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Notice of Construction Application

ECY 070-410 (Rev. 03/2018) of 6

Pacific NW Farmers Co-op

Rosalia Grain Terminal

Permit Modification

A notice of construction permit is required before installing a new source of air pollution or

modifying an existing source of air pollution. This application applies to facilities in

Ecology’s jurisdiction. Submit this application for review of your project. For general

information about completing the application, refer to Ecology Forms ECY 070-410a-g,

“Instructions for Ecology’s Notice of Construction Application.”

Ecology offers up to 2 hours of free pre-application help. We encourage you to schedule a

pre-application meeting with the contact person specified for the location of your proposal

(see below). For more help than the initial 2 free hours, submit Part 1 of the application and

the application fee. You may schedule a meeting with us at any point in the process.

Completing the application, enclose it with a check for the initial fee and mail to:

To request ADA accommodation, call (360) 407-6800, 711 (relay service), or 877-833-6341 (TTY).

Check the box for the location of your proposal. For help, call the contact listed below.

Ecology Permitting Office Contact

CRO

Chelan, Douglas, Kittitas, Klickitat, or Okanogan County

Ecology Central Regional Office – Air Quality Program

Lynnette Haller

(509) 457-7126

[email protected]

ERO

Adams, Asotin, Columbia, Ferry, Franklin,

Garfield, Grant, Lincoln, Pend Oreille, Stevens,

Walla Walla, or Whitman County

Ecology Eastern Regional Office – Air Quality Program

Karin Baldwin

(509) 329-3452

[email protected]

NWRO

San Juan County

Ecology Northwest Regional Office – Air Quality Program

Dave Adler

(425) 649-7267

[email protected]

IND

Kraft and Sulfite Paper Mills and Aluminum Smelters

Ecology Industrial Section – Waste 2 Resources Program

Permit manager: ____________________________________

James DeMay

(360) 407-6868

[email protected]

NWP

U.S. Department of Energy Hanford Reservation

Ecology Nuclear Waste Program

Lilyann Murphy

(509) 372-7951

[email protected]

WA Department of Ecology

Cashiering Unit

P.O. Box 47611

Olympia, WA 98504-7611

For Fiscal Office Use Only:

001-NSR-216-0299-000404

mailto:[email protected]






ECY 070-410 (Rev. 03/2018) of 6

Check the box for the fee that applies to your application.

New project or equipment

$1,500: Basic project initial fee covers up to 16 hours of review

$10,000: Complex project initial fee covers up to 106 hours of review

Change to an existing permit or equipment

$200: Administrative or simple change initial fee covers up to 3 hours of review

Ecology may determine your change is complex during completeness review of your application. If

your project is complex, you must pay the additional $675 before we will continue working on your

application.

$875: Complex change initial fee covers up to 10 hours of review

$350 flat fee: Replace or alter control technology equipment (WAC 173-400-114)

Ecology will contact you if we determine your change belongs in another fee category. You must

pay the fee associated with that category before we will continue working on your application.

Read each statement, then check the box next to it to acknowledge that you agree.

The initial fee you submitted may not cover the cost of processing your application. Ecology will

track the number of hours spent on your project. If the number of hours Ecology spends exceeds

the hours included in your initial fee, Ecology will charge you $95 per hour for the extra time.

You must include all information in this application. Ecology may not process your application if it

does not include all the information requested.

Submittal of this application allows Ecology staff to inspect your facility.


ECY 070-410 (Rev. 03/2018) of 6

Part 1: General Information

I. Project, Facility, and Company Information

1. Project Name

NOC Modification - Grain Receiving

2. Facility Name

Rosalia Grain Terminal

3. Facility Street Address

5851 SR 271, Rosalia, WA 99170

4. Facility Legal Description

West Half of Section 31, Township 20N, Range 44E

5. Company Legal Name (if different than Facility Name)

Pacific Northwest Farmers Cooperative, Inc.

6. Company Mailing Address (street, city, state, zip)

P.O. Box 271, Colfax, WA 99111

II. Contact Information and Certification

1. Facility Contact Name (who will be on-site)

Keith Becker

2. Facility Contact Mailing Address (if different than Company Mailing Address)

3. Facility Contact Phone Number

509-397-4381 (office) or 509-595-8262 (cell)

4. Facility Contact Email

[email protected]

5. Billing Contact Name (who should receive billing information)

Keith Becker

6. Billing Contact Mailing Address (if different than Company Mailing Address)

7. Billing Contact Phone Number

509-397-4381

8. Billing Contact Email

[email protected]

9. Consultant Name (optional – if 3rd party hired to complete application)

Beth Hodgson, PE

10. Consultant Organization/Company

Spring Environmental, Inc.

11. Consultant Mailing Address (street, city, state, zip)

1011 N. Cedar St., Spokane, WA 99201

12. Consultant Phone Number

509-328-7500

13.Consultant Email

[email protected]

14. Responsible Official Name and Title (person responsible for project policy or decision-making)

Keith Becker, Operations Manager

15. Responsible Official Mailing Address

P.O. Box 271, Colfax, WA 99111

16. Responsible Official Phone

509-397-4381 (office) or 509-595-8262 (cell)

17. Responsible Official Email

[email protected]

18. Responsible Official Certification and Signature I certify that the information on this application is accurate and complete.

Signature ____________________________________________________________ Date____________________

keith

Placed Image

keith

Typewriter

6-19-2019


ECY 070-410 (Rev. 03/2018) of 6

Part 2: Technical Information

The Technical Information may be sent with this application to the Ecology Cashiering Unit,

or may be sent directly to the appropriate Ecology office along with a copy of this application.

For all sections, check the box next to each item as you complete it.

III. Project Description

Attach the following to your application:

Description of your proposed project Appendix A

Projected construction start and completion dates Construction complete – modification only

Operating schedule and production rates Appendix B

List of all major process equipment with manufacturer and maximum rated capacity Already on

file

Process flow diagram with all emission points identified Appendix A

Plan view site map Appendix A

Manufacturer specification sheets for major process equipment components Already on file

Manufacturer specification sheets for pollution control equipment Already on file

Fuel specifications, including type, consumption (per hour and per year), and percent sulfur NA

IV. State Environmental Policy Act (SEPA) Compliance

Check the appropriate box below.

SEPA review is complete.

Include a copy of the final SEPA checklist and SEPA determination (e.g., DNS, MDNS,

EIS) with your application. Already on file

SEPA review has not been conducted.

If SEPA review will be conducted by another agency, list the agency. You must

provide a copy of the final SEPA checklist and SEPA determination before Ecology

will issue your permit.

