.0006 IblMMBtu) = 74 Ib PMIO: (123,634.1 MMBtu)(0.005 IblMMBtu) = 618 Ib

HAE (Fuel Oil):

NOx: (191,479.2 MMBtu)(O.62 IblMMBtu) = 118,717 Ib CO: (191,479.2 MMBtu)(0.033 IblMMBtu) = 6,319 Ib VOC: (191,479.2 MMBtu)(0.005 Ib/MMBtu) = 957 Ib SOX: (191,479.2 MMBtu)(l .O IbiMMBtu) = 191,479 Ib PM10: (191,479.2 MMBtu)(O.l4 IblMMBtu) = 26,807 Ib

Quarter 4

NOx: (170,767.3 MMBtu)(0.21 IblMMBtu) = 35,861 Ib CO: (170,767.3 MMBtu)(0.36 IblMMBtu) = 61,476 Ib VOC: (170,767.3 MMBtu)(0.0014 IblMMBtu) = 239 Ib SOX: (170,767.3 MMBtu)(0.0006 IblMMBtu) = 102 Ib PM10: (170,767.3 MMBtu)(0.005 IblMMBtu) = 854 Ib

HAE (Fuel Oil):

NOx: (162,579.6 MMBtu)(0.62 IblMMBtu) = 100,179 Ib CO: (161,579.6 MMBtu)(0.033 IblMMBtu) = 5,332 Ib VOC: (161,579.6 MMBtu)(O.OOS IblMMBtu) = 808 Ib SOX: (161,579.6 MMBtu)(l.O IblMMBtu) = 161,580 Ib PMIO: (161,579.6 MMBtu)(O.l4 IblMMBtu) = 22,621 Ib

D. Actual Emission Reductions (AER):

Newark Sierra has installed control devices to control emissions while firing on natural gas. They have also reduced #6 fuel oil combustion contaminant emissions by reducing it's use. AERs will be calculated utilizing the following equations:

AER (natural gas): HAE X CE (District rule 2201 section 6.5.3)

5

AER(#6 fuel oil): HAE - PE (District rule 2201 section 6.5.1)

Where:

0 HAE is the historical actual emissions calculated in section V.C of this document

CE is the control efficiency and is calculated utilizing the following equation:

0

CE = (EFI - EF2) i EF, Where:

0 EF1 is the premodification EF

0 EF2 is the postmodification EF

CE(N0x) = (0.21 - 0.0365) + (0.21) = 0.826 CE(C0) = (0.36 - 0.15) i (0.36) = 0.583 CE(V0C) = (0.0014 - 0.0014) i (0.0014) = 0.0 CE(S0x) = (0.0006 - 0.0006) i (0.0006) = 0.0 CE (PMIO) = (0.005 - 0.005) i (0.005) = 0.0

PE is the potential to emit while firing on #6 fuel oil

Newark Sierra stated in the application for the ATC’s authorizing these reductions that they wished to retain the right to bum #6 fuel oil seven days per year. It was not known which quarter the fuel oil would be burned in, therefore, the ATC’s were conditioned such that #6 fuel oil could be burned for seven days per calendar quarter. The AERs will therefore be adjusted to reflect seven days per calendar quarter of #6 fuel oil usage.

The potential fuel oil usage, for each boiler, as limited by the PTOs is 2,664 MMBtu/day. Therefore, the combined quarterly potential to emit of the boilers, while operating on #6 fuel oil is:

NOx: (7 days/qtr)[(2)(2,664 MMBtu/day)](O.62 IblMMBtu) = 23,124 lblqtr CO: (7 days/qtr)[(2)(2,664 MMBtu/day)](O.l5 IblMMBtu) = 5,594 Ib/qtr VOC: (7 days/qtr)[(2)(2,664 MMBtu/day)](0.005 IblMMBtu) = 186 Ib/qtr SOX: (7 days/qtr)[(2)(2,664 MMBtu/day)](l.O IblMMBtu) = 37,296 Ib/qtr PMIO: (7 days/qtr)[(2)(2,664 MMBtu/day)](O.lI IblMMBtu) = 4,103 Ib/qtr

6

AERs:

Quarter 1 :

NOX: CO: VOC: (160 Ib)(O.O) + (1,139 Ib - 186 Ib) = 953 Ib SOX: PM10: (571 Ib)(O.O) + (31,890 Ib - 4,103 Ib) = 27,787 Ib

(23,987 lb)(0.826) + (141,229 Ib - 23,124 Ib) = 137,918 Ib (41,121 lb)(0.583) + (7,517 Ib - 5,594 Ib) = 25.897 Ib

(69 Ib)(O.O) + (227,788 Ib - 37,296 Ib ) = 190,492 Ib

Quarter 2

NOX: CO: VOC: (2 Ib)(O.O) + (1,634 Ib - 186 Ib) = 1,448 Ib SOX: PM10: (8 Ib)(O.O) + (45,746 Ib - 4,103 Ib) = 41,643 Ib

(320 lb)(0.826) + (202,589 Ib - 23,124 Ib) = 179,729 Ib (548 lb)(0.583) + (10,783 Ib - 5,594 Ib) = 5,508 Ib

(1 Ib)(O.O) + (326,756 Ib - 37,296 Ib) = 289,460 Ib

Quarter 3:

NOX: (25,963 lb)(0.826) + (118,717 Ib - 23,124 Ib) = 117,038 Ib CO: (44,508 lb)(0.583) + (6,319 Ib - 5,594 Ib) = 26,673 Ib VOC: (173 Ib)(O.O) = 0.0 Ib + (957 Ib - 186 Ib) = 771 Ib SOX: (74 Ib)(O.O) = 0.0 Ib + (191,479 Ib - 37,296 Ib) = 154,183 Ib PM10: (618 Ib)(O.O) + (26,807 Ib - 4,103 Ib) = 22,704 Ib

Quarter 4:

NOX: CO: VOC: (239 Ib)(O.O) = 0.0 Ib + (808 Ib - 186 Ib) = 622 Ib SOX: PM10: (854 Ib)(O.O) = 0.0 Ib + (22,621 Ib - 4,103 Ib) = 18,518 Ib

(35,861 lb)(0.826) + (100,179 Ib - 23,124 Ib) = 106,676 Ib (61,476 lb)0.583) + (5,332 Ib -5,594 Ib) = 35,579 Ib

(102 Ib)(O.O) = 0.0 Ib + (161,580 Ib - 37,296 Ib) = 124,284 Ib

7

Summary of AERs:

NOx CO voc

Quarter 1 (Ib) Quarter 2 (Ib) Quarter 3 (Ib) Quarter 4 (Ib) 137,918 179,729 117,038 106,676 25,897 5,508 26,673 35,579 953 1.448 77 1 622

SOX 1190,492 1289,460 1154,183 I 124,284 PMIO 127,787 I 41,643 122,704 118,518

E. Air Quality Improvement Deduction:

Per District rule 2201, section 6.5, a 10% air quality improvement deduction must be applied to the AERs prior to banking. The air quality improvement deductions are as follows:

F. Increase InPermitted Emissions:

No IPE associated with this project.

G. Bankable Emissions Reductions:

The bankable emission reductions are equal to the AERs minus the air quality improvement deduction.

8

VI. Cornpl iance:

A. Real Reductions:

The reductions were generated by replacing the burners and reducing the quantity of fuel oil that could be burned. The burners have been replaced and source testing showed the reductions have occurred. The Permits to Operate (PTO’s) for these units restrict the fuel oil usage to seven days per calendar quarter. Should the facility burn more fuel oil than allowed by the permit then enforcement action would occur. Therefore the reductions are real.

B. Enforceable Reductions:

The Permits to Operate include enforceable emission and fuel oil usage limits, which if complied with, will ensure the reductions are continuing to occur. Should the required source testing show the limits are being exceeded, or if the fuel oil usage exceeds the permitted quantities enforcement action would be taken. Therefore the reductions are enforceable.

C. Quantifiable Reductions:

The reductions were calculated utilizing actual baseline period fuel usage and emissions factors which were derived from source testing or EPA document AP-42. Therefore,. the reductions are quantifiable.

D. Permanent Reductions:

The PTO’s include emission concentration and fuel usage limits. Should increases in emission concentration or fuel oil usage be required then the facility would be required to apply to the District for an ATC. The application would be subject to New Source Review, which would ensure that the reductions continue to occur. Therefore, the reductions are permanent.

E. Surplus Reductions:

The applications for the ATC’s authorizing these reductions were received and deemed complete on December IO, 1991, and the District’s Air Quality Attainment Plan was adopted on January 30, 1992. The boiler control measure (District rule 4305) was not placed on the District list of control measures until August 27, 1992. Therefore, per District rule 2201, section 6.2.1, no discounting of the HAEs is required. Therefore, the reductions are surplus.

9

F. Timeliness:

For each boiler, the reductions occurred on March 27, 1997, which is the date that the ATC's were converted to PTO's. The ERC application was received on June 16,1997 which is less than 180 days after the reductions occurred. Therefore the application was timely.

VII. Recommendation:

Issue Emission Reduction Credit Certificates to Newark Sierra for NOx, CO, VOC, SOX and PMIO reductions in the following amounts:

It is further recommended that at the time that the ERC's are issued that each emission concentration limit and the fuel oil usage limits be modified such that they state that they are for the purpose of enforcing ERCs.

10

- 1 .

. ' - , '. ~ $EB-03-98 TUE 15: 06 2723 .. I . FAX NO. 209 545 8652 P. 01/01

- .I NORrIfERN aECl0N

- c ~ m L R e c t o N ERCD'UBLIC NOTICE CHECK LIST - SOUTARRN REGION PROJECT# 9211l114 MODEMED FILE NAME: N W 0 3 8 4 . P B C

. I d R€Wr C O M n -- x- ERC rmEwMINARY PUBUC NOTICE -- ERC FINAL PUBLIC NOTICE -- NSWCEQA PRELIMINARY PUBLIC NOTICE -- NSWCEQA FINAL. PUBLIC NOTICE

ENCLOSED DOCUMENTS REQUIRE:

ERC TRANSFER OF PREVIOUSLY BANKED CREDITS

-Enter Correct Date, Print All Documents from MODEMED File and Obtaln Directors Signature

Y -Send Preliminary Notice Letters to CARB, EPA and Applicant; Including rbe Following Attachments

Other: X ~ l i ~

-Send Preliminary Public Notice for Puhlication fo

-Send Signed Copies of J?relimhwy Notict Letters to Regional Office Ann: -Mcndcs

- Direnor's Signature and District Seal Embossed on ERC Certificates

-- Ducctor's Signature on Cover Leaer and Mail Cover Letter & ERC Certified Mail to:

Ceniflcatrs by

- Applicant: ..

. - A p p l i h and Additional Addressee8 (see cover lemrs)

- - Send CopiGs of Signa and Seal Embossed ERC Ceriificates and Signed cover lctttr to Regional Office Am:-

- - Other Special lnstruciions (please specify)

Date Completed L y

3 Upon Complction FAX to R%giot\ll Office Arm: MadrsEhnnhpff - _, .. ,- ,.. .. -- .-. - ''

.~ . . - . - . - . .

. :... : ' , . . ,.

. . . . . ~' ' . : ' ;

. . . , , , . . . . . ' 1 ;.. . . . .. . . . , . , . . : . .. . ..: .. . ....

THE

GROUP Newark Sierra Paperboard Corp. N M M K

A Newark Group, Inc Company Producls from Recycled Fibers

800 Wesl Church Street Stockton. CA 95203 2091466-5251 Fax 2091942-1214

June 9,1997

Mr. Mark Schonhoff San Joaquin Valley Unified Air Pollution Control District 4230 Kieman Avenue, Suite # 130 Modesto, CaXomia 95556

SAfii JOAQiJli\l VALLEY UNIFIED A.P.C.D.

NO. REGION

Subject: Newark Sierra Paperboard Corporation Application for Emission Reduction Credit Banking For Credits Available from the Implementation of Authority to Construct Permits N-577-3-1 and N-577-4-1

Dear Mr. SchonhofE

Enclosed is an application package for Emission Reduction Credit Banking for credits available from the implementation of Authority to Construct Permits N-577-3-1 and N-5?7-4-1 for boilers # 1 and 2, respectively. Included are the following items:

1. SJVUAPCD Application Form For Emission Reduction Credits

2. Calculations of Actual Emission Reductions Modified From the Engineering Evaluation

3. Required $650 filing fee.

Other infoim2tion that may be necessary to process this Emission Reduction Credit applicztion has been previously submitted in the Application for Authority to Construct dated December 1991. This includes the actual historical fuel usage in Table 3-1. Source test information has also been previously submitted to the SJVUAPCD.

AER calculations completed in the Application Review for the fourth quarter of 1989 through the third quarter of 1991 are appropriate, with the following modifications:

I . New CO emission factor is 0.075 pounds per MMBtu instead of . . 0.15 pounds per MMBtu , . . . .

r . . . . . . . . . . as initially proposed

.. - L .

Mr. Mark Schonhoff June 9,1997 Page 2

-..

2. Blend No. 6 fuel oil used in the third quarter of 1991 (included in Table 3-1 of the Application for Authority to Construct) has been added to the quantity of Kern No. 6 fuel oil used in the Engineering Evaluation.

3. Natural gas only will be used. Fuel oil will not be used as secondary fuel.

If you have any questions regarding this application, please contact our consultant, Ms. Wilma Dreessen ofBrown and Caldwell, at (510) 210-2289 or myself at (209) 466-7088.

Very truly yours,

Mark Vincent General Manager

MV:wjd

Enclosures

cc: Todd Lopez, Brown and Caldwell Wilma Dreessen, Brown and Caldwell David Wong, Newark Sierra Paperboard Corporation Mike Rogge, Newark Sierra Paperboard Corporation John Lennert, Newark Sierra Paperboard Corporation

.

c:\projects\nrpc\retrofit\erc.doc


APPLICATION FOR:

SI- 800 West Church Street

Stoc kton C m

[ 1 ERC RE-IsSue AFTER PAR'nAL Use I YEMISSION REWCITON CREDIT &nQ I 1 CONSOLIDATlON OF ERC CFUl7FICAlTS IERC'IXANSFEROFOWMeRSBIP

4

4. DATE OF REWCFION 1 / 2 7 / 9 7 (Balrer # i

31.7197 (Boiler # 1 )

1. ERC TO BE ISSUED To:

1

3rd QTR

jTzGFj

Newark Sierra Paperboaed Corporation

voc NOX co PMlO SOI OTBER

1,139 161,042 40,085 31,890 227,788

1,634 202,854 11,217 45,746 326,756

957 140,229 41,569 26,807 191,479

129,800 - 54,020 22,621 161,580 808 .-

0 0 s s s s

2. MAILING ADDRESS

SrrpIT.0. Bmr 800 West Church Street

CUP Stockton s(rc CA np- 95203

3. WCATION OF REDUCAOR

9. TYPE OR PlUXT NAME OF APPLICANT:

Mark Vincent

DA'IE: 'IELZPEONE N O

5 / 3 0 / 9 7 (2091 466-7088

Northern Regional Office * 4230 Kiernan Ave.. Suite 130 * Modesto, California 95356 * (209) 545-7000 * FAX (209) 545-8652 @< ....,I,. ,..., n.., -:, ,,,, n ,,,,...

