San Joaquin Valley LL qmq AIR POLLUTION CONTROL DISTRICT HEALTHY

San Joaquin Valley AIR POLLUTION CONTROL DISTRICT

q m q LL

HEALTHY AI R LIVINGm

MAR 2 9 2011

John Dean Spreckels Sugar Company P 0 Box 68 Mendota, CA 93640

Re: Notice of Preliminary Decision - Emission Reduction Credits Project Number: C-1090909

Dear Mr. Dean:

Enclosed for your review and comment is the District's analysis of Spreckels Sugar Company's application for Emission Reduction Credits (ERCs) resulting from the shutdown of one beet sugar processing operation, one 40 MMBtuIhr fuel oil fired lime kiln and one 31 1 NIMBtuIhr natural gas fired boiler, located at 39400 Whitesbridge Road in Mendota, CA. The quantity of ERCs proposed for banking is 2,253 Ib-VOClyear, 10,924 Ib-NOxIyear, 32,596 Ib-COlyear, 16,958 Ib-PMl Olyear, and 80,882 Ib-SOxIyear.

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

Thank you for your cooperation in this matter. If you have any questions regarding this matter, please contact Mr. Dustin Brown of Permit Services at (559) 230-5932.

Sincerely,

---' - "

d

David Warner Director of Permit Services

Enclosures

S e y e d S a d r e d i n

Executive DirectorIAir Pollution Control Office1

Northern Region Central Region (Main Office] Southern Region 4800 Enterprise Way 1990 E. Gettysburg Avenue 34946 Flyover Court

Modesto, CA 95356-8718 Fresno, CA 93726-0244 Bakersfield, CA 93308.9725 Tel: 12091 557-6400 FAX: (209) 557-6475 Tel: (559) 230.6000 FAX: (5591 230.6081 Tel: 661.392.5500 FAX: 661-392.5585

Ptlnted @n rar~rled paper 0

B n E HEALTHY AIR LIVING"

MAR 2 9 2011

Gerardo C. Rios (AIR 3) Chief, Permits Office Air Division U.S. E.P.A. - Region IX 75 Hawthorne Street San Francisco, CA 941 05


Dear Mr. Rios:

Enclosed for your review and comment is the District's analysis of Spreckels Sugar Company's application for Emission Reduction Credits (ERCs) resulting from the shutdown of one beet sugar processing operation, one 40 MMBtuIhr fuel oil fired lime kiln and one 31 1 MMBtuIhr natural gas fired boiler, located at 39400 Whitesbridge Road in Mendota, CA. The quantity of ERCs proposed for banking is 2,253 Ib-VOClyear, 10,924 Ib-NOdyear, 32,596 Ib-COlyear, 16,958 Ib-PMlOIyear, and 80,885 Ib-Sodyear.



Sincerely,

Director of Permit Services

Enclosure

S e y e d S a d r e d i n Executive DirectorlAir Pollution Control Officer

Northern Region Central Region [Main Office) Southern Region 4800 Enterprise Way 1990 E. Gettysburg Avenue 34946 Flyover Court

Modesto, CA 95356.8718 Fresno, CA 93726.0244 Bakersfield, CA 93308-9725 Tel: 1209) 557.6400 FAX: 1209) 557.6475 Tel: 1559) 230-6000 FAX: (559) 230.6061 Tel: 661.392-5500 FAX: 661.392.5585

Prcnled on rerycled paper. 0

San loaqlein Valley AIR POLLUTION CONTROL DISTRICT

m m m HEALTHY All R LIVING"

MAR 2 9 2011

Mike Tollstrup, Chief Project Assessment Branch Stationary Source Division California Air Resources Board PO Box 281 5 Sacramento, CA 9581 2-281 5


Dear Mr. Tollstrup:

Enclosed for your review and comment is the District's analysis of Spreckels Sugar Company's application for Emission Reduction Credits (ERCs) resulting from the shutdown of one beet sugar processing operation, one 40 MMBtuIhr fuel oil fired lime kiln and one 31 1 MMBtuIhr natural gas fired boiler, located at 39400 Whitesbridge Road in Mendota, CA. The quantity of ERCs proposed for banking is 2,253 Ib-VOCIyear, 10,924 Ib-NOxIyear, 32,596 Ib-COIyear, 16,958 Ib-PMlOIyear, and 80,885 Ib-SOxIyear.



David Warner Director of Permit Services

Enclosure

S e y e d S a d r e d i n Executive DirectorlAir Pollution Control Officer

Northern Region Central Region (Main Office) Southern Region 4800 Enterprise Way 1990 E. Gettysburg Avenue 34946 Flyover Court

Modesto, CA 95356.8718 Fresno. CA 93726.0244 Bakersfield, CA 93308.9725 Tel: (209) 557-6400 FAX: (209) 557.6475 Tel: (559) 230.6000 FAX: (559) 230.6061 Tel: 661.392.5500 FAX: 661.392.5585

Pt~nred on recycled paper. 0

Fresno Bee

NOTICE OF PRELIMINARY DECISION FOR THE PROPOSED ISSUANCE OF

EMISSION REDUCTION CREDITS

NOTICE IS HEREBY GIVEN that the San Joaquin Valley Unified Air Pollution Control District solicits public comment on the proposed issuance of Emission Reduction Credits to Spreckels Sugar Company for the shutdown of one beet sugar processing operation, one 40 MMBtuIhr fuel oil fired lime kiln and one 31 1 MMBtuIhr natural gas fired boiler, located at 39400 Whitesbridge Road in Mendota, CA. The quantity of ERC1s proposed for banking is 2,253 Ib-VOClyear, 10,924 Ib-NOxlyear, 32,596 Ib-COlyear, 16,958 Ib-PM~~lyear, and 80,885 Ib- SOxlyear.