Agency Reviewing SEPA:

_________________________________________________________________

If SEPA review will be conducted by Ecology, fill out a SEPA checklist and submit it

with your application. You can find a SEPA checklist online at

www.ecology.wa.gov/Regulations-Permits/SEPA/Environmental-reviews/SEPA-

document-templates


ECY 070-410 (Rev. 03/2018) of 6

V. Emissions Estimations of Criteria Pollutants

Does your project generate air pollutant emissions? Yes No Appendix B

If yes, provide the following information about your air pollutant emissions:

Air pollutants emitted, such as carbon monoxide (CO), lead (Pb), nitrogen dioxide (NO2), ozone

(O3), and volatile organic compounds (VOC), particulate matter (PM2.5, PM10, TSP), sulfur

dioxide (SO2)

Potential emissions of criteria air pollutants in tons per hour, tons per day, and tons per year

(include calculations)

Fugitive air pollutant emissions – pollutant and quantity

VI. Emissions Estimations of Toxic Air Pollutants

Does your project generate toxic air pollutant emissions? Yes No

If yes, provide the following information about your toxic air pollutant emissions:

Toxic air pollutants emitted (specified in WAC 173-460-1501)

Potential emissions of toxic air pollutants in pounds per hour, pounds per day, and pounds per

year (include calculations)

Fugitive toxic air pollutant emissions - pollutant and quantity

VII. Emission Standard Compliance NA

Does your project comply with all applicable standards identified? Yes No

Provide a list of all applicable new source performance standards, national emission standards

for hazardous air pollutants, national emission standards for hazardous air pollutants for source

categories, and emission standards adopted under the Washington Clean Air Act, Chapter 70.94

RCW.

VIII. Best Available Control Technology

Provide a complete evaluation of Best Available Control Technology (BACT) for your

proposal. Appendix C

1 http://apps.leg.wa.gov/WAC/default.aspx?cite=173-460-150

http://apps.leg.wa.gov/WAC/default.aspx?cite=173-460-150

http://apps.leg.wa.gov/WAC/default.aspx?cite=173-460-150


ECY 070-410 (Rev. 03/2018) of 6

IX. Ambient Air Impacts Analyses

Does your project cause or contribute to a violation of any ambient air quality standard or

acceptable source impact level? Yes No Appendix D

Provide the following:

Ambient air impacts analyses for criteria air pollutants (including fugitive emissions)

Ambient air impacts analyses for toxic air pollutants (including fugitive emissions) NA

Discharge point data for each point included in ambient air impacts analyses (include only if

modeling is required) Appendix D

Exhaust height

Exhaust inside dimensions (diameter or length and width)

Exhaust gas velocity or volumetric flow rate

Exhaust gas exit temperature

Volumetric flow rate

Discharge description (i.e., vertically or horizontally) and if there are any obstructions (e.g.,

raincap)

Emission unit(s) discharging from the point

Distance from the stack to the nearest property line

Emission unit building height, width, and length

Height of tallest building on-site or in the vicinity, and the nearest distance of that building to the

exhaust

Facility location (urban or rural)

Rosalia Grain Terminal June 18, 2019

NOC Application – Grain Receiving Modification Appendix A

APPENDIX A

PROJECT DESCRIPTION


NOC Application – Grain Receiving Modification Appendix A-1

Project Description Pacific Northwest Farmers Cooperative Rosalia Grain Terminal

Introduction

Pacific Northwest Farmers Cooperative, Inc. (PNW) operates a shuttle train loading facility at 5851

State Route 271 near Rosalia, Washington. The facility operates under Approval Orders 11AQ-E445

and 18AQ-E027 and includes a shipping and receiving facility, a wheat and barley grain handling and

distribution system, silo bins, hopper bottom bins, grain storage piles, and receiving pits for the piles.

Summary of Approval Orders

Approval Order No. 11AQ-E445 was issued to McCoy Grain Company March 3, 2012 for the

original shuttle terminal to receive grain via rail and hopper truck and ship grain via shuttle train; the

terminal consisted of the shipping and receiving facility, distribution system, three grain silo bins, and

three hopper bottom bins. Approval Order No. 18AQ-E027 was issued July 12, 2018 to add two

additional receiving pits, four piles for temporary storage, and associated handling equipment.

Prior to issuance of the second approval order, operation of the terminal was transferred from McCoy

Grain Company to PNW Farmers Co-op.

Project Proposal

Under Approval Orders 11AQ-E445 and 18AQ-E027, only hopper trucks are to be used for grain

delivery. PNW Farmers Co-op would like to modify condition 1.3 of Approval Order 18AQ-E027 to

allow both hopper trucks and straight trucks to be used for receiving. Furthermore, PNW would also

like to modify conditions 1.6 and 1.7 of Approval Order 18AQ-E027 so that a maximum opacity limit

of 20% is used for both conditions, per WAC 173-400-040 (2).

Based on potential emissions of particulate matter smaller than 10 microns (PM10) and smaller than

2.5 microns (PM2.5) for the grain receiving operations exceeding the exemption threshold in WAC

173-400-110, an NOC modification is required. A modeling report demonstrating compliance with

National Ambient Air Quality Standards is included in Appendix D.

Process Flow

Figure 1 illustrates the process flow for operations at the terminal. Emission sources from these

operations are described in the next section.


NOC Application – Grain Receiving Modification Appendix A-2

Figure 1

Rosalia Grain Terminal June 18, 2019 March 19, 2019

NOC Application – Grain Receiving Modification Appendix A-3 Appendix A-3

Emission Sources

Emission sources for the facility’s operations include receiving pits, grain drops, pile unloading, and

pile storage. Due to facility observations and the fact that they are enclosed, conveyors are not

considered emission sources. Receiving occurs by train or truck in the enclosed shuttle train facility

and by truck at two outdoor receiving pits. Grain drops occur at storage piles or into grain conveyance

systems. Piles are unloaded using frontend loaders, which dump grain into a portable hopper and

conveyor, which convey the grain to the shuttle train facility. Figure 2 provides a bird’s-eye view of

the original shuttle train facility, its storage pile locations, and locations the portable hopper is used.