.. ~. .

'' . &.

-

Natural Gas HAE WQW

NOx: 23,987 SOX: 69 CO: 41,121 NMHC: 160 PM10: 571

c ~ \ c ~ \ * v ; ~ & * , . Fro,

3. Actual Emission Reductions (AER): Appli ,-.tion R e d ; c u

AER = (HAE X CE) where: HAE = (EF)(Fuel Usage)

Table Of Quarterly Average HAE's - Fuel Oil Usage

ThermslQtr


2,277,880 (227,788.0 X lo6)

(BTU/QW

Q@

1

2

3

- 4

Natural Gas Usage ThermslQtr (BTUlQtr)


1,142,238 (114,223.8 X lo6)

- 15,234

(1,523.4 X IO6)

1,236,341 (123,634.1 X lo6)

1,707,673 (170,767.3 X lo6)

NOx: 320 s o x : 1 CO: 548 NMHC: 2 PM10: 8

NOx: 25,963 s o x : 74 CO: 44,508 NMHC: 173 PM10: 618

NOx: 35,861 s o x : 102 CO: 61,476 NMHC: 239 PMlO: 854

NOx: 141,229 SOX: 227,788 CO: 7,517 NMHC: 1,139 PM10: 31,890

3,267,562 (326,756.2 X lo6)

6 I . @y-z3? 19 r,.Ii.s.;L

0 IC

(see T a b L 7-1 ,f o>,iiwV-,

1,615,796 161,579.6 X lo6)

NOx: 202,589 SOX: 326,756 CO: 10,783 NMHC: 1,634 PMlO: 45,746

NOx: 113,695 SOX: 183,379 CO: 6,052 NMHC: 917 PMlO: 25,673

NOx: 100,179 SOX: 161,580 CO: 5,332 NMHC: 808 PMIO: 22.621

Baseline period is the forth quarter of 1989 through the third quarter of 1991.

13

, .". Newark Sierra will be installing a control device to control emissions while firing on natural gas. They will be reducing #6 fuel oil combustion contaminant emissions by reducing it's use. Therefore AER will be calculated utilizing the following equations:

. AER (Natural Gas): HAE * CE (Rule 2201 Section 6.5.2)


Sierra has stated that they wish to retain the right to bum #6 fuel oil seven days per year for emergency purposes (application package, Section 4). It is not known which quarter the fuel oil will be burned in therefore all four quarters will be corrected to reflect seven days of fuel oil usage.


BTU Rating: Each boiler will be limited to 2664 MMBTU/day of #6 fuel oil usage therefore the combined allowable #6 fuel oil usage, for both boilers combined, will be 5328 MMBTUlday . be

oil) = (7 days/qtr)(5328 MMBTU/day)(0.62 IbIMMBTU) = 23,123.5 Ib/qtr P&,,(fuel oil) = (7 days/qtr)(5328 MMBTU/day)(l.O IblMMBTU) = 37,296.0 Ib/qtr PE,,(fuel oil) = (7 days/qtr)(5328 MMBTU/day)(O.lS IblMMBTU) = 5,594.4 lblqtr PEm,,(fuel oil) = (7 days/qtr)(5328 MMBTU/day)(O.OOS IWMMBTU) = 186.5 Ib/qtr PE,,,,(fuel oil) = (7 days/qtr)(5328 MMBTU/day)(O.ll Ib/MMBTU) = 4102.6 Ib/qtr

AER = (HAE * CE),, Gu + (HAE - PE)", Fuel 00

Quarter 1: AER (NOx) = (23,987 lb)(0.826) + (141,229 Ib) 13,"3.5 l&) - AER (SOX) = (69 Ib)(O) + 227,788 1b)- -

3 1 , 1 3 9 l b AER (CO) = (41,121 Ib) &*+ (7,517 lb)- AER (NMHC) = (160 Ib)(O) + (1,139 Ib\-

*,,, = 31,890 l b AER (PMIO) = (571 Ib)(O) + (31,890 I b ) + € € Q & b ) -

Quarter 2: AER (NOx) = (320 1b)(0.826) + (202,589 Ib 2?,12?.5 I&& - :?!?,H8tB- = d O J , B S Y l h AER (SOX) = (1 Ib)(O) + (326,756 Ib\-3-= . = 3 2 L , 7 ~ ~ Ib

, -= I G I , o q a Ib = 21-+,-too Ib 3 r t o , b ~ ~ lb -

- 7-

- - 1 1 , Z I ~ I b AER (CO) = (548 l b ) w + (10,783 lb)+- - - = i , L 3 + I b

I

AER (NMHC) = (2 Ib)(O) + (1,634 lb)-I8&54b)--4+8-b AER (PM10) = (8 Ib)(O) + (45,746 1b)- - = t+sIi-q/, Ib

b Quarter 3: ( i i s , t l t lb) AER (NOx) = (25,963 l b ) ( 0 . 8 ~ l ; ) . , $ q ~ I , , . - L t ~ t s i ~ t o , i ~ a , Ib

AER (PMlO) = (618 Ib)(O) + & & s G 2:,578tb- = ac,sa+ I b

Quarter 4: AER (NOx) = (35,861 1b)(0.826) + (100,179 Ibl4-- = !2q,860 Ib AER (SOX) = (102 Ib)(O) + (161,580 lb)-37+2%:l3-lk+- , - i L I , S S O I b AER (CO) = (61,476 Ib)@-&~+ (5,332 l b ) - 5 ; - 5 9 4 ; 1 + ~ - SLt,oao Ib

AER (SOX) = (74 Ib)(O) + &3%9&- - AER (CO) = (44,508 l b ) @ # $ ' + ~ & & i ~ 4 5 + & - & - - AER (NMHC) = (173 Ib)(O) + 4%7&-48 .

- ~ I , S L ~ l b - 73-m - 9 r t l b

= 8 0 8 \b AER (NMHC) = (239 Ib)(O) + (808 Ib)- - AER (PM10) = (854 Ib)(O) + (22,621]-- - = a.a,Lzi Ib

Summery Of AER's:

0.36

15


June 30, 1997

Newark Sierra Paperboard Attn: Mark Vincent 800 W. Church Street Stockton, CA 95203

Re: Notice of Receipt of Complete Application - Emission Reduction Credits Project Number: 970384

Dear Mr. Vincent:

The District has completed a preliminary review of your application for Emission Reduction Credits (ERCs) resulting from the boiler modifications at 800 W. Church Street in Stockton, CA.

Based on this preliminary review, the application appears to be complete. However, during processing of your application, the District may request additional information to clarify, correct, or otherwise supplement, the information on file.

Please be advised that ERCs cannot be issued for the reductions that occurred as a result of the discontinued use of fuel oil, or for the reductions in CO emissions down to 0.075 IblMMBtu. This is because those emission reductions resulted from the modifications authorized by Authorities to Construct (ATCs) N-577-3-1 and N-5774-1 which allowed the use of fuel oil and CO emissions of 0.15 IblMMBtu. You may however submit a separate application for the actual emission reductions that will occur as a result of the January 15, 1997 application to discontinue the use of fuel oil and to reduce the CO emissions to 0.075 IblMMbtu. In that case the baseline period will be the two year period immediately preceding that ATC application.

Pursuant to District Rule 3010, section 3.0, your application may be subject to an hourly Engineering Evaluation Fee. If the applicable fees exceed the submitted application filing fee, the District will notify you at the conclusion of our review.

David L. Crow Executive DirenorfAir Pollurion Conrrol O&er

1991 Tuo l~ inn~ Slice!. Su8le 200 . Freina C A 9372\ . 12091 417 r K Q * FAX (209) 233 M57

- Central Region Southern Region Northern Region

4230 Ksernan duenue. Suite 130 * Mmeno. CA 95356 12091 545-10W f Far 1209) 545.8652

1999 Tuolumne SYX!. Suiic 200 . rresno. CA 93721 27W M Slreel, Suite 275 * BakerrI8eld. CA 93301 1209) 497.1000 f Far 12091 2332057 18051 862 -5m. ~a~ ,8051 862-5201 .. c, w"%"a on"~F"C,"o P O W ,

Newark Sierra June 30.1997 Page 2

Thank you for your cooperation. Should you have any questions, please contact Mr. Anthony Mendes at (209) 545-7000.

Sincerely,

Seyed Sadredin Director of Permit Services

s Manager

MJS

cc: Brown and Caldwell Attn: Wilma Dreesen 3480 Buskirk Avenue Pleasant Hill 94523

NOV-19-98 THU 14 : 47 P. 01/01

PROOF of PUBLICATION .............................. NOTICE ................ ?.................o-....*..**.......... ?, ................... Y...Y...............?.......*?*....

....................... ~o.o..o**.ooo***oooo*o.oo*oo.o.n.

STATE OF CALIFORNIA } ss. COUNTY OF S A N JOAQUN

THE UNDERSIGNED SAYS: t am a citizen of the United States and a resident of San Joaquin County; I am over the age of eighteen years, and not a

to or interested in the above- enti parr ed matter, I am the principal clerk of the printer of ME RECORD, a newspaper of general circulotion, printed and published daily in the City of Stockton, County of San Joaquin and which newspaper has been adjudged a newspaper of general circulation by the Superior h u r t of the County of San Joaquin, State of Cdihrnia, under the date of February 25, 1952, File Number 52857, San Jwquin County Records; that the notice, of which the annexed is a printed copy (set in type nor smaller than nonpareil), has been published in each regular and entire issue of said newspaper and not in any supplement thereof on the followin dates, t o w i t ......~~.e.f. .~ik.~0~.400e~.0~..~.......*.. f ......................................................... .....................~.................,.*.*............ ........................* ~0...0*00~.00004*0...0..0......

a11 in he year 19 98 ................................. ....... ....... at Stockton, California

Stella Hetnsndea Signamre

.

N O V - 0 6 - 9 8 F R I 12:53 PPI / l.1457 November 10 NOTICE O f FINAL AC- TION FOR THB l88U- A W E OF EMISSION RE- DUCTION CREDIT5

. __ .

P . O 1

. .

February 10,

GOPY San Joaquin Valley Unified Air Pollution Control District

1998

Newark Sierra Paperboard Corporation A!ln: Mark Vincent 800 W. Church Street Stockton, CA 95203

Re: Notice of Preliminary Decision - Emission Reduction Credits Project Number: 970384

SAN JOA a UIN VALLEY UNlFlE A.P.C.D. NO. REGION

Dear Mr. Vincent:

Enclosed for your review and comment is the District’s analysis of Newark Sierra Paperboard Corporation’s application for Emission Reduction Credits (ERC’s) resulting from the retrofit of two boilers with low NOx burners and the reduced use of #6 fuel oil at 800 W. Church Street in Stockton, CA. The quantity of ERC’s proposed for banking is 487,224 Ib/yr of NOx, 84,291 Ib/yr of CO, 3,415 lblyr of VOC, 682,578 lblyr of SOX and 99,587 lblyr of PM10.

Also enclosed is the public notice of this decision which will be published approximately three days from the date of this letter. Please submit your written comments on this project within the 3Oday public comment period which begins on the date of publication of the public notice.

If you have any questions regarding this matter, please contact Mark Schonhoff of Permit Services at (209) 545-7000.


SS:MJS/ba Enclosures

c: , Anthony Mendes, Permit Services Manager


February 10, 1998

Raymond Menebroker, Chief Project Assessment Branch Stationary Source Division California Air Resources Board P. 0. Box 2815 Sacramento. CA 95812-2815


Dear Mr. Menebroker:

Enclosed for your review and comment is the District?s analysis of Newark Sierra Paperboard Corporation?s application for Emission Reduction Credits (ERC?s) resulting from the retrofit of two boilers with low NOx burners and the reduced use of #6 fuel oil at 800 W. Church Street in Stockton, CA. The quantity of ERC?s proposed for banking is 487,224 lblyr of NOx, 84,291 lblyr of CO, 3,415 Ib/yr of VOC, 682,578 Ib/yr of SOX and 99,587 Ib/yr of PM10.

Also enclosed is the public notice of this decision which will be published approximately three days from the date of this letter. Please submit your written comments on this project within the 30-day public comment period which begins on the date of publication of the public notice.



SS:MJS/ba Enclosures c: Anthony Mendes, Permit Services Manager

David L. Crow Erecutive DirectorlAir Pollution Control Oficer

193s T Y O I Y ~ ~ O street. sum MO. F I B ~ O . CA 93721 .IZOOI 4 8 7 . 1 0 ~ . F ~ X 12091 233-2057

Northern Region Central Reiion Southern Repjon

San Joaquin Vdey Unified Air Pollution Control District

February 10, 1998

Matt Haber, Chief Permits Office Air Division U.S. E.P.A. - Region IX 75 Hawthorne Street San Francisco, CA 94105


Dear Mr. Haber:

Enclosed for your review and comment is the District's analysis of Newark Sierra Paperboard Corporation's application for Emission Reduction Credits (ERC's) resulting from the retrofit of two boilers with low NOx burners and the reduced use of #6 fuel oil at 800 W. Church Street in Stockton, CA. The quantity of ERC's proposed for banking is 487,224 Ib/yr of NOx, 84,291 Ib/yr of CO, 3,415 Ib/yr of VOC, 682,578 lblyr of SOX and 99,587 Ib/yr of PM10.




SS:/MJS/ba Enclosures

c: Anthony Mendes, Permit Services Executive DirectorlAir Pollution Control Officer

1999 Tuolumne Slrwt. Sme 2W. Fresno. CA 93721 . (209) 197.10W. Fax 1209) 233-2057

Southern Region Noahern Region Centnl Region 27W M Slreet, Sua0 275. Bakadold. CA 93301

(605) 862-5202. Fax IBOSI 862.5201 4224 War- AM"=. Suns 130. MMmo. CA 95356

1209) 545.7~0. F= (2091 ~ 5 . 8 6 5 2 1999 Tvolumna Straw. Suile 2W . Fresno. CA 93721

(2091 497.1WO. Fax 12091 253-2057

_ .

San Joaquin Valley Fax Transmittal Unified Air Pollution Control District Pages: 2

Date: FEBRUARY 10,1997

To: Margaret (Legal Advertisement)

The Record of SJ County (943-8560)

From: Brenda Alipaz

Re: NOTICE' OF PRELIMINARY DECISION FOR THE PROPOSED ISSUANCE OF EMISISON REDUCTION CREDITS PROJECT #970384

Please complete the followng instructions:

PUBLISH FOR ONE DAY ONLY BY: FEBRUARY 13,1998

FAX PROOF OF NOTICE TO: MARK SCHONHOFF PERMIT SERVICES (209) 545-8652

BILLING ADDRESS: San Joaquin Valley Unified APCD 1999 Tuolumne Street-Suite 200 Fresno, CA 93721 Attn: Administrative Services Phone: (209) 497-1000

Thank you for your cooperation.

The Record

NOTICE OF PRELIMINARY DECISION FOR THE PROPOSED ISSUANCE OF

EMISSION REDUCTION CREDITS

NOTICE IS HEREBY GIVEN that the San Joaquin Valley Unified Air Pollution Control District solicits public comment on the proposed issuance of Emission Reduction Credits (ERC’s) to Newark Sierra Paperboard Corporation for the retrofit of two boilers with low- NOx burners and the reduced use of #6 fuel oil, at 800 W. Church Street in Stockton, CA. The quantity of ERC’s proposed for banking is 487,224 Ib/yr of NOx, 84,291 Ib/yr of CO, 3,415 lb/yr of VOC, 682,578 Ib/yr of SOX and 99,587 lblyr of PM10.