The analysis of the regulatory basis for this proposed action, Project #C- 1090909, is available for public inspection at http:llwww.valleyair.org/notices/public~noticesidx.htm and the District office at the address below. Written comments on this project must be submitted within 30 days of the publication date of this notice to DAVID WARNER, DIRECTOR OF PERMIT SERVICES, SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT, 1990 EAST GETTYSBURG AVENUE, FRESNO, CA 93726.

Emission Reduction Credit Ban,king Application Review

Shutdown of Beet Sugar Manufacturing Operations

Processing Engineer: Dustin Brown Lead Engineer: Joven Refuerzo

Date: March 24,201 1

Facility Name: Mailing Address:

Primary Contact: Phone: Email:

Spreckels Sugar Company P 0 Box 68 Mendota, CA 93640

John Dean - Regional Manager (559) 655-4961 Ext. 273 [email protected]

Alternate Contact: Anne Ogrey Phone: (209) 834-7679 E-mail: [email protected]

Facility Location: 29400 Whitesbridge Road Fresno, CA 93640

Deemed Complete Date: December 11,2009 Project Number: C-I090909

I. Summary:

Spreckels Sugar Company operated a sugar beet processing facility in Fresno, CA. The facility ceased production operations in August of 2008 and began disassembling and removing the equipment associated with the beet sugar manufacturing process (PTO C-1179-I), one 40.0 MMBtuIhr natural gas or fuel oil fired lime kiln (PTO C-1179- 2) and one 31 1.0 MMBtuIhr natural gas fired boiler (PTO C-1179-6) from the site in May of 2009. Therefore, the facility is applying for NOx, CO, VOC, PMlo and SOx emissions reduction credits for the shutdown of these sugar beet processing operations.

The District acknowledges that this ERC banking project was deemed complete on December 11, 2009 and should have been processed and sent out for preliminary notice within 60 days of being deemed complete. However, the project file was inadvertently misplaced for a long period of time and was only recently rediscovered. Therefore, the District is now moving forward with the processing of this project, as expeditiously as possible.

Spreckels Sugar Company has also surrendered Permits to Operate (PTO1s) C-1179-1- 3, '-2-3 and '-6-8. A copy of the surrendered PTO's is included in Attachment A of this document.

Spreckels Sugar Company C- 1 1 79, 1090909

Based on the historical operating data prior to the shutdown, the amounts of bankable Actual Emission Reductions (AER's) for NOx, CO, VOC, PM10 and SOx emissions are as shown in the table below. These values are calculated in Section V of this document:

Bankable Emissions Reductions Credits (ERC's)

Pollutant

II. Applicable Rules:

1 VOC 0 767 1,032 454

Rule 2201 - New and Modified Stationary Source Review Rule (9121106) Rule 2301 - Emission Reduction Credit Banking (1 211 7192) Rule 4201 - Particulate Matter Concentration (1 211 7192) Rule 4202 - Particulate Matter - Emission Rate (12117192) Rule 4301 - Fuel Burning Equipment (1 211 7192) Rule 4306 - Boilers, Steam Generators and Process Heaters - Phase 3 (1 0116108) Rule 431 3 - Lime Kilns (3127103) Rule 4320 - Advanced Emission Reduction Options for Boilers, Steam Generators, and

Process Heaters Greater than 5.0 MMBtuIhr (10116108) Rule 4801 - Sulfur Compounds (1 211 7192)

1'' Qtr. ERC's (I blq t r) ~

Ill. Location of Reductions:

Physical Location of Equipment: 29400 W. Whitesbridge Road in Mendota, CA.

znd Qtr. ERC's (I blq tr)

IV. Method of Generatinq Reductions:

The AER's were generated by shutting down the beet sugar manufacturing process, one 40.0 MMBtuIhr natural gas or oil fired lime kiln and one 31 1.0 MMBtuIhr natural gas fired boiler. The equipment description for each unit is as follows:

3rd Qtr. ERC's (I blq t r)

BEET SUGAR MANUFACTURING PROCESS WlTH FIRST CARBONATION, SETTLING AND FILTRATION; SECOND CARBONATION, SULFITATION, CARBON ABSORPTION, CRYSTALLINE SUGAR MELTING, SUGAR DRYING, AND CARBON REGENERATION WlTH 2.4 MMBTUIHR CARBON KILN SERVED BY VEN-TRISLOT SCRUBBER AND CYCLONE

4th Qtr. ERC's (I blq t r)


40 MMBTUIHR ROTARY DRUM LIME KILN DIRECT-F1RE.D COEN OIL BURNER USING #6 FUEL OIL OR NATURAL GAS, EXHAUS'TING TO WATE,R SPRAY SCRUBBER, PEABODY TRAY SCRUBBER, AND TO CARBONA'I'ION

31 1 MMBTUIHR COMBUSTION ENGINEERING BOILER, MODEL VU60 N0.0516, EQUIPPED WITH FOUR COEN 4-DAF-30 LOW NOX GASIOIL BURNERS AND A FLUE GAS RECIRCULATION SYSTEM

V. Calculations:

A. Assumptions

C-1179-1 (sugar beet processing line):

- PMgo is the only pollutant emitted from the sugar best processing operations - The carbon kiln listed under this permit unit was not used during the

baseline period; therefore, no emissions reductions will be associated with that part of this sugar beet processing operation (historical actual usage records provided by Spreckels Sugar for this project)

C-I 179-2 (40 MMBtu/hr lime kiln):

- During the baseline period, the lime kiln was only fired on fuel oil #6 (fuel usage records provided by the applicant)

- NOx, CO, VOC, PMlo and SOx err~issions were the only pollutants generated from the combustion of fuel oil #6 in the lime kiln

- Fuel oil #6 higher heating value is 150,000 Btulgallon (typical District value) - 10 therms = 1 MMBtu of heat output (conversion factor received from Pacific

Gas and Electric Company)

C- 1 1 79-6 (31'1 MMBtu/hr boiler):