Figure 2


NOC Application – Grain Receiving Modification Appendix B

APPENDIX B

EMISSION CALCULATIONS

Pacific Northwest Farmers Cooperative Grain TerminalEmissions Summary

Emissions (lb/hr)

Receiving Handling 1 Shipping 2 Traffic Fugitives StorageOriginal Terminal

(increase)Total

PM10 6.20E+00 3.74E-02 3.42E-03 2.9 14.8 0.4 24PM2.5 1.04E+00 6.38E-03 5.81E-04 0.3 2.2 0.1 3.6

Emissions (lb/yr)


(increase)Total

PM10 1.40E+03 4.91E+03 1.07E+01 347 14.8 3.32E+03 9996PM2.5 2.37E+02 8.37E+02 1.81E+00 34.7 2.2 5.64E+02 1676

Emissions (tpy)


(increase)Total

WAC 173-400 Threshold

Modeling Required

PM10 6.99E-01 2.45E+00 5.34E-03 1.74E-01 7.38E-03 1.66 5.0 0.75 YesPM2.5 1.18E-01 4.19E-01 9.07E-04 1.74E-02 1.12E-03 0.28 0.8 0.5 Yes

1) Handling emissions include emissions from pile drop (4), and grain transfers to shipping facility.

2) Shipping emissions include emissions from pile unloading to hoppers (3).

Rosalia Grain Terminal NOC Application - Grain Receiving Modification

June 18, 2019Page B-1

Pacific Northwest Farmers Cooperative Grain TerminalStorage Piles - Facility Info

Facility InformationAs submitted with NOC 18AQ-E027

Production:Grain: 4,800,000 bushels/year = 144,000 tpyOperations: 3120 hours/yr (12 hours per day, 5 days per week, 52 weeks per year)Storage: 8760 hours/yr

Throughput: Maximum MaximumMaximum Receiving Rate (2 pits): 20,000 bushels/hr/pit 2,400,000 lb/hr 14,400 tpd * 1 bushel = 60 lbsMaximum Handling Rate: 4,800,000 lb/hr 28,800 tpd

Pile Conveyors (2) 20,000 bushels/hr/pit 2,400,000 lb/hr1-2 Crossover Conveyor 20,000 bushels/hr 1,200,000 lb/hr1-2 Bucket Elevator 20,000 bushels/hr 1,200,000 lb/hr3-4 Drag Conveyor 20,000 bushels/hr 1,200,000 lb/hrPile Drop (4) 20,000 bushels/hr/pile 1,200,000 lb/hr

Maximum Shipping Rate: 2,400,000 lb/hr 28,800 tpd

Storage:Grain Piles (4): 1,200,000 bushel/pile 144,000 tons

Traffic:0.2 miles/trip (Average of increase in driving distance between existing receiving pit and 2 new receiving pits)



Pacific Northwest Farmers Cooperative Grain TerminalOriginal Terminal Emissions

Shuttle Train Grain Loading FacilityCalculations from NOC AQ11-E455. Yellow highlight indicates modification for including straight trucks.

1,282,979 bushel grain elevator for receiving and loading shuttle trains for wheat and barleyIncludes:

Truck receiving pitRailcar receiving pit40,000 bph receiving belt conveyor (totally enclosed)40,000 bph receiving bucket elevator4 x 40,000 bph receiving upper belt conveyors (totally enclosed)Upper drag conveyor (totally enclosed)2 x 60,000 bph loadout belt conveyors (totally enclosed)60,000 bph shipping bucket elevator to a bulk weighing scale

I. Uncontrolled Emissions Calculations

Truck Receiving (Straight Truck & Hopper Truck)360,000 tons/yr throughput

AP-42 Emissions factor (9.9-1)0.002866 lbs/ton (PM2.5-scaled by truck mix) 0.017016 lbs/ton (PM10-scaled by truck mix) Uncontrolled Emissions Increase

1,032 lbs/yr PM2.5 (scaled by truck mix) 6,126 lbs/yr PM10 (scaled by truck mix) PM2.5 564 (lbs/yr) PM10 3,318 (lbs/yr)468 lbs/yr PM2.5 (Hopper only) 2,808 lbs/yr PM10 (Hopper only)

Fugitive Emissions at 80% Control Efficiency (assuming 80% emissions go to baghouse) Enclosure Control Emissions Increase206 lbs/yr PM2.5 (scaled by truck mix) 1,225 lbs/yr PM10 (scaled by truck mix) PM2.5 113 (lbs/yr) PM10 664 (lbs/yr) Fugitive94 lbs/yr PM2.5 (Hopper only) 562 lbs/yr PM10 (Hopper only) PM2.5 1 (lbs/yr) PM10 7 (lbs/yr) Controlled by Baghouse

Grain Handling Conveyors, 2 Bucket Elevators, 4 Enclosed Belt Conveyors, and Enclosed Drag Conveyor720,000 tons/yr throughput

AP-42 Emissions factor (9.9-1)0.0058 lbs/ton (PM2.5) 0.034 lbs/ton (PM10)4,176 lbs per year PM2.5 24,480 lbs per year PM10

Storage Bin Vents (6 Tanks)360,000 tons/year bin filling throughput

AP-42 Emissions factor (9.9-1)0.0011 lbs/ton (PM2.5) 0.0063 lbs/ton (PM10)

396 lbs per year PM2.5 2,268 lbs per year PM10

Rail Shipping360,000 tons/year loadout from rail receiving hopper

AP-42 Emissions factor (9.9-1)0.00037 lbs/ton (PM2.5) 0.0022 lbs/ton (PM10)

133 lbs per year PM2.5 792 lbs per year PM10

Truck Shipping360,000 tons/year loadout from rail receiving hopper

AP-42 Emissions factor (9.9-1)0.0049 lbs/ton (PM2.5) 0.029 lbs/ton (PM10)1,764 lbs per year PM2.5 10,440 lbs per year PM10

Truck Dust Bin LoadoutLoadout Spout: 15 gr/acf x 1 lbs / 7,000 grains x 32,000 acf/min x 60 min/hr x 8760 hrs/yr

18,021 tons of dust from dust filterAP-42 Emissions factor (9.9-1)

0.0049 lbs/ton (PM2.5) 0.029 lbs/ton (PM10)88.3 lbs per year PM2.5 523 lbs per year PM10

Total Uncontrolled Potential Fugitive PM2.5 Dust Emissions3.79 tons/yr PM2.5 22.3 tons/yr PM10

Total Emissions from Storage Bin Vents, Truck Dust Bin & Truck Shipping:1.12 tons/yr PM2.5 6.6 tons/yr PM10

Total Fugitive Emissions from Dust Collection Points at 80% Collection Efficiency:0.45 tons/yr PM2.5 2.6 tons/yr PM10

II. Baghouse Emissions

32,000 cfm Baghouse Filter (Receiving, Conveying, and Shipping is Aspirated to Baghouse Filter)8760 hrs/yr

720,000 tons throughput0.005 gr/acf filter exhaust loading per test on comparable system