The analysis of the regulatory basis for this proposed action, Project #970384, is available for public inspection at the District office at the address below. Written comments on this project must be submitted within 30 days of the publication date of this notice to SEYED SADREDIN, DIRECTOR OF PERMIT SERVICES, SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT, 4230 KIERNAN AVENUE, SUITE 130, MODESTO, CA 95356.

.

TO 5458652 . . !

!

800 west Chu~chsrre~l Stodrton. CA 95203 209:4&251 Far 2091942-1214

FAX (209) 545-8652

January 10, 1996

Mark Schonhoff

Air Sari pol 30ar ution control District

Dear Mark,

Re: Authority to Construct and Air Emission Credits

I would appreciate it if you would confirm back to me in writing that my understanding of our conversation today (listed below) is correct.

Because Newark Sierra filed an ATC before the time that i tighter low NOX standards were approved, we will be able bank the air emission credits if we use the technology tl we pro osed at that time. If we should decide to utilizi entirefy different method such as selective catalytic reduction rather than a low NOx burner installation, we 5 only be able to bank those air emission credits for the reduction below 30 ppm.

If you could FAX me your response, i t would be appreciatc

in Valley Unified

Sincerely,

\ MichaeliJ. Rogge

P.O1

HE IM(Aw( ROUP

d

TOT& p.01

.. . - 0 a San Joaquin Valley i

Unified Air Pollution Control District

January 16, 1995

Newark Sierra Paperboard Corp. Attn: Mike Rogge 800 W. Church Street Stockton, CA 95203

RE: Emission Reduction Credit Eligibility

Dear Mr. Rogge:

The District has received your letter dated Januaty 10, 1996 and offers the following response:

Ninety percent of the actual NOx and CO reductions authorized by Authority to Construct Permits (ATCs) N-577-3-1 and N-577-4-1 are eligible for banking. These reductions are eligible for banking because the applications for the ATCs authorizing the method of reductions were deemed complete prior to the date of adoption of the California Clean Air Act Plan.

Should another method of achieving the NOx and CO reductions be chosen then ATCs authorizing that method of reduction would be required. These new applications would not be deemed complete prior to the date that the regulatory measure (District rule 4305) was placed on the District's list of scheduled control measures (8/27/92) and onk ninety percent of the NOx and CO reductions in excess of those required by District rule 4305 would be eligible for banking.

Ninety percent of any VOC, SOX or PMIO reductions that actually occur as a result of an alternate method of NOx and CO control are eligible for banking at this time.

,

Newark Sierra Paperboard Corp. January 16.1996 Page 2

Should you have any questions please contact Mark Schonhoff at (209) 545-7000.

Sincerely,

Seyed Sadredin Director Of Permit Services

Permit (&&ices Manager - Northern Region

SSIAMIMJS

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MAY-26-98 12:16 FR0M:BROWN 8. CALDWELL ID:5109379026 PAGE 1

, Unless oihwise indicated or obvious fmm the nature ofthc bansmind, UIc information contained in this facsimile message is confideatid infurmarim i n t d d for thc use of thc individual or cntiry named below. If the reader of rhis mossage is not thc inttnded ncipimL or the employee or agsnt responsible to dclivcr it to thc inrrnded rccipims you are hmby norifid that my dissominstion, distribution or wpying of this communication i s strictly prohibited. If you havc reccived this wmmunication in enor, plme notify us 8( the telcphone numbcr listed. Thank you.

B R O W N A N D C A L D W E L L

May 26,1998

L FAX TRANSMIll'AL COVER SHEET 1 PLEASE DELIVER THE FOLLOWING PAGES TO:

Name: Mark Schonhoff Compsny: San Joaquin Unified Air Pollution Conwol Dishict

Citylstate: Modesto, CA FAX NO: (209) 545-8652

TEnS TRANSMITTAL IS BHNG SENT FROM.

Name: Wilma Dreessen Returuoriginals: Y e s N N o 0 Employee No: 8110 stamp: Y a M N o 0 Project No: 6090 Staple: YesB N o 0 'I'SSkGk: 16.5

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SPECIAL lNSTRUCTIONS/REMARKS:

Attached is the request for the engineering evaluation that went to EPA and a request, in advance, for your reponse to the letter from Ed Pike at the EPA. Thank you.

NUMBER OF PAGES BEING TRANSMITTED INCLUDING COVER SHEER 2 Environmental Engimnng And Consulhilg

FEB-19-98 THU 10:36 P. 01/01

PROOF of PUBLICATION ............ n....................r..................o.o 1

Notice

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........ u...........,"oo....oooo....~..........~.o.,"o ............. *.......**.......**,o....................- STATE OF UwoRNIA } 5s. M COUNTY OF SAN JOAQUIN

THE UNDERSIGNED SAYS: I am a citizen of the United States and o resident of Son Joaquin County; I am over the age of eighteen years, and not a par r to or interested in the above- enti ed matter. I am the principal clerk of the printer of THE RECORD, a newspaper of geneml circulation, printed and published daily in the City of Stockton, County of San Jwquin and which newspaper has been d\udged a newspaper of general circulahon by he ~uperiw Court of the County of S<ln Jwquin, Sfate of California, under the date of February 25, 1952, File Number 52857, San Joaquin Counfy Recards; that the notice, of which the annexed is a printed copy (set in type not smaller than nonpareil), has been published in each regular and entire issue of raid newspaper and not in any supplement thereof an the following dates, to-wit: ...... % . ~ . 2 0 . 1 , ! ..................... W..., ........ 00000....................~..................... ......................................................... ......................................................... all in the year 19..2!.. .......................... I declare under penal the for oing is true an correct.

at Stockton, California

3 Of p'iury that 13 1998 Execu t3 on . . . . .~~~~~.~o* . .~ . . . . .o .......

.. .....~............*-.....................~..~.,.......

SAN JOA UIN VALLEY

NO. REGION UNlFlE 8 A.P.C.D.

. . . . . . . . .,, _... . i /?..;. : .,:. ............... .. . . . . . :A::&. - .... j: . . . . . . . . . . . . . . . , , . . ._

% Ste l la Bernand

EMISSION'REDUCTJON CREDIT (ERC) PRELIMINARY REVIEW WORKSHEET

1. Type of ERC source: (a) Permitted point source @) Un-permitied point source [ I (c) Area source [ ]

3. Method resulting in emission reduction:

I. Shutdown [ 1; If permitted source specify permit number($ of shutdown units:

(a) Date of surrender of the operating permit(s): emissions from the source for which ERC are requested:

; if section a. docs not apply state &I) Date last

r

11. Retr0fit.M; If-permitted source specify permit number(s) of modified units: &chr & Cy?{

l,fi&r N-sj7-?-/ P D I c/

-5- 77- 4-1

(a) ATC application(s) completeness date: 4 / 0 / 4 / ; if the ATC is renewed specify date of completeness of renewal application: AI!A

111. Process change [ 1; If permitted source specify permit number(s) of modified units:

_1

, (a) ATC application(s).completeness date: '

renewal application:

IV: Other [ 1; specify:

; if the ATC is renewed specify date of completeness of

la. Baseline period:

I. Shutdown: The baseline emissions shall be selected from a period as prescribed in Rule 2201 immediately pieceding the banking application: quaker of 19 through __ quarter of 19

n. RetrofitlProcas change: The baseline emissions shall be selected from a period as prescribed in Rule immediately preceding completeness date of the ATC application: A B quarter of 19 d? through 3 quarter of 19 4 0 111. Retrofitlhocess change(renewa1): The baseline emissions shall be selected from il period as prescribed in Rule 2201 immediately preceding the completeness date of the ATC renewal application: through quarter of 19

I

quarter of 19

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4b. The baseline period selected in seclion 4a. is (check one):

1. [ ] Two consecutive years of operation immediately prior to the submission of the complete application.

-. . . I ,.+ 2. [ ] Another time period of a t least two.consecutive,ye& within five yehis immediately prior to the submission of the complete application.

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4c. Baseline period proposed by the applicant if other than specified in section 4a: ll

5. Timeliness:

1. Shutdown: (a) Date of shutdown (from sechon 3J:-: (b) Date of application: [ ] Not within 180 days N-577-3-1 3/>7/47

11. RetrofitlProcess change: (a) Date of initial start-up (from Change Order): b! /I./ 97 @ Within 180 days [ 1 Not within 180 days

111. Other: Specify

[ 1 Within 180 days

(b) Date of application: -

6. If ERCs requested are from performance based limits, does the PTO has enforceable conditions (see District policy NSR~ERC 21-a? r 1 yes l y ~ NO %q w'll I ,&rIrq v he sec W r '

7. Is appropriate filing fee paid: [ f i Y e s [ I No . 8.

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PROJECT ROUTING FORM

PRELIMINARY REVIEW ENGR DATE

PROJECT NUMBER: 970384 FACILITY ID: 577 PERMIT NOS:--___

APPLICANT NAME:%

PREMISE ADDRESS:?

S W R DATE

ENGINEERING EVALUATION

E. Engmeenng Evaluation Complete

I( F. Supervising Engineer Approval ' .I I II

INIT DATE

11 G: Compliance Division Approval [ ] Not Required

11 H. Permit Services Manager Approval

Director Renew: [ ] Not Required [ ] Required

CLERICAL STAFF: Perform tasks as indicated below. Initial and date when completed.

[ I P R E L W A R Y R E W [ I Mail Incompleteness Letter to the Applicant Mail Completeness Letter to the Applicant. ( 1 Mail Intent to Deny Lener to the Applicant (Certified Mail). Mail Denial Letter to the Applicanf (Certifies Mail).

1 1 [ I

1 E!B!XECTS NOT NO'l'IFICATLQci

[ ] PRELIMINARY DISPOSITION

[ FINAL DISPOSITION: [ I Mail ATC(s) to Distribution.

[ 1 Mail Imminent Denial Letter to the Appliwit (Certified Mail).

[ I Mail Denial Letter to the Applicant (Certif&J Mail).

1-

[ 1 PRELIMINARY DECISION I1 [ I

[ I FINAL DECISION: [ I [ I [ I

Deliver Ad to the Newspaper NOT LATER THAN Mail copies of Cover Letter &d Engineering Evaluation to Distribution.

Deliver Ad to the Newspaper NOT LATER THAN Mail copies of Cover Letter and ATC(s) to Distribution. Mail copies of Cover Leaer to Distribution.

LmINEmm

I APPLICANT [ I EPA - 75 Hawthorne St.. San Francisco. CA 94105 Am: A-3-4 I ENGINEER [ I 'ARB - Stationary Source Div. Chief, PO Box 2815, Sacramento, CA 95812 1 COMPLIANCE [ I SJVUAPCD - 1999 Tuolumne St.. Fresno, CA 93721 Atm: Seyed Sadredin I PREMISE FILE

1 BLDG DEIT [ I OTHER

. . 1 FIRE DEFT [ I SCHOOL

*. ,

TELEPHONE RECORD FORM

Project ## 4703734 Datemime/

Initials Names of All Persons Involved and Conversation Record

San Joaquin val ley U I I I I I ~ U MI- LU

=errnit Services Division Aflolications for Authority to Construct or Emission Reduction Credits

Breakdown of Processinq Time

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Company Name: A/.e3Q ,IC -5pefr-s

Facility Id: a Project Number: q%%%L?

Project Description: 6 r fb1b.f R-etrof; +z

[I TOTAL BILLING HOURS ][-I . _

Activity Code List

11- Pra-Application Meeting (phonal 12- Prs-Application Mooting (in person) )3- Applicstion Log-in )4 Preliminary Review )5- DslSciansy Lottar 16- Varbalnclaphona rewest lor

infomation 17- Billing )a- Cornplstonoss L ~ R U )S- Post Application Mootinas IO- BACT Determination 11- Emissions Calculations 12- Compliance Determination 13- Project Description. flow Digram,

14 Risk Arrocrmant 15- CEQA Rousw 16- Draft Conditions 17- Prepare ATC 18- Prsparo ERC IS- Prepare Preliminary Notice 20- Prepare final Notice 99- Roworking of Engineering

Equipment Listing

Evaluation

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L B C e L L 0 4 0

T/T 'd

ERC Application Evaluation Project #: 970384

Application #'s: N-130-1, N-130-2, N-130-3, N-1304 & N-130-5

Engineer: Mark Schonhoff Date: January 15,1998

Company Name: Newark Sierra Paperboard Mailing Address: 800 W. Church Street

Stockton. CA 95203

Contact Name: Mark Vincent Phone: (209) 466-7088

Date Application Received: June 16,1997 Date Application Deemed Complete: June 30, 1997

1. Summarv;

The applicant is proposing to receive emission reduction credits (ERC's) for reductions that occurred as a result of retrofitting two boilers with low-NOx burners and reducing their permitted potential to burn #6 fuel oil. The bankable emission reductions, as shown in this analysis, are:

Total 1487,224 184,291 1 3,415 1682,578 ] 99,587 I The modifications that resulted in the reductions were performed under District application numbers N-577-3-1 and N-577-4-1. The applicant subsequently applied for, and received Authorities to Construct to discontinue the use of #6 fuel oil and to lower the CO emission limits. Those reductions will not be considered in this'application.

lL Aaal icable Ru les;

Rule 2201: Rule 2301:

New and Modified Stationary Source Review (June 15, 1995) Emission Reduction Credit Banking (December 17, 1992)

111. Locat ion Of R educt iom

800 W. Church Street Stockton. CA

JV. Me thod Of Generatina Re ductions:

Installation of low-NOx burners and reductions in the quantity of #6 fuel oil that may be burned. The modifications were performed under District application numbers N-577-3-1 and N-577-4-1,

V. ERC Calculations;

A. Assumptions and Emission Factors:

Emission Factors:

The derivation of the following emission factors is shown in the application review for the Authorities to Construct that authorized these reductions. The application numbers are N-577-3-1 and N-577-4-1.

B. Baseline Period Determination and Data:

Per District Policy NSfUERC 10-1 the baseline period will be the two years immediately prior to the Authority to Construct (ATC) application for the modification that resulted in the reductions. The application was received on December 5, 1991. Since ERCs are issued on a quarterly basis the baseline period will be the 8 complete calendar quarters immediately preceding the ATC application. That period is the fourth quarter of 1989 through the third quarter of 1991.

2

.- . . -

Qtr. 1 natural gas (therms) (therms) (therms)

1989 _---- ---I-

1990 17,736 72 1,958,831

Qtr 2 natural gas Qtr 3 natural gas

Baseline period fuel usages:

The fuel usages are from table 3-1 of the application for ATC’s N-577-3-1 8, N-577- 4-1.

Qtr 4 natural gas (therms)

28,784 3,386,562

1991 2,266,740 Average 1,142,238

Fuel Oil:

^-^ 30,397 15,235 1,236,341 1,707,673 -

6tr.l fuel oil (therms)

1989 -- 1990 3,415,713 1991 1,140,048 Average 2,277,881

For the purpose of matching the emission factor units with the fuel usage units the fuel usage’s will be converted from therms to MMBtu utilizing the conversion factor of 100,000 BTU/therm (0.1 MMBtultherm).

