1 *Eng Q5 "r STATE OF MAINE DEPARTMENT OF ENVIRONMENTAL PROTECTION PAUL R. replace Paranoia Ano GOVERNOR Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine New Source Review A-180-77-4-A NSR #2 After review of the air emissions license amendment application, staff investigation reports and other documents in the applicant's file in the Bureau of Air Quality, pursuant to 38 M.R.S.A., Section 344 and Section 590, the Department finds the following facts: I. REGISTRATION A. Introduction 221119 Electric Power Generation LE (E 3'1" Red Shield manufactures pulp in Old Town, Maine. ln addition to operating the pulp mill process, Red Shield produces energy and process steam. The mill also operates support facilities including the wastewater treatment plant, labs, and shipping and receiving operations. Red Shield is an existing stationary source currently operating under a Part 70 license and amendments. Red Shield is considered a Part 70 major source as defined in Definitions Regulations, 06-096 CMR 100 (as amended). Amendment Description Red Shield has submitted an amendment proposing to increase the carbon monoxide (CO) limit from the Biomass Boiler from 0.35 lb/MMBtu to 0.9 lb/MMBtu. Reasons for this change include the firing of green wood (which has a higher moisture content than the construction and demolition wood fuel mix originally licensed for the facility), and the type, size, and age ofthe boiler. Based on the Departmenfs review of Red Shie1d's application suhrnittal, information from other -operating biomass boilers in the State, Red Shield's li HO USE l'Si.E 106 I-IUGAN ROAD, 3l2 1235 Sl \\li i\Rl\ {207) 287-T826 All-\iNlf. 04401 MAINE ISLIE., t))4 ST. (ECU) 'Ml-4570 FAX: (207) 94l-4584 QZUT) 822-6300 FAX: $22-6303 (2019'cle DRAFT DRAFT DRAFT 6/11/2012 Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine New Source Review A-180-77-4-A 2 NSR #2 historical data, the age of the unit, the moisture content and consistency of the fuel, startup/shutdown effects on CO emissions, the relationship between CO and NOX emissions, and proposed federal regulations, the Department has concluded that prior to January 1, 2016, the Biomass Boiler will be licensed at a CO limit of 0.8 lb/MMBtu on a 30 day rolling average, including all operating times. Beginning January i, 2016, the CO limit shall be 0.45 lb/MMBtu, excluding pre- defined staitup and shutdown periods. The ambient air quality modeling analysis submitted by Red Shield at the higher emission rate (0.9 lb/MMBtu) demonstrated compliance with ambient air quality standards; and therefore the lower rates set forth in this license will be further below the standards. Red Shield has also requested an increase in the allowable incineration time of non-condensable gases (NCGS) in the Biomass Boiler from 20% of the total NCG incineration time to C. Emission Equipment This amendment addresses the following equipment: EMISSION UNIT ID UNIT CAPACITY UNIT TYPE Biomass Boiler 265.2 MMBtu/hr with Fuel Burning - biomass, 16 MW extraction construction and demolition condensing turbine wood, NCGS, and generator supplemental natural gas D. Application Classification The modification of a major source is considered a major modification based on whether or not expected emissions increases exceed the "Significant Emission Inc1?ease Levels" as given in Regulation, 06-096 CMR 100 (as amended). The emission increases are determined by subtracting the average actual emissions of the 24 months preceding the modification (or representative 24 months) or current licensed allowed, whichever is more stringent, from the maximum future license allowed emissions. The result of this determination is the following: DRAFT DRAFT DRAFT 6/ll/2012 Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine New Source Review A-180-77-4-A 3 NSR #2 Average Current Actual Emissions Future or Current License Net Significance License Allowed Allowed Change Level 1 Pollutant tons/ ear) (tonl ear) ton/year) ton/ ear 3 Calculated using actual incineration time in the Biomass Boiler of 12.2% and the licensed emission rates of 85 lb/hr with NCGS and 6.6 without NCGS. Calculated using current licensed 0.35 lb/MMBtu limit and 8760 hr/yr. Note: The above numbers are for the Biomass Boiler only. No other equipment at the is affected by this amendment. This amendment is determined to be a major modification for CO and a minor modification for SO2. The amendment has been processed under Minor and Source Air Emission License Reguiofions 06-096 CMR 115 (as amended) and is simultaneously being processed under Parr 70 Emission License Regziiafions 06-096 CMR 140 (as amended) as a Part 70 Significant Modification to revise the Part 70 license liinits f`or CO emissions and NCG firing time in the Biomass Boiler. II. BEST TREATMENT (BPT) A. B. Introduction ln order to receive a license the applicant must control emissions from each unit to a level considered by the Department to represent Best Practical Treatment (BPT), as defined in Definitions Regulation, 06-096 CMR 100 (as amended). Separate control requirement categories exist for new and existing equipment as Well as for those sources located in designated non-attainment areas. BPT for new sources and modifications requires a demonstration that emissions are receiving Best Available Control Technology (BACT), as defined in 06-096 CMR 100 (as amended). BACT is a top-down approach to selecting air emission controls considering econoinic, environmental and energy impacts. Biomass Boiler CO The Biomass Boiler is a 265.2 MMBtu/hr Babcock Wilcox boiler manufactured in 1986 and installed at the Red Shield facility in 2004/2005. The boiler is currently licensed with a CO limit of" 0.35 lb/MMBtu. Due to the firing of green wood with high moisture content instead 'of construction and demolition wood DRAFT DRAFT DRAFT 6/ll/2012 Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine New Source Review A-180-77-4-A 4 NSR #2 waste, and the size and age of the boiler, Red Shield has submitted an amendment to increase the CO limit. 