120 tons/hr throughput6.01 tons/yr PM

Total Controlled Baghouse Emissions6.01 tons/yr PM2.5 6.01 tons/yr PM10

III. Total PM2.5 & PM10 EmissionsTotal Controlled PM2.5 Emissions

7.6 tons/yr PM2.5 15.3 tons/yr PM10

Rosalia Grain TerminalNOC Application - Grain Receiving Modification


Pacific Northwest Farmers Cooperative Grain TerminalStorage Piles - Grain Handling

Receiving, Handling, and ShippingUpdated from submittal for NOC 18AQ-E027

Source Pollutant

Emission

Factor 1Emission

Factor Units lb/hr lb/day lb/yr tpy Emission ControlControl

Efficiency lb/hr lb/day lb/yr tpy

PM10 0.017016 lb/ton 20.4 245.0 2450.3 1.23Below ground, baffled

pit, choke flow 2 70% 6.13E+00 7.35E+01 7.35E+02 0.37

PM2.5 0.002866 lb/ton 3.4 41.3 412.7 0.21Below ground, baffled

pit, choke flow 2 70% 1.03E+00 1.24E+01 1.24E+02 0.06

PM10 3.42E-03 lb/hr 3.42E-03 4.10E-02 10.7 0.01 Perforated Tube 0% 3.42E-03 4.10E-02 1.07E+01 0.01

PM2.5 5.81E-04 lb/hr 5.81E-04 6.98E-03 1.8 0.00 Perforated Tube 0% 5.81E-04 6.98E-03 1.81E+00 0.00

PM10 3.42E-03 lb/hr 3.42E-03 4.10E-02 10.7 0.01 None 0% 3.42E-03 4.10E-02 1.07E+01 0.01

PM2.5 5.81E-04 lb/hr 5.81E-04 6.98E-03 1.8 0.00 None 0% 5.81E-04 6.98E-03 1.81E+00 0.00

PM10 0.034 lb/ton 3.40E-02 4.08E-01 4896.0 2.45 None 0% 3.40E-02 4.08E-01 4.90E+03 2.45

PM2.5 0.0058 lb/ton 5.80E-03 6.96E-02 835.2 0.42 None 0% 5.80E-03 6.96E-02 8.35E+02 0.42

1) Emission factors from AP-42 Table 9.9.1-1 (May 2003), except pile drop. Emission factors for receiving are weighted by truck type (straight or hopper).

PM10 Pile drop, and hopper dump emissions calculated using 400 grains/scfm (excessively dusty air - per Perry's Chemical Engineering Handbook, 6th edition page 20-105 for PM10.)

Assuming 17% of PM10 emissions are PM2.5 because that is the case for all other Handling emission sources in this table.

2) Control efficiency based on comparable baffling equipment ( https://www.ce-grp.com/mideco-dust-control-pty-ltd/burnley-baffles-for-dust-suppression/ ).

Source PollutantEmission

Factor 1Emission

Factor UnitsCorresponding

Percentage of Trucks2

PM10 0.059 lb/tonPM2.5 0.01 lb/tonPM10 0.0078 lb/tonPM2.5 0.0013 lb/ton

1) Emission factors from AP-42 Table 9.9.1-1 (May 2003)

2) Assuming 600 bushels in a straight truck, and 1200 bushels in a hopper truck

Receiving - Straight Truck

Receiving - Hopper Truck

Percentage of Bushels by

Receiving Traffic

18%

82%

Handling (Grain Drop to

Shipping)

Uncontrolled Emissions Controlled Emissions

Receiving (Straight Truck &

Hopper Truck)

Frontend Loader (Dump to Hopper)

Handling (Grain Pile Drop)

Corresponding

Number of Trucks2

1440

3280

31%

69%



Pacific Northwest Farmers Cooperative Grain TerminalStorage Piles - Grain Storage

Storage Piles - Wheat and BarleyAs submitted with NOC 18AQ-E027

Source Pollutant

Emission Factor

(lb/ton) 1 lb/hr lb/yr tpy lb/hr lb/yr tpy

PM10 1.03E-03 147.64 147.64 7.38E-02 14.76 14.76 7.38E-03PM2.5 1.55E-04 22.36 22.36 1.12E-02 2.24 2.24 1.12E-03

1) Emissions generated by storage piles (including drop operation) are estimated using the following equation: E (lb/ton) = k (0.0032) (U/5)1.3/(M/2)1.4;

where k = particle size multiplier, U = mean wind speed, M - material moisture content (AP-42, Chapter 13, 13.2.4)k PM10 0.35

PM2.5 0.053

U (mph) 23.6 (per usa.com website for Cheney, WA)

M-wheat/barley(%) 9 (facility-specific estimate)

2) Emission control efficiency for pile covers: 90%

Storage Piles

Uncontrolled Emissions Controlled Emissions 2



Pacific Northwest Farmers Cooperative Grain TerminalTraffic Fugitives

Traffic FugitivesAs submitted with NOC 18AQ-E027

Source Pollutant

Emission Factor

(lb/VMT) * lb/hr lb/day lb/yr tpy

PM10 0.36 2.89 34.74 347 0.17PM2.5 0.036 0.29 3.47 35 0.017

* For vehicles traveling on unpaved surfaces at industrial sites, emissions are estimated using the following equations: E (lb/VMT) = k (s/12)a (W/3)b;

where k, a, b = empirical constants, s = mean vehicle speed (mph), W = mean vehicle weight, and Eext (lb/VMT) = E(365-P)/365 where P = # of days precipitation is at least 0.254 mm.

AP-42, Chapter 13, 13.2.2-4, Table 13.2.2-2, (November 2006)

PM10 PM2.5

k 1.5 0.15

a 0.9 0.9

b 0.45 0.45

s 10 mph

W 36 tons

Load 30 tons/truckload

P 51 (Per AP-42 Figure 13.2.2-1)

Gravel Eff 46% (Per the " WRAP Fugitive Control Handbook," dated September 7, 2006)

Dust Suppress Eff 80% (Per the " WRAP Fugitive Control Handbook," dated September 7, 2006)

Mi= 0.2 miles/trip

Veh= 480 trips/day

O= 10 days/year (equivalent number of days assuming worst case daily trips and maximum annual production)

VMT = Mi*Veh*O= 960 miles/year

Emissions

Traffic Fugitives




NOC Application – Grain Receiving Modification Appendix C

APPENDIX C

BACT ANALYSIS


NOC Application – Grain Receiving Modification Appendix C-1

BACT Analysis Pacific Northwest Farmers Cooperative Rosalia Grain Terminal

Introduction Pacific Northwest Farmers Cooperative, Inc. (PNW) operates a shuttle train loading

facility at the Rosalia Grain Terminal at 5851 State Route 271 near Rosalia, Washington.