Natural Gas:

Qtr 2 fuel oil (therms) (therms) (therms) _-I-- ____-- 3,231,592

Qtr 3 fuel oil Qtr 4 fuel oil

3,354,455 1,107,234 0 3,180,669 2,722,350 ------ 3,267,562 1,914,792 1,615,796

Qtr. 1: (1,142,238 therrns)(O.l MMBtu/therm) = 114,223.8 MMBtu Qtr. 2: (15,235 therms)(O.l MMBtuhherm) = 1,523.5 MMBtu Qtr. 3: (1,236,341 therms)(O.l MMBtu/therm) = 123,634.1 MMBtu Qtr. 4: (1,707,673 therms)(O.l MMBtuhherm) = 170,767.3 MMBtu

Fuel Oil:

Qtr. 1: (2,277,881 therms)(O.l MMBtu/therm) = 227,788.1 MMBtu Qtr. 2: (3,267,562 therrns)(O.l MM Btultherm) = 326,756.2 MMBtu Qtr. 3: (1,914,792 therms)(O.l MMBtuhherrn) = 191,479.2 MMBtu Qtr. 4: (1,615,796 therms)(O.l MMBtu/therm) = 161,579.6 MMBtu

3

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C. Historical Actual Emissions:

Quarter 1:

HAE (Natural Gas)

NOx: (114,223.8 MMBtu)(0.21 IblMMBtu) = 23,987 Ib CO: (114,223.8 MMBtu)(0.36 Ib/MMBtu) = 41,121 Ib VOC: (1 14,223.8 MMBtu)(0.0014 IblMMBtu) = 160 Ib SOX: (114,223.8 MMBtu)(0.0006 IblMMBtu) = 69 Ib PMlO: (1 14,223.8 MMBtu)(0.005 IblMMBtu) = 571 Ib

HAE (Fuel Oil):

NOx: (227,788.1 MMBtu)(0.62 IblMMBtu) = 141,229 Ib CO: (227,788.1 MMBtu)(0.033 IbNMBtu) = 7,517 Ib VOC: (227,788.1 MMBtu)(0.005 IblMMBtu) = 1,139 Ib SOX: (227,788.1 MMBtu)(l.O Ib/MMBtu) = 227,788 Ib PMIO: (227,788.1 MMBtu)(O.l4 IblMMBtu) = 31,890 Ib

Quarter 2

HAE (Natural Gas)

NOx: (1,523.5 MMBtu)(0.21 IblMMBtu) = 320 Ib CO: (1,523.5 MMBtu)(O.36 IblMMBtu) = 548 Ib VOC: (1,523.5 MMBtu)(0.0014 IblMMBtu) = 2 Ib SOX: (1,523.5 MMBtu)(0.0006 Ib/MMBtu) = 1 Ib PMIO: (1,523.5 MMBtu)(0.005 IblMMBtu) = 8 Ib

HAE (Fuel Oil):

NOx: (326,756.2 MMBtu )(0.62 Ib/MMBtu) = 202,589 Ib CO: (326,756.2 MMBtu)(0.033 IblMMBtu) = 10,783 Ib VOC: (326,756.2 MMBtu)(0.005 IblMMBtu) = 1,634 Ib SOX: (326,756.2 MMBtu)(l .O Ib/MMBtu) = 326,756 Ib PMIO: (326,756.2 MMBtu)(O.l4 IblMMBtu) = 45,746 Ib

4

z . . ..

Quarter 3:

HAE (Natural Gas):

NOx: (123,634.1 MMBtu)(0.21 IblMMBtu) = 25,963 Ib CO: (123,634.1 MMBtu)(0.36 IblMMBtu) = 44,508 Ib VOC: (123,634.1 MMBtu)(0.0014 IblMMBtu) = 173 Ib SOX: (123,634.1 MMBtu)(0.0006 IblMMBtu) = 74 Ib PMIO: (123,634.1 MMBtu)(0.005 IblMMBtu) = 618 Ib

HAE (Fuel Oil):

NOx: (191,479.2 MMBtu)(0.62 IblMMBtu) = 118,717 Ib CO: (191,479.2 MMBtu)(0.033 IblMMBtu) = 6,319 Ib VOC: (191,479.2 MMBtu)(0.005 IblMMBtu) = 957 Ib SOX: (191,479.2 MMBtu)(l.O IblMMBtu) = 191,479 Ib PMIO: (191,479.2 MMBtu)(O.l4 IblMMBtu) = 26,807 Ib

Quarter 4:

NOx: (170,767.3 MMBtu)(0.21 IblMMBtu) = 35,861 Ib CO: (170,767.3 MMBtu)(0.36 IblMMBtu) = 61,476 Ib VOC: (170,767.3 MMBtu)(0.0014 IblMMBtu) = 239 Ib SOX: (170,767.3 MMBtu)(0.0006 IblMMBtu) = 102 Ib PMIO: (170,767.3 MMBtu)(0.005 IblMMBtu) = 854 Ib

HAE (Fuel Oil):

NOx: (161,579.6 MMBtu)(O.62 IblMMBtu) = 100,179 Ib CO: (161,579.6 MMBtu)(0.033 IblMMBtu) = 5,332 Ib VOC: (161,579.6 MMBtu)(O.OOS IblMMBtu) = 808 Ib SOX: (161,579.6 MMBtu)(l.O IblMMBtu) = 161,580 Ib PMIO: (161,579.6 MMBtu)(O.l4 IblMMBtu) = 22,621 Ib

D. Actual Emission Reductions (AER):

Newark Sierra has installed control devices to control emissions while firing on natural gas. They have also reduced #E fuel oil combustion contaminant emissions by reducing it's use. AERs will be calculated utilizing the following equations:

AER (natural gas): HAE X CE (District rule 2201 section 6.5.3)

5

AER(#6 fuel oil): HAE - PE (District rule 2201 section 6.5.1)

Where:

HAE is the historical actual emissions calculated in section V.C of this document

0 CE is the control efficiency and is calculated utilizing the following equation:

CE = (EF1 - EF,) + EF, Where:

0

0

EF1 is the premodification EF

EF, is the postmodification EF

CE(N0x) = (0.21 - 0.0365) t (0.21) = 0.826 CE(C0) = (0.36 - 0.15) i (0.36) = 0.583 CE(V0C) = (0.0014 - 0.0014) i (0.0014) = 0.0 CE(S0x) = (0.0006 - 0.0006) + (0.0006) = 0.0 CE (PMlO) = (0.005 - 0.005) i (0.005) = 0.0

PE is the potential to emit while firing on #6 fuel oil

Newark Sierra stated in the application for the ATCs authorizing these reductions that they wished to retain the right to burn #6 fuel oil seven days per year. It was not known which quarter the fuel oil would be burned in, therefore, the ATCs were conditioned such that #6 fuel oil could be burned for seven days per calendar quarter. The AERs will therefore be adjusted to reflect seven days per calendar quarter of #6 fuel oil usage.

The potential fuel oil usage, for each boiler, as limited by the PTO's is 2,664 MMBtu/day. Therefore, the combined quarterly potential to emit of the boilers, while operating on #6 fuel oil is:

NOx: (7 days/qtr)[(2)(2,664 MMBtu/day)](O.62 IblMMBtu) = 23,124 lblqtr CO: (7 days/qtr)[(2)(2,664 MMBtu/day)](O.lS IblMMBtu) = 5,594 lblqtr VOC: (7 days/qtr)[(2)(2,664 MMBtu/day)](0.005 IblMMBtu) = 186 lblqtr SOX: (7 days/qtr)[(2)(2,664 MMBtu/day)](l .O IblMMBtu) = 37,296 Ib/qtr PM10: (7 days/qtr)[(2)(2,664 MMBtu/day)](O.l 1 Ib/MMBtu) = 4,103 Ib/qtr

6

AERs:

Quarter 1:

NOX: CO: VOC: (160 Ib)(O.O) + (1,139 Ib - 186 Ib) = 953 Ib SOX: PMIO: (571 Ib)(O.O) + (31,890 Ib - 4,103 Ib) = 27,787 Ib

(23,987 lb)(0.826) + (141,229 Ib - 23,124 Ib) = 137,918 Ib (41,121 lb)(0.583) + (7,517 Ib - 5,594 Ib) = 25,897 Ib

(69 Ib)(O.O) + (227,788 Ib - 37,296 Ib ) = 190,492 Ib

Quarter 2

NOX: CO: VOC: (2 Ib)(O.O) + (1,634 Ib - 186 Ib) = 1,448 Ib SOX:

(320 lb)(0.826) + (202,589 Ib - 23,124 Ib) = 179,729 Ib (548 lb)(0.583) + (10,783 Ib - 5,594 Ib) = 5,508 Ib

(1 Ib)(O.O) + (326,756 Ib - 37,296 Ib) = 289,460 Ib PM10: (8 Ib)(O.O) + (45,746 Ib - 4,103 Ib) = 41,643 Ib

Quarter 3:

NOX: CO: VOC: (173 Ib)(O.O) = 0.0 lb + (957 Ib - 186 Ib) = 771 Ib SOX: PM10: (618 Ib)(O.O) + (26,807 Ib - 4,103 Ib) = 22,704 Ib

(25,963 lb)(0.826) + (118,717 Ib - 23,124 Ib) = 117,038 Ib (44,508 lb)(0.583) + (6,319 Ib - 5,594 Ib) = 26,673 Ib

(74 Ib)(O.O) = 0.0 Ib + (191,479 Ib - 37,296 Ib) = 154,183 Ib

Quarter 4:

NOX: CO: VOC: (239 Ib)(O.O) = 0.0 Ib + (808 Ib - 186 Ib) = 622 Ib SOX: PM10: (854 Ib)(O.O) = 0.0 Ib + (22,621 Ib - 4,103 Ib) = 18,518 Ib

(35,861 lb)(0.826) + (100,179 Ib - 23,124 Ib) = 106,676 Ib (61,476 lb)0.583) + (5,332 Ib -5,594 Ib) = 35,579 Ib

(102 Ib)(O.O) = 0.0 Ib + (161,580 Ib - 37,296 Ib) = 124,284 Ib

Summary of AERs:

Quarter 1 (Ib) Quarter 2 (Ib) NOx 137,918 179,729 co 25,897 5,508 voc 953 1,448 SOX 190,492 289,460 PMln 777R7 41 643

Quarter 3 (Ib) Quarter 4 (Ib) 117,038 106,676 26,673 35,579 77 1 622 1 54,183 124,284 22.704 18.518

E. Air Quality Improvement Deduction:

Per District rule 2201, section 6.5, a 10% air quality improvement deduction must be applied to the AERs prior to banking. The air quality improvement deductions are as follows:

Quarter 1 (Ib) Quarter 2 (Ib) Quarter 3 (Ib) Quarter 4 (Ib) NOx 13,792 17,973 11,704 10,668 co 2,590 551 2,667 3,558 voc 95 145 77 62 SOX 19,049 28,946 15,418 12,428 PMlO 2.779 4.164 2.270 1.852

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NOx co

F. Increase In Permitted Emissions:

Quarter 1 (Ib) Quarter 2 (Ib) Quarter 3 (Ib) Quarter 4 (Ib) 124,126 161,756 105,334 96,008 23.307 4.957 24.006 32.021

No IPE associated with this project.

G. Bankable Emissions Reductions:

The bankable emission reductions are equal to the AERs minus the air quality improvement deduction.

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VOC SOX PMlO

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858 1,303 694 560 171,443 260,514 138,765 11 1,856 25,008 37,479 20,434 16,666

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VI. C O m D l w

A. Real Reductions:

The reductions were generated by replacing the burners and reducing the quantity of fuel oil that could be burned. The burners have been replaced and source testing showed the reductions have occurred. The Permits to Operate (PTOs) for these units restrict the fuel oil usage to seven days per calendar quarter. Should the facility burn more fuel oil than allowed by the permit then enforcement action would occur. Therefore the reductions are real.

B. Enforceable Reductions:

The Permits to Operate include enforceable emission and fuel oil usage limits, which if complied with, will ensure the reductions are continuing to occur. Should the required source testing show the limits are being exceeded, or if the fuel oil usage exceeds the permitted quantities enforcement action would be taken. Therefore the reductions are enforceable.

C. Quantifiable Reductions:

The reductions were calculated utilizing actual baseline period fuel usage and emissions factors which were derived from source testing or EPA document AP-42. Therefore, the reductions are quantifiable.

D. Permanent Reductions:

The PTO's include emission concentration and fuel usage limits. Should increases in emission concentration or fuel oil usage be required then the facility would be required to apply to the District for an ATC. The application would be subject to New Source Review, which would ensure that the reductions continue to occur. Therefore, the reductions are permanent.

E. Surplus Reductions:

The applications for the ATC's authorizing these reductions were received and deemed complete on December 10, 1991, and the District's Air Quality Attainment Plan was adopted on January 30, 1992. The boiler control measure (District rule 4305) was not placed on the District list of control measures until August 27, 1992. Therefore, per District rule 2201, section 6.2.1, no discounting of the HAE's is required. Therefore, the reductions are surplus.

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F. Timeliness:

For each boiler, the reductions occurred on March 27, 1997, which is the date that the ATC’s were converted to PTOs. The ERC application was received on June 16, 1997 which is less than 180 days after the reductions occurred. Therefore the application was timely.

VII. Recommendation:

Issue Emission Reduction Credit Certificates to Newark Sierra for NOx, CO, VOC, SOX and PMlO reductions in the following amounts:

It is further recommended that at the time that the ERC‘s are issued that each emission concentration limit and the fuel oil usage limits be modified such that they state that they are for the purpose of enforcing ERC’s.

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.I iwmmm REGION

CENTRAL REGION

- ERCPUBLIC NOTICE CHECK LIST PROJECT# eza184

-. - - SOUTHERN REGION MODEMED FILE NAME: NEW70384.PBC

d d REQST COMPL

_ _ ERC TRANSFER OF PREVIOUSLY BANKED CREDITS ~~ x- ERC PRELIMINARY PUBLIC NOTICE -- ERC FINAL PUBLIC NOTICE -- NSWCEQA PRELIMINARY PUBLIC NOTICE -- NSWCEQA FINAL PUBL1C:NOTICE

ENCLOSED DOCUMENTS REQUIRE:

-Enter Correct Date, Print All Documents from MODEMED File and Obtain Directors Signature

X -Send Preliminary Notice Letters to CARB, EPA and Applicant; Including the Following Attachments:

X Other:

L -Send Preliminary Public Notice for Publication to

L -Send Signed Copies of Preliminary Notice Letters to Regional Office Attn: h h m y l h & s

_ _ Director's Signature and District Seal Embossed on ERC Certificates

-- Director's Signature on Cover Letter and Mail Cover Letter & ERC Certified Mail to: - Applicant: -

Certificates by

Applicant and Additional Addressees (see cover letters)

- - Send Copies of Signqd and Seal Embossed ERC Certificates and Signed cover letter to Regional Office Attn:-

-- Other Special Instructions (please specify)

Date Completed /BY

3 I

Upon Completion FAX to Regional Office Attn: .~~ ~. .- - - --

. . .. ~ .; . , .... .: .. . . _.----- I~ ! L:: .., ' , : :: . , . . ..~ . . . . . . .,

, . . ..-.: . ' . i , . , , . . ,

.,. !'. . . ... I,: :, I . , . . . . .i :;.. . . , .. . . .i . : .~. . . . .