1. Background The boiler was originally licensed under different ownership and a number of amendments were issued addressing CO from the unit. The boiler initially had operational difficulties meeting the carbon monoxide (CO) and nitrogen oxide (N OX) license limits simultaneously. A temporary increase in the short term CO limit was given to the previous owners which allowed for operational changes to be made to the boiler to address CO while maintaining NOX emissions from the unit. A temporary CO limit of 1.1 lb/MMBtu was in place while the boiler was adjusted. The facility was shutdown soon after and sold. The new owners requested the same temporary limit (1.1 to allow for start-up and re-tuning. Then the facility was once again shutdown for a short time period and sold. Under Red Shield Acquisition, Inc., two amendments addressing CO emissions were issued. Air emission license amendment A-180-71-AX-A, dated January 13, 2009, allowed for the extension of the 1.1 lb/MMBtu CO limit in order to take into account the firing of green wood only (without construction and demolition wood waste as part of the fuel mix). Firing green wood alone results in higher CO emissions than construction and demolition wood waste due to the higher moisture content of the green wood. The temporary 1.1 lb/MMBtu limit was proposed until September 30, 2009 to allow for Red Shield to submit a major nioditication application for a permanent green wood CO limit. Air emission license amendment BA-A was subsequently issued on September 21, 2009 to allow for a temporary CO limit of 0.9 lb/MMBtu when tiring green wood chips. At that time, Red Shield proposed to investigate using waste heat to dry the biomass fuel (or a portion of it) prior to feeding it into the boiler or using other methods to achieve the 0.35 lb/MMBtu limit. At the end of the preliminary design and economics review of the Biomass Boiler energy savings project and other projects, if it was determined that the projects were not feasible or could not be funded, Red Shield would revert back to submitting the full major modification process with air quality modeling to justify a permanent higher CO limit. - Red Shield's current Part 70 license contains condition which requires a CO limit of 0.9 lb/M1\/lBtu and 306.0 lb/hr valid until October 1, 2010 when firing green wood only and 0.35 lb/MMBtu and 119.3 lb/hr after October 1, 2010. This language was incorporated into the Part 70 license from air emission license amendment A-180-71-BA-A. In order to revise the CO limits, a full major modification amendment was submitted. DRAFT DRAFT DRAFT 6/11/2012 Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine New Source Review BACT Red Shield submitted a BACT analysis, including information on CO formation, a review of similar sources, available CO control technology options (focusing on technical feasibility and economic, environmental and energy impacts for each), and a proposed CO emission limit. An ambient air quality dispersion modeling analysis was also submitted in support of the application to show compliance with Ambient Air Quality Standards. The formation of CO from biomass boilers can be attributed to a number of factors, including the fuel fired in the unit, the type of unit (fluidized bed or spreader stokers) and the age and the size of the boiler. Red Shield's boiler is a spreader stoker type which initially burned a combination of green wood and construction and demolition Wood Waste for a short time. Construction and demolition Wood waste fuel has a typical moisture content range of 25-35%. The facility now only fires green wood chips with a typical moisture content of 40-50%, which can be affected by factors such as winter conditions (ice and snow) and periods of Wet Weather. Typically, the higher the moisture content, the higher the CO emissions. Also, the olde1? and smaller the boiler, the more difficult it is to prevent the formation of CO emissions. In addition to the stand-alone CO factors to consider, there is an inverse relationship between NOX and CO emissions. When NOX decreases, CO may increase and vice-versa. Red Shield has been meeting the NOX emission limits from the Biomass Boiler While addressing CO. Similar Source Cfonqoarisons As part ofthe CO emission control technologies review, Red Shield identitied similar sized boilers in EPA's Clearinghouse (RBLC), as Well as boiler licenses on state agency Websites. The following sources were included in the review: Biomass Boilers with CO Limits (from the RBLC) Facilit State MMBtu/hr Fuel stem lb/MMBtu desi FGR LLC wood catal st Lindale TX l/S/2010 213 biomass good Renewable combustion Energy ractices DRAFT DRAFT DRAFT 6/ll/2012 Red Shield Acquisition, LLC Penobscot County Old Town, Maine Departmental Findings of Fact and Order New Source Review A-180-77-4-A 6 NSR #2 Luikin TX i0/26/2009 693 wood good 0.075 Generating Plant combustion practices, fluidized bed eic lci c`f Biomass catalyst Generation Skagit County WA l/25/2006 430 bari<&, good 0.43 Lumber Mill wood combustion Waste practices 5-il 1;-it Schiller Station NH 720 biomass good combustion practices BD Inland GA i0fl3/2004 856 bark good 0.29 Paperboard and combustion Packaging, Inc. ractices ta- Thermal VA ?20 Wood good 0.44 Ventures combustion _tractices SD Warren Co - ME I 1300 wood good boiler 0.40 Skowbegan waste design and (SAPPI) good combustion practices combustion ractices Wickiiffe Miil aitte iacl eal A number oftiuidized bed boilers are listed, Whose design is different than the spreader stoker at Red Shield. Two entries have oxidation Montville Power, LLC and South Point Biomass Generation. Construction on Montville Power has not yet started and the oxidation catalyst was proposed to DRAFT DRAFT DRAFT 6/ll/2012 Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine New Source Review A-180-77-4-A 7 NSR #2 avoid BACT. South Point Biomass Generation's control system is for the combined flue gas from five Wood and coal tired boilers and the air quality region was designated as non-attainment for CO when the application was