The facility operates under Washington State Department of Ecology (Ecology) Approval

Orders 11AQ-E445 and 18AQ-E027 and includes a shipping and receiving facility, a

wheat and barley grain handling and distribution system, three grain silos, three hopper

bottom bins, and four grain storage piles. PNW is submitting a permit modification

application to allow both hopper trucks and straight trucks to be used for receiving.

Sources of emissions from the proposal include:

1. Receiving

2. Handling

3. Storage Piles

4. Pile Unloading

5. Shuttle Train Loading Facility

6. Traffic Fugitives

Regulated Emissions

Emissions of the following criteria pollutants are greater than the exemption levels of

WAC 173-400-100, Table 110(5) and will be the subject of this BACT analysis:

Particulate Matter less than 10 microns (PM10)

Particulate Matter less than 2.5 microns (PM2.5)

Selected Acronyms Used Throughout This Report

BACT – Best Available Control Technology

CFR – Code of Federal Regulations

NOC – Notice of Construction

PM10 – Particulate Matter less than 10 microns

PM2.5 – Particulate Matter less than 2.5 microns

RBLC – EPA RACT/BACT/LAER Clearinghouse

SQER – Small Quantity Emission Rate

TPY – Tons Per Year, unit of measure for emission rate

Step 1: Identify Technologies

Under the State of Washington’s New Source Review rules (“NSR”), which are

promulgated and enforced by the Washington Department of Ecology and local air quality

districts, best available control technologies (BACT) are required for construction and

modification of specified stationary sources.



BACT is defined as an emission limitation (including a visible emission standard) based on the maximum

degree of reduction for each pollutant subject to regulation under the Clean Air Act which

would be emitted from any proposed major stationary source or major modification which

the Administrator, on a case-by-case basis, taking into account energy, environmental,

and economic impacts and other costs, determines is achievable for such source or

modification through application of production processes or available methods, systems,

and techniques, including fuel cleaning or treatment or innovative fuel combustion

techniques for control of such pollutant.1

Under those analyses, control techniques for criteria pollutants may be classified into two

broad categories – (1) inherently lower emitting processes/practices and (2) emission

controls2.

Spring Environmental met with Ecology January 8, 2019 to review previous applications,

various process flow, and emission control technologies available for grain handling

facilities. The control techniques identified for control of particulate matter include:

1. Receiving

a. Below ground baffled receiving pit

b. Enclosure

c. Enclosure with baghouse/dust collector/cyclone/ESP/scrubber

d. Dust suppression: water fogging, oil control

2. Handling

a. Flow control

b. Enclosed conveyors

c. Enclosed conveyors with baghouse/dust collector/cyclone/ESP/scrubber


3. Storage Piles

a. Flow control: perforated tube

b. Pile covers: tarps

c. Dust suppression: water fogging, oil control

4. Pile Unloading

a. Flow control for loading

b. Dust suppression: water fogging, oil control

c. Minimize drop height


a. Flow control for loading

b. Enclosure

c. Enclosure with baghouse/dust collector/cyclone/ESP/scrubber


e. Enclosed conveyors

1 “New Source Review Workshop Manual”, DRAFT October 1990, Section I.

2 “New Source Review Workshop Manual”, DRAFT October 1990, Section IV.A.




a. Gravel roads

b. Gravel roads with dust suppression: water or chemical spray

c. Vacuum sweeper

d. Best management practices

Step 2: Infeasible Options

An electrostatic precipitator (1c, 2c, 5c) is infeasible due to the

flammable/explosive potential of grain dust.

A cyclone (1c, 2c, 5c) is infeasible for this process due to low particulate loading.

A wet scrubber (2c) is ineffective for Handling Operations because the grain is

wet from the insecticide that is currently applied using water.

A wet scrubber (1c, 5c) is infeasible for Shipping and Receiving operations due to

low particulate loading.

Using mineral oil for dust suppression (1d, 2d, 3c, 4b, 5d) would reduce the

efficacy of the insecticide that is currently applied on the conveyor using water.

There is no other process step where mineral oil could be applied evenly.

Furthermore, oil application is more effective after given time to soak in.

Baghouses and enclosures are not feasible for Pile Unloading (4c). Pile Unloading

is performed using a tractor to haul grain from the piles to a rented hopper and 36-

inch open conveyor that feeds to an enclosed conveyor to the existing shipping

facility. The enclosed conveyor is controlled by an existing baghouse in the

shipping facility.

Step 3: Effectiveness Ranking

According to the 1990 Draft New Source Review Manual, feasible technologies are next

ranked by the degree of reduction (i.e. “% reduction”). The potential to emit per the NOC

application is 27.7 tpy of PM10 and 4.6 tpy of PM2.5.

1. Receiving

Type of Control Control

Technique Ref. % Reduction

Potential

Emissions PM10

(tpy)

Potential

Emissions PM2.5

(tpy)

Enclosure with Baghouse 1c 99% 1.23E-2 2.1E-3

Enclosure 1b 75% 0.31 5.3E-2

Below Ground Baffled

Receiving Pit with STET 1a 70% 0.37 6.3E-2

Water Fogging 1d 62% 0.47 8.0E-2

None -- 0% 1.23 0.21



2. Handling



Potential

Emissions PM10

(tpy)

Potential

Emissions PM2.5

(tpy)

Enclosed Conveyors with

Baghouse 2c 99% 2.45E-2 4.2E-3

Enclosed Conveyors 2b 95% 0.12 2.1E-2

Water Fogging 2d 62% 0.93 0.16

Flow Control 2a 50% 1.23 0.21

None -- 0% 2.45 0.42

3. Storage Piles



Potential

Emissions PM10

(tpy)

Potential

Emissions PM2.5

(tpy)

Pile Cover 3b 90% 7.4E-3 1.1E-3

Water Fogging 3c 62% 2.8E-2 4.2E-3

Perforated Tube 3a 50% 3.7E-2 5.5E-3

None -- 0% 7.4E-2 1.1E-2

4. Pile Unloading



Potential

Emissions PM10

(tpy)

Potential

Emissions PM2.5

(tpy)

Water Fogging 4b 62% 2.0E-3 3.5E-4

Flow Control 4a 50% 2.7E-3 4.6E-4

Minimize Drop Height 4c 50% 2.7E-3 4.6E-4

None -- 0% 5.3E-3 9.1E-4




Potential

Emissions PM10

(tpy)

Potential

Emissions PM2.5

(tpy)