. . DATE TO BE SENT]

Newark Sierra Paperboard Corporation Attn: Mark Vincent 800 W. Church Street Stockton, CA 95203


Dear Mr. Vincent:

Enclosed for your review and comment is the District’s analysis of Newark Sierra Paperboard Corporation’s application for Emission Reduction Credits (ERC’s) resulting from the retrofit of two boilers with low NOx burners and the reduced use of #6 fuel oil at 800 W. Church Street in Stockton, CA. The quantity of ERC’s proposed for banking is 487,224 Ib/yr of NOx, 84,291 lblyr of CO, 3,415 Ib/yr of VOC, 682,578 Ib/yr of SOX and 99,587 Ib/yr of PM10.

Also enclosed is the public notice of this decision which will be published approximately three days from the date of this letter. Please submit your written comments on this project within the 30day public comment period which begins on the date of publication of the public notice.


Sincerely,


SS:MJS/ba Enclosures

c: Anthony Mendes, Permit Services Manager

, . . [DATE TO BE SENT]

Raymond Menebroker, Chief Project Assessment Branch Stationary Source Division California Air Resources Board P. 0. Box 2815 Sacramento, CA 95812-2815



Enclosed for your review and comment is the District’s analysis of Newark Sierra Paperboard Corporation’s application for Emission Reduction Credits (ERC’s) resulting from the retrofit of two boilers with low NOx burners and the reduced use of #6 fuel oil at 800 W. Church Street in Stockton, CA. The quantity of ERC’s proposed for banking is 487,224 lb/yr of NOx, 84,291 lblyr of CO, 3,415 lb/yr of VOC, 682,578 lb/yr of SOX and 99,587 lblyr of PMlO.



Sincerely,


SS:MJS/ba Enclosures c: Anthony Mendes, Permit Services Manager

.. .

,. [DATE TO BE SENT]

Matt Haber, Chief Permits Office Air Division U.S. E.P.A. - Region IX 75 Hawthorne Street San Francisco, CA 94105


Dear Mr. Haber:

Enclosed for your review and comment is the District’s analysis of Newark Sierra Paperboard Corporation’s application for Emission Reduction Credits (ERC’s) resulting from the retrofit of two boilers with low NOx burners and the reduced use of #6 fuel oil at 800 W. Church Street in Stockton, CA. The quantity of ERC’s proposed for banking is 487,224 Ib/yr of NOx, 84,291 Ib/yr of CO, 3,415 lblyr of VOC, 682,578 lblyr of SOX and 99,587 Ib/yr of PM10.



Sincerely,


SS:/MJS/ba Enclosures

c: Anthony Mendes, Permit Services Manager

..

The Record

NOTICE OF PRELIMINARY DECISION FOR THE PROPOSED ISSUANCE OF

EMISSION REDUCTION CREDITS

NOTICE IS HEREBY GIVEN that the San Joaquin Valley Unified Air Pollution Control District solicits public comment on the proposed issuance of Emission Reduction Credits (ERC’s) to Newark Sierra Paperboard Corporation for the retrofit of two boilers with low- NOx burners and the reduced use of #6 fuel oil, at 800 W. Church Street in Stockton, CA. The quantity of ERC’s proposed for banking is 487,224 Ib/yr of NOx, 84,291 Ib/yr of CO, 3,415 lblyr of VOC, 682,578 lblyr of SOX and 99,587 Ib/yr of PM10.

The analysis of the regulatory basis for this proposed action, Project #970384, is available for public inspection at the District office at the address below. Written comments on this project must be submitted within 30 days of the publication date of this notice to SEYED SADREDIN, DIRECTOR OF PERMIT SERVICES, SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT, 4230 KIERNAN AVENUE, SUITE 130, MODESTO, CA 95356.

' .* . . . .

San Joaquin Valley Unified Air Pollution Control

November 5, 1998

Newark Sierra Paperboard Corporation Attn: Mark Vincent 800 W. Church Street Stockton, CA 95203

District

Dear Mr. Vincent:

RE: Notice of Final Action - Emission Reduction Credits Project Number: 970384

The Air Pollution Control Officer has issued Emission Reduction Credits (ERCs) to Newark Sierra Paperboard Corporation for emission reductions generated by retrofitting two boilers with low NOx burners and reducing the fuel oil usage of those boilers, at 800 W. Church Street in Stockton. CA.

Enclosed are copies of the ERC Certificates and of the notice of final action to be published approximately three days from the date of this letter.

All comments received following the District's preliminary decision on this project were considered.

Thank you for your cooperation in this matter. If you have any questions, please contact Mr. Anthony Mendes at (209) 545-7000.


SS:MJS:cl Enclosures

c: [Anthony Mendes, Permit Services Manager

. .


November 5, 1998

Matt Haber, Chief Permits Office Air Division

‘ US. E.P.A. - Region IX 75 Hawthorne Street San Francisco, CA 94105

Dear Mr. Haber:


The Air Pollution Control Ofticer has issued Emission Reduction Credits (ERCs) to Newark Sierra Paperboard Corporation for emission reductions generated by retrofitting two boilers with low NOx burners and reducing the fuel oil usage of those boilers, at 800 W. Church Street in Stockton. CA.


All comments received following the District‘s preliminary decision on this project were considered.



November 5, 1998

Raymond Menebroker, Chief Project Assessment Branch Stationary Source Division California Air Resources Board P.O. Box 2815 Sacramento. CA 95812-2815



The Air Pollution Control Officer has issued Emission Reduction Credits (ERCs) to Newark Sierra Paperboard Corporation for emission reductions generated by retrofitting two boilers with low NOx burners and reducing the fuel oil usage of those boilers, at 800 W. Church Street in Stockton, CA.




Sincerelv.

. Seved Sadredin Director of Permit Services

The Record - San Joaquin County

NOTICE OF FINAL ACTION FOR THE ISSUANCE OF EMISSION REDUCTION CREDITS

NOTICE IS HEREBY GIVEN that the Air Pollution Control Officer has issued Emission Reduction Credits to Newark Sierra Paperboard Corporation for emission reductions generated by retrofitting two boilers with low NOx burners and reducing the fuel oil usage of those boilers, at 800 W. Church Street in Stockton, CA.


The application review for Project #970384 is available for public inspection at the SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT, 4230 KIERNAN AVENUE, SUITE 130, MODESTO, CA 95356. '

San Joaquin Valley Unified Air Pollution Cont ro

/

Quarter 1 858 Ibs

/ Northern Regional Ofiice * 4230 Kiernan Ave., Suite 130 * Modesto, CA 95356

/ Emission Reduction Credit Certificate

Quarter 4- I Q w e r 2 Quarter 3 \ AB.& lbs 694 Ibs 560 Ibs

Issued To: Newark Sierra Paperboard Corporation

Street '

Of:

[ I Conditions Attached

Method Of Reduction [ 1 Shutdown of En [ 1 Shutdown of E [ X ] Other: Re low-NOx burners and reducing the fuel oil usage of thosc

S an Joa q u in XI lle y Unified Air Pollution Control District

Northern Regional Office * 4230 Kiernan Ave., Suite 130 * Modesto, CA 95356

Emission Reduction Credit Certificate N- 130-2

Issued To: Newark Sierra Paperboard Corporation Issue Date: November 5,1998

Location of Reduction: 800 W. Church Street Stockton, CA

For NOx Reductions In The Amount Of:

Quarter 1 Quarter 2 Quarter 3 Quarter 4 124,126 Ibs 161,756 Ibs 105,334 Ibs 96,008 Ibs

[ 1 Conditions Attached

Method Of Reduction [ [ [ X 1 Other: Retrofit of two boilers with low-NOx burners and reducing the fuel oil usage of those boiler!

1 Shutdown of Entire Stationary Source I Shutdown of Emissions Unit




Emission Reduction Credit Certificate N-130-3



For CO Reductions In The Amount Of:

Quarter 1 Quarter 2 Quarter 3 Quarter 4 23,307 lbs 4,957 lbs 24,006 lbs 32,021 Ibs

[ 1 Conditions Attached

Method Of Reduction [ [ I X ] Other: Retrofit of two boilers with low-NOx burners and reducing the fuel oil usage of thos

] Shutdown of Entire Stationary Source ] Shutdown of Emissions Unit

boilers


Quarter 1 25.008 Ibs


Quarter 2 Quarter 3 Quarter 4 37.479 Ibs 20.434 lbs 16.666 Ibs




For PMlO Reductions In The Amount Of:

[ ] Conditions Attached

Method Of Reduction [ [ [ X] Other:

] Shutdown of Entire Stationary Source ] Shutdown of Emissions Unit

Retrofit of two boilers with low-NOx burners and reducing the fuel oil usage of thosc bo i I e r s

David L. Crow, APCO


San Joaquin Valley Unlfied Air Pollution Control District

Quarter 1 171,443 lbs

Northern Regional Offwe * 4230 Kiernan Ave., Suite 130 * Modesto, CA 95356

Quarter 2 Quarter 3 Quarter 4 260,514 lbs 138,765 Ibs 111,856 Ibs




For SOX Reductions In The Amount Of:

] Conditions Attached

Method Of Reduction [ [ [ X] Other: Retrofit of two boilers with low-NOx burners and reducing the fuel oil usage of those

boilers

1 Shutdown of Entire Stationary Source 1 Shutdown of Emissions Unit

David L. Crow. APCO


please fonvard to Mark,Schonhoff mailbox:/~~7C/apps/endusr/netscape ... O~EPA~BS.RTPTOK.EPA,GOV&numbe~S7

Subject: please forward to Mark Schonhoff Date: Fri, 13 Feb 1998 11:01:59 -0800

From: [email protected] To: [email protected]

Hi -

today. I will be reviewing this project, and would appreciate a copy of several document that contain information used in your evaluation. Please send me a copy of the permits and applications for N-577-3-1 and N-577-4-1 and the application for this ERC. I would also like a copy of the pre-modification permits for these units and any other information that would be helpful for reviewing the proposed ERC. Thank you for your help. Please call me if you have any questions.

I received the proposed ERC for Newark Sierra Paperboard Corporation

Ed (415) 744-1211

SAN JOA UIN VALLEY

NO. REGION UNlFlE 8 A.P.C.D.

I "

I o f l 02/20/98 08:13:51


Fax Transmittal 4230 Kiernan Avenue, Suite 130 Modesto, California 95356 Phone (209) 545-7000 Fax (209) 545-8652

From : Number of pages (including cover sheet): I 0

P M ~ prof5 ~/ -s77-3- -0$4-0 p T i t s i d - sn -3 -1 4 4-/

Per Your Request For Your Information

Per Our Conversation [7 For Your Approval

0 Take Appropriate Action 0 Review & Comment

0 Please Answer @ Review & Return

Original transmittal will follow via mail

FAXFORM.XLS( rev. Z1996)


APPLICATION FOR

S l d 800 West Church Street

Cilp Stockton

I XEMISSION REDUCTION CREDIT (ERC) I 1 CONSOLIDATION OF ERC CERllFlCA?lZS

I I ERC REISSUE A F l E R PARTUL Vse I IERCTRNSFFROPOW4FSSmP

4. DATE OF REWCITON 1 / 2 7 / 9 7 (Barer #1

3 7 7 / 9 7 (Boiler # 1 )

1. ERC To BE ISSUED To:

Newark Si e r r a Paper boa r'd Corporation

800 West Church Street 2. MAILING ADDRESS:

s(rrruT.0. h u

C**i S toc kton st.m C A ~ l p - 95203

3. LOCATION OF REDUCITON: I

2nd QTR

3rd QTR El- I TOTALCOST ]

voc NOX co PMlO sox OTIIER

1 , 1 3 9 161,042 40,085 31 ,890 227,780

1 ,634 202,854 11,217 45,746 326,756

957 140,229 41,569 26,807 191,479

129,800 5 4 , 0 2 0 22,621 161,580 808

S S s S t

.- - $

5. PERMITNOQ: N-577-3-1 and N-577-4-1 EXISTINGERCNOQ:

6. -OD RESULTING IN EhUSSION REWCIION:

8. -A'NIU? OF, A P P L I W

[ 1 PROCESS CHANGE

TWE OR PRINT TlTLE OF APPLICANT:

9. TYPE OR PRINT NMlE OF APPLICANT:

Mark Vincent

General Manager

DATE: TELEPUONE NO:

5 I 3 0 I 9 7 ( 2 0 9 ) 466-7088

. . I ,

; ': i. ) . :., ,op i ' ,v

,)!,;?.] l a L ' J !

C ' . . . :-I 3 , , :i

L. .. .._I . i'

. . . - . . '. ; ,:

-

RECEIVED:$. ~ o , ~ FILMGFEE n

DATEPAID: &I 16 9-J CK& 080787

PROJECI' NO.:

SAN JOAQUIN VALLEY UNIFIED AIR POLL7JTION CONTROL DISTRICT 2321 WEST WASHINGTON ST., STE. I, P.O. BOX 2009, STOCKTON, CA 95201

Telephone: (209) 468-3470 APPLICATION FOR AUTHORITY TO CONSTRUCT

' '

- BUSINESS NAME:

NEWARK SIERRA PAPERBOARD CORPORATION - MAILING ADDRESS (Include City & Zip Code): - 800 West Church Street, Stockton CA 95203

~ - SITE ADDRESS:

* Is the facility located within 1000 feet of any K-12 school? Yes / / NO fl/ 800 West Church Street, Stockton CA 95203

Is rhe site address zoned properly for the proposed use? (INDICATE THE ZONING DESIGNATION)

Yes / % NO / / - . . .

Is this application the result of a Nonce of Violanon or a Nodce to Comply? Yes / / No / / If yes. give the Notice Number

. * DESCFUPTIoN: INSTALLATION OF LOW NOX BURNERS (STE ACCOMPAh'ING INFORMATION) . FOR BOILER I/ 2

(Please anach additional sheets, if necessary.)

THE FOLLOWING SHOULD ACCOMPANY THIS APPLICATION: A ,MAP OF THE LOCATION OF TKE FACIUT. ' ?ROCESS FLOW DIAGRAM (if applicable). PROCESSF'RODUCnON RATS OPERATING SCHEDIRE. AND DESCRIPTION OR

W A C I I I R E R S CATALOG OF EQUIPMWr AND AIR POLLUTION CONlROL E Q I I I P m . SEE UST AND C R m R I A (AB4841 T O M FOR FURTHER DETAILS. .

*x y&JiQ% REG. DIR. OF ENVIRONIENTAL AFFAIRS Signature of Applicant Title of Signer

- MICHAEL J. X E G E

Type or Print Name of Signer Telephone Number: (209)-466 5251

. DATE RECEIVED:

I- cn I " 1 Panrrbo lrd corn N w - k P a c l c P i p c r u a m co n Nrwrrh S orr i PsnPmowe cero XmARK SIERRA PAPERBOABD CORWRATION

- MAILING ADDRESS (Indude Ciey & Zip Code):

800 West Q N c h Street, Stockton CA 95203

4 800 West church Sireet, Stodrton CA 95203

- -

ilTE ADDRESS:

s the faciliry located within 1000 feet of any K-12 school? Yes / / NO p/ Yes /% No / / - s the site address zoned properly for the proposed use?