- During the baseline period, the boiler was only fired on PUC-regulated natural gas (fuel usage records provided by the applicant)

- NOx, CO, VOC, PMlo and SOx emissions were the only pollutants gene~ated from the combustion of natural gas in the boiler

- Natural gas higher heating value is 1,000 Btulscf (typical District value) - 1'0 therms = 1 MNlBtu of heat output (conversion factor received from Pacific

Gas and Electric Company)


B. Emission Factors (EF's)

C-I 179-1 (sugar beat processing):

The beet sugar processing operation has never been source tested for PMlo emissions. In addition, the permit for the beet sugar processing operation does not list any PMlo emission factors. In accordance with AP-42, section 9.10.1.2, the only PMlo emissions from the sugar beet processing operation is from the drying of the sugar crystals once they have been separated from the liquor solution they are processed in. The drying of the sugar crystals at this facility occurred in two stages. The first stage was the sugar granulator and the second stage was the sugar cooler. Both stages were served by a centrifugal separator equipped with water sprays. AP-42, Table 9.10.1.2-1, dated March 1997, shows the following total particulate matter (Filterable plus condensable PM) emission factors for these types of operations:

Sugar Granulator PM EF: 0.0677 Ib-PMIton of sugar output Sugar Cooler PM EF: 0.1 343 Ib-PMlton of sugar output

Total PM EF: 0.202 Ib-PMIton of sugar output

District Rule 2201, section 4.1 1.2, states that in the absence of PMlo err~ission factors or speciation data, 50% of the total suspended particulates emission factor shall be assumed to be PMlo. Since this operation never performed PMlo source testing on the sugar drying operation and AP-42 only lists PM emission factor data, the total PMlo emission factor for this operation will be detecmined as follows:

Total PMlo EF = Total PM EF (Iblton of sugar output) x 0.50 Ib-PMldlb-PM Total PMIO EF = 0.202 Ib-PMIton of sugar output x 0.50 Ib-PMldlb-PM

Total PMlo EF = 0.101 Ib-PM40/ton of sugar output

C-1779-2 (40 MMBtu/hr lime kiln):

NOx Emissions:

This lime kiln was source tested for NOx emissions two times, May 13, 2004 and May 3, 2007 (lime kiln source test result summary pages included in Attachment E). Therefore, the historical actual NOx emissions during the baseline period will be calculated utilizing the lower of either the permitted emission factor or the average of the emission factors measured during the source tests.


Source Test

CO Emissions:

This lime kiln was never source tested for CO emissions. AP-42, Section 11 .I 7, Table 11 . I 7-6 lists emission factors for lime manufacturing. However, only emission factors for coal fired and gas fired lime kilns are listed. Information provided by the applicant for this project indicates that the lime kiln was only fired on #6 fuel oil during the baseline period. Therefore, AP-42, Section 11 .I 7 cannot be used to reference emission factors for an oil fired lime kiln.

AP-42, Sections 1.3 and 1.4 list emission factors for gas and oil combustion in boilers and furnaces, respectively. The gas fired lime kiln emission factors listed in AP-42, Section 11 . I7 were compared to the gas fired boiler emission factors listed in AP-42, Section 1.4 (see comparison in Attachment G). The gas fired boiler emission factors listed in AP-42, Section 1.4 were much less than the gas fired lime kiln emission factors listed in AP-42, Section 11 .I 7. Therefore, it will be assumed that the oil fired boiler emission factors listed in AP-42, Section 1.3 are representative of the emissions that could have been expected from Spreckels Sugar's oil fired lime kiln.

Therefore, the historical actual CO emissions during the baseline pe~iod will be calculated utilizing the lower of either the permitted emission factor or the emission factor for fuel oil corr~bustion from AP-42, Table 1.3-1 (9/98), Boilers less than 100 MMBtuIhr, as presented in the table below.

Pollutant

CO * 5.0 1b110' gallons converted to IblMMBtu using the following equation: (5 1b110' gallon) x (gallon11 50,000 Btu) x ( lo6 BtulMMBtu3 = 0.033 IblMMBtu.

Permitted EF (IblMMBtu)

0.033

AP-42 EF (I blMMBtu)

0.033*

HAE EF (I b1MMBtu)

0.033


VOC Emissions:

This lime kiln was never source tested for VOC emissions. AP-42, Section 1 1.17, Table 1 1 . I 7-6 lists emission factors for lime manufacturing. However, only emission factors for coal fired and gas fired lime kilns are listed. Information provided by the applicant for this project indicates that the lime kiln was only fired on #6 fuel oil during the baseline period. Therefore, AP-42, Section 11 . I7 cannot be used to reference emission factors for an oil fired linie kiln.

AP-42, Sections 1.3 and 1.4 list emission factors for gas and oil combustion in boilers and furnaces, respectively. The gas fired lime kiln emission factors listed in AP-42, Section 11 .I7 were compared to the gas fired boiler emission factors listed in AP-42, Section 1.4 (see comparison in Attachment G). The gas fired boiler errlission factors listed in AP-42, Section 1.4 were much less than the gas fired lime kiln emission factors listed in AP-42, Section 11.17. Therefore, it will be assumed that the oil fired boiler emission factors listed in AP-42, Section 1.3 are representative of the emissions that could have been expected from Spreckels Sugar's oil fired lime kiln.

Therefore, the historical actual VOC emissions during the baseline period will be calculated utilizing the lower of either the permitted emission factor or the emission factor for fuel oil corr~bustion from AP-42, Table 1.3-3 (9/98), Industrial Boilers, as presented in the table below.

PMlo Emissions:

Pollutant

VOC

This lime kiln was source tested for PMlo emissions on September 23, 1977. The source test only displayed results in grainslstandard cubic feet and pounds per hour. 'There was no additional information provided to indicate the firing or processing rate of the lime kiln at the time of the test to determine. Therefore, useful PMlo emission factors could not be derived from the data obtained during that source test.

