Avista Kettle FallsOctober 2020
Project Number:
UPGRADE PROJECT
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Contents i Ramboll
2. Project Description
...............................................................................
3
2.1 Physical Description
...................................................................................
3
2.2 Project Location
........................................................................................
4
2.3 Project Schedule
.......................................................................................
5
2.4 Project Emissions
......................................................................................
5
2.4.2 Process Equipment Emission Calculations
............................................ 8
2.5 Total Project Emissions
..............................................................................
9
2.6 Facility-Wide Potential to Emit
....................................................................
10
3. Regulatory Analysis
...........................................................................
11
3.1 Federal Regulations
..................................................................................
11
3.1.2 Air Operating Permit
.......................................................................
12
3.1.3 Chemical Accident Prevention Provisions
............................................ 12
3.1.4 New Source Performance Standards
.................................................. 12
3.1.5 National Emission Standards for Hazardous Air Pollutants for
Source
Categories
.....................................................................................
12
3.2.1 Notice of Construction
.....................................................................
12
3.2.2 Toxic Air Pollutants
.........................................................................
13
3.2.3 State Environmental Protection Act
................................................... 13
3.2.4 General Air Regulations
...................................................................
13
4. Best Available Control Technology Analysis
....................................... 15
4.1 BACT Review Process
................................................................................
15
4.2 PM, PM10, and PM2.5 BACT
..........................................................................
17
4.3 Wood Fuel Handling Equipment
..................................................................
18
4.3.1 Identify Commercially Available Emission Reduction
Alternatives ........... 18
4.3.2 Eliminate Technically Infeasible Alternatives
....................................... 18
4.3.3 Rank Remaining Alternatives
............................................................
19
4.3.4 Consider Energy, Environmental, and Cost Factors
.............................. 19
4.3.5 Propose BACT
................................................................................
20
4.4.1 Identify Commercially-Available Emission Reduction
Alternatives ........... 20
4.4.2 Eliminate Technically Infeasible Alternatives
....................................... 20
4.4.3 Rank Remaining Alternatives
............................................................
21
4.4.4 Consider Energy, Environmental and Cost Factors
............................... 21
4.4.5 Propose BACT
................................................................................
22
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Contents ii Ramboll
5.2 Model Application
.....................................................................................
23
5.2.3 Meteorological Data
........................................................................
26
5.3 Ambient Standard Compliance Demonstration
.............................................. 29
TABLES
Table 1. Fuel Yard Transfer Points
..............................................................................
7 Table 2. Material Handling Transfer Point Emissions
...................................................... 8 Table 3.
Process Equipment Emissions
........................................................................
9 Table 4. Fuel Yard Upgrade Project Daily Emissions Summary
...................................... 10 Table 5. Fuel Yard
Upgrade Project Annual Emissions Summary
.................................... 10 Table 6. PSD Applicability
........................................................................................
11 Table 7. Volume Source Release Parameters
.............................................................. 28
Table 8. Model-Predicted Concentrations for SIL Assessment
........................................ 29 Table 9.
Model-Predicted Design Concentrations for NAAQS/WAAQS Compliance
Assessment
...........................................................................................................................
30
FIGURES
Figure 1. Facility Location
..........................................................................................
5 Figure 2. Receptor Grid
...........................................................................................
25 Figure 3. Windrose for KCLS 5-year Dataset
.............................................................. 27
Figure 4. Facility Layout and Emission Unit Locations
.................................................. 31
APPENDICES
Appendix B: Process Flow Diagrams
Appendix C: Project Emission Calculations
Appendix D: BACT Cost-Effectiveness Calculations
Appendix E: AERMOD Modeling Files (Provided Electronically)
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 1 Introduction
1. INTRODUCTION
The Avista Corporation (Avista) owns and operates the Kettle Falls
Generating
Station (KFGS), which is located about 3 miles northwest of Kettle
Falls,
Washington, in Stevens County. The KFGS is a biomass-fired
steam-electric power
station capable of generating up to 53.5 megawatts (MW) gross (“the
facility”).
On February 27, 2020, Ramboll submitted a Notice of Construction
(NOC)
application to the Washington Department of Ecology (Ecology) on
Avista’s behalf.
This application detailed Avista’s plans to upgrade the fuel yard
at the KFGS. This
project included the addition of truck dumpers, truck scales,
conveyors, a disc
screen, and a hammer hog. The proposed changes would have had no
effect on
operation of the existing boiler and no other emission units would
have been
affected as a result of the project. In April 2020, Ecology
approved the fuel yard
upgrade project and issued Approval Order No. 20AQ-E026.
Since that time, the global economic climate has changed as a
result of the COVID-
19 pandemic, and Avista is proposing to update the fuel yard
upgrade project to
reduce the cost. Avista is requesting, by means of this NOC
application submitted
to Ecology’s Eastern Regional Office, that Ecology authorize Avista
to make the
proposed changes to the facility that are outlined in this
application. Avista has
retained Ramboll US Corporation (Ramboll) to assist with
preparation of this NOC
application. Signed and dated applicable Ecology NOC application
forms are
provided in Appendix A.
• Description of the proposed project;
• Quantification of anticipated air pollutant emissions;
• A discussion of air quality regulations applicable to the
project;
• An analysis of Best Available Control Technology (BACT);
and
• A discussion of the dispersion modeling setup and results.
1.2 Summary of Findings
The proposed changes to the existing facility and method of
operation will result in
direct emissions of fugitive dust to the atmosphere. The analyses
documented in
this application indicate that the post-project facility will
comply with all applicable
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 2 Introduction
regulations and will not cause or contribute to a violation of an
ambient air quality
standard. We believe that, other than minor updates to the
equipment list, no
changes to Approval Order No. 20AQ-E026 are necessary to
accommodate the
proposed changes to the fuel yard upgrade outlined in this
application.
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 3 Project Description
2. PROJECT DESCRIPTION
2.1 Physical Description
The KFGS uses a wood-fired, spreader-stoker boiler to produce steam
that drives a
single-shaft turbine-generator to produce electricity. Wood fuel
for the boiler is
stored in the fuel yard at the facility, which receives an average
of 50 trucks per
day containing wood fuel. Fuel deliveries occur throughout the day,
and trucks
enter and exit the site from Highway 395 at an access point located
along the
eastern property boundary.
• Wood waste collection and transport system;
• Wood-fired boiler – Power Block;
• Gas-fired combustion turbine-generator.
The majority of this equipment will remain in place. Changes
proposed by Avista
that constitute the project under consideration are as
follows:
• Replace the existing two truck dumpers and scales;
• Replace sections of the conveyor system associated with the wood
waste
collection and transport system; and
• Add a new disc screen and hammer hog to sort and resize
material.
The proposed changes to the facility are necessary because parts
are unavailable to
repair certain pieces of outdated equipment. The expected overall
effect of the
proposed changes is to improve the efficiency of the fuel delivery
process and of
fuel yard operations in general.
As described in the February NOC application, the fuel yard upgrade
project was to
include construction of a new paved road south of the fuel yard
that would have
exited the site to Peachcrest Road. The February application also
included a
proposal to install a new building that would have housed a control
room as well as
a new disc screen and hammer hog. Both of these aspects of the
proposed upgrade
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 4 Project Description
project (i.e., the new road and the new building) have been removed
to reduce
construction costs. Avista will continue to use the existing
control room and will
install the new disc screen and hammer hog within the enclosures
provided by the
manufacturers. Additionally, the proposed conveyor will be shorter
than previously
proposed, which reduces the number of new material transfer points
by one.