Enclosure with Baghouse 5c 99% 0.22 3.8E-2

Enclosed Conveyors 5e 95% 1.1 0.19

Enclosure 5b 75% 5.6 0.95

Water Fogging 5d 62% 8.5 1.4

Flow Control 5a 50% 11.2 1.9

None -- 0% 22.3 3.8






Potential

Emissions PM10

(tpy)

Potential

Emissions PM2.5

(tpy)

Gravel Roads with

Chemical Dust Suppressant 6b 80% 0.32 3.2E-2

Gravel Roads with Water

Spray 6b 55% 0.72 7.2E-2

Gravel Roads 6a 46% 0.86 8.6E-2

Best Management Practices 6d 44% 0.90 9.0E-2

Vacuum Sweeper 6c 16% 1.3 0.13

None -- 0% 1.6 0.16

Step 4: BACT Cost Analysis

The emission control technology selected for Storage Piles is a pile cover; the emission

control technology selected for Pile Unloading is minimizing the drop height from the

front end loaders and flow control on the hopper and first conveyor; the emission control

technology selected for the Shuttle Train Unloading Facility is a baghouse and enclosure;

and the emission control technology selected for Traffic Fugitives is chemical dust

suppressant on gravel roads. These selected control technologies have the highest

emission reduction potential. Therefore, cost analysis was only performed for Receiving

and Handling operations.

Greater control efficiency can be achieved using a baghouse or dust collector for

Receiving and Handling operations. With baghouse or dust collector control, total

emissions for the operations would be 3.7E-2 tpy PM10 and 6.3E-3 tpy PM2.5, a reduction

of 3.6 tpy PM10 and 0.62 tpy PM2.5 over uncontrolled emissions.

The costs were provided as defined below assuming an equipment life of 10 years and an

interest rate of 7%. Annual labor costs were calculated using EPA’s Cost Control Manual

and wages from the U.S. Bureau of Labor Statistics.

A quote was obtained from Baxter Air Engineering for Donaldson Torit dust collectors:

one baghouse for each receiving pit, and one dust collector for each pile tube, a total of six

units. Annual operating costs were calculated based on predicted power usage and current

utilities rates in Rosalia, WA. Cost calculations for a baghouse from the Air Pollution

Control Textbook are included for comparison. The detailed cost analysis is included in

Attachment 1.

The cost for a 10,000 cfm Donaldson Torit baghouse was obtained from a brochure to just

control emissions from the receiving pits. The detailed cost analysis is included in

Attachment 1.



Control Technology Capital

Cost

Annual

O&M

Costs

Annualized

Cost3

Cost per Ton

PM10

Removed

Cost per Ton

PM2.5 Removed

Donaldson Co. Torit

CPV & MBT Dust

Collectors4

$247,000 $279,000 $314,000 $87,000 $507,000

Baghouse from Air

Pollution Control Book $1350,000 $279,000 $471,000 $131,000 $760,000

Donaldson Torit for

Receiving Pits $77,900 $260,000 $271,000 $223,000 $1,303,000

Spring Environmental recommends that baghouse control is not cost effective for

Receiving and Handling combined and Receiving individually.

Step 5: BACT Recommendation

Spring Environmental recommends that BACT be defined as:

1. Receiving: 70% emissions control using below ground pit with baffles for the

Receiving pits. PM10 and PM2.5 emissions would be a maximum of 0.37 tpy

and 6.3E-2 tpy respectively with the selected technology.

2. Handling: 95% emissions control using enclosed conveyors. PM10 and PM2.5

emissions would be a maximum of 0.12 tpy and 2.1E-2 tpy respectively with

the selected technology.

3. Storage Piles: 90% emissions control using pile covers. In addition, perforated

tubes were installed per PNW. PM10 and PM2.5 emissions would be a

maximum of 7.4E-3 tpy and 1.1E-3 tpy respectively with the selected

technology.

4. Pile Unloading: 50% emissions control minimizing the drop height and

controlling flow. PM10 and PM2.5 emissions would be a maximum of 2.7E-3

tpy and 4.6E-4 tpy respectively with the selected technology.

5. Shuttle Train Loading Facility: 99% emissions control with an 80% efficient

enclosure. PM10 and PM2.5 emissions would be a maximum of 0.22 tpy and

3.8E-2 tpy respectively with the selected technology.

6. Traffic Fugitives: 80% emissions control using gravel roads with chemical

dust suppressant. PM10 and PM2.5 emissions would be a maximum of 0.32 tpy

and 3.2E-2 tpy respectively with the selected technology.

3 Assuming 10 years and 7% interest.

4 Quote from Baxter Air Engineering for Donaldson Co. Torit CPV & Dust Collectors.


NOC Application – Grain Receiving Modification Appendix D

APPENDIX D

MODELING RESULTS


NOC Application – Grain Receiving Modification Appendix D-1

Air Quality Modeling Pacific Northwest Farmers Cooperative Rosalia Grain Terminal

1. Purpose: To determine the off-site impact of PM10 and PM2.5 associated with allowing grain

delivery by straight trucks, in addition to hopper trucks. Pacific Northwest Farmers Cooperative,

Inc. (PNW) operates a grain loading facility at 5851 State Route 271 near Rosalia, Washington.

2. Applicable Regulations and Requirements: PM10 and PM2.5 air pollutant emissions are

limited by impact as defined in WAC 173-400-110. The applicable thresholds are included in

Table 1.

3. Model Description: EPA provides guidance on applicability of specific air quality dispersion

models in the review and preparation of new source permits. EPA’s Guideline of Air Quality

Models is documented in Appendix W of 40 CFR Part 51. In accordance with this guidance, the

first approach is to determine whether a conservative estimate using a screening model would be

acceptable based on site specific parameters. If the screening model using AERSCREEN is

unable to demonstrate compliance, refined modeling is performed using AERMOD.

4. Facility Layout: The facility layout and emission points are included in Appendix A of the

application package.

5. Emissions Data: Emissions estimates were developed using the emissions inventories from

the two approval orders. The increase in emissions resulting in adding straight truck grain

delivery was used for predicting the impact to the original Shuttle Train Loading Facility. Only

the receiving emissions factor changed. The total potential emissions for the grain pile NOC

were used for predicting the impact, and grain handling emissions were updated based on

recommendations from the Department of Ecology to include:

Eliminate emissions from conveyors;

Use Ecology’s calculation of 400 grains/scfm for excessively dusty air for grain

drop operations; and

Add additional emission point where grain from piles drops to Shuttle Train

Loading Facility conveyors.

Detailed emissions calculations are included in Appendix B of the application package.

Table 1: Particulate Matter Exceeding Exemption Threshold

POLLUTANT POTENTIAL TO

EMIT

EXEMPTION

THRESHOLD

EXCEEDS THRESHOLD?