AP-42, Section 11 . I 7, Table 11.17-6 lists emission factors for lime manufacturing. However, only emission factors for coal fired and gas fired lime kilns are listed. Information provided by the applicant for this project indicates that the lime kiln was only fired on #6 fuel oil during the baseline period. Therefore, AP-42, Section 1 1.17 cannot be used to reference emission factors for an oil fired lime kiln.

* 0.28 1b110' gallons converted to IbIMMBtu using the following equation: (0.28 1b110' gallon) x (gallon11 50,000 Btu) x ( lo6 BtuIMMBtu) = 0.0019 IbIMMBtu.

HAE EF (I b/MMBtu)

0.001 9

Permitted EF (I b/M MBtu)

0.002

AP-42 EF (I b/MMBtu)

0.001 9*


AP-42, Sections 1.3 and 1.4 list emission factors for gas and oil combustion in boilers and furnaces, respectively. The gas fired lime kiln emission factors listed in AP-42, Section 1 1.17 were compared to the gas fired boiler emission factors listed in AP-42, Section 1.4 (see comparison in Attachment G). The gas fired boiler emission factors listed in AP-42, Section 1.4 were much less than the gas fired lime kiln emission factors listed in AP-42, Section 11.17. Therefore, it will be assumed that the oil fired boiler err~ission factors listed in AP-42, Section 1.3 are representative of the emissions that could have been expected from Spreckels Sugar's oil fired lime kiln.

Therefore, the historical actual PMlo emissions during the baseline period will be calculated utilizing the lower of either the permitted emission factor or the emission factor for fuel oil combustion from AP-42, Table 1.3-1 (9/98), Boilers less than 100 NINIBtuIhr, as presented in the table below.

I1 . .. 11

* 5.75 1 b l l 0 ~ gallons converted to IbIMMBtu using the following equation: (0.28 1bl10' gallon) x (gallon/150,000 Btu) x ( lo6 BtuIMMBtu) = 0.038 IbIMMBtu.

Pollutant

PMqn

SOx Emissions:

This lime kiln was never source tested for SOx emissions. AP-42, Section 1 1 .I 7, Table 11.17-6 lists emission factors for lime manufacturing. However, only emission factors for coal fired and gas fired lime kilns are listed. Information provided by the applicant for this project indicates that the lime kiln was only fired on #6 fuel oil during the baseline period. Therefore, AP-42, Section 11 .I 7 cannot be used to reference eniission factors for an oil fired lime kiln.

Permitted EF (I b1MMBtu)

0.031

AP-42, Sections 1.3 and 1.4 list emission factors for gas and oil combustion in boilers and furnaces, respectively. The gas fired lime kiln emission factors listed in AP-42, Section 11 . I7 were compared to the gas fired boiler emission factors listed in AP-42, Section 1.4 (see comparison in Attachment G). The gas ,fired boiler ernission factors listed in AP-42, Section 1.4 were much less than the gas fired lime kiln emission factors listed in AP-42, Section 11.17. Therefore, it will be assumed that the oil fired boiler emission factors listed in AP-42, Section 1.3 are representative of the emissions that could have been expected from Spreckels Sugar's oil fired lime kiln.

('' AP-42 emission factor is a combined total of the filterable particulate matter and the condensible particulate mattter (10 lb/103 gallons + 1.5 lb110~ gallons = 11.5 lb/103 gallons). In accordance with District Rule 2201, Section 4.1 1.2, since the AP-42 emission factor only totals the PM and not PMIo, 50% of the total PM emission factor will be used for the purposes of these HAE calcualtions: 11.5 I~-PM/IO~ gallons x 0.5 Ib-PM,dlb-PM = 5.75 I ~ - P M , ~ I O ~ gallons.

AP-42 EF") (I blMMBtu)

0.038*

HAE EF (I blM M Btu)

0.031


Therefore, the historical actual SOx emissions during the baseline period will be calculated utilizing the lower of either the permitted emission factor or the emission factor for fuel oil combustion from AP-42, Table 1.3-1 (9/98), Boilers less than 100 MMBtuIhr, as presented in the table below.

Permitted EF AP-42 EF") HAE ElF 11 Pollatant I IlblMMBtuJ I IlblMMBtu, I IlblMMBtu, I

C- 1 I 79-6 (3 1 1 MMBtu/hr boiler):

sox

NOx and CO Emissions:

This boilerloxidizer system was source tested for NOx and CO emissions two times, May 4,2005 and May 14,2008 (boiler source test result summary pages included in Attachment F). Therefore, the historical actual NOx and CO emissions during the baseline period will be calculated utilizing the lower of either the permitted emission factor or the average of the emission factors measured during the source tests.

* 94.2 1b110' gallons converted to IblMMBtu using the following equation: (0.28 1b110' gallon) x I]

(gallon/I150,000 Btu) x ( l o6 BtuIMMBtu) = 0.628 IbIMMBtu.

1.57

") AP-42 emission factor is 157 times the fuel oil #6 sulfur content. The permit for this lime kiln limits the maximum fuel sulfur content to 1.5%. However, based on the inspection reports for this facility dating from 2005 through 2008, the actual fuel certifications for the fuel oil #6 used in this lime kiln show that the sulfur content was 0.6%. Therefore, as a conservative estimate, the AP-42 emission factor will be determined using a fuel sulfur content of 0.6%.

0.628* 0.628

Spreckels Sugar Company C- 1 179, 1090909

VOC Emissions:

This boiler was never source tested for voc emissions. Therefore, the historical actual VOC emissions during the baseline, period will be calculated utilizing the lower of either the permitted emission factor or the emission factor for natural gas combuktion from AP-42, Tables 1.4-1 and 1.4-2 (7/98), as presented in the table below.