To summarize, the current fuel yard upgrade proposal differs from
the previously
proposed upgrade in the following ways:
• No new paved road will be constructed, and trucks will continue
to enter and
exit the facility at the current locations;
• No new building will be constructed; and
• The layout of the proposed conveyor system has been updated
to
accommodate the other changes, resulting in one fewer new transfer
point.
Following implementation of the proposed project, modified as
described above,
delivered wood fuel will be unloaded from trucks by two new truck
dumpers into a
receiving hopper. The fuel will then be conveyed to a new disc
screen, which will
sort material by size. Fuel of acceptable size will be transferred
to the existing fuel
stackout system and fuel storage operation; oversized fuel will be
sent to a hammer
hog to be sized, and then sent to the existing stackout system and
fuel storage. A
process flow diagram of the equipment and operations, as currently
proposed, is
shown in Appendix B.
2.2 Project Location
All changes associated with the project will occur at the existing
facility, the location
of which is shown in Figure 1.
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 5 Project Description
Figure 1. Facility Location
2.3 Project Schedule
Avista plans to commence work on the proposed project once the
permit is issued.
Installation of the proposed equipment will be ongoing for a period
of 24 – 36
months. Any pauses in construction will be less than 18 months in
duration.
2.4 Project Emissions
To determine the applicability of regulations, and to assess
potential air quality
impacts associated with the proposed project, the types of and
quantities of air
pollutants expected to be emitted by the proposed new emission
units were
identified. The proposed project will result in emissions of
particulate matter (PM),
including PM with aerodynamic diameters less than 10 and 2.5
microns (PM10 and
PM2.5, respectively). This section describes how project emissions
were calculated,
and documents assumptions made as part of those calculations.
Methodologies used to calculate emissions for project emission
units are presented
in the following sections, and the calculated emissions are
summarized in Table 4
and Table 5. Detailed emission calculations are provided in
Appendix C.
Equipment manufacturer specifications were provided in the February
2020 NOC
application.
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 6 Project Description
2.4.1 Material Handling Transfer Point Emission Calculations
Emissions for the new material handling transfer points associated
with the
proposed new fuel yard equipment were estimated using an emission
factor
calculated using Equation 1 from Chapter 13.2.4 of the 5th Edition
of EPA’s AP-42
(Aggregate Handling):1
k = particle size multiplier, dimensionless
U = mean wind speed, miles per hour (mph)
M = material moisture content (%)
This equation provides an emission factor for each material
transfer point at the
facility. The particle size multipliers for PM, PM10, and PM2.5
were obtained from
AP-42. The assumed mean wind speed for the project site was based
on the annual
average wind speeds measured at Colville Airport from October 1989
through
April 2004.2 The moisture content of the wood fuel was
conservatively assumed to
be 50 percent, based on Avista’s historical records.
Wood fuel delivered to the facility will potentially pass through
up to 14 transfer
points. These transfer points are shown in the facility process
flow diagram in
Appendix B, and a description of each is provided in Table 1 below.
The table also
includes total amount of material passing through each transfer
point, a description
of the control device, if any, for the transfer point, and the
control efficiency.
1 https://www3.epa.gov/ttn/chief/ap42/ch13/final/c13s0204.pdf,
published November 2006. 2
https://mesonet.agron.iastate.edu/sites/windrose.phtml?station=CQV&network=WA_COOP
Ramboll 7 Project Description
Transfer Point
50% Steel cover and baffles on truck dumpers
50%
Conveyor #1 50%
Covered transfer point,
75%
Screen 100%
1% -- 0%
oversize fuel bin)
70% Covered transfer point, with covered conveyors
75%
100% Covered transfer point, with covered conveyors
75%
100% Covered transfer point, with covered conveyors
75%
10
-- Recycled material 2 --
Conveyor #1a -- Recycled material 2 --
Notes: 1 Transfer point control efficiencies based on the United
States Environmental Protection Agency’s
Control of Open Fugitive Dust Sources Final Report, September 1988.
2 The two transfer points identified as OS1 and OS2 will
exclusively handle oversized fuel recycled
through the material handling system. Oversized material is assumed
to contain no fines and, therefore, these transfer points will have
no potential to generate emissions. As a result, no
controls are needed for these two transfer points.
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 8 Project Description
Emission rates were calculated using the calculated emission
factor, the maximum
expected material throughput, and the control efficiency at each
transfer point. The
following maximum wood fuel throughput assumptions were used:
• Daily wood chip throughput = 3,500 ton/day; and
• Annual wood chip throughput = 1,253,000 ton/year.
Estimated emissions from material handling operations are presented
in Table 2
Detailed calculations are also included in Appendix C.
Table 2. Material Handling Transfer Point Emissions
Pollutant Emission Factor
PM 1.12E-05 0.108 0.0194
PM10 5.28E-06 0.0512 0.00917
PM2.5 8.00E-07 7.76E-03 1.39E-03
Notes: 1 Calculated using theoretical max daily throughput of 3,500
ton/day
2 Calculated using theoretical max annual throughput of 1,253,000
ton/year
2.4.2 Process Equipment Emission Calculations
The proposed project will include installation of new equipment
used to process
received wood fuel: a disc screen and a hammer hog. Because
equipment-specific
emission factors are not available, emissions were calculated using
the log
debarking emission factor from EPA Region 10’s memo to sawmills
located in the
Pacific Northwest.3 Log debarking was judged to be the activity
with an emission
factor that is most similar to the hammer hog operation. No
emission factor was
available for an activity similar to disc screen operation, so the
log debarking
emission factor was used, though it likely overestimates emissions.
The emission
factor for log debarking is 0.024 lb PM/ton material handled.
Particle size
distribution was also obtained from the EPA Region 10 memo, and is
50 percent for
PM10 and 25 percent for PM2.5.
3 EPA Region 10. “Particulate Matter Potential to Emit Emission
Factors for Activities at Sawmills,
Excluding Boilers, Located in Pacific Northwest Indian Country”,
dated May 8, 2014. Available
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 9 Project Description
All wood chips delivered to the facility will be routed through the
disc screen.
Approximately 30 percent of the wood chips are routed to the hammer
hog to be
ground into smaller pieces. This equates to the following
throughput rates for the
disc screen and hammer hog:
• Daily wood chip throughput (disc screen) = 3,500 ton/day;
• Daily wood chip throughput (hammer hog) = 1,050 ton/day;
• Annual wood chip throughput (disc screen) = 1,253,000 ton/year;
and
• Annual wood chip throughput (hammer hog) = 375,000
ton/year.
The disc screen and hammer hog will be enclosed. The enclosure is
assumed to
capture 75 percent of the fugitive dust emissions generated by the
new wood fuel
processing equipment. Estimated emissions from the new wood fuel
processing
equipment are presented in Table 3. Detailed calculations are also
included in
Appendix C.