(YES/NO)

PM10 5.2 tons/year 0.75 tons/year

Yes

PM2.5 0.9 tons/year 0.5 tons/year Yes

6. Source Parameters: The source parameters used in AERMOD are based on equipment

specifications, site observations, and Google Earth, and are included in Tables 2-4.



Table 2: AERMOD Point Source Parameters

POINT SOURCES HEIGHT (m) DIAMETER (m) TEMPERATURE VELOCITY (m/s)

Pile Drop (4) 16.8 0.61 Ambient 14

Shuttle Train

Loading Facility

Baghouse

3.7 1.2 Ambient 14

Pile to Ship

Transfer (2) 3 3 Ambient 14

Table 3: AERMOD Volume Source Parameters

VOLUME SOURCES HEIGHT

(m)

INITIAL LATERAL

DIMENSION (m)

INITIAL VERTICAL

DIMENSION (m)

Storage Piles (4) 21.2 7.3 4.9

Pile Receiving Pits (2) 1.5 0.7 0.7

Hopper (portable)*

3.0 1.0 1.4

Shuttle Train Loading

Facility Fugitives 39.6 14.9 9.1

* Hopper is used for pile unloading in one of three locations (see Figure 1), depending on which pile is being unloaded. Emissions are apportioned to locations based on pile capacities.

Table 4: AERMOD Area Source Parameters

AREA

SOURCE

DISTANCE

TRAVELED (m)

HEIGHT (2 x

TRUCK) (m)

DIMENSIONS

(m)

INITIAL VERTICAL

DIMENSION (m)

Traffic

Fugitives 321.9 6.1 179.8 x 198.1 2.8

Based on operating hours, emissions were scaled to daytime operations (6AM to 7PM) for

receiving, handling, traffic and shipping operations.

See pages D-6 and D-7 for UTM coordinates and emission rates for each source.



7. Buildings: Based on the limited number of buildings, and distance between sources, no building

downwash effects were included in AERMOD.

8. Receptor Network: AERMAP was used to develop a receptor grid with elevated receptors to

account for the varied terrain in the surrounding area. A flagpole receptor height of 1.5 meters was

used. The receptor grid is sufficiently narrow to provide an appropriate representation of dispersion

characteristics, with the following:

12.5-m spacing from the ambient air boundary out to 150 meters

25-m spacing from 150 to 400 meters

50-m spacing from 400 to 900 meters

100-m spacing from 900 to 2,000 meters

300-m spacing from 2,000 to 4,500 meters

600-m spacing from 4,500 to 10,000 meters

The area map is shown in Figure 1.

The ambient air boundary is the property boundary, outlined in blue in Figure 2.

Figure 1: Area Map



Figure 2: Property Boundary

9. Elevation Data: The terrain immediately surrounding the facility has low rolling hills.

AERMAP was used to extract elevation data for AERMOD given the complex terrain

surrounding the facility. Terrain data was obtained from the following website:

https://www.mrlc.gov/viewerjs/.

10. Meteorological Data: Five-year meteorological data (2014-2018) for Spokane, station ID

24517, was used for surface data. The nearest upper air station is located in Spokane at the

Spokane International Airport, site ID 04106. Data was obtained through the National Oceanic

and Atmospheric Administration (NOAA) based on the years of interest and the two site IDs.

AERMET was used to process the surface and upper-air meteorological data. Surface

meteorological data and upper air data is collected from the following websites:

ftp://ftp.ncdc.noaa.gov/pub/data/noaa and https://ruc.noaa.gov/raobs/ respectively.

One-minute ASOS data was available from 2014-2018 from the Spokane station and was used to

run AERMINUTE which outputs hourly wind data for AERMET. ASOS wind data was

collected from the following website: ftp://ftp.ncdc.noaa.gov/pub/data/asos-onemin/.

11. Land Use Classification: The area surrounding the site is rural.

12. Background Concentrations: Background values were obtained using NW AIRQUEST

tool, http://lar.wsu.edu/nw-airquest/lookup.html, on 12/5/2018. The PM10 24-hr background was

60 µg/m3. The PM2.5 24-hr background was 12 µg/m

3, and the annual background was 4.7

µg/m3.

https://www.mrlc.gov/viewerjs/

ftp://ftp.ncdc.noaa.gov/pub/data/noaa

https://ruc.noaa.gov/raobs/

ftp://ftp.ncdc.noaa.gov/pub/data/asos-onemin/

http://lar.wsu.edu/nw-airquest/lookup.html



13. Evaluation of Compliance with Standards: The modeling was conducted as described

above and compared to the National Ambient Air Quality Standards (NAAQS) to demonstrate

compliance.

The results of the refined modeling indicate that the facility will not cause an exceedance of the

NAAQS for particulate matter with 31% of deliveries from straight trucks, corresponding to 18%

of total bushels delivered. AERMOD output is included beginning on page D-8.

POLLUTANT AVERAGING PERIOD RESULTS

(µg/m3)*

BACKGROUND

(µg/m3)

TOTAL

(µg/m3) NAAQS/ASIL (µg/m3)

PM10 24-hr 85.9 60 146 150

PM2.5 24-hr 14.2 12 26 35

Annual 1.3 4.7 6 12 * Using third highest value for PM10 per National Ambient Air Quality Standards 40 CFR 50.

This Air Quality Modeling was prepared by Jenelle Scott, P.E., under the direction of Beth

Fifield Hodgson, P.E. of Spring Environmental, Inc.

Spring Environmental Inc.

1011 N. Cedar Street

Spokane, WA 99201-1914

Tel:(509) 328-7500

Fax: (509) 328-7501

Pacific Northwest Farmers Cooperative Grain TerminalModeling Inputs

Pile 1 734Pile 2 727Pile 3 728Pile 4 727

Receiving 1-2 730Receiving 3-4 732Shipping 1-2 728

Point Source Shipping 3-4 732UTM 475855.0 E 5226353.5 N 475868.8 E 5226255.6 N 475750.3 E 5226337.8 N 575765.4 E 5226239.9 N Traffic 726

Stack Height 55.0 ft 16.76 m 55.0 ft 16.76 m 55.0 ft 16.76 m 55.0 ft 16.76 m Hopper 1-2 727Stack Diameter 2.0 ft 0.61 m 2.0 ft 0.61 m 2.0 ft 0.61 m 2.0 ft 0.61 m Hopper 3 729

Stack Temperature Ambient -- -- -- Ambient -- -- -- Ambient -- -- -- Ambient -- -- -- Hopper 4 729Stack Velocity -- -- 0.67 m/s -- -- 0.67 m/s -- -- 0.67 m/s -- -- 0.67 m/s Baghouse 729