PMlo Emissions:

Pollutant

VOC

This boiler was never source tested for PMlo emissions. Therefore, the historical actual PMlo emissions during the baseline period will be calculated utilizing the lower of either the permitted emission factor or the emission factor for natural gas combustion from AP-42, Tables 1.4-1 and 1.4-2 (7/98), as presented in the table below.

Permitted EF (IblMMBtu)

0.002

SOx Emissions:

This boiler was never source tested for SOx emissions. Therefore, the historical actual SOx emissions during the baseline period will be calculated utilizing the lower of, either the perrnitted SOx EF, or the SOx EF for natural gas com bustion from District Policy APR 1 720, Generally Accepted SOx Emission Factor for Combustion of PUC-Quality Natural Gas, as presented in the table below.

AP-42 EF (I blMMBtu)

0.0055

Pollutant

PMIO

HAE EF (I blMMBtu)

0.002

AP-42 EF (I b1MMBtu)

0.0076

Permitted EF (I blMMBtu)

0.005

HAE EF (I b1MMBtu)

0.005

Pollutant

sox

Permitted EF (I bINIMBtu)

0.001

District Policy APR 1720 (IblMMBtu)

0.00285

HAE EF (IblMMBtu)

0.001


C. Baseline Period Determination and Data

Baseline Period Determination:

'The primary purpose of this facility was to produce sugar by processing sugar beets. The facility has furnished sugar production records from the facility, fuel oil usage records for the 40 MMBtuIhr lime kiln, and natural gas usage records for the 31 1 MMBtulhr boiler dating from January 2004 through December 2008. Since the primary business of this facility was producing sugar and the lime kiln and boiler were only utilized during portions of the sugar manufacturing process, the actual sugar production records will be used to determine the baseline period for this facility.

First, the normal source operation (NSO) car1 be deterrr~ined using the quarterly sugar production records provided by Spreckels Sugar Company dating from January 2004 through December 2009. As shown above, this ERC banking application was not deemed complete until December 2009. However, the facility ceased operation in December of 2008. Therefore, the production records from 2009 are all zeros. Since the normal operation of this facility did not resl-~lt in zero sugar production, the 2009 data will not be include in the NSO determination.

I I I I I

Average I 0 38,638 40,292 8,643 21,893 11

Normal Source Operation (NSO) Determination

In accordance with District Rule 2201, Section 3.8, the baseline period is the two consecutive years of operation immediately prior to the submission of the complete application; or another period of at least two consecutive years within the five years immediately prior to the submission of the complete application if it is more representative of Normal Source Operations (NSO).

Year

2004 2005 2006 2007 2008

As discussed above, the two consecutive years prior to the submission of the complete application are not representative of NSO since 2009 included no sugar production. Therefore, the District will look at another time period of at least two years within the five years immediately prior to the submission of the complete application to determine the baseline period.

Q1 Sugar Production

(tonlqtr)

0 0 0 0 0

Q2 Sugar Production

(tonlqtr)

53,712 45,097 37,870 29,254 27,256

4 3 Sugar Production

(tonlqtr)

48,065 45,258 33,1105 45,614 29,417

4 4 Sugar Production

(tonlqtr)

12,869 2 1,255 9,090

0 0

Average Sugar

production (tonlqtr) 28,662 27,903 20,016 18,717 14,168

Spreckels Sugar Company C-1179, 1090909

Based on the records provided by the facility, the period of time that most closely represent this facility's normal source ope~ations was the two year period dating from the start of the 3rd quarter in 2005 to the end of the 2"d quarter in 2007. Therefore, baseline period has been determined to be the two year period dating from the start of the 3rd quarter in 2005 to the end of the 2nd quarter in 2007 (see Attachment C for the Baseline Period Determination Calculations).

Baseline Period Data:

The following sugar production records, lime kiln oil usage records and boiler natural gas usage records were provided by Spreckels Sugar Company and can be found in Attachment D.

C-1179-1 (Sugar Produced):

C- I 1 79-2 (40 MMBtu/hr Lime Kiln):

Year

2005 2006 2007

C-I 179-6 (31 1 MMBtu/hr Boiler):

Quarter I (tonslqtr)13)

NIA 0 0

Year

2005 2006

'3' Applicant's records are in units of Cwt. C is a multiplication factor of 100 and wt is pounds. Therefore, the sugar production records were converted to tons using the following equation: tons produced = (wt (Ib) x 100) I 2,000 (Iblton).

Quarter 2 (tons/qtr)(')

NIA 37,870 29,254

Quarter I (thermslqtr)

NIA 0

Year

2005 2006 2007

Quarter 3 ( t~ns lq t r ) '~ )

45,258 33,105

NIA

Quarter 2 (thermslqtr)

NIA 525.303

Quarter 4 (tons/qtr)(')

21,255 9,090 NIA


3,031,524 1,462,673

NIA

Quarter I (thermslqtr)

NIA 0 0


720,965 598.202


401 , I 32 167.371


NIA 4,169,952 3,443,700


5,511,829 4,694,896

NIA


D. Historical Actual Emissions (HAE's)

C-1179-1 (beet sugar processing):

As shown above, a PMIO emission factor of 0.101 Iblton of sugar output will be used to calculate the HAE's from the shutdown of this sugar beet processing operation. Therefore, the historical actual PMlo emissions can be estimated using this emission factor and the sugar beet processing rates listed above.

PMIO HAE = 0.1 01 Iblton of sugar output x Throughput (tons of sugarlquarter)

PMlo HAE

C- I I 79-2 (40 MMBtu/hr lime kiln):

Year

2005 2006 2007

Average

NOx Emissions:

As shown above, a NOx emission factor of 0.0227 IbIMMBtu (17.2 ppmvd @ 3% 02) will be used to calculate the HAE's from the shutdown of this lime kiln. Therefore, the historical actual NOx emissions can be estimated using this emission factor and the fuel usage rates listed above.