Pollutant Disc Screen Hammer Hog Total
Daily
(lb/day)
Annual
(ton/year)
Daily
(lb/day)
Annual
(ton/year)
Daily
(lb/day)
Annual
(ton/year)
2.5 Total Project Emissions
Summaries of the emissions for the project are presented below in
Table 4 (daily
emissions) and Table 5 (annual emissions). The project’s estimated
emissions
exceed the modeling thresholds Ecology provided, as per email
correspondence
dated December 12, 2019. Therefore, Ramboll conducted air
dispersion modeling to
assess compliance with air quality standards, as described in
Section 5 of this
report.
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 10 Project Description
Pollutant
PM 0.108 27.3 27.4
PM10 0.0512 13.7 13.7
PM2.5 7.76E-03 6.83 6.83
Pollutant Annual Emissions (ton/year)
Material Handling Transfer Points
Process Equipment Project Total
PM 0.0194 4.89 4.91
PM10 0.00917 2.44 2.45
PM2.5 1.39E-03 1.22 1.22
2.6 Facility-Wide Potential to Emit
According to Section 3 of the Technical Support Document prepared
by Ecology in
April 2020, total facility-wide emissions excluding the project was
90 tons of PM.
Including the emissions for the proposed project, facility-wide
potential to emit
would total 94.9 tons/year.
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 11 Regulatory Analysis
3. REGULATORY ANALYSIS
This section identifies and discusses federal, state, and local air
quality regulations
and guidelines that potentially apply to the Project.
3.1 Federal Regulations
3.1.1 Prevention of Significant Deterioration (PSD)
Ecology administers the PSD program that applies to major sources
and major
modifications. The major source and major modification threshold
values are
dependent on facility type. The facility is deemed a major source
for the purposes
of the PSD program because potential annual emissions of a
regulated pollutant
exceed 250 tons per year.
As the facility is a major source with respect to PSD regulations,
it is appropriate to
confirm that the proposed changes will not trigger a PSD permit
modification. PSD
applies if there is an increase in annual emissions in tons per
year that exceeds
prescribed “significant emission rates” (SERs). The increase is
determined by
comparing potential or projected actual emissions after a physical
change with
baseline actual emissions during a baseline period. As discussed
above, the
proposed changes associated with the project will have no effect on
boiler operation
and no other emission sources are affected as a result of the
project.
For simplicity, baseline actual emissions for the facility are set
to zero and the
potential emission increases attributable to the project are
compared to the PSD
SERs in Table 6. As shown in the table, the project does not result
in a significant
emission increase of any PSD pollutant and major new source review
is not
required.
(tpy) (tpy)
(SERs) 40 CFR 52.21(b)(23).
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 12 Regulatory Analysis
3.1.2 Air Operating Permit
Title V of the federal Clean Air Act requires facilities to obtain
an Air Operating
Permit if potential annual emissions are greater than 100 tons of a
regulated
criteria pollutant, 10 tons of a single hazardous air pollutant
(HAP), or 25 tons of all
HAP combined. KFGS is subject to the Title V permit program and
currently
operates under an Air Operating Permit issued by Ecology. Because
approval of the
proposed project will not contravene any existing Air Operating
Permit conditions,
changes to the operating permit are not required before
implementation of the
project.
3.1.3 Chemical Accident Prevention Provisions
40 CFR Part 68 is designed to prevent the accidental release of
certain (specified)
toxic and flammable substances. A stationary source that has more
than a
threshold quantity of a regulated substance in a process must
develop a Risk
Management Plan (RMP). The facility does not store any substances
regulated by
40 CFR 68.130, and is therefore not required to develop and submit
an RMP.
3.1.4 New Source Performance Standards
New Source Performance Standards (NSPS) are nationally uniform
standards
applied to specific categories of stationary sources that are
constructed, modified,
or reconstructed after the standard was proposed. NSPS are found in
Title 40, Part
60 of the CFR. NSPS usually represent a minimum level of control
that is required
on a new source. None of the currently promulgated NSPS regulations
applicable to
the proposed new equipment.
3.1.5 National Emission Standards for Hazardous Air Pollutants for
Source
Categories
The National Emission Standards for Hazardous Air Pollutants
(NESHAPs)
regulations contained in 40 CFR Part 61 – 63 establish emission
standards for
certain source categories of HAP emissions. This part represents
the federal
regulatory mechanism used to regulate HAPs under the Clean Air Act
(CAA) after
the CAA was amended November 15, 1990. None of the currently
promulgated
NESHAP regulations are applicable to the proposed new
equipment.
3.2 State and Local Regulations
3.2.1 Notice of Construction
WAC 173-400-110 requires that an NOC application be filed, and an
Approval Order
(AO) issued, prior to the construction of an air contaminant source
or emission unit.
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 13 Regulatory Analysis
To obtain an AO, the applicant must demonstrate that the project
will employ BACT
to control pollutant emission increases attributable to the
project, that ambient air
quality standards will be protected, and that the project will
comply with
Washington Toxic Air Pollutant (TAP) regulations. In addition,
Ecology must confirm
that the project will meet all relevant NSPS and NESHAPs
requirements. This permit
application is intended to fulfil all requirements needed for
Ecology to issue an AO.
3.2.2 Toxic Air Pollutants
Air pollutants identified as TAPs in Washington are regulated by
WAC 173-460,
which was last revised by the Ecology in June 2009; a new revision
was
promulgated in mid-December 2019. The project does not have the
potential to
emit any TAPs.
3.2.3 State Environmental Protection Act
All projects required to obtain a permit prior to construction or
an agency approval
to proceed are subject to SEPA requirements. A copy of the final
SEPA
Determination of Nonsignificance (DNS) was provided to Ecology in
February 2020
with the previous permit application. Because the scope and
footprint of the current
fuel yard upgrade project does not exceed those of the project as
previously
defined, the DNS issued for that project fully encompasses and
addresses the
currently proposed project.
3.2.4 General Air Regulations
Ecology has established air quality regulations that apply to the
project site. WAC
173-400-040 establishes general emission standards that apply to
all emission
units. Paraphrasing this section, it: 1) limits opacity from all
emission units to
20 percent (with some exceptions); 2) prohibits particulate matter
fallout that
affects adjacent properties; and 3) requires reasonable precautions
to prevent
odors and the release of fugitive emissions that affect neighboring
properties.
WAC 173-400-050 limits particulate matter emissions greater than
0.2 grains per
dry standard cubic foot from general process units and combustion
units that burn
wood-derived fuels to produce steam.
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 15 Best Available Control Technology Analysis
4. BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS
As discussed in Section 3.2, an NOC permit application must be
filed with Ecology,
and project construction cannot commence until Ecology issues an
AO. Among the
requirements that must be satisfied for Ecology to issue an AO is
that all new or
modified sources of air pollutants not previously emitted or that
will increase as a
result of the project must employ BACT. The intent of the analysis
presented in this
section is to fulfil that requirement.
The project will result in the installation and operation of new
equipment for
handling and processing wood fuel delivered to the facility by
truck. New fuel
handling equipment includes two truck dumpers and five conveyors,
and new fuel
processing equipment includes a disc screen and a hammer hog.