- j chis application the d r of a Nonce of Violadon or a Nodce to Comply? Yes / / No /x/

NDNDICATE THE ZONING DfSIGNA'llON)

- ' F yes, give rhe Noace Number

:QU'PMENT I X S W I O N OF LOW NOX BUlWERS (SPE AccoMeANING INFORMATION) FOR BOILER /I1 -

- (Please ana& additional sheers, if necessary.)

HE FOLLOWING SHOULD ACCOMPANY THIS APPLICATION: A MAP OF THE L O ~ ~ O N OF THE FA^. ~

,OQsS FLOW DIAGRAM (if applicable). PROCESS/PRODUCXON RAZ OPERATUG SCHEDUE, AND DESCNPnON OR i N U F A C . 5 CATALOG OF EQUIPMENT AM) A B P O W O N CONTROL EQUIPMENT. SEE I S T AM) CRiTZUA (i4B-884) !RM FOR FURTHER DETAU.

REG. DIR. OF AFFAIRS

Signature of Applicant Tide of Signer

MIUGi .I;;BoGGE Telephone Number: (2091-466 5251

Type or Print Name of Signer

San Joaquin Valley Umfied Air Pollution Control District

PERMIT TO OPERATE PERMIT NO: N- 577-3-1 EXPIRATION DATE: 08/01/2001

LEGAL OWNER OR OPERATOR: NEWARK SIERRA PAPERBOARD CORP. MAILING ADDRFSS: 800 W. CHURCH STREET

STOCKTON, CA 95203

LOCATION: 800 W. CHURCH STREET, STOCKTON

EQUIPMENT DESCRIPTION: BABCOCK AND WlLCOX MODEL 62222-37 BOILER WITH ONE 134 MMBTUlHR TODD DRMB BURNER.

CONDITIONS

1. No air contaminant shall be dischar ed into the atmosphere for a eriod or periods aggregatin more than

2. No air contaminant shall be released into the atmosphere which causes a public nuisance.

3. The boiler shall only be fired on natural gas or No. 6 fuel oil.

4. The NOx emission concentration shall not exceed 0.0365 Ib/mmbtu while firing on natural gas.

5. The CO emission concentration shall not exceed 0.15 lblmmbtu while firing on natural gas.

6. The Nh4HC emission concentration shall not exceed 0.0014 Ib/mmbtu while firing on natural gas.

7. The SOX emission concentration shall not exceed 0.0006 Ib/mmbtu while firing on natural gas.

8. The PMlO emission concentration shall not exceed 0.005 Iblmmbtu while firing on natural gas.

9. The #6 fuel oil usage shall not exceed 2664 mmbtulday.

three minutes in any one hour whick is dark or darker than Ringe P mann 1 or equivalent to 20k opacity.

CONDITIONS CONTINUE ON NEXT PAGE This Permit to Operate remains valid through the permit expiration date listed above. subject to payment of annual pennit fees and compliance with permit conditions and all applicable local, state, and federal regulations. This permit is valid only at the location specifid above, and becomes void upon any transfer of ownership or location. Any modification of the equipment or operation, as defined in District Rule 2201. will require a new permit. This permit shall be posted as prescribed in District Rule 2010.

DAVID L. CROW Executive Lhrector/APCO

Northern Regional Office *4230 Kiernan Ave.. Surte 130 *Modzsto, California 95356 *(209) 545-7000* FAX (209) 545-8652 1 9 7 bU . Y*SK

c FOR N- 577-3- 1 Page: 2

fuel oil is burned an time durin the day then the combined heat input from natural gas and #6 fuel oil shall not exceed z' 664 mmbtuhay.

11. The NOx emission concentration shall not exceed 0.62 lblmmbtu while firing on #6 fuel oil.

12. The CO emission concentration shall not exceed 0.15 lblmmbtu while firing on #6 fuel oil.

13. The NMHC emission concentration shall not exceed 0.005 lblmmbtu while firing on #6 fuel oil.

14. The SOX emission concentration shall not exceed 1.0 lblmmbtu while firing on #6 fuel oil.

15. The PMlO emission concentration shall not exceed 0.11 lblmmbtu while firing on #6 fuel oil.

16. The #6 fuel oil usage shall not exceed 18,648 mmbtu per calendar quarter.

17. The sulfur content of the #6 fuel oil shall not exceed 0.9% by weight.

18. Separate daily logs of the quantity of natural gas and #6 fuel oil shall be kept on the premises at all times. The records shall be retained for a penod of at least two years and shall be made available for District inspection upon request.

shall be installed in the fuel lines to the boiler and shall be in proper working condition at ab times.

19. Totalizing fuel flow meters which measure the amount of natural gas and #6 fuel oil enterin the boiler

20. Source testing shall be performed in accordance with District rule 4305 (Boilers, Steam Generators and Process Heaters).

21. Source testing shall be conducted using the methods and procedures approved by the District. The District must be notified 30 days prior to any compliance source test, and a source test plan must be submitted for approval 15 days prior to testing.

22. The results of each source test shall be submitted to the District within 60 days thereafter.

23. Sampling facilities for source testing shall be provided in accordance with the provisions of Rule 1081 (Source Sampling).

PERMIT NO: N- 577-4-1 EXPIRATION DATE: 08/01l2001

LEGAL OWNER OR OPERATOR NEWARK SIERRA PAPEiiBOARD CORP.

STOCKTON. CA 95203 MAILING ADDRESS: 800 W. CHURCH STREET

LOCATION 800 W. CHURCH STREET, STOCKTON

EQUIPMENT DESCRIPTION: BABCOCK AND WILCOX MODEL 62222-37 BOILER WITH ONE 134 MMBTUlHR TODD DRMB BURNER.

CONDITIONS

1. No air contaminant shall be dischar ed into the atmosphere for a


3. The boiler shall only be tired on natural gas or No. 6 fuel oil.

4. The NOx emission concentration shall not exceed 0.0365 lblmmbtu while firing on natural gas.


6. The NMHC emission concentration shall not exceed 0.0014 Iblmmbtu while firing on natural gas.

7. The SOX emission concentration shall not exceed 0.0006 lblmmbtu while firing on natural gas.

8. The PMlO emission concentration shall not exceed 0.005 lblmrnbtu while firing on natural gas.


nod or periods aggregatin more than three minutes in any one hour whicf is dark or darker than Ringe p" mann 1 or equivalent to 20k opacity.

..

CONDITIONS CONTINUE ON NEXT PAGE This Permit to Operate remains valid through the permit expiration date listed above, subject lo payment of annual permit fees and compliance with permit conditions and all applicable local, state, and federal regulations. This permit is valid only at the location specified above, and becomes void upon any transfer of ownership or location. Any modification of the equipment or operation, as defined in District Rule 2201, will require a new permit. This permit shall be posted as prescribed in District Rule 2010.

DAVID L. CROW Executive Vmctor/AI'CO

Northern Regional Oflice *4230 Kiernan Ave., Suite 130 'Modesto. California 95356 *(209) 545-7000* FAX (209) 545-8652 , M A 1 .. UkW

v-' CONDITIONS FOR N- 577-4-1

10. If #6 fuel oil is burned an time durin

11. The NOx emission concentration shall not exceed 0.62 lbllnmbtu while firing on #6 fuel oil.



14. The SOX emission concentration shall not exceed 1 .O Ib/mmbtu while firing on #6 fuel oil.


16. The #6 fuel oil u s g e shall not exceed 18,648 mmbtu per calendar quarter.

17. The sulfur content of tine #6 fuel oil shall not exceed 0.9% by weight.

18. Totalizing fuel flow meters which measure the amount of natural gas and #6 fuel oil enterin the boiler

the day then the combined heat input fuel oil shall not exceed 2 664 mmbtuhay.

shall be installed in the fuel lines to the boiler and shall be in proper working condition at afl times.

19. Separate daily logs of the quantity of natural gas and #6 fuel oil shall be kept on the premises at all times. The records shall be retamed for a period of at least two years and shall be made available for District inspection upon request.

20. Source testing shall be conducted in accordance with District rule 4305 (Boilers, Steam Generators and Process Heaters).

!l. Source testing shall be conducted usinf: the methods and procedures amroved bv the District. The District musf be notified 30 days prior to any compliance source test,-hd a socrce test plan must be submitted for approval 15 days prior to testing.

'2. The results of each source test shall be submitted to the District within 60 days thereafter.


... . ..


PERMIT TO OPERATE PERMIT NO: N- 577-3-0 EXPIRATION DATE: 08/01/2001

,-. .? /I, - y.; , 7 -7 . j _- j ._ 1 - i ? ' - .

STOCKTON, CA 95203

LOCATION: 800 W. CHURCH STREET, STOCKTON . .'<I. /-.I .: >~

B & W INTEGRAL FURNACE, STIRLING DESIGN, DUAL DRUM, CLASS FZZAESPL BOILER # I (BUILT IN 1937) WITH THREE (3) COEN CPF BURNERS SERVING A GENERAL ELECTRIC 3.5 MW STEAM TURBINE GENERATOR.

EQUIPMENT DESCRIlTION:

CONDITIONS


2. Particulate matter emissions from any combustion source shall not exceed 0.1 grainddscf (calculated to 12% carbon dioxide).

3 . No air contaminant shall be dischar ed into the atmosphere for a eriod or periods aggregatin more than

4. A record of daily fuel consum tion shall be mdntained, retained on the premises for a period of at

5. A daily log of hourly power production sh6ll be maintained on the premise and shall be made available

three minutes in any one hour whicE is dark or d.arker than Ringe P mann 1 or equivalent to 20k opacity.

least two years and made avai P able for Distjct inspection upon request. i

for District inspection.

6 . The baghouse cleaning frequency

7. The facility shall produce no

shall be adjusted to optimize the control efficiency.

per hour of electricity.

fuel oil with a maximum sulfur content of 3%. 8. The boiler shall be fired on

This Permit to Operate remains compliance with permit

date listed above, subject to payment of annual permit fees and federal regulations. This permit is valid only at the location

specified above, and becomes VOI upon any transfer of ownership or locaiion. Any modification of the equipment or operation, as defined in District Rule 2201. will require a new permit. This permit shall be posted as prescribed in District Rule 2010. 7

/ /'

i

DAVID L. CR0,W Executive UirectorljPCO

/

Northern R gional Office *4230 Kieman Ave., Suite 130 *Modesto. California 95356 *(209) 545-7000* FAX (209) 545-8652 P ,*B,.21-.OILL

San Joaquin Valley Unified Air Pollution Control District /

i /

PERMIT TO OPERATE ,/ /’ PERMIT NO: N- 577-4-0 EXPIRATIOPIDATE 08/01~2001

STOCKTON, CA 95203 // b y A/- q 7 p +,i’

.I ‘y/7/’9 7 ,’ ,,’ &5,

LOCATION: 800 W. CHURCH STREET, STOCKTON l‘

EQUIPMENT DESCRIPTION: B & w INTEGRAL FURNACE, STIRLING DESIGN, DUAL DRUM, CLASS FZAESP,E’BOILER #2 (BUILT IN 1937) WITH THREE (3) COEN SAZ BURNERS SERVING A GENERAL ELECTRIC 3.5 MW STEAM TURBINE GENERATOR.

/; CONDITIONS , i i

; 1. No air contaminant shall be released into the atmosphere which causes a public nuisance.

2. No air contaminant shall be dischar ed into the atmosphere fo i a eriod or periods aggregatin more,than

3. Particulate matte 12% carbon dio

4. A record of daily fuel c least two years and ma

5. A daily log of hourly least two years and m

6 . The baghouse cleanin

7. The facility shall pro

8. The boiler shall

three minutes in any one hour whick is dark or darker than R’inge P mann 1 or equivalent to 20$0 opacity.

.I grainddscf (calculated to

ined on the premises for a period of at

the premises for a period of at

ize the control efficiency.

lfur content of 3%.

This Permit to Operate r compliance with permit specified above. and h defined in District Ru

ect to payment of annual permit fees and This permit is valid only at the location cation of the equipment or operation, as scribed in District Rule 2010.

/’ DAVID L. CROW kxautive Director/APCO

Northern R Tional Office *4230 Kiernan Ave., Suite 130 *Modesto, California 95356 *(209) 545-7000* FAX (209) 545-8652

I l g 7 . n .. OWL ,P

:..a - 3 .


Fax Transmittal 4230 Kiernan Avenue, Suite 130 Modesto, California 95356 Phone (209) 545-7000 Fax (209) 545-8652

Number of pages (including cover sheet):

Description :

Per Your Request

Per Our Conversation

Take Appropriate Action

Please Answer

For Your Information

a For Your Approval

Review & Comment

0 Review 8 Return

0 Original transmittal will follow via mail

c

Remarks I Response :

FAXFORM.XLS( rev. 21996)

. / .


AUTHORITY TO CONSTRUCT PERMlT NO: N- 577-3-1 ISSUANCE D A T E 03/10/95

LEGAL OV.'hTR OR OPERATOR NEWARK SIERRA PAPERBOARD COW. MAILING A D D m S : 800 W. CHURCH STREET

STOCKTON, CA 95203

LGCATiC-N: 800 W. CHURCH STREET, STOCKTON

EQUIPMENT DESCRIPTION BOILER #l. BABCOCK AND WJLCOX MODEL #G2222-37. MODIFICATION TO INSTALL THREE TODD VERIFLAME BURNERS kATED AT 45 MMBTUNR EACH AND FLUE GAS RECIRCULATION.

CONDITIONS

1. No air contaminant shall be dischar ed into the atmos here for a rid or periods aggre ating more than three minutes in any one hour whic fi is as dark as or a arker than f&gelmann 1 or equiv 3 ent to 20% opacity.



4. The NOx emission concentration shall not exceed 0.0365 lblmmbtu while firing on natural gas


6 . The NMHC emission concentration shall not exceed 0.0014 lblmmbtu while firing on natural gas.

7. The SOX emission concentration shall not exceed 0.0006 lb/mmbtu while fuing on natural gas.

8. The PMlO emission concentration shall not exceed 0.005 lb/mmbtu while firing on natural gas.


CONDITIONS CONTINUE ON NEXT PAGE This is NOT a PERMIT TO OPERATE. Approval or denial of a PERMIT TO OPERATE will he made after an inspection to verify that the equipment has been constructed in accordance with the approved plans, specifications and conditions of this Authority to Construct, and to determine if the equipment can be operated in compliance with all Rules and Regulations of the San Joaquin Valley Unified Air Pollution Control District. YOU MUST NOTIFY THE DISTRICT COMPLIANCE DIVISION AT (209) 545-7000 WHEN CONSTRUCTION OF THE EQUIPMENT IS COMPLETED. Unless construction has commenced pursuant to Rule 2050, this Authority to Construct shall expire and application shall be cancelled two years from the date of issuance. The applicant is responsible for complying with all laws, ordinances and regulations of all other governmental agencies which may pertain to the above equipment.