Q1 (Iblquarter)

NIA 0 0

0

NOx HAE = 0.0227 IbIMMBtu x Fuel Oil Usage (thermslqtr) x 1 NlMBtu I 10 therms

3,390

Q4 (Iblquarter)

2,147 91 8 NIA

Q2 (lblquarter)

NIA 3,825 2.955

NOx HAE

Q3 (Iblquarter)

4,571 3,344 NIA

3,958

Year

2005 2006

I I I I I

1,533

Average

Q1 (I blq uarter)

NIA 0

0

Q4 (Iblquarter)

91 1 380

Q2 (I blq uarter)

NIA 1 ,1'92

11,066

Q3 (Iblquarter)

1,637 1,358

1,,498 646

Spreckels Sugar Company C- 1 1 79, 1~090909

CO Emissions:

As shown above, a CO emission factor of 0.033 IbIMMBtu will be used to calculate the HAE's from the shutdown of this lime kiln. Therefore, the historical actual CO emissions can be estimated using this emission factor and the fuel usage rates listed above.

CO HAE = 0.033 IbIMMBtu x Fuel Oil Usage (thermslqtr) x 1 NlNlBtu / 10 therms

VOC Emissions:

CO HAE

As shown above, a VOC emission factor of 0.0019 IbIMMBtu will be used to calculate the HAE's from the shutdown of this lime kiln. Therefore, the historical actual VOC emissions can be estimated using this emission factor and the fuel usage rates listed above.

Year

2005 2006 2007

Average

VOC HAE = 0.0019 IbIMMBtu x Fuel Oil Usage (thermslqtr) x 1 MMBtu / 10 therms

Q1 (I blquarter)

N/A 0 0

0

PMlo Emissions:

VOC HAE

As shown above, a PMlo emission factor of 0.031 IbIMMBtu will be used to calculate the HAE's from the shutdown of this lime kiln. Therefore, the historical actual PMlo emissions can be estimated using this emission factor and the fuel usage rates listed above.

Q2 (I blquarter)

N/A 1,733 1,365

1,549

Year

2005 2006 2007

Average

Q3 (Iblquarter)

2,379 1,974 NIA

2,177

Q4 (I blquarter)

1,324 552 N/A

938

Q l (I blquarter)

N/A 0 0

0

Q2 (I blquarter)

N/A 100 79

90

Q3 (I blquarter)

137 114 N/A

126

Q4 (I blquarter)

76 32 NIA

54


PMqo HAE = 0.031 IblMMBtu x Fuel Oil Usage (thermslqtr) x 1 MMBtu I 10 therms

SOx Emissions:

PMlo HAE

As shown above, a SOx emission factor of 0.628 IbIMMBtu will be used to calculate the HAE's from the shutdown of this lime kiln. Therefore, the historical actual SOx emissions can be estimated using this emission factor and the fuel usage rates listed above.

Year

2005 2006 2007

Average

SOx HAE = 0.628 IbIMMBtu x Fuel Oil Usage (thermslqtr) x 1 MMBtu 1 10 therms

II SOX HAE II

Q1 (I blquarter)

NIA 0 0

0

Average 0 29,480 41,422 17,851 1

Year

2005 2006 2007

C-1179-6 (311 MMBtu/hr boiler):

4 4 (I blquarter)

1,244 51 9 NIA

882

4 2 (Il blquarter)

NIA 1,628 1,282

1,455

NOX Emissions:

Q3 (Il blquarter)

2,235 1,854 NIA

2,045

Q l (Iblquarter)

NIA 0 0

As shown above, a surplus NOx emission factor of 0.0307 IblMMBtu (25.2 ppmvd @ 3% 02) will be used to calculate the HAE's from the shutdown of this boiler. Therefore, the historical actual NOx emissions can be estimated using this emission factor and the fuel usage rates listed above.

NOx HAE = 0.0307 IbIMMBtu x NG Usage (thermslqtr) x 1 MMBtu I 10 therms

-. Q2

(Iblquarter) NIA

32,989 25.970

Q3 (Ilblquarter)

45,277 37,567

NIA

Q4 (I blquarter)

25,191 10,511 -

NIA


CO Emissions:

NOx HAE

As shown above, a CO emission factor of 0.0282 IblMMBtu (38.05 ppmvd @ 3% 02) will be used to calculate the HAE's from the shutdown of this boiler. Therefore, the historical actual CO emissions can be estimated using this emission factor and the fuel usage rates listed above.

Year

2005 2006 2007

Average

CO HAE = 0.0282 IbINIMBtu x NG Usage (thermslqtr) x 1 MMBtu I 10 therms

Q1 (I blquarter)

NIA 0 0

0

VOC En-rissions:

CO HAE

As shown above, a VOC emission factor of 0.002 IbIMMBtu will be used to calculate the HAE's from the shutdown of this boiler. Therefore, the historical actual VOC emissions can be estimated using this emission factor and the fuel usage rates listed above.

Q2 (I blquarter)

NIA 12,802 10,572

11,687

Year

2005 2006 2007

Average

VOC HAE = 0.002 IbIlVIMBtu x NG Usage (thermslqtr) x 1 MMBtu I 10 the~ms

Q3 (I blquarter)

16,921 14,4183

NIA

15,667

Q1 (Iblquarter)

NIA 0 0

0

Q4 (Iblquarter)

9,307 4,490 NIA

6,899

VOC HAE

4 2 (Iblquarter)

NIA 11,759 9,711

10,735

Year

2005 2006 2007

Average

4 3 (Iblquarter)

15,543 13,240

NIA

14,392

Q1 (Iblquarter)

NIA 0 0

0

Q4 (Iblquarter)

8,549 4,125 NIA

6,337

Q2 (Iblquarter)

NIA 834 689

762

Q3 (Iblquarter)

1,102 939 NIA

1,021

4 4 (Iblquarter)

606 293 NIA

450

Spreckels Sugar Company C- 1 1 79, 1,090909

PMlo Emissions:

As shown above, a PMlo emission factor of 0.005 IbIMMBtu will be used to calculate the HAE's from the shutdown of this boiler. Therefore, the historical actual PMlo emissions can be estimated using this emission factor and the fuel usage rates listed above.