submitted, so a Lowest Achievable Emission Rate (LAER) analysis was performed. Five facilities, shown as shaded in the table above, havebiomass boilers sized close to Red Shield's unit (265 MMBtu/hr) and list good combustion practices as the primary control for CO. Hibbing Public Utilities is also licensed to burn low-moisture fuels, such as untreated residuals from manufacturing processes and construction and demolition Wood. Koda Energy and Boralex- Sherman operate larger boilers. The two closest boilers in size are Northern Sun and Del-tin Fiber with CO limits of 0.63 lb/MMBtu and 0.78 lb/MMBtu, respectively. A review of the currently licensed Part 70 sources in Maine resulted in the following information: Comparison of Similar Licensed Biomass Boilers in Maine Facilit MMBtu/hr Manufact. Control Boralex - Ashland 585 1992 SNCR, 0.95 24 hour block ecotube at all operating times Boralex - Fort 523 1987 ecotube 0.45 annual stack test Fairfield (235.4 capabilites is license limit) Boralex - 586 1992 SNCR, 0.95 24 hour block times 11 1 ecotube revised Table Notes: These spreader Stoker units fire wood and most are also able to tire construction and demolition debris and,/or reprocessed wood fuel. SNCR Selective Non-catalytic Reduction. R-SCR Regenative Selective Catalytic Reduction. SSM startup, shutdown, malfunction. The Red Shield boiler is the second oldest and the smallest of the units listed. The current limit for Red Shield (0.35 lb/MMBtu) and the proposed limit (0.90 lb/MMBtu) are on a 30~day rolling average, including all operating times. Red Shield does not currently cornbust low moisture fuel, such as construction and demolition wood Waste or reprocessed wood fuel, as most of DRAFT DRAFT DRAFT 6/ll/2012 Overfire Air Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and O1 del Old Town, Maine New Source Revlcw A-180-77-4-A 8 NSR #2 the other units do. The boiler size, boiler age, and fuel combusted can affect the formation of CO in biomass boilers. Red Shield also does not have add on NOX control. NOX from the Red Shield Biomass Boiler is minimlzed through boiler operation. NOX and CO emissions can have an inverse 1elat1onsh1p as previously stated. CO Control Technologies Boiler CO emissions reductions can be attained through combustlon modification techniques, post-combustion controls, good combusnon practices, and boiler configuration retrofits. The primary combustion modification technique is the use of an overtite air system to ensure complete combustion takes place, often in the upper portion of the boiler's combustion chamber. Complete combustion reduces the level of CO in the exhaust. The amount of emission reductions achieved is dependent on the uncontrolled CO concentration, the combustion chamber oxygen content, the air distribution between the burner and overfire air ports, and the type and method of fuel fired. CO reductions of up to 25% can be achieved in a boiler with an overfire air system versus a boiler without an overfire air system. A The Biomass Boiler at Red Shield is already equipped with an overfire air system. Oxidation Catalyst Post combustion controls for CO reduction is mainly the use of an add-on oxidation catalyst system which passes the boiler flue gas exhaust through a catalyst bed that converts the CO to carbon dioxide. CO reductions of between 65-95% can be achieved in a boiler with an oxidation catalyst. However, oxidation catalyst systems are most efficient in a specific exhaust temperature range (500-l and when used with clean fuels (natural gas, propane, #2 fuel oil). If the exhaust gases are lower than the optimal temperature range, then additional heat is needed to raise the temperature; and if _the catalyst gets plugged by material in 'non-clean' fuel, including particulates and metal compounds from wood, then it loses its effectiveness. To rectify the possible plugging and fouling problems, the oxidation catalyst system can be located of the particulate matter control device, but this location may result in additional blowers and a temperature increase for the system to work properly. The oxidation catalyst is technically feasible for Red Shield's Biomass Boiler if the catalyst system is located of the current DRAFT DRAFT DRAFT 6/ll/2012 Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine New Source Review electrostatic precipitator (ESP), the flue gas temperature is raised, and a soot blower is used. ,Putting the catalyst system in the boiler's HRSG (heat recovery steam generator) section would not be practical, so it would need to be located after the ESP. The temperature would need to be raised from to for optimum performance. A soot blower would be needed to keep the catalyst bed free of any build up of particulate or rnetals. A The cost of increasing the flue gas temperature would require a natural gas duct burner (assumed to be a unit which consumes 26.8 natural gas per hour) at a cost of over $1 million per year based on This burner would also add approximately 10.5 tons of CO that would need to be treated. The energy used by a duct burner is counter to the design of the boiler which recovers heat with an econoinizer. The overall operating cost associated with the installation of an oxidation catalyst based on a 95% reduction of CO (993.1 tons/yr) is $1292 per ton of CO reduced. The use of an oxidation catalyst with the added annual expense of a duct burner would compromise the financial operational viability of the Biomass Boiler. An oxidation catalyst system has been installed as LAER on units, but would not be considered BACT for this situation. Good Combustion Practices Good combustion practices to reduce CO emissions from biomass boilers include good operator and maintenance practices; maintaining proper stoichiometric fuel-to>>air ratios; monitoring of fuel quality, temperature, and combustion air distribution; and development and utilization of a startup and shutdown plan. There is no specific percent reduction given to good combustion practices, but without them, CO emissions could increase significantly. The cost for