4.1 BACT Review Process
BACT, as it applies to regulated pollutants not subject to major
new source review,
is defined in WAC 173-400-030 as:
“…an emission limitation based on the maximum degree of reduction
for each air
pollutant subject to regulation under chapter 70.94 RCW emitted
from or which
results from any new or modified stationary source, which the
permitting authority,
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 and available methods,
systems, and
techniques, including fuel cleaning, clean fuels, or treatment or
innovative fuel
combustion techniques for control of each such pollutant. “
In a December 1, 1987 memorandum from the EPA Assistant
Administrator for Air
and Radiation, the agency provided guidance on the “top-down”
methodology for
determining BACT. The “top-down” process involves the
identification of all
applicable control technologies according to control effectiveness.
Evaluation begins
with the “top,” or most stringent, control alternative. If the most
stringent option is
shown to be technically or economically infeasible, or if
environmental impacts are
severe enough to preclude its use, then it is eliminated from
consideration and then
the next most stringent control technology is similarly evaluated.
This process
continues until the BACT level under consideration cannot be
eliminated by
technical or economic considerations, energy impacts, or
environmental impacts.
The top control alternative that is not eliminated in this process
becomes the
proposed BACT basis.
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 16 Best Available Control Technology Analysis
This top-down BACT analysis process can be considered to contain
five basic steps:
• Step 1: Identify all available emission reduction alternatives
with practical
potential for application to the specific emission unit for the
regulated
pollutant under evaluation;
• Step 4: Evaluate the economic, energy, and environmental impacts
starting
with the most effective alternative; and
• Step 5: Select BACT, which will be the most effective practical
alternative not
rejected in the previous steps.
Formal use of these steps is not always necessary. However, both
EPA and Ecology
have consistently interpreted the statutory and regulatory
definitions of BACT as
containing two core requirements, which EPA and Ecology believe
must be met by
any BACT determination, regardless of whether it is conducted in a
“top-down”
manner. First, the BACT analysis must include consideration of the
most stringent
available technologies: i.e., those that provide the “maximum
degree of emissions
reduction.” Second, any decision to require a lesser degree of
emissions reduction
must be justified by an objective analysis of “energy,
environmental, and economic
impacts” contained in the record of the permit decisions.
Additionally, the minimum emission reduction to be considered in a
BACT analysis
must result in an emission rate no less stringent than the
applicable New Source
Performance Standard (NSPS) emission rate, if any NSPS standard for
that
pollutant is applicable to the source.
This BACT analysis was conducted in a manner consistent with the
stepwise
approach outlined above. Alternatives for achieving potential
reductions in air
emissions were identified for each emission unit. These options
were identified by
researching the EPA database known as the RACT/BACT/LAER
Clearinghouse
(RBLC), drawing upon previous environmental permitting experience
for similar
emission units, and surveying available literature. Economic,
environmental, and
energy impacts were evaluated for available emission reduction
alternatives judged
to be technically feasible.
Assessing the technical feasibility of emission reduction
alternatives is discussed in
EPA's draft "New Source Review Workshop Manual." Using terminology
from this
manual, if an alternative has been "demonstrated" successfully for
the type of
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 17 Best Available Control Technology Analysis
emission unit under review, then it would normally be considered
technically
feasible. For an undemonstrated alternative, “availability” and
“applicability”
determine technical feasibility. An available alternative is one
that is commercially
available; meaning that it has advanced through the following
steps:
• Concept stage;
• Pilot scale testing;
• Commercial sales.
Suitability for consideration as BACT involves not only commercial
availability, as
evidenced by past or expected near-term deployment on the same or
similar type
of emission unit but can also require consideration of the physical
and chemical
characteristics of the emissions or exhaust. An emission reduction
method
applicable to one emission unit may not be applicable to a similar
unit, due to
physical and/or chemical differences.
4.2 PM, PM10, and PM2.5 BACT
Particulate matter emissions are generated when wood fuel is
handled or
transferred from one piece of equipment to another. Following
implementation of
the Project, wood fuel will continue to be delivered to the
facility by truck, but,
instead of the current truck unloading system, two vertical truck
dumpers will be
used to unload the trucks. Conveyors will be used to move the wood
fuel from the
truck dumps to the disc screen, and from the screening/sizing
operations to existing
fuel handling equipment and operations. Both the disc screen and
the hammer hog
have the potential to generate particulate matter emissions when
they are
operated.
Material handling emission factors are typically based on moisture
content and silt
fraction, which is defined at the percentage of the materials that
passes through a
200-mesh screen (i.e., particles that are less than 75 micrometers
in size). Because
the wood fuel received at KFGS is approximately 50 percent moisture
by weight,
and the silt content of wood chips and bark is much less than 1
percent by weight,
there is little material available to generate airborne particulate
matter, and even
less is available in the size fractions identified at regulated
pollutants (i.e., PM10 and
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 18 Best Available Control Technology Analysis
PM2.5). The analyses presented here are conservative, in that they
consider PM
emissions as total suspended particulate (TSP). If the analyses
were adjusted to
consider only PM10 or PM2.5, the emission rates involved would
decrease
considerably, making cost-effectiveness calculations more
unfavorable.
4.3 Wood Fuel Handling Equipment
Wood fuel will arrive at the facility by truck and be removed from
trucks by two
truck dumpers. Five new conveyors will be added to move the fuel
from one
location to another. The proposed configuration of this new
equipment will create
13 new material transfer points when operated.
4.3.1 Identify Commercially Available Emission Reduction
Alternatives
Based on reviews of the RBLC, regulatory agency guidance, and
permit for similar
sources, the following emission reduction alternatives have been
used to reduce
particulate matter emissions from wood fuel handling
operations:
• Good operating practice;
4.3.2 Eliminate Technically Infeasible Alternatives
In this section, the technical feasibility of each of the emission
reduction
alternatives identified in the previous section is considered.
Alternatives that are
considered not technically feasible for application to the emission
unit under
consideration are removed from consideration as BACT.
Good operating practice include operating and maintaining equipment
as
recommended by the manufacturer and using best management practice.
Operating
truck dumpers, conveyors, and transfer points under such conditions
is technically
feasible, and, because of the ubiquity of these practices, they are
considered a
baseline alternative for reducing particulate matter emissions from
these emission
units.
Water spraying and misting of truck dumpers, conveyors, and
transfer points are
technically feasible for reducing particulate matter emissions,
though not common
practice for wood fuel operations.
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 19 Best Available Control Technology Analysis
Enclosures are commonly used and are technically feasible for
reducing particulate
matter emissions from truck dumpers, conveyors, and transfer
points. Typically,
truck dumper enclosures are three-sided, conveyor enclosures
completely surround
the conveyor along its length, and transfer point enclosures are
five-sided (i.e., four
walls and a roof) with access openings as necessary for the
equipment delivering
the material to, and taking it away from, the transfer point.
Fabric filters are technically feasible for controlling particulate
matter emissions
from conveyors and transfer points when used in conjunction with
enclosures.
Because truck dumper enclosures, if employed, typically have only
three sides,
which compromises the collection efficiency of a fabric filter to
the point where it is
technically infeasible. It is not common for fabric filters to be
employed with
covered conveyors, particularly when wood fuel is the conveyed
material.
4.3.3 Rank Remaining Alternatives
In this section, technically feasible emission reduction
alternatives are ranked in
order of decreasing effectiveness, along with the approximate
emission reduction
effectiveness expected for each alternative:
• Fabric filter with enclosure – 99 percent effective;
• Enclosure – 50 to 75 percent effective, depending on
configuration;
• Water spraying/misting – 50 percent effective; and
• Good operating practice – baseline alternative
4.3.4 Consider Energy, Environmental, and Cost Factors
In this section, energy, environmental, and cost factors are
considered, starting
with the most effective alternative.