PMI0 HAE = 0.005 IbIMMBtu x NG Usage (thermslqtr) x 1 MMBtu 1 10 therms

SOx Emissions:

PMlo HAE

As shown above, a SOx emission factor of 0.001 IbIMMBtu will be used to calculate the HAE's from the shutdown of this boiler. Therefore, the historical actual SOx emissions can be estimated using this emission factor and the fuel usage rates listed above.

Year

2005 2006 2007

Average

SOx HAE = 0.001 IbIMMBtu x NG Usage (thermslqtr) x 1 MMBtu 1 10 therms

Q1 (I blquarter)

NIA 0 0

0

E. Adjustments to HAE's

SOx HAE

Pursuant to Section 3.22 of Rule 2201, Historical Actual Emissions must be discounted for any emissions reduction which, is:

4 2 (I blquarter)

NIA 2,085 1,722

1,904

required or encumbered by any laws, rules, regulations, agreements, orders, or

e attributed to a control measure noticed for workshop, or proposed or contained in a State Implementation Plan, or proposed in the District Air Quality Plan for attaining the annual reductions required by the California Clean Air Act.

Year

2005 2006 2007

Average

4 3 (I blquarter)

2,756 2,347 NIA

2,552

Q1 (Iblquarter)

NIA 0 0

0

Q2 (Iblquarter)

NIA 41 7 344

381

4 4 (I blquarter)

1,516 731 NIA

1,124

Q3 (Iblquarter)

551 469 NIA

51 0

Q4 (Iblquarter)

303 146 NIA

225


Adjustment for Rule 2201 - New and Modified Stationary Source Review Rule:

Section 2.0 states that this rule shall apply to all new stationary sources and all modifications to existing stationary sources which are subject to the District permit requirements and after construction emit, or may emit, one or more affected pollutants.

C-1179-1 (sugar beet processing):

As discussed above, Spreckels Sugar Company is proposing to receive emission reduction credits for the shutdown of the sugar beet processing operations at this location. 'This facility is not a new stationary source and the shutdown of this operation does not meet the definition of a modification. Therefore, Rule 2201 does not apply at this time.

Pursuant to information in the facility files, this operation was not previously ever subject to the provisions of District Rule 2201. Therefore, no adjustment to the calculated HAE's above is necessary.


As discussed above, Spreckels Sugar Company is proposing to receive emission reduction credits for the shutdown of their beet sugar processing operations at this location. This facility is not a new stationary source and the shutdown of this operation does not meet the definition of a modification. Therefore, Rule 2201 does not apply at this time.

In accordance with information in the facility files, this operation was previously subject to District Rule 2201 when the original permits were issued and subsequently modified in 1998. Based on the actual production records provided by Spreckels Sugar Company, this operation demonstrated compliance with alJ of the Rule 2201 requirements (best available control technology (BACT), daily emission limits, etc.). Therefore, no adjustment to the calculated HAE's above is necessary.

C-I 179-6 (31 1 MMBtu/hr boiler):

As discussed above, Spreckels Sugar Company is proposing to receive emission reduction credits for the shutdown of their beet sugar processing operations at this location. 'This facility is not a new stationary source and the shutdown of this operation does not meet the definition of a modification. Therefore, Rule 2201 does not apply at this time.


In accordance with information in the facility files, this operation was previously subject to District Rule 2201 when the original permits were issued and subsequently modified in 2004.. Based on the actual production records provided by Spreckels Sugar Company, this operation demonstrated compliance with all of the Rule 2201 requirements (best available control technology (BACT), daily emission limits, etc.). Therefore, no adjustment to the calculated HAE's above is necessary.

Adjustment for Rule 4201 - Particulate Matter Concentration:

Section 3.1 prohibits discharge of dust, fumes, or total particulate matter into the atmosphere from any single source operation in excess of 0.1 grain per dry standard cubic foot.


PM Conc. (grlscf) = (PM emission rate) x (7,000 grllb) (Air flow rate) x 660 minlhr) x (24 hrlday)

PMlo emission rate = 49.7 ~ b / d a ~ ( ~ ) PM emission rate = 99.4 lblday (assuming 50% of the PM is PMlo) Exhaust Gas Flow = 11,000 scfm (provided by the applicant for this project)

PM Conc. (grlscf) = [(99.4 lblday) * (7,000 grllb)] + [(I 1,000 ft3/min) * (60 minlhr) * (24 hrlday)] PM Conc. = 0.044 grldscf

Therefore, the emission factor used to calculate the actual PM emission concentration from this sugar beet processing operation demonstrates that this unit was in compliance with the requirements of this rule and no adjustment is necessary.


F-Factor for Fuel Oil #6: 9,1160 dscf1MMBtu at 60 O F

PMlo Emission Factor: 0.031 Ib-PMlo/MMBtu Percentage of PlVl as PMlo in Exhaust: 100% Exhaust Oxygen (02) Concentration: 3% Excess Air Correction to F Factor = 20.9 = 1.17

(20.9 - 3)

0.031lb-PM 7,000grain 9 , 1 6 0 f r 3 x , . 1 7 X

MMB tu lb - PM ) I [ MMBlu

(4) Daily PMlo emission rate determined using the worst case historical actual emissions calculated above for the 3d quarter of 2005 and the maximum number of operating days in that quarter: (4,571 Ib-PMldqtr / 92 daysl3rd qtr = 49.7 Ib-PM,dday).

18


GL = 0.020 grainldscf < 0.1 grainldscf

In addition, the source test performed on this lime kiln on September 23, 1977, showed that the maximum PM concentration in the exhaust stack was 0.029 grainsldscf.