DAVID L. CROW, EXECUTIVE DIRECTOR/APCO

PERMIT SERVICES

Nod& Regina1 Office *4230 Kiernan Ave., Suite 130 *Modesto. California 95356 *(209) 545-7000* FAX (209) 545-8652 t~> ,O.LL.EK

,I , .,ihITIONS FOR N- 577-3-1 c R. Page: 2

10. If #6 fuel oil is burned an time durin the day then the combined heat input from natural gas and #6 \

11. The NOx emission concentration shall not exceed 0.62 lblmmbtu while firing on #6 fuel oil.



14. The SOX emission concentration shall not exceed 1.0 Iblmmbtu while firing on #6 fuel oil.


16. The #6 fuel oil usage shall not exceed 18,648 mmbtu per calendar quarter.


18. Separate daily logs of the quantity of natural gas and #6 fuel oil shall be kept on the premises at all times. The records shall be retamed for a period of at least two years and shall be made available for District inspection upon request.

fuel oil shall not exceed 2 664 mmbtu B day.

.

19. Totalizing fuel flow meters which measure the amount of natural gas and #6 fuel oil enterin the boiler shall be installed in the fuel lines to the boiler and shall be in proper worlang condition at af 1 times.

the NOx and CO emission limits of this permit. 20. The boiler shall be source tested while firing on natural gas in order to demonstrate compliance with

21. The source testing shall be conducted within 90 days of initial start up and on an annual basis thereafter.

22. Source testing shall be conducted usjng the methods and procedures approved by the District. The District must be notified 30 days pnor to any compliance source test, and a source test plan must be submitted for approval 15 days pnor to testing.


24. Sampling 'facilities for source testing shall be provided in accordance with the provisions of Rule 1081 (Source Sampling).

(


AUTHORITY TO CONSTRUCT PERMIT NO: N- 577-4-1 ISSUANCE DATE: 03/10/95

LEGAL OWNER OR OPERATOR. WARK SIERRA PAPERBOARD cow. MAILING ADDRESS: 800 w. CHURCH STREET

STOCKTON, CA 95203

LOCATION 800 W. CHURCH STREET, STOCKTON

EQUIF'MENT DESCRIPTION BOILER #2, BABCOCK AND WILCOX MODEL 62222-37. MODIFICATION TO INSTALL THREE TODD VERIFLAME BURNERS RATED AT 45 MMBTUEIR EACH AND FLUE GAS RECIRCULATION.

CONDITIONS

1. No air contaminant shall be dischar ed into the atmos here for a nod or periods aggre ating more than three minutes in any one hour whici is as dark as or B arker than Engelmann 1 or equv 3 ent to 20% opacity.



4. The NOx emission concentration shall not exceed 0.0365 lblmmbtu while firing on natural gas.

5 . The CO emission concentration shall not exceed 0.15 lblmmbtu while firing on natural gas.

6 . The Nh4HC emission concentration shall not exceed 0.0014 lblmmbtu while firing on natural gas.

7. The SOX emission concentration shall not exceed 0.0006 lblmmbtu while firing on natural gas.

8. The PMlO emission concentration shall not exceed 0.005 lblmmbtu while firing on natural gas.


CONDITIONS CONTINUE ON NEXT PAGE This is NOT a PERMIT TO OPERATE. Approval or denial of a PERMIT TO OPERATE will he made after an inspection to verify that the equipment has heen constructed in accordance with the approved plans, specifications and conditions of this Authority to Construct, and to determine if the equipment can be operated in compliance with all Rules and Regulations of the San Joaquin Valley Unified Air Pollution Control District. YOU MUST NOTIFY THE DISTRICT COMPLIANCE DIVISION AT (209) 545-7000 WHEN CONSTRUCTION OF THE EQUIPMENT IS COMPLETED. Unless construction has commenced pursuant to Rule 2050, this Authority to Construct shall expire and application shall be cancelled two years from the date of issuance. The applicant is responsible for complying with all laws, ordinances and regulations of all other governmental agencies which may pertain to the above equipment.

DAVID L. CROW, EXECUTIVE DIRECTORIAPCO

RMIT SERVICES

No& Regina1 Office *4230 Kieman Ave.. Suite 130 +Modesto, California 95356 *(209) 545-7000' FAX (209) 545-8652 IW>>IO - LLW

' .' ,kbInONS FOR N- 577-4-1 c e Page: 2 10. If #6 fuel oil is burned an time durin the day then the combined heat input from natural gas and #6 i

fuel oil shall not exceed zy 664 mmb J day.

11. The NOx emission concentration shall net exceed 0.62 lblmmbtu while firing on #6 fuel oil.

12. The CO emission concentration shall not exceed 0.15 lblmmbtu while fuing on #6 fuel oil.


14. The SOX emission concentration shall not exceed 1.0 lblmmbtu while firing on #6 fuel oil.

15. The PMlO emission concentration shall not exceed 0.1 1 lblmmbtu while firing on #6 fuel oil. . 16. The #6 fuel oil usage shall not exceed 18,648 mmbtu per calendar quarter.


18. Separate daily logs of the quantity of natural gas and #6 fuel oil shall be kept on the premises at all times. The records shall be remned for a period of at least two years and shall be made available for District inspection upon request.

19. Totalizing fuel flow meters which measure the amount of natural gas and #6 fuel oil enterin the boiler shall be installed in the fuel lines to the boiler and shall be in proper worlang condition at ;si times.

the NOx and CO emission limits of this permit. 20. The boiler shall be source tested while firing on natural gas in order to demonstrate compliance with

21. The source testing shall be conducted within 90 days of initial start up and on an annual basis thereafter.

22. Source testing shall be conducted using the methods and procedures approved by the District. The District must be notified 30 days prior to any compliance source test, and a source test plan must be submitted for approval 15 days prior to testing.



Application Review

ADDIication Number:

Proiect Number:

Facilitv Name:

Mailing Address:

Contact Name:

Phone #:

I. Proaosal:

Mark Schonhoff March 8, 1995

N-577-3-1 N-577-4-1

NIA

Newark Sierra Paperboard Corporation

800 W. Church Street Stockton, CA 95203

Michael Rogge

(209) 466-5251

Issue an Authority To Construct to install low NOx burners on two existing boilers.

In the past, Newark Sierra utilized #6 fuel oil as the primary fuel in the boilers. They are now proposing to install low NOx burners and utilize natural gas as the primary fuel for both boilers. They have requested to have their #6 fuel oil usage limited to seven days per quarter.

11. ADDlicable Rules:

Rule 2010: Permits Required Rule 2201: Rule 4001: Rule 4101: Visible Emissions Rule 4102: Nuisance Rule 4301: Fuel Burning Equipment

New & Modified Stationary Source Review (October 21, 1993) New Source Performance Standards (Subpart Db)

m.

w.

V.

VI.

Proiect Location:

Street Address: 800 W. Church Street Stockton, CA

Process Descriation: Newark Sierra is in the business of making paperboard from waste paper. They also operate a cogeneration plant which utilizes steam from these two boilers. Presently the turbines are not being operated and 100% of the steam produced is being utilized by the paperboard operation. If the turbines are brought back into operation they would utilize approximately 1/3 of the steam produced. None of the electricity generated when the turbines are in operation is sold.

Equipment Listing: Present: 2 Babcock and Wilcox Model # 62222-37, NB 10950 Boilers equipped with:

Boiler 1: 3 Coen CPF Parallel Flow

Boiler 2: 3 Coen DAZ-22 circular Burners.

register burners.

Each boiler is rated at 113 MMBTUlhr while firing on natural gas and 11 1 MMBTUlhr while firing on #6 fuel oil.

Proposed: The new burners will be Todd Variflame low NOx burners rated at 45 MMBTUlhr each. There will be three burners per boiler (135 MMBTUlhour per boiler).

Emission Control Technolow Evaluation:

The burners utilize low excess air combustion, multi-stage combustion, and flue gas recirculation to control NOx:

1. Low Excess Air Combustion:

2. Multi-Stage Combustion:

The combustion process will take place with a minimum amount of air which minimizes the amount of free oxygen available to form NOx.

Fuel and air are injected at various stages withiin the flame envelope. This helps to optimize combustion and NOx levels.

2

3. Flue Gas Recirculation: Exhaust gas is introduced into the combustion process, lowering the combustion temperature, and reducing the amount of excess air available for NOx formation.

VII. Calculations:

A. Emission Factors:

Premodification Emission Factors (Natural Gas):

C A B tested both boilers for NOx and CO on 12/11/85, however only the gas usage of boiler #2 was logged. It will be assumed that the NOx and CO emission factors derived from the source test results can be used for both boilers.

Gas usage: 2.676 MMCF in boiler #2 on the day of the test (From application package, page 3-8). Assuming that the usage was uniform on an hourly basis the hourly usage was:

(2.676 MMCF124 hr)(lOOO BTU/CF) = 111.5 MMBTUlhr

The maximum capacity of the boiler, while firing on natural gas, is 113 MMBTU/hr therefore the boiler was firing at an acceptable rate for the test.

The following equation will be utilized to calculate the NOx and CO emission factors:

EF(1blMMBTU) = (PPM)(MW)(2.59 X 10-9)(F-Factor)[20.9/(20.9 - %03]

Where: PPM is the average tested concentration (Application Pkg., Appendix D) MW is the molecular weight 2.59 X is a constant F-Factor is 8740 (From F-Factor Manual)

NOx: Average Tested Concentration: 170 PPM (Application Pkg. App. D)

EF(N0x) = (170)(46)(2.59 X 10-9)(8740)[20.9/(20.9 - 3)] = 0.21 lb/MMBTU

CO: Average Tested Concentration: 490 PPM

EF(C0) = (490)(28)(2.59 X 109)(8740)[20.9/(20.9 - 3)] = 0.36 1blMMBTU

3

NMHC and PMlO were not tested for and the SOX emissions were reported to be negligible therefore estimates will be made using AP-42 emission concentrations.

NMHC Concentration:

EF (NMHC) = (1.41 Ib/MMCF)(l CFllOOO BTU) = 0.0014 IblMMBTU

SOX Concentration (as SOJ:

EF (SOX) = (0.6 Ib/MMCF)(l CFllOOO BTU) = 0.0006 IblMMBTU

PMlO Concentration:

EF (PM10) = (5 lb/MMCF)(l CF/1000 BTU) = 0.005 Ib/MMBTU

1.41 Ib/MMCF (AP-42, Table 1.4-3)

0.6 Ib/MMCF (AP-42, Table 1.4-2)

5 IblMMCF (AP-42, Table 1.4-1)

Premodification Emission Factors, #6 Fuel Oil:

Each boiler was source tested. Boiler #1 was tested by the California Air Resources Board on 12/11/85 and #2 was tested by BCA on 9/10/91. The fuel oil burned during the 1991 test on boiler #2 was Kern Oil And Refining Company Oil which is the same blend (Sulfur content of 0.74 to 1.0% and a nitrogen content of between 0.34 and 0.96%) as the fuel oil burned during the baseline period (Quarter 4 of 1989 through Quarter 3 of 1991). The fuel oil burned during the 1985 test on boiler #1 was a different blend. Since the boilers are similar it will be assumed that the emission factors for NOx, SOX and PM10, derived from the data from the 9/10/91 test, can be applied to both boilers. NMHC emissions were not tested, therefore the AP-42 emission factor will be utilized. CO was tested and the emission rate was found to be 0.25 lblhr which equates to approximately 4 PPM. This does not seem realistic therefore the CO emission factor will be estimated utilizing AP-42.

#6 fuel usage: 308 barrels (12,936 gallons (2.42 gal/bbl) during the entire day of the source test. Assuming that the usage was uniform throughout the day the hourly usage was 539 gallons. (Application Package, Page 3-9)

#6 fuel oil heating value: #6 fuel usage: Sulfur Content: 0.91 % Nitrogen Content: 0.83 %

NOx emission rate:

EF(N0x) = (50.2 Ib/hr)(l hrB0.85 MMBTU/hr) = 0.62 Ib/MMBTU

150,000 BTU/gal (AP-42, A-4) (150,000 BTU/ga1)(539 gallhr) = 80.85 MMBTU/hr


4

CO emission concentration: 5 lb/lO’ gal (AP-42 table 1.3-1)

EF(C0) = (5 lb/lO’ gal)(l ga1/150,000 BTU) = 0.033 Ib/MMBTU

SOX Emission Rate: 84.7 lb/hr (Application Package, Appendix D)

EF (SOX) = (84.7 Ib/hr)(l hrBO.85 MMBTU) = 1.0 Ib/MMBTU

NMHC emission Concentration:

EF(NMHC) = (0.76 lb/lO’ gal)(l ga1/150,000 BTU) = 0.005 IblMMBTU

TSP Emission Rate: PMlO Fraction: 0.87 (PM10 manual)

PMlO Emission Rate = (12.74 lb/hr)(0.87) = 11.1 lblhr

EF(PM10) = (11.1 Ib/hr)(l hd80.85 MMBTUlhr) = 0.14 Ib/MMBTU

Postmodification Emission Factors, Natural Gas

0.76 lb/103 gal (AP-42, Table 1.3-1)


NOx: c o : NMHC:

0.0365 Ib/MMBTU (Vender Guarantee, Application Package, appendix F) 0.15 Ib/MMBTU (Vender Guarantee, Application Package, appendix F) AP-42 emission concentration was guaranteed (Application Package, Sect. 3):

Emission concentration: Natural Gas Heating Value: 1000 BTU/SCF EF(V0C) = (1.41 lb/MMCF)(l CF/1000 BTU) = 0.0014 Ib/MMBTU

SOX: AP-42 emission rate was guaranteed:

Emission concentration: Natural Gas Heating Value: 1000 BTU/SCF EF(S0x) = (0.6 Ib/MMCF)(l CFllOOO BTU) = 0.0006 Ib/MMBTU

1.41 IblMMCF (AP-42 table 1.4-3)

0.6 Ib/MMCF (AP-42 table 1.4-2)

PM10: AP-42 emission concentration was guaranteed:

Emission concentration: Natural Gas Heating Value: 1000 BTUISCF EF(PM10) = (5 Ib/MMCF)(l CF/1000 BTU) = 0.005 IblMMBTU

5 Ib/MMCF (AP-42 table 1.4-2)

5

Postmodification Emission Factors, #6 Fuel Oil

NOx: The burner manufacturer has guaranteed an emission concentration of 265 to 540 PPM (0.33 to 0.69 Ib/MMBTU) depending on the type of fuel used. The applicant has proposed 0.62 Ib/MMBTU (Application Package, table 4-1).

The vender has guaranteed 200 PPM (0.15 Ib/MMBTU) CO:

VOC: The applicant has proposed the AP-42 emission concentration (Application Package, Table 4-1).

NMHC emission Concentration: EF(NMHC) = (0.76 lb/103 ga1)(539 gal/hr)(l hrl80.85 MMBTU) = 0.005 Ib/MMBTU

0.76 lb/103 gal (AP-42 Table 1.3-1)

NOx

SOX: The applicant is proposing an emission factor of 1 .O Ib/MMBTU based on their expectation that they can match the SOX emission rate achieved during the 9/10/91 source test (Application Package, table 4-1). Newark Sierra stated in the application that they would be limited to a fuel oil sulfur content of 0.9% by weight.

PM10: The applicant is proposing an emission factor of 0.11 IblMMBTU.