The most effective emission reduction alternative for conveyors and
transfer points
is a fabric filter in conjunction with an enclosure. However,
because potential
emissions are minimal, employing even a small baghouse at each
transfer point
results in a cost effectiveness that exceeds the range of
reasonable abatement
costs. Assuming a 5,200 acfm baghouse for each transfer point, the
cost
effectiveness is greater than one million dollars per ton (detailed
cost-effectiveness
calcs are provided in Appendix D). Potential emissions from
conveyors is even less
than that of transfer points, so the calculated cost effectiveness
would be even less
favorable. The next most effective emission reduction alternative
is an enclosure,
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 20 Best Available Control Technology Analysis
which is proposed as BACT for conveyors and transfer points, so no
additional
assessment of energy, environmental, and cost factors are
necessary.
Because good operating practice is the only available alternative
for reducing
particulate matter from truck dumpers, no assessment of energy,
environmental,
and cost factors is necessary for those emission units.
4.3.5 Propose BACT
Avista proposes the following work practices as BACT for limiting
particulate matter
from the following emission units:
• Truck dumpers – employ good operating practice; and
• Conveyors and transfer points – employ enclosures.
4.4 Wood Fuel Processing Equipment
A disc screen will be used to separate wood of acceptable size from
wood that is too
large for the fuel handling system. Oversized wood fuel will be
sent to a hammer
hog, which will reduce the size of the material to that which the
wood fuel handling
system can accommodate.
4.4.1 Identify Commercially-Available Emission Reduction
Alternatives
Based on reviews of the RBLC, regulatory agency guidance, and
permit for similar
sources, the emission reduction alternatives identified as
available for wood fuel
handling equipment are the same as those identified as available
for use in
reducing particulate matter emissions from wood fuel processing
operations.
4.4.2 Eliminate Technically Infeasible Alternatives
In this section, the technical feasibility of each of the emission
reduction
alternatives identified in the previous section is considered.
Alternatives that are
considered not technically feasible for application to the emission
unit under
consideration are removed from consideration as BACT.
Good operating practice include operating and maintaining equipment
as
recommended by the manufacturer and using best management practice.
Operating
disc screens and hammer hogs under such conditions is technically
feasible, and,
because of the ubiquity of these practices, they are considered a
baseline
alternative for reducing particulate matter emissions from these
emission units.
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 21 Best Available Control Technology Analysis
Disc screens and hammer hogs are both typically installed within
enclosures to keep
precipitation from impacting operation and performance of this
equipment. Water
spraying and misting would have the same effect as precipitation,
and so is
considered technically infeasible for reducing particulate matter
emissions from
these emission units.
Enclosures are commonly used and are technically feasible for
reducing particulate
matter emissions from disc screens and hammer hogs. Typically, this
equipment is
installed and operated in an enclosure to protect the equipment
from the weather
and ensure that the equipment operates properly and doesn’t require
premature
maintenance or replacement.
Fabric filters are technically feasible for controlling particulate
matter emissions
from disc screen and hammer hogs when used in conjunction with
enclosures.
4.4.3 Rank Remaining Alternatives
In this section, technically feasible emission reduction
alternatives are ranked in
order of decreasing effectiveness, along with the approximate
emission reduction
effectiveness expected for each alternative:
• Fabric filter with enclosure – 99 percent effective
• Enclosure – 50 to 95 percent effective, depending on
configuration; and
• Good operating practice – baseline alternative
4.4.4 Consider Energy, Environmental and Cost Factors
In this section, energy, environmental, and cost factors are
considered, starting
with the most effective alternative.
The most effective emission reduction alternative for disc screens
and hammer hogs
is a fabric filter in conjunction with an enclosure. However, the
minimal emission
potential and large area over which the emissions occur, requires a
relatively large
baghouse (i.e., approximately 75,000 acfm) to capture relatively
few emissions.
Assuming a 75,000 acfm baghouse is used to capture emissions from
both the disc
screen and the hammer hog results in a cost effectiveness of
greater than $30,000
per ton abated, which is outside the range of reasonable costs for
BACT (detailed
cost-effectiveness calcs are provided in Appendix D). The next most
effective
emission reduction alternative is an enclosure, which is proposed
as BACT for disc
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 22 Best Available Control Technology Analysis
screens and hammer hogs, so no additional assessment of energy,
environmental,
and cost factors is necessary.
4.4.5 Propose BACT
Avista proposes the work practice of employing an enclosure as BACT
for limiting
particulate matter emission from the disc screen and hammer
hog.
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 23 Air Quality Impact Analysis
5. AIR QUALITY IMPACT ANALYSIS
The regulatory requirement for assessments of compliance with
ambient standards
are typically satisfied using air dispersion modeling analyses.
This section
documents the methodology and results of the near-field air quality
impact
analysis. Modeling files are provided electronically as Appendix
E.
5.1 Dispersion Model Selection
A review of regulatory modeling techniques was conducted to select
an appropriate
air quality model to simulate dispersion of air pollutants emitted
by the proposed
project for a near-field air quality impact analysis. The selection
of regulatory
modeling tools is influenced by the potential for exhaust plumes to
interact with
onsite structures (i.e., “building downwash”) or to impact
intermediate or complex
terrain. While no on-site buildings were identified as having the
potential to interact
with exhaust plumes from the proposed project, the modeling domain
includes both
intermediate and complex terrain.
In this situation, the EPA’s “Guideline of Air Quality Models” in
40 CFR 51
Appendix W (“the Guideline”) recommends the use of AERMOD, which
was
specifically designed to estimate impacts of air pollutants in
areas containing both
simple and intermediate/complex terrain. The most current version
of AERMOD
(Version 19191) was used for the dispersion modeling
analysis.
5.2 Model Application
AERMOD was applied using regulatory defaults in addition to the
options and data
discussed in this section.
Ambient pollutant concentrations were calculated using AERMOD for
24-hour and
annual averaging periods for comparison to applicable regulatory
thresholds.
5.2.2 Modeling Domain, Receptors, and Terrain
Terrain elevations for receptors were prepared using 1/3rd
arc-second elevation
data from the National Elevation Dataset (NED), which is a product
of the United
States Geological Survey (USGS). The NED is a seamless elevation
dataset covering
the continental United States, Alaska, and Hawaii, and is available
on the internet
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 24 Air Quality Impact Analysis
from the USGS National Map Viewer4. These data have a horizontal
spatial
resolution of approximately 10 meters (m), or 33 feet (ft).
The receptor set included receptors spaced 250 m apart covering the
outermost
portion of the 10-kilometer (km) domain. Nested grids of 25-m,
50-m, and 100-m
spaced receptors covered areas 400m, 800m, 4km, and 10km from the
property
boundary, respectively. Receptors were also located at 10-m
intervals along the
property boundary. Receptor locations are shown in Figure 2. The
base elevation
and hill height scale for each receptor were determined using
AERMAP (version
18081).