Fugitives 728

Volume SourceUTM 475855.0 E 5226353.5 N 475868.8 E 5226255.6 N 475750.3 E 5226337.8 N 475765.4 E 5226239.9 N Spacing Distance

Diameter 85.0 m -- -- 85.0 m -- -- 85.0 m -- -- 85.0 m -- -- 12.5 150Height 15.5 m -- -- 15.5 m -- -- 15.5 m -- -- 15.5 m -- -- 25 400

1/2 of height 7.8 m -- -- 7.8 m -- -- 7.8 m -- -- 7.8 m -- -- 50 900Initial Lateral Dim. 6.2 m -- -- 6.2 m -- -- 6.2 m -- -- 6.2 m -- -- 100 2000Initial Vertical Dim. 3.6 m -- -- 3.6 m -- -- 3.6 m -- -- 3.6 m -- -- 300 4500

600 10,000

Volume SourceUTM 475901.8 E 5226312.9 N 475807.3 E 5226295.8 N 475871.0 E 5226308.0 N 475790.0 E 5226314.4 N 475792.1 E 5226269.2 N

Pit DimensionsEmission Height 5.0 ft 1.52 m 5.0 ft 1.52 m 10.0 ft 3.0 m 10.0 ft 3.0 m 10.0 ft 3.0 m

Long Side 10.0 ft 3.0 m 10.0 ft 3.0 m 17.0 ft 5.2 m 17.0 ft 5.2 m 17.0 ft 5.2 mShort Side 10.0 ft 3.0 m 8.0 ft 2.4 m 10.0 ft 3.0 m 10.0 ft 3.0 m 10.0 ft 3.0 m

Initial Lateral Dim. 2.4 ft 0.7 m 2.2 ft 0.7 m 3.2 ft 1.0 m 3.2 ft 1.0 m 3.2 ft 1.0 mInitial Vertical Dim. 2.3 ft 0.7 m 2.3 ft 0.7 m 4.7 ft 1.4 m 4.7 ft 1.4 m 4.7 ft 1.4 m

Point SourceUTM 475907.1 E 5226312.7 N 475812.3 E 5226295.7 N

Stack Height 3.0 ft 0.91 m 3.0 ft 0.91 mStack Diameter 3.0 ft 0.91 m 3.0 ft 0.91 m

Stack Temperature Ambient -- -- -- Ambient -- -- --

Stack Velocity -- -- 0.3 m/s -- -- 0.3 m/s

Area SourceUTM 475821.5 E 5226199.1 N

Distance Traveled on Property (total of truck entry, drop off & exit) 1056.0 ft 321.9 m

Height of truck 10.0 ft 3.0 mHeight of source (2 x truck

height) 20.0 ft 6.1 mEasterly length 590.0 ft 179.8 mNortherly length 650.0 ft 198.1 mAngle from North 355.0 º -- --

Initial Vertical Dim. 9.3 ft 2.8 m

Volume Source Point SourceUTM 475971.5 E 5226305.7 N UTM E 5226298.8 N

Height 130.0 ft 39.6 m Stack Height ft 3.7 m

Max Horizontal -- ft 25.0 mStack

Diameter ft 1.2 m

Min Horizontal -- ft 15.0 mStack

Temperature -- -- --

Initial Lateral Dim. 49.0 ft 14.9 m Stack Velocity -- 14.1 m/sInitial Vertical Dim. 30.0 ft 9.1 m

Shipping Terminal Fugitives

Pile 3 Pile 4

Truck Receving 3-4

Rectangular pit dimensions, 10'x 8'

Pile 1 Pile 2

Truck Receving 1-2

Rectangular pit dimensions, 10'x 10'

Hopper (Location 1-2)

Shipping Transfer 1-2

Hopper (Location 3)

Shipping Transfer 3-4

Traffic Fugitives

Elevation (m)

Pile Drop 4

Receptor Grid (m)

Hopper (Location 4)

Velocity based on 20,000 bushels/hr flow rateInitial lateral dimension = square root(length*width)/4.13Initial vertical dimension = height/2.15

Pile Drop 1

Shipping Terminal parameters from initial modeling for AQ11-E455

Pile Drop 3Pile Drop 2

Traffic and Shipping dimensions from Google EarthConveyor diameter based on conveyor width

Ambient

--

Shipping TerminalBaghouse475982.0

12.0

3.8


June 18, 2019Page D-6

Pacific Northwest Farmers Cooperative Grain TerminalModeling Results

AERMOD Modeling Results - NOC Modification

Pollutant Baghouse2 Receiving

Fugitives3

PM10 9.54E-05 9.54E-03PM2.5 1.62E-05 1.62E-03

1) Increase from NOC 11AQ-E445

Pollutant Pile Drop 1 Pile Drop 2 Pile Drop 3 Pile Drop 4 Storage Pile 1 Storage Pile 2 Storage Pile 3 Storage Pile 4 Receiving 1-2 Receiving 3-4 Traffic

PM10 1.08E-04 1.08E-04 1.08E-04 1.08E-04 5.31E-05 5.31E-05 5.31E-05 5.31E-05 3.86E-01 3.86E-01 5.00E-03PM2.5 1.83E-05 1.83E-05 1.83E-05 1.83E-05 8.04E-06 8.04E-06 8.04E-06 8.04E-06 6.50E-02 6.50E-02 5.00E-04

1) From NOC 18AQ-E027

Pollutant Hopper 1-2 Hopper 3 Hopper 4Shipping

Transfer 1-2Shipping

Transfer 3-4PM10 2.14E-03 1.07E-03 1.07E-03 2.14E-03 2.14E-03PM2.5 3.65E-04 1.83E-04 1.83E-04 3.65E-04 3.65E-04

1) Operations updated from NOC 18AQ-E027

PollutantAveraging

Period Results1 Background2 Total ImpactNAAQS/ASIL

(µg/m3)NAAQS/ASIL Exceeded?

PM10 24-hr 85.9 60 146 150 No24-hr 14.2 12 26 35 No

Annual 1.3 4.7 6 12 No1) Using third highest value for PM10 per National Ambient Air Quality Standards 40 CFR 50.

2) Background values obtained from WSU Northwest International Air Quality Environmental Science and Technology Consortium, NW Airquest, accessed 12/5/2018.

PM2.5

AERMOD Modeled Impact (µg/m3)

Emissions (g/s) - Shuttle

Emissions (g/s) - Pile Unload to Hoppers

Emissions (g/s) - Four Storage Piles1


June 18, 2019Page D-7

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