maintaining good operating practices are the direct operating costs of the operating staff and supervisory staff to make sure the boiler is functioning at its optimal efficiency at all times. Retrofit to fluidized bed boiler The _manufacturer Babcock Wilcox has information on retrofitting the boiler from a Stoker grate to a fluidized bed which could result in reducing CO emissions by approximately 10%. This is a feasible option; however, in the hierarchy of CO emission reduction options, converting the boiler to a fluidized bed design achieves the lowest incremental gain (an oxidation catalyst has a control efficiency of 65-96%, overfire air and good DRAFT DRAFT 6/ll/2012 Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine New Source Review combustion practices have a control efficiency of greater than 25%) Based on the comparison ranking and the cost of boiler redesign, retrofitting the boiler to a fiuidized bed was not considered BACT for the control ot`CO for Red Shield. Red Shield 's Proposed BA CT Red Shield proposed the continued use of an overfire air system and good combustion practices as BACT with a CO limit of 0.90 lb/MMBtu and 238.5 lb/hr based on the current emission limits for similar sources in Maine as Well as sources listed in the RBLC. Red Shield proposed to continue efforts to optimize the Biomass Boiler to reduce the formation of CO. The proposed BACT limits were considered by the Department, with a final conclusion of a two phased approached as described in the Departinent Findings - BACT Conclusion section below. Additional Federal Considerations EPA has federal rules under review to which the Red Shield Biomass Boiler will be applicable (as the rule is currently drafted): 40 CFR Part 63, Subpart National Emission Standards for Hazardous Air Pollutants (NESHAP) for Major Sources: Industrial, and Institutional Boilers and Process Heaters. The rule and the proposed rule revisions address particulate matter (PM), hydrogen chloride mercury and CO from boilers at major sources across the nation. Red Shield will need to meet the applicable final promulgated limits prior to the compliance deadline in the rule once it is finalized. Department Findings - BA CT Conclusion Based on the Department's review of Red Shield'S application submittal, information from other operating biomass boilers in the State, and Red Shield's historical data, it has been determined that the age of the unit, the moisture content and consistency of the fuel, and startup and shutdown events have a varying effect on CO emissions. However, the Department concludes that Red Shield can achieve additional minimization of CO emissions by focusing on tuning the boiler's overtire air system and the boiler's operating practices. Historical data from Red Shield over the past 12 months showed large variations in CO emissions on a 24 hour basis from numerous startup and shutdown events, which has a significant bearing when calculating the 30 day rolling average. Red Shield was also focused on repairing the Biomass Boiler turbine generator. The turbine generator failed in March 2010 and was rebuilt DRAFT DRAFT DRAFT 6/ll/2012 Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine New Source Review A-180-77 11 NSR #2 as an extraction condensing turbine generator. The rebuild did not- increase the steam demand on the Biomass Boiler or change the 16 MW capability of the generator. However, as the generator was being worked on, the Biomass Boiler CO emissions trended up during normal operating periods since the Biomass Boiler was operated at lower than normal loads during that' time. The data shows that CO emissions since November of 2011 have been below 0.8 lb/MMBtu on a 30 day rolling average. The Department concludes that prior to January 1, 2016 Red Shield shall meet a Biomass Boiler CO BACT limit of 0.8 lb/MMBtu_on a 30 day rolling average for all operating times, including startup and shutdown, with the following calculation correction: for no more than four hours during startup, Red Shield may replace stack O2 levels that exceed 14.0% with a value ot 14.0 and recalculate the hourly lb/MMBtu actual average for CO using the 14.0 value. This calculation correction is used when O2 levels skew the correction factor from realistic monitored data when excess air is at a maximum during initial startup conditions and is consistent with monitoring requirements in 40 CFR Part 75. The CO limit shall be 212.2 lb/hr, demonstrated to be in compliance with ambient air quality standards. This limit, effective through December 31, 2015, will allow boiler experts to be brought on-site, allow for staff to continue to fine tune the unit, as well as allow Red Shield to plan for the revised federal requirements in 40 CFR Part 63, Subpart when promulgated. Beginning January 1, 2016, the CO limit shall be 0.45 lb/MMBtu on a 30 day rolling average, excluding startups and Red Shield shall submit a Biomass Boiler startup and shutdown CO emissions minimization plan for the Department's approval by July l, 2015 clearly defining what constitutes startup and shutdown periods. The _document shall be developed using appropriate internal and external expertise; and shall include information such as specific startup and shutdown timeframe ranges (including warm and cold startups), operating parameter measurements (ie. boiler temperature, definition of tirst tire, oxygen levels), and any additional information as necessary. Beginning January 1, 2016, the CO lb/hr limit shall be 119.3 lb/hr. The exclusion of predefined startup and shutdown scenarios recognizes the operational difficulties of the Biomass Boiler during periods of ramping up or down, but will require very specific startup/shutdown conditions to be met for those emissions to be excluded from the 30 day rolling average calculations. Red Shield will be required to include the emissions from the startup/shutdown periods as part of the compliance documentation and reporting. DRAFT DRAFT DRAFT 6/11/2012 -1. Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine New Source Review A 180 77-4-A 12 NSR #2 Biomass Boiler NCG Firing Red Shield has proposed a revision to the incineration time for tiring Low Volume High Concentration (LVHC) gases, also known as Non-Condensable Gases (NCGS), in the Biomass Boiler. The Lime Kiln is the primary incinerator for the LVHC gases (NCGS) generated by the pulp mill, with #5 Power Boiler and the Biomass Boiler as back-up. Currently, primary is defined as greater than 80% of the total incineration time on an annual basis. Red Shield has requested the Biomass Boiler NCG incineration percentage be increased from 20% to This will result in a 39.9 tons/year increase of SO2, based on the licensed limit of 85 lb/hr when tiring NCGS. The Departrnent approves the increase in NCG incineration time in the Biomass Boiler. Operationally, the Lime Kiln can build up 'rings' Within the unit which need to be removed during shutdowns and allowing the slight increase in use of the Biomass Boiler may lessen this build up. Red Shield has also noted a slight decrease in CO when NCGS are tired in the Biomass Boiler. The Biomass Boiler S02 emissions were included in a previous ambient air quality analysis and showed compliance with ambient air quality standards. The short term emissions are not increasing with this amendment. II AMBIENT AIR QUALITY ANALYSIS Overview A refined ambient air quality dispersion modeling analysis was performed to show that emissions from Red Shield, in conjunction with other sources, will not cause or contribute to violations of National Ambient Air Quality Standards (NAAQS) for CO. Since SO2, PMID and N02 were addressed as part ofa previous modeling analysis and because no emissions changes for these pollutants are proposed, no further modeling for these pollutants is required. The current licensing action for Red Shield represents a major modification to an existing major source. Based upon the magnitude of proposed emissions increase and the distance from the source to any Class area, the affected Federal Land Managers (FLl\/ls) and MEDEP-BAQ have determined that an assessment of Class I Air Quality Related Values (AQRVS) is not required. Model Inputs The AERMOD-PRIME refined model was used to address standards and increments in all areas. If applicable, the modeling analysis accounted for the DRAFT DRAFT DRAFT 6/ll/2012 Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine New Source Review . 13 NSR #2 potential of building wake and cavity effects on emissions from all modeled stacks that are below their calculated formula GEP stack heights. All modeling was performed in accordance with all applicable requirements of the Maine Department of Environmental Protection, Bureau of Air Quality (MEDEP- BAQ) and the United States Environmental Protection Agency (USEPA). A valid 5-year hourly off-site meteorological database was used in the AERMOD-PRIME retined modeling analysis. Wind data was collected at two levels (10 and 76 meters) at Red Shield's meteorological monitoring site during the 5-year period 1991-1995. Surface data collected at the Bangor National Weather Service (NWS) site were substituted for any missing data. All other missing data were interpolated or coded as missing, per USEPA guidance. ln addition, hourly Bangor NWS data, from the same time period, were used to supplement the primary surface dataset for the required variables that were not explicitly collected at the monitoring site. The surface meteorological data was combined with concurrent hourly cloud cover and upper-air data obtained from the Caribou NWS. Missing cloud cover and/or upper-air data values were interpolated or coded as missing, per USEPA guidance. All necessary representative micrometeorological surface variables for inclusion into AERMET (surface roughness, Bowen ratio and albedo) were calculated using AERSURFACE from procedures recommended by USEPA. Point-source parameters, used in the modeling for are listed in Table TABLE Point Source Stack Parameters Stack Base Stack Stack Stack Easting Northiug Elevation Height Height Diameter NAD83 NAD83 Facilit [Stack In km km HEI DRAFT DRAFT DRAFT 6/ll/2012 Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Ordel Old Town, Maine New Source Review A-180-77-4-A 14 NSR #2 Emission parameters for CO NAAQS modeling are listed in Table Ill-2. TABLE Stack Emission Parameters Stack Stack Averaging CO Temp Velocity 5 5. .malta 30-55 444-00 15-34 #5 Boiler 455-40 'Recovery Boiler 39.40 505.40 17.65 10-29 330-70 10-30 Smelt Dissolving Tank 348.70 335-90 70-22 C. Single Source Modeling Impacts refined modeling results for Red Shield alone are shown in Table Any maximum predicted impacts that exceeded their respective significance level are indicated in boldface type. TABLE Maximum Impacts from Red Shield Alone Class II Max Receptor Receptor Receptor Significance Pollutant Averaging Impact UTME UTMN Elevation Level Period (pgfmi) (km) (km) (pg/mi) Co 535.74 528.474 4973.560 29.75 226.99 528.774 4973.160 30.68 Combined Source Modeling Impacts Because all modeled impacts lrom Red Shield alone were less than significance levels for all CO averaging periods, no background data or other local sources need to be included inthe analysis. Class I Impacts The current licensing action for Red Shield represents a major modification to an existing major source. Based upon' the magnitude of proposed emissions increase and the distance from the source to any Class I area, the affected Federal Land Managers (FLMS) and MEDEP-BAQ have determined that an assessment of Class I Air Quality Related Values (AQRVS) is not required. DRAFT DRAFT DRAFT 6/ll/2012 Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine New Source Review A-180-77-4-A 15 NSR #2 F. Summary ln summary, it has been demonstrated that emissions from Red Shield will not cause or contribute to violations of National Ambient Air Quality Standards (NAAQS) for CO. ORDER Based on the above Findings and subject to conditions listed below, the Department concludes that the emissions from this source: - - will receive Best Practical Treatment, will not