Ramboll 25 Air Quality Impact Analysis
Figure 2. Receptor Grid
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 26 Air Quality Impact Analysis
5.2.3 Meteorological Data
The EPA’s meteorological program, AERMET, was used to process
meteorological
data for use with AERMOD. AERMET combines the surface
meteorological
observations with twice-daily upper air soundings to calculate the
meteorological
variables and profiles required by AERMOD. AERMET (Version 19191)
was used for
this modeling analysis, and the option to adjust the surface
friction velocity (U*) for
low-wind or stable conditions was used, without the Bulk Richardson
Number
option.
A representative meteorological data set was prepared using surface
meteorological
data from the National Weather Service (NWS) station at Deer Park
Airport (station
KDEW). KDEW was determined to be the closest station, despite being
located
85 km southwest of the facility. Ramboll believes that these data
should be
representative of conditions onsite, since both are located in
valleys running north-
south. A windrose summarizing the wind speed and wind direction
data from the
data set along with wind data statistics is provided in Figure
3.
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 27 Air Quality Impact Analysis
Figure 3. Windrose for KCLS 5-year Dataset
Additional meteorological variables and geophysical parameters are
required for the
AERMOD dispersion model to estimate surface energy fluxes and
construct
boundary layer profiles. Surface characteristics including albedo,
Bowen ratio, and
surface roughness length were determined for the area surrounding
the facility and
the Deer Park Airport meteorological station using the AERMET
surface
characteristics pre-processor, AERSURFACE (Version 20006), and USGS
National
Land Cover Dataset (NLCD) 2016 landuse data. Land cover, impervious
layer, and
canopy coverage data were all included.
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 28 Air Quality Impact Analysis
Upper air data concurrent with the 5-year KDEW dataset were
obtained from the
upper air station at the Spokane International Airport (KOTX),
which is located
approximately 110 km south of the facility.
5.2.4 Emission Unit Characterization
The air quality impact analysis requires estimates of the source
parameters to
characterize initial dispersion and pollutant releases from
emission sources. Source
parameters for the proposed facility were obtained from
georeferenced engineering
design drawings and are summarized in Table 7 below.
Table 7. Volume Source Release Parameters
Model ID
UTM Easting1
1. UTM Zone 10, NAD83 Datum
The base elevation of each emission unit was estimated using
AERMAP.
While AERMOD includes the EPA’s Building Profile Input Program for
the PRIME
algorithm (BPIP PRIME) to estimate downwash effects from buildings,
the effects of
downwash are only considered for Point sources. Since all sources
included in the
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 29 Air Quality Impact Analysis
proposed project were modeled as Volume sources, no building
dimensions or
downwash effects were included in the modeling.
Figure 4 shows an aerial view of the facility layout with all
modeled emission
sources.
5.3 Ambient Standard Compliance Demonstration
Ambient PM10 and PM2.5 concentrations attributable to the project
were evaluated
using the inputs described in this section. Table 8 compares
AERMOD-predicted
maximum PM10 and PM2.5 concentrations to applicable Significant
Impact Levels
(SILs). The SILs represent incremental, project-specific impact
levels that the State
of Washington accepts as insignificant with respect to assessing
compliance with
the National Ambient Air Quality Standards (NAAQS) or the
Washington Ambient Air
Quality Standards (WAAQS, which, for PM10 and PM2.5, are identical
to the NAAQS).
Table 8. Model-Predicted Concentrations for SIL Assessment
Pollutant Period
(µg/m³) Over SIL?
PM2.5
24-Hour 4.0 1.2 Yes
Annual 0.71 0.3 Yes
1. Design concentrations are the maximum 24-hour PM10
concentration, the highest 5- year average of the maximum 24-hour
average PM2.5 concentrations at each
receptor, and the highest 5-year average of the maximum annual
average PM2.5 concentrations at each receptor
2. SIL = Significant Impact Level, from WAC 173-400-113
As shown in Table 8, the design concentration predicted by AERMOD
for 24-hour
average PM10, 24-hour average PM2.5, and annual average PM2.5
exceed the
corresponding SILs. As a result, a cumulative analysis is required
to determine
compliance with the NAAQS, which is typically accomplished by
adding a
background value to modeled results. A representative background
concentration
for the area was obtained from the NW AIRQUEST consortium5, managed
by the
Ramboll 30 Air Quality Impact Analysis
Idaho Department of Environmental Quality. Background
concentrations obtained
from NW AIRQUEST are based on data from 2014-2017.
Results of this analysis are summarized in Table 9. As shown in the
table, the
impacts from the proposed project including background
concentrations are less
than the applicable ambient standards for all pollutants of
concern. This result
indicates that the proposed project does not have the potential to
cause or
contribute to an exceedance of the ambient air quality
standards.
Table 9. Model-Predicted Design Concentrations for
NAAQS/WAAQS
Compliance Assessment
PM10 24-Hour 7.3 98 105 150 No
PM2.5 24-Hour 2.4 23 25 35 No
Annual 0.71 9.1 10 12 No
1. Design concentrations are the highest 6th-high 24-hour average
PM10 concentration over five modeled years, the highest 5-year
average of the 98th percentile 24-hour average PM2.5 concentrations
at each receptor, and the highest 5-year average of the annual
average PM2.5
concentrations at each receptor
2. The 24-hour average PM10 and PM2.5, and annual average PM2.5
background concentrations were obtained from the NWAirquest
website.
3. Total concentration is the sum of the design concentration and
the background concentration.
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Ramboll 31 Air Quality Impact Analysis
Figure 4. Facility Layout and Emission Unit Locations
APPENDIX A
Notice of Construction Application
ECY 070-410 (Rev. 3/2018) Page 1 of 3 To request ADA accommodation,
call (360) 407-6800, 711 (relay service), or
877-833-6341(TTY).
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 two hours of free pre-application assistance.
We encourage you to
schedule a pre-application meeting with the contact person
specified for the location of your
proposal, below. If you use up your two hours of free
pre-application assistance, we will
continue to assist you after you submit Part 1 of the application
and the application fee. You
may schedule a meeting with us at any point in the process.
Upon completion of the application, please enclose a check for the
initial fee and mail to:
Check the box below for the fee that applies to your
application.
Check the box for the location of your proposal. For assistance,
call the contact listed below:
Ecology Permitting Office Contact
Lynnette Haller
(509) 457-7126
Garfield, Grant, Lincoln, Pend Oreille, Stevens,
Walla Walla or Whitman County
Ecology Eastern Regional Office – Air Quality Program
Karin Baldwin
(509) 329-3452
David Adler
(425) 649-7267
Ecology Industrial Section – Waste 2 Resources Program
Permit manager: ____________________________________
James DeMay
(360) 407-6868
US Department of Energy Hanford Reservation
Ecology Nuclear Waste Program
001-NSR-216-0299-000404
Notice of Construction Application
ECY 070-410 (Rev. 3/2018) Page 2 of 3 To request ADA accommodation,
call (360) 407-6800, 711 (relay service), or
877-833-6341(TTY).
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 under
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 bill you $95
per hour for the extra time.
You must include all information requested by 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 visit and
inspect your facility.
DocuSign Envelope ID: 4FE7F37F-6831-4AF5-ABA8-E28569BB9A85
Notice of Construction Application
ECY 070-410 (Rev. 3/2018) Page 3 of 3 To request ADA accommodation,
call (360) 407-6800, 711 (relay service), or
877-833-6341(TTY).
