avista kettle falls - wa

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
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)
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
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.
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
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.
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.
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
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%
75%
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.
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
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.
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.
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).
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.
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.
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.
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
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
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.
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,
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.
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.
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.
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
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.
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
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).
Figure 2. Receptor Grid
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.
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.
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
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
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.
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
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
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____________________
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
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%
Conveyor #1 50%
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 − (%)
APPENDIX D
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
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
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
4.3.5 Propose BACT
4.4.1 Identify Commercially-Available Emission Reduction 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

avista kettle falls - wa

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