violate applicable emission standards, will not violate applicable ambient air quality standards in conjunction with emissions from other sources. The Department hereby grants Air Emission License pursuant to the preconstruction licensing requirements of 06-096 CMR ll5 and subject to the standard and special conditions below. Severability. The invalidity or unenforceability of any provision, or part thereof, of this License shall not affect the _remainder of the provision or any other provisions. This License shall be construed and enforced in all respects as if such invalid or unenforceable provision or part thereof had been omitted. SPECIFIC CONDITIONS Mote: The following requirements shall be included in air emissions license A-l80-7l- A-l through amendment being issued concurrently with this new source review amendment] Biomass Boiler CO A. CO emissions from the Biomass Boiler shall not exceed the following: Pollutant lb/MMBtu Averaging Time Com liance Method CO 0.8 30 day rolling ave, CEM (PI`i0l' to Jaltllafy at all operating times 1, 2016) 0.45 30 day rolling ave, CEM (Begifltling excluding startup and Januany l, 2016) Shutdown DRAFT DRAFT DRAFT 6/ll/20l2 B. Calculations Corrections Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine New Source Review 16 NSR #2 (Prior to Januar 1, 2016) (Beginning Januar I, 2016) [06-096 CMR 115, l. For no more than four (4) hours during start-up, Red Shield may make the following calculation corrections for the Biomass Boiler: Stack O2 levels that exceed 14.0% may be replaced with a value of 14.0. 2. Hourly lb/MMBtu averages for CO may be recalculated if the observed stack O3 is greater than 14.0% f`or no more than four (4) hours during startup. 3. The recalculated hourly lb/MMBtu averages may be used for compliance purposes. [06-096 CMR 115, C. By July 1, 2015 Red Shield shall submit a Biomass Boiler startup and shutdown CO emissions minimization plan for the Department's approval which clearly defines startup and shutdown periods. The document shall be developed using appropriate internal and external expertise; and shall include information such as specific startup and shutdown timeframe ranges (including warm and cold startups), operating parameter measurements (ie. boiler temperature, definition of first fire, oxygen levels), and any additional information as necessary. [06-096 CMR 115, (2) NCG Incineration The Lime Kiln shall be the primary incinerator for the LVHC gases (NCGS) generated by the pulp mill, with the Biomass Boiler as back-up, and #5 Power Boiler as the secondary back->>up. Primary shall be defined as greater than 70.3% ofthe total incineration time on an annual basis. lf a kiln failure occurs, Red Shield shall incinerate the LVHC gases in the Biomass Boiler or #5 Power Boiler. Records shall be maintained to document compliance with the 70.3% LVHC gas incineration time in the Lime Kiln, the use of the Biomass Boiler as back-up (no greater than 29.7% incineration timePower Boiler as secondary back-up. [06-096 CMR 124, TRS, and 06-096 CMR 115, DRAFT DRAFT DRAFT 6/ll/2012 Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine New Source Review A-180-77-4-A 17 NSR #2 (3) Boiler NESHAP Red Shield shall meet all applicable requirements of 40 CFR Part 63, Subpart National Emission Standards for Hazardous Air Po/Izrfarrts for Major Sources: Indusiriaf, Commercial, and Boilers and Process Heaters for the Biomass Boiler. [40 CFR Part 63, Subpart DONE AND DATED IN AUGUSTA, MAINE THIS DAY OF 2012. DEPARTMENT OF ENVIRONMENTAL PROTECTION BY, PATRICIA W. AHO, COMMISSIONER PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES Date of initial receipt of application: October 17, 2011 Date of application acceptance: October 21, 2011 Date tild with the Board of Environmental Protection: This Order prepared by Kathleen E. Tarbuck, Bureau ot`Air Quality. DRAFT DRAFT DRAFT 6/'11/2012 STATE OF MAINE I i - DEPARTMENT OF ENVIRONMENTAL PROTECTION ai? 4 3% 5 Ei My PAUL R. LEPAGE Paraicui w. Ano Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine Part 70 Air Emission License A-180-70-D-A Amendment #3 2 After review of the air emissions license amendment application, staff investigation reports and other documents in the applicant's file in the Bureau of Air Quality, pursuant to 38 M.R.S.A., Section 344 and Section 590, the Department finds the following facts: I. REGISTRATION A. Introduction 2211 19 Electric Power Generation Red Shield manufactures pulp in Old Town, Maine. In addition to operating the pulp mill process, Red Shield produces energy and process steam. The mill also 1 operates support facilities including the wastewater treatment plant, labs, and shipping and receiving operations. Red Shield is an existing stationary source currently operating under a Part '70 license and subsequent amendments. Red Shield is considered a Part 70 major source as defined in Definitions Regulations, 06-096 CMR 100 (as amended). B. Amendment Description Red Shield has submitted a Part 70 amendment application to incorporate air emission license amendment (issued [date will be inserted when jinalizedj, 2012) into the Part '70 license. The New Source Review air emission license amendment processed under Minor and Major Source Air Emission License Reguiaffoms' 06-096 CMR 115 (as amended), licenses an increase in the CO limit from the Biomass Boiler and an increase in the allowable incineration time of non-condensable gases (NCGS) in the Biomass Boiler. f\ UG USTA. 1? HOUSE BANGOR PORTLAND PRESQUE ISLE. MAINE i06 SUITE 6 M2 l1O.f'ti'D E235 DRIVE, P.-XRK MAINE 04401 Lir\lNli 04103 PRESQUE. ISLE, 046i'9-2094 RAY BLDG., ST. (2017) 941-45?0 PAX: (QUT) 94l~~i58~1 {2Ui) S22-6300 FAX: li.