Part 1: General Information
Kettle Falls Generation Station Fuel Yard Upgrade Project
2. Facility Name
3. Facility Street Address
4. Facility Legal Description
Kettle Falls Generating Station
Avista Corporation
P.O. Box 3727, Spokane, WA 99220-3727
II. Contact Information and Certification 1. Facility Contact Name
(who will be onsite)
Kevin Booth
2. Facility Contact Mailing Address (if different than Company
Mailing Address)
1411 E Mission, PO Box 3727 MSC -21, Spokane WA 99220-3727
3. Facility Contact Phone Number
509-495-4738
Kevin Booth
6. Billing Contact Mailing Address (if different than Company
Mailing Address)
1411 E Mission, PO Box 3727 MSC -21, Spokane WA 99220-3727
7. Billing Contact Phone Number
509-495-4738
[email protected]
9. Consultant Name (optional – if 3rd party hired to complete
application elements)
Lanka DeSilva
19020 33rd Avenue West, Suite 310, Lynnwood, WA 98036
12. Consultant Phone Number
[email protected]
14. Responsible Official Name and Title (who is responsible for
project policy or decision-making)
Jason Thackston, Sr VP Energy Resources
16. Responsible Official Phone
18. Responsible Official Certification and Signature
I certify that the information on this application is accurate and
complete.
Signature ________________________________________
Date____________________
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
APPENDIX B
Disc Screen #1 Hammer Hog
Conveyor #2a (Accepts
Conveyor #4Disc Screen #2
Oversize Fuel Bin
Transfer Tower #1a
Process Building Bypass
Disc Screen #1 Hammer Hog
Conveyor #2a (Accepts
iz e d
Transfer Tower #1a
3 – Conveyor #1 to Disc Screen #1
4 – Process Building Metal Bypass to Recycle
5 – Disc Screen #1 to Hammer Hog
6 – Process Building Hammer Hog Bypass to Bunker
7 – Disc Screen #1 to Conveyor #2a
8 – Hammer Hog to Conveyor #2a
9 – Conveyor #2a to Conveyor #2b
10 – Conveyor #2b to existing fuel yard equipment
OS1 – Oversize Fuel Bin to Conveyor #8
OS2 – Conveyor #8 to Conveyor #1a
H a m
m e r
H o g
Hammer Hog Bypass Bunkers
Transferred via Front-End Loader
Existing Fuel Yard
1
OS1OS1
Legend:
1
OS1
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
APPENDIX C
Kettle Falls, WA
Kettle Falls, WA
Site Information
Transfer
Point
dumper A 50%
truck dumpers 50%
dumper B 50%
truck dumpers 50%
Conveyor #1 50%
Covered transfer point,
Conveyor #1 50%
Covered transfer point,
Screen 100%
Conveyor #8 -- Recycled material --
OS2 Conveyor #8 to
Conveyor #1a -- Recycled material --
Daily (ton/day)
Facility Operations (day/year)
Kettle Falls, WA
Emission Calculations 6
Conversions:
Notes:
2 Wood fuel moisture content based on fuel yard upgrade design
parameters.
3 Wood fuel throughput for entire fuel yard based on 3,500 tons/day
and 358 days/year.
4 New material handling transfer point numbers correspond to
facility process flow diagram.
1) Reload bin to Conveyor #8
2) Conveyor #8 to Conveyor #1
6 Emissions calculated as follows:
8 Uncontrolled emission factor calculated using Equation 1 in AP-42
5th Edition Chapter 13.2.4 for Aggregate
Handling (November 2006) for units lb/ton.
7 Particle size multiplier, k, from AP-42 5th Edition Chapter
13.2.4 for Aggregate Handling (November 2006),
first table on page 13.2.4-4. PM is based on PM30.
1 Annual average wind speed for Colville Airport from October 1989
through April 2004.
(https://mesonet.agron.iastate.edu/sites/windrose.phtml?station=CQV&network=WA_COOP)
Certain wood waste handling points associated with the fuel yard
upgrade will only handle oversized fuel
that is recycled through the material handling system. These
transfer points are handling, by definition,
oversized material and therefore no emissions are expected from
these transfer points. These points
include:
Pollutant
5 Transfer point control efficiencies based on the United States
EPA's Control of Open Fugitive Dust Sources
Final Report, September 1988.
=
×
= 0.0032 × 5
1.3
Kettle Falls, WA
Conversions:
2,000 lb/ton
Notes: 1 Wood fuel throughput for entire fuel yard based on 3,500
tons/day and 358 days/year.
5 Emissions calculated as follows:
4 Particle size percentage and uncontrolled emission factor for log
debarking based on EPA Region 10 memo "Particulate Matter
Potential to Emit Emission factors for Activities at Sawmills,
Excluding Boilers, Located in Pacific Northwest Indian Country",
dated May
8, 2014.
Total
2 Disc screen throughput assumes 100% of wood fuel is processed
through the disc screen. Hammer hog throughput assumes 30% of
wood fuel is processed through the hog.
Parameter
3 Conservative assumption, based on equipment being contained
within an enclosure, in addition to being located inside of a
building.
=
× 1 − (%)
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
APPENDIX D
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Baghouse for Wood Fuel Handling
Baghouse Cost Estimate for Wood Fuel Handling Avista - Kettle Falls
Generating Station Kettle Falls, Washington
CAPITAL COSTS DIRECT COSTS COST Source I. Purchased Equipment
a. Primary Equipment $20,000 Camfil Vendor Quote b. Instrumentation
(0.1*a) $2,000 OAQPS 6, Ch1 c. Sales tax (0.03*a) $600 OAQPS 6, Ch1
d. Freight (0.05*a) $1,000 OAQPS 6, Ch1
Total Purchases Equipment Cost [TEC] $23,600 Calculation
II. Direct Installation Costs a. Foundation and Supports (0.04*TEC)
$944 OAQPS 6, Ch1 b. Handling and Erection (0.50*TEC) $11,800 OAQPS
6, Ch1 c. Electrical (0.08*TEC) $1,888 OAQPS 6, Ch1 d. Piping
(0.01*TEC) $236 OAQPS 6, Ch1 e. Insulation for Ductwork (0.07*TEC)
$1,652 OAQPS 6, Ch1 f. Painting (0.04*TEC) $944 OAQPS 6, Ch1
$17,464 Calculation
INDIRECT COSTS III. Indirect Installation
a. Engineering and Supervision (0.10*TEC) $2,360 OAQPS 6, Ch1 b.
Construction and Field Expenses (0.2*TEC) $4,720 OAQPS 6, Ch1 c.
Contractor Fee (0.10*TEC) $2,360 OAQPS 6, Ch1 d. Contingencies
(0.03*TEC) $708 OAQPS 6, Ch1
IV. Other Indirect Costs a. Startup (0.01*TEC) $236 OAQPS 6,
Ch1
$10,384 Calculation
Total Capital Costs [TCC] (TEC+TDC+TIC) $51,448 Calculation
Total Annualized Captial Costs [TACC] (20 years @ 7% interest)
$4,856 Calculation DIRECT AND INDIRECT ANNUALIZED COSTS
DIRECT OPERATING COSTS (DOC) I. Labor for operation
($30/person-hour)(0.25 hr/shift)(1 shifts/day)(5 day/wk)(52 wk/yr)
$1,950 Engineering Estimate II. Supervisory Labor (0.15*operation
labor) $293 OAQPS 6, Ch1 III. Maintenance Labor
($35/person-hour)(0.25 hr/shift)(1 shifts/day)(1 day/wk)(52 wk/yr)
$455 Engineering Estimate IV. Maintenance Material (100% of
maintenance labor) $455 OAQPS 6, Ch1 V. Replacement Bags $100
Engineering Estimate VI. Utility Costs (fan) = (3 hp)(0.7457
kW/hp)(8,760 hr/yr)($0.06/kWhr) $1,176 Engineering Estimate VII.