- Before Modification After Modification

Natural Gas # 6 Fuel Oil Natural Gas # 6 Fuel Oil (Ib/1O6 BTU) (Ib/1O6 BTU) (lb/106 BTU) (lb/106 BTU)

0.21 0.62 0.0365 0.62

PMlO

II s o x I 0.0006 I 1 .o I '0.0006 I 1 .o II

0.005 0.14 0.005 0.11

II co I 0.36 I 0.033 I 0.15 I 0.15 I1 II NMHC I 0.0014 I 0.005 I 0.0014 I 0.005 II

6

.. . .

B. Assumptions Made:

1. Emission Factors for a source test from one boiler may be applied to the other.

C. Emission Calculations:

1. Maximum Proposed Emissions: Newark Sierra requested to have their emissions limited such that offsets and public notice are not triggered. Additionally they requested to be limited such that BACT for fuel oil combustion emissions is not triggered. In order to achieve that, there must be no Increase In Permitted Emissions of NOx, NMHC, SOX or PMlO and the NSR balance for CO must be less than 550 pounds per day

Both boilers are prebaseline units. Boiler #2 has not been modified since the baseline date and in 1985 Newark Sierra modified boiler # l . That modification resulted in a SOX NSR balance of 150 pounds per day, a CO NSR balance of 11.5 pounds per day and a PMlO NSR balance of 12.5 Ib/day. Therefore, in order to avoid exceeding any of the above mentioned threshold levels each boiler must be limited to no more than the following:

PEPM (Oil): NOx = (111 MMBTU/hr)(24 hr/day)(0.62 IWMMBTU) = 1651.7 lblday CO = (111 MMBTU/hr)(24 hr/day)(0.033 IblMMBTU) = 87.9 Ib/day NMHC = (111 MMBTU/hr)(24 hr/day)(0.005 IblMMBTU) = 13.3 lblday SOX = (111 MMBTU/hr)(24 hr/day)(l.O Ib/MMBTU) = 2664.0 lblday PMlO = (111 MMBTU/hr)(24 hr/day)(0.14 Ib/MMBTU) = 373.0 Ib/day

PEPM (Gas): NOx = (113 MMBTU/hr)(24 hr/day)(0.21 Ib/MMBTU) = 569.5 Ib/day CO = (113 MMBTU/hr)(24 hr/day)(0.36 Ib/MMBTU) = 976.3 Ib/day NMHC = (113 MMBTU/hr)(24 hr/day)(0.0014 IblMMBTU) = 3.8 Ib/day SOX = (113 MMBTU/hr)(24 hr/day)(0.0006 IblMMBTU) = 1.6 lblday PMlO = (113 MMBTU/hr)(24 hr/day)(0.005 Ib/MMBTU) = 13.6 lblday

Worst Case PEPM: NOx = 1651.7 Ib/day CO = 976.3 Ib/day NMHC = 13.3 Ib/day SOX = 2664 lblday PMlO = 373 Ib/day

7

Maximum Proposed Emissions:

Newark Sierra has proposed no change in the NOx, CO, NMHC or SOX emission concentrations and a decrease in the PMlO emission concentration while firing on #6 fuel oil. Therefore, in order to ensure no increase in emissions while firing on #6 fuel oil the boilers will be limited to their premodification #6 fuel oil burning capacity which is:

(1 11 MMBTU/hr)(24 hr/day) = 2664 MMBTU/day

NOx = (2664 MMBTU/day)(0.62 IblMMBTU) = 1651.7 Ib/day CO = (2664 MMBTU/day)(O.lS Ib/MMBTU) = 399.6 Ib/day NMHC = (2664 MMBTU/day)(O.OOS IWMMBTU) = 13.3 Iblday SOX = (2664 MMBTU/day)(l.O lb/MMBTU) = 2664.0 lblday PMlO = (2664 MMBTU/day)(O.ll 1blMMBTU) = 293.0 Ib/day

NOx = (135 MMBTU/hr)(24 hr/day)(0.0365 Ib/MMBTU) = 118.3 lblday CO = (135 MMBTU/hr)(24 hr/day)(0.15 lb/MMBTU) = 486.0 Ib/day NMHC = (135 MMBTU/hr)(24 hr/day)(0.0014 1blMMBTU) = 4.5 Ib/day SOX = (135 MMBTU/hr)(24 hr/day)(0.0006 1blMMBTU) = 1.9 Ib/day PMlO = (135 MMBTU/hr)(24 hr/day)(0.005 IblMMBTU) = 16.2 lb/day

PE (Oil):

PE (Gas):

Worst Case PE: NOx = 1651.7 lblday CO = 486.0 Ib/day NMHC = 13.3 Ib/day SOX = 2664.0 lb/day PMlO = 293.0 lblday

The Potential To Emit is less than or equal to the Potential To Emit Prior to The Modification.

Daily Emission Limits:

Conditions Will Be The Same For Both Boilers: Equipment Description: 135 MMBTU/HR Boiler

1.

2.

The boiler shall be fired on natural gas or #6 fuel oil only,

The NOx emission concentration shall not exceed 0.0365 Ib/mmbtu while firing on natural gas.

8

..


The NMHC emission concentration shall not exceed 0.0014 lb/mmbtu while firing on natural gas.

The SOX emission concentration shall not exceed 0.0006 lblmmbtu while firing on natural gas.

The PMlO emission concentration shall not exceed 0.005 lb/mmbtu while firing on natural gas.

The #6 fuel oil usage shall not exceed 2664 mmbtu/day.

If #6 fuel oil is burned at any time during the day then the combined heat input from natural gas and #6 fuel oil shall not exceed 2664 mmbtulday.

The NOx emission concentration shall not exceed 0.62 lblmmbtu while firing on #6 fuel oil.

4.

5 .

6.

7 .

8.

9.

10.

11.

The CO emission concentration shall not exceed 0.15 lblmmbtu while firing on #6 fuel oil. The NMHC emission concentration shall not exceed 0.005 Ib/mmbtu while firing on #6 fuel oil.

12. The SOX emission concentration shall not exceed 1.0 lb/mmbtu while firing on #6 fuel oil.

The PMlO emission concentration shall not exceed 0.11 lblmmbtu while firing on #6 fuel oil.

The #6 fuel oil usage shall not exceed 18,648 mmbtu's per calendar quarter'

13.

14.

* The applicant originally requested to be limited to 7 days per year of fuel oil usage. It was not certain which quarter the fuel usage would take place in therefore they will be allowed 7 days per quarter. Refer to the AER section of this application review for further information:

(2,664 MMBTU/day)(7 days/qtr) = 18,648 mmbtulqtr

9

Natural Gas EF’s (Ib/MMBTU)

EF I EF2 ACE

NOx 0.21 0.0365 0.826

#6 Fuel Oil EF’s (IblMMBTU)

EF I EF2 ACE

0.62 0.62 0.0

HAPE (Natural Gas, Per Boiler):

NOx = (113 MMBTU/hr)(24 hr/day)(0.21 lb/MMBTU)(l-0.826) = 99.1 lb/day CO = (113 MMBTU/hr)(24 hr/day)(0.36 lb/MMBTU)(l-0.583) = 407.1 lb/day NMHC = (113 MMBTU/hr)(24 hr/day)(0.0014 Ib/MMBTU)(l-0.0) = 3.8 Ib/day SOX = (113 MMBTU/hr)(24 hr/day)(0.0006 Ib/MMBTU)(l-0.0) = 1.6 Ib/day

PMlO = (113 MMBTU/hr)(24 hr/day)(0.005 lb/MMBTU)(l-0.0) = 13.6 Ib/day

IPE (Natural Gas, Per Boiler):

NOx = 118.3 lb/day - 99.1 Ib/day = 19.2 lb/day CO = 486.0 Ib/day - 407.1 Ib/day = 78.9 Ib/day NMHC = 4.5 Ib/day - 3.8 Ib/day = 0.7 lb/day SOX = 1.9 Ib/day - 1.6 Ib/day = 0.3 Ib/day

PMlO = 16.2 Ib/day - 13.6 Ib/day = 2.6 lb/day

10

(Rounds to zero because it is less than 0.5 Ib/day per District policy)

co 0.36 0.15 0.583 0.033 0.15 0.0’

NMHC 0.0014 0.0014 0.0 0.005 0.005 0.0

sox 0.0006 0.0006 0.0 1 .o 1.0 0.0

PMlO 0.005 0.005 0.0 0.14 0.11 0.214

HAPE (Fuel Oil, Per Boiler):

NOx = (111 MMBTU/hr)(24 hr/day)(0.62 Ib/MMBTU)(l-0.0) = 1651.7 Ib/day CO = (111 MMBTU/hr)(24 hr/day)(0.033 Ib/MMBTU)(l-0.0) = 87.9 Ib/day NMHC = (111 MMBTU/hr)(24 hr/day)(0.005 lb/MMBTU)(l-0.0) = 13.3 Ib/day SOX = (111 MMBTU/hr)(24 hr/day)(l.O Ib/MMBTU)(l-0.0) = 2664.0 Ib/day PMlO = (111 MMBTU/hr)(24 hr/day)(0.14 lb/MMBTU)(1-0.214) = 293.1 Ib/day

IPE (Fuel Oil, Per Boiler): NOx = 1651.7 Ib/day - 1651.7 lblday = 0.0 Ib/day CO = 399.6 lblday - 87.9 Ib/day = 311.7 Ib/day NMHC = 13.3 lb/day - 13.3 lblday = 0.0 Ib/day SOX = 2664.0 lb/day - 2664.0 Ib/day = 0.0 Ib/day PMlO = 293.0 Ib/day - 293.1 Ib/day = 0.0 lb/day'

1. Does not equal zero because of emission factor calculation round off.

11

IPE For Inclusion In The NSR Balance (Each Boiler):

Pollutant

NOx

co NMHC

Where PEBcforc = PEPM And PEAflcr = PE

PEPM (#6 Fuel Oil) PEPM (Nat. Gas) PEPM (Worst Case) (lb/day) (Iblday) (Ib/day)

1651.7 569.5 1651.7

87.9 916.3 976.3

13.3 3.8 13.3

PMlO

-sox- - 1 2664.0 I 1.6 I 2664.0 II 373.0 13.6 373.0

12

Natural Gas Usage ThermsIQtr (Ib/Qtr) (BTU/Qtr)


Natural Gas HAE

1,142,238 NOx: 23,987

CO: 41,121 NMHC: 160 PM10: 571

15,234 NOx: 320

CO: 548 NMHC: 2 PM10: 8

(114,223.8 X 10') SOX: 69

(1,523.4 X 10') sox : 1

Qtr

1

2

3

4

Fuel Oil Usage Therms/Qtr (BTU/Qtr)


2,277 ~ 880 (227,788.0 X lo6) '

3,267,562 (326,756.2 X 10')

_____

1,236,341 (123,634.1 X lo6)

1,707,673 (170,767.3 X lo6)

NOx: 25,963 sox : 74 CO: 44,508 NMHC: 173 PM10: 618

NOx: 35,861 1,615,796 sox: 102 161,579.6 X 10') CO: 61,476 NMHC: 239 PM10: 854

1,833,790 (183,379.0 X IO')

Fuel Oil HAE (IblQtr)

NOx: 141,229 SOX: 227,788 CO: 7,517 NMHC: 1,139 PM10: 31,890

NOx: 202,589 SOX: 326,756 CO: 10,783 NMHC: 1,634 PM10: 45.746

~~~

NOx: 113,695 SOX: 183,379 CO: 6,052 NMHC: 917 PM10: 25.673

NOx: 100,179 SOX: 161,580 CO: 5,332 NMHC: 808 PMlO: 22,621

13

. . .

Newark Sierra will be installing a control device to control emissions while firing on natural gas. They will be reducing #6 fuel oil combustion contaminant emissions by reducing it's use. Therefore AER will be calculated utilizing the following equations:

AER (Natural Gas): HAE * CE (Rule 2201 Section 6.5.2)


Newark Sierra has stated that they wish to retain the right to bum #6 fuel oil seven days per year for emergency purposes (application package, Section 4). It is not known which quarter the fuel oil will be burned in therefore all four quarters will be corrected to reflect seven days of fuel oil usage.


BTU Rating: Each boiler will be limited to 2664 MMBTUlday of #6 fuel oil usage therefore the combined allowable #6 fuel oil usage, for both boilers combined, will be 5328 MMBTU/day .

PE,,,(fuel oil) = (7 days/qtr)(5328 MMBTU/day)(0.62 1blMMBTU) = 23,123.5 lblqtr PE,,,(fuel oil) = (7 days/qtr)(5328 MMBTU/day)(l .O Ib/MMBTU) = 37,296.0 lb/qtr PE,,(fuel oil) = (7 days/qtr)(5328 MMBTU/day)(O. 15 Ib/MMBTU) = 5,594.4 Ib/qtr PE,,,,(fuel oil) = (7 days/qtr)(5328 MMBTU/day)(O.OOS Ib/MMBTU) = 186.5 Ib/qtr PE,,,(fuel oil) = (7 days/qtr)(5328 MMBTU/day)(O. 11 Ib/MMBTU) = 4102.6 lb/qtr

AER = (HAE * CE)~at.cj, + (HAE - PEh, FUCI oil

Quarter 1: AER (NOX) = (23,987 lb)(0.826) + (141,229 Ib - 23,123.5 Ib) = 137,919 Ib AER (SOX) = (69 Ib)(O) + (227,788 Ib - 37,296.0 Ib) = 190,492 Ib AER (CO) = (41,121 lb)(0.583) + (7,517 Ib - 5,594.4 Ib) = 25,896 Ib AER (NMHC) = (160 Ib)(O) + (1,139 Ib - 186.5 Ib) = 953 Ib AER (PM10) = (571 Ib)(O) + (31,890 Ib - 4,102.6 lb) = 27,787 Ib

Quarter 2: AER (NOx) = (320 lb)(0.826) + (202,589 Ib - 23,123.5 Ib) = 179,730 Ib AER (SOX) = (1 Ib)(O) + (326,756 Ib - 37,296.0 Ib) = 289,460 Ib AER (CO) = (548 1b)(0.583) + (10,783 Ib - 5,594.4 Ib) = 5,508 Ib AER (NMHC) = (2 Ib)(O) + (1,634 Ib - 186.5 lb) = 1,448 lb AER (PM10) = (8 Ib)(O) + (45,746 lb - 4,102.6 Ib) = 41,643 Ib

14

Quarter 3: AER (NOX) = (25,963 lb)(0.826) + (113,695 Ib - 23,123.5 Ib) = 112,017 Ib AER (SOX) = (74 Ib)(O) + (183,379 Ib - 37,296.0 Ib) = 146,083 Ib AER (CO) = (44,508 1b)(0.583) + (6,052 Ib - 5,594.4 Ib) = 26,406 Ib AER (NMHC) = (173 Ib)(O) + (917 Ib - 186.5 Ib) = 731 Ib AER (PM10) = (618 Ib)(O) + (25,673 - 4,102.6 lb) = 21,570 Ib

Quarter 1 (W

NOx 137,919

sox 190,492

co 25,896

' Quarter 2 Quarter 3 Quarter 4 ( W ( W (W

179,730 112,017 106,677

289,460 146,083 124,284

5,508 26,406 35,578

NMHC

PMlO

15

953 1,448 73 1 622

27,787 41,643 21,570 18,518