-XX: T560-3143 wel: silc: 'w A. rJv'd Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine Part 70 Air Emission License A-130-70-D-A 2 Amendment #3 The previous licensed CO limit was 0.35 lb/MMBtu on a 30 day rolling average. Prior to January l, 2016, the Biomass Boiler will be licensed at a CO limit of 0.8 lb/MMBtu on a 30 day rolling average, including all operating times. Beginning January 1, 2016, the CO limit shall be 0.45 lb/MMBtu, excluding pre~>>defined startup and shutdown periods. The allowable incineration time of non-condensable gases (NCGS) in the Biomass Boiler, used as a back-up incineration unit for the Lime Kiln, shall go from 20% of the total NCG incineration time to 29.7%. C. Emission Equipment This amendment addresses the following equipment: EMISSION UNIT ID UNIT CAPACITY UNIT TYPE Biomass Boiler 265.2 MMBtu/hr with Fuel Burning - biomass, 16 MW extraction construction and demolition condensing turbine wood, NCGS, and supplemental natural gas D. Application Classification The incorporation of the New Source Review requirements into the Part 70 license for an increase to the licensed Biomass Boiler CO limit and NCG firing time is classified as a Part 70 Significant Modification and has been processed under Parr 70 Emission License Regufafions 06-096 CMR 140 (as amended). Part 70 Significant Modification procedures are used for applications requesting license changes that do not qualify as Administrative Revisions or Part 70 Minor License Modifications. The New Source 'Review amendment was considered a major modification for CO and a minor modification for S02 based on the expected emissions increases compared to the "Significant Emission Increase Levels" as given in Dejiniffons Regulation, 06>>-096 CMR 100 (as amended) for major sources. The emission increases were determined by subtracting the average actual emissions of the 24 months preceding the modification (or representative 24 months) or current licensed allowed, whichever is more stringent, from the maximum future license allowed emissions. The result of this determination is the following: A DRAFT DRAFT DRAFT 6/11/2012 Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine Part 70 Air Emission License A 180 70-D-A 3 Amendment #3 Average Current Actual Emissions Future License Allowed Allowed Change Level Pollutant tons/year) (ton/year) (toni ear) (ton/year) - . 3 Calculated using actual incineration time in the Biomass Boiler of 12.2% and the licensed emission rates of 85 lb/hr with NCGS and 6.6 without NCGS. Calculated using current licensed 0.35 limit and 8760 hr/yr. Note: The above numbers are for the Biomass Boiler only. No other equipment at the facility is affected by this amendment. Based on changes to the licensed emission levels, the application is not considered an Administrative Revision or Part '70 Minor License Modification; and has been processed as a Part '70 Significant Modification. II PART 70 SIGNIFICANT MODIFICATION DESCRIPTION Overview Red Shield submitted an air emission license amendment application addressing Biomass Boiler CO emissions and NCG incineration time with the request that the Chapter 115 New Source Review maj or modilication amendment and the Part '70 Significant Modification amendment be processed simultaneously. The amendment application included a BACT analysis and an ambient air quality modeling analysis. The BACT and modeling analysis information is included in the New Source Review license amendment A-180-77-4-A (issued [date will be inserted when jfnalizedj, 2012). Biomass Boiler CO The 265.2 MMBtu/hr capacity Babcock Wilcox Biomass Boiler was manufactured in 1986 and installed at the Red Shield facility in 2004/2005. The boiler is currently licensed with a CO limit of 0.35 lb/MMBtu on a 30 day rolling average. Due to the tiring of green wood with high moisture content instead of construction and demolition Wood fuel, and the size and age of the boiler, Red Shield requested an increase ofthe CO limit. The Department approves the incorporation of the New Source Review requirements of into the Part '70 license, revising the Biomass Boiler CO licensed emission limits. DRAFT DRAFT DRAFT 6/11/2012 Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine Part 70 Air Emission License A 180 4 Amendment #3 Prior to January 1, 2016 Red Shield shall meet a CO BACT limit of 0.8 lb/MMBtu on a 30 day 1?olling average from the Biomass Boiler for all operating times, including startup and shutdown, with the following calculation correction: for no more than four hours during startup, Red Shield may replace stack O2 levels that exceed 14.0% with a value of 14.0 and recalculate the hourly lb/MMBtu actual average for CO using the 14.0 value. The CO limit shall be 212.2 lb/hr, demonstrated to be in compliance with ambient air quality standards. This limit, effective through December 31, 2015, will allow boiler experts to be brought on-site, allow for staff to continue to fine tune the unit, as well as allow Red Shield to plan for the revised federal requirements in 40 CFR Part 63, Subpart when promulgated. Beginning January 1, 2016, the CO limit shall be 0.45 lb/MMBtu on a 30 day 1?olling average, excluding startups and shutdowns. Red Shield shall submit a Biomass Boiler startup and shutdown CO emissions minimization plan for the Departmenfs approval by July 1, 2015 clearly defining what constitutes startup and shutdown periods. The document shall be developed using appropriate internal and external expertise; and shall include information such as specific startup and shutdown timeframe ranges (including warm and cold startups); operating parameter measurements (ie. boiler temperature, definition of first fire, oxygen levels); and any additional information as necessary. Beginning January 1, 2016, the CO lb/hr limit shall be 119.3 lb/hr. Biomass Boiler NCG Firing Red Shield proposed a revision to the incineration time for firing Low Volume High Concentration (LVHC) gases, also known as Non-Condensable Gases (N CGS), in the Biomass Boiler. The Lime Kiln is the primary incinerator for the LVI-IC gases (NCGS) generated by the pulp mill, with #5 Power Boiler and the Biomass Boiler as back->>up. Currently, primary is defined as greater than 80% of the total incineration time on an annual basis. Red Shield requested the Biomass Boiler NCG incineration percentage be increased from 20% to 29.7%, resulting in a 39.9 tons/year increase of SO2, based