Fuel Penalty (none) $0
INDIRECT OPERATING COSTS (IOC) VIII. Overhead (0.6*O&M
costs(I-IV of DOC) $1,892 OAQPS 6, Ch1 IX. Administration
(0.02*TCC) $1,029 OAQPS 6, Ch1 X. Property Tax (0.01*TCC) $514
OAQPS 6, Ch1 XI. Insurance (0.01*TCC) $514 OAQPS 6, Ch1
Total Direct and Indirect Annualized Costs [TDIAC] (DOC+IOC) $8,378
Calculation Total Annualized Costs Fabric Filter [TACoc]
(TACC+TDIAC) $13,234 Calculation
Baseline emissions (from Ecology) tons/year 0.007135 Engineering
Estimate Emissions w/ 800cfm Bin Vent Filter (0.004 gr/dscf)
tons/year 0.000071 Calculation Reduction from baseline Percent 0.99
Calculation Total Emissions Reduction tons/year 0.0071 Calculation
Cost per ton Controlled $/ton $1,873,545 Calculation
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
Baghouse for Disc Screen and Hammer Hog
Baghouse for Disc Screen and Hammer Hog Avista - Kettle Falls
Generating Station Kettle Falls, Washington
CAPITAL COSTS DIRECT COSTS COST Source I. Purchased Equipment
a. Primary Equipment (75,000 acfm pulse-jet baghouse w/polyester
filters) $176,614 OAQPS 6, Ch1 b. Instrumentation (0.1*a) $17,661
OAQPS 6, Ch1 c. Sales tax (0.03*a) $5,298 OAQPS 6, Ch1 d. Freight
(0.05*a) $8,831 OAQPS 6, Ch1
Total Purchases Equipment Cost [TEC] $208,405 Calculation
II. Direct Installation Costs a. Foundation and Supports (0.04*TEC)
$8,336 OAQPS 6, Ch1 b. Handling and Erection (0.50*TEC) $104,202
OAQPS 6, Ch1 c. Electrical (0.08*TEC) $16,672 OAQPS 6, Ch1 d.
Piping (0.01*TEC) $2,084 OAQPS 6, Ch1 e. Insulation for Ductwork
(0.07*TEC) $14,588 OAQPS 6, Ch1 f. Painting (0.04*TEC) $8,336 OAQPS
6, Ch1
$154,219 Calculation
INDIRECT COSTS III. Indirect Installation
a. Engineering and Supervision (0.10*TEC) $20,840 OAQPS 6, Ch1 b.
Construction and Field Expenses (0.2*TEC) $41,681 OAQPS 6, Ch1 c.
Contractor Fee (0.10*TEC) $20,840 OAQPS 6, Ch1 d. Contingencies
(0.03*TEC) $6,252 OAQPS 6, Ch1
IV. Other Indirect Costs a. Startup (0.01*TEC) $2,084 OAQPS 6, Ch1
b. Performance Test (0.01*TEC) $2,084 OAQPS 6, Ch1
$93,782 Calculation
Total Capital Costs [TCC] (TEC+TDC+TIC) $456,406 Calculation
Total Annualized Captial Costs [TACC] (20 years @ 7% interest)
$43,081 Calculation DIRECT AND INDIRECT ANNUALIZED COSTS
DIRECT OPERATING COSTS (DOC) I. Labor for operation
($30/person-hour)(0.25 hr/shift)(3 shifts/day)(360 day/yr) $8,100
OAQPS 6, Ch1 II. Supervisory Labor (0.15*operation labor) $1,215
OAQPS 6, Ch1 III. Maintenance Labor ($35/person-hour)(0.25
hr/shift)(3 shifts/day)(360 day/yr) $9,450 OAQPS 6, Ch1 IV.
Maintenance Material (100% of maintenance labor) $9,450 OAQPS 6,
Ch1 V. Replacement Bags and Replacement Labor $2,500 OAQPS 6, Ch1
VI. Utility Costs (fan) = (0.000181)(75,000 acfm)(10 in H2O)(8640
hr/yr)($0.06/kWhr) $70,373 OAQPS 6, Ch1 VII. Compressed Air
(pulse-jet) (2 scfm/1,000 acfm)(75,000 acfm)($0.25/1,000 scf)(60
min/hr)(8640 hr/yr)$19,440 OAQPS 6, Ch1 VIII. Waste Disposal (6.5
ton/yr)($25/ton) $163 OAQPS 6, Ch1
INDIRECT OPERATING COSTS (IOC) IX. Overhead (0.6*O&M costs(I-IV
of DOC) $16,929 OAQPS 6, Ch1 X. Administration (0.02*TCC) $9,128
OAQPS 6, Ch1 XI. Property Tax (0.01*TCC) $4,564 OAQPS 6, Ch1 XII.
Insurance (0.01*TCC) $4,564 OAQPS 6, Ch1
Total Direct and Indirect Annualized Costs [TDIAC] (DOC+IOC)
$155,876 Calculation Total Annualized Costs Fabric Filter [TACoc]
(TACC+TDIAC) $198,957 Calculation
Baseline emissions (from Ecology) tons/year 6.57 Engineering
Estimate Emissions w/ 800cfm Bin Vent Filter (0.004 gr/dscf)
tons/year 0.07 Calculation Reduction from baseline Percent 0.99
Calculation Total Emissions Reduction tons/year 6.50 Calculation
Cost per ton Controlled $/ton $30,589 Calculation
Notice of Construction Permit Application Kettle Falls Generation
Station Fuel Yard Upgrade Project
APPENDIX E
Contents
Tables
2.4.2 Process Equipment Emission Calculations
2.5 Total Project Emissions
3. Regulatory Analysis
3.1 Federal Regulations
3.1.2 Air Operating Permit
3.1.5 National Emission Standards for Hazardous Air Pollutants for
Source Categories
3.2 State and Local Regulations
3.2.1 Notice of Construction
3.2.2 Toxic Air Pollutants
3.2.4 General Air Regulations
4.1 BACT Review Process
4.3 Wood Fuel Handling Equipment
4.3.1 Identify Commercially Available Emission Reduction
Alternatives
4.3.2 Eliminate Technically Infeasible Alternatives
4.3.3 Rank Remaining Alternatives
4.3.5 Propose BACT
4.4.1 Identify Commercially-Available Emission Reduction
Alternatives
4.4.2 Eliminate Technically Infeasible Alternatives
4.4.3 Rank Remaining Alternatives
4.4.5 Propose BACT
5.1 Dispersion Model Selection
5.2.3 Meteorological Data
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Fuel Yard Upgrade Process Flow Diagram_Ramboll_8.24.2020.vsdx
Facility PFD
New Equipment
Emission Points