on the licensed limit of 85 lb/hr when firing NCGS. The Department approves the incorporation of the New Source Review requirements of into the Part '70 license, revising the Biomass Boiler NCG incineration time to 29.7%. The Biomass Boiler emissions were included in a previous ambient air quality analysis and showed compliance with ambient air quality standards. The short term S02 emissions are not increasing with this amendment. DRAFT DRAFT DRAFT 6/11/2012 Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine Part 70 Air Emission License 5 Amendment #3 ORDER Based on the above Findings and subject to conditions listed below, the Department concludes that the emissions from this source: - will receive Best Practical Treatment, - will not violate applicable emission standards, will not violate applicable ambient air quality standards in conjunction with emissions from other sources. The Department hereby grants Part 70 License A-180-70-D-A pursuant to 06-096 CMR 140 and the preconstruction permitting requirements of 06-096 CMR 115 and subject to and amendments A-180-70-B-A and and the special conditions below. Federally enforceable conditions in this Part 70 license must be changed pursuant to the applicable requirements in 06-096 CMR 115 for making such changes and pursuant to the applicable requirements in 06-096 CMR 140. For each special condition which is state enforceable only, state-only is designated with the following statement: Enforceable by State-only. Severability. The invalidity or unenforceability of any provision, or part thereof, of this License shall not affect the remainder of the provision or any other provisions. This License shall be construed and enforced in all respects as if such invalid or unenforceable provision or part thereof had been omitted. SPECIFIC CONDITIONS The following shall replace Condition in air emission license A-180-70-A-I (issued December 2, 2009): (15) Biomass Boiler and Turbine F. Non-condensable Gases Red Shield may incinerate NCGS in the Biomass Boiler as a back-up control option to the lime kiln for no greater than 29.7% ofthe total incineration time on an amiual basis. Records shall be maintained to document compliance with the Biomass Boiler incineration time. [06-096 CMR 140, BPT and BACT, license (2005), and A-180-77-4-A (2012)] DRAFT DRAFT DRAFT 6/11/2012 Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine Part 70 Air Emission License A-180-70-D-A 6 Amendment #3 The following shall replace Condition l5(H) in air emission license A-180-70-A-I (issued December 2, 2009): (15) Biomass Boiler and Turbine H. Emission Limits l. Emissions from the Biomass Boiler shall not exceed the following: 40 CFR Part 51, Appendix at all operating times 1, 2016) (B?3iH11iHg excluding startup and sanuafy 1, 20I6) Shmdown 40 CFR Part 51, Appendix CFR Appendix A (Prior to Janual 1, 20 16) (Beginning Januar E, 2016) Method 25 or 25A [06-096 CMR 140, BPT and BACT, licenses A-180-71-AI-A (2004), A480- (2005), A-180-71-AL-M (2005), (2009), BA-A (2009), and (20l2)] 2. Calculations Corrections a. For no more than four (4) hours during start-up, Red Shield may make the following calculation corrections for the Biomass Boiler: Stack O2 levels that exceed 14.0% may be replaced with a value of l4.0. DRAFT DRAFT DRAFT 6/11/2012 Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine Part 70 Air Emission License A-180-70-D-A 7 Amendment #3 b. Hourly averages for CO may be recalculated if the observed stack O2 is greater than 14.0% for no more than four (4) hours during startup. e. The recalculated hourly lb/MMBtu averages may be used for eompliance purposes. [06-096 CMR 115, The following shall be added to Condition 15 in air emission license A-180-70-A-I (issued December 2, 2009): (15) Biomass Boiler and Turbine M. CO Startup/Shutdown Definition Submittal By July 1, 2015 Red Shield shall submit a Biomass Boiler startup and shutdown C0 emissions minimization plan for the Department's approval which clearly detines startup and shutdown periods. The document shall be developed using appropriate internal and external expertise; and shall include information such as specific startup and shutdown timeframe ranges (including warm and cold startups), operating parameter measurements (ie. boiler temperature, definition of first tire, oxygen levels), and any additional information as necessary. [06-096 CMR 115, N. Boiler NESHAP Red Shield shall meet all applicable requirements of 40 CFR Part 63, Subpart National Emission Standards for Hazardous' Air for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters' for the Biomass Boiler. [40 CFR Part 63, Subpart The following shall replace Condition in air emission license A-180-70-A-I (issued December 2, 2009): (25) Lime Kiln C. The Lime Kiln shall be the primary incinerator for the LVHC gases (NCGS) generated by the pulp mill, with the Biomass Boiler as back-up, and #5 Power Boiler as the secondary back-up. Primary shall be defined as greater than 70.3% of the total incineration time on an annual basis. If a kiln failure occurs, Red Shield shall incinerate the LVHC gases in the Biomass Boiler or #5 Power Boiler. Records shall be maintained to document compliance with the 70.3% LVHC gas incineration time in the Lime Kiln, the use of the -Biomass Boiler as back~up (no greater than 29.7% incineration time), and the DRAFT DRAFT DRAFT .6/11/2012 Red Shield Acquisition, LLC Departmental Penobscot County Findings of Fact and Order Old Town, Maine Part 70 Air Emission License A-180-70-D-A 8 Amendment #3 use of the #5 Power Boiler as secondary back-up. [06-096 CMR 124, TRS and 06-096 CMR 115, I DONE AND DATED IN AUGUSTA, MAINE THIS DAY OF 2012 DEPARTMENT OF ENVIRONMENTAL PROTECTION BY: PATRICIA W. AHO, COMMISSIONER PLEASE NOTE ATTACHED SHEET FOR GUIDANCE ON APPEAL PROCEDURES Date of initial receipt ofapplication: October 17, 2011 Date of application acceptance: October 21, 2011 Date tiled with the Board of Environmental Protection: This Order prepared by Kathleen E. Tarbuck, Bureau of Air Quality. DRAFT DRAFT DRAFT 6/11/2012