Therefore the emission factor used to calculate the actual PM emission concentration from this lime kiln demonstrates that this unit was in compliance with the requirements of this rule and no adjustment is necessary.

C-I 179-6 (31 1 iMMBtu/hr boiler):

F-Factor for Natural Gas: 8,578 dscf1MMBtu at 60 O F

PMlo Emission Factor: 0.005 Ib-PMlo/MMBtu Percentage of PM as PMlo in Exhaust: 100% Exhaust Oxygen (02) Concentration: 3% Excess Air Correction to F Factor = 20.9 = 1.17

(20.9 - 3)

0.005lb-PM 7,000grain 8,5783' X

MMBtu lb - PM ) [ MMBtu

Therefore the emission factor used to calculate the actual PM emission concentration from this boiler demonstrates that this unit was in compliance with the requirements of this rule and no adjustment is necessary.

Adjustment for Rule 4202 - Particulate Matter Emission Rate:


Section 4.1 of this rule contains the following equations for the allowable PM emissions:

E = 3 . 5 9 ~ ' ~ ~ P less than or equal to 30 tonslhr) 6 E = 17.31 PO (P greater than 30 tonslhr) where, E = Emissions in Pounds per hour

P = Process weight rate in tons per hour

Based on the sugar production records provided by Spreckels Sugar Company, the maximum amount of sugar produced during any quarter of the baseline period was the 3rd quarter of 2005. Based on the additional information provided by the applicant for this project, during the 3rd quarter of 2005, this facility sliced a total of 368,856 tons of sugar beets. Using a worst case operating scenario of 24 hours per day and 92 days in the third quarter, the maximum hourly processing rate is as follows:


P = 368,856 (tons-3rd quarter) 1 [92 (days/3rd quarter) x 24 (hourslday)]

P = 167.1 tonslhour

Therefore, the allowable PM emission rate is:

During the 3rd quarter of 2005, the historical actual PMlo emissions were 4,571 pounds. Assuming as a worst case that the PMlo emissions only accounted for 50% of the total PM emissions from this operation (Rule 2201, 4.1 1.2) and using a worst case operating scenario of 24 hours per day and 92 days in the third quarter, the maximum hourly PM emissions rate is as follows:

Eactual = [4,571 (Ib PMIO-3rd quarter) x Ib-PM I 0.5 Ib-PMlo] I [92 (days13'~ quarter) x 24 (hourslday)]

Eactual = 4.14 Iblhr

Therefore the emission factor used to calculate the actual PM emission rate from this beet sugar processing operation demonstrates that this unit was in compliance with the requirements of this rule and no adjustment is necessary.

Adiustment for Rule 4301 - Fuel Burning Equipment:

C-1,179-2 and '-6 (lime kiln and boiler):

This rule specifies maximum emission rates in Iblhr for S02, N02, and combustion contaminants (defined as total PM in Rule 1020).

Therefore the emission factors used to calculate the historical actual emissions from the 40 MMBtuIhr lime kiln and the 31 1 MMBtuIhr boiler meet the requirements for this rule and no adjustment is necessary.

Spreckels Sugar Company C- 1 179, 1090909

Adjustment for Rule 4306 - Boilers, Steam Generators and Process Heaters - Phase 3:

C- I 179-6 (31 1 MMBtu/hr boiler):

Pursuant to information in the facility files, the boiler operated by Spreckels Sugar was determined to be a load following unit. District Rule 4306, Section 5.1, Category G requires a 31 1 MMBtuIhr natural gas fired, load following boiler to comply with the following limits: NOx: 15 ppmv @ 3% 02; and CO: 400 ppmv @ 3% 0 2 . As discussed in the adjustments for Rule 4320 below, the historical actual NOx emissions from the boiler will be calculated based on an adjusted emission factor of 7 ppmv @ 3% 02. In addition, the historical actual CO emissions for the boiler will be calculated using an emission factor of 38.05 ppmv @ 3% 02. Therefore the emission factors used to calculate the actual emission reductions from this boiler will meet the requirements of this rule and no adjustments or further discussion are necessary.

Adjustment for Rule 4313 - Lime Kilns:

C-I 179-2 (40 MMBtu/hr lime kiln):

Section 4.1 states that a lime kiln shall not discharge into the atmosphere any gases, which contain oxides of nitrogen, expressed as NO2, that exceed any of the following limits:

- 0.10 pound per million Btu when burning gaseous fuel; - 0.12 pound per million Btu when burning distillate fuel oil; or - 0.20 pound per million Btu when burning residual fuel oil.

As shown above, the HAE1s for NOx emissions from the lime kiln were dete~mined using an emission factor of 0.0227 IbIMMBtu. Therefore the emission factor used to calculate the historical actual emissions from this lime kiln meet the requirements for this rule and no adjustment is necessary.


Adjustment for Rule 4320 - Advanced Emission Reduction Options for Boilers, Steam Generators and Process Heaters Greater than 5.0 MMBtulhr:

C-7 7 79-6 (37 7 MMBtu/hr boiler):

District Rule 4320, Section 5.2 requires a 31 1 NIMBtuIhr natural gas fired boiler to comply with the following lirti~its: NOx: 7 ppmv @ 3% 0 2 (0.008 IblMMBtu); and CO: 400 ppmv @ 3% 02. lt i l addition, Section 5.4 states that to limit particulate matter emissions, all boilers shall fire exclusively on PUC- quality natural gas. As shown above, the HAE's for the boiler were determined using the following emission concentrations: NOx: 22.5 ppmv @ 3% 0 2 (0.0307 IblMMBtu); and CO: 38.05 ppmv @ 3% 0 2 . In addition, this unit was exclusively fired on PUC-regulated natural gas. Therefore, the fuel used in this boiler and the CO emission factor used to calculate the HAE's from this boiler meet the requirements of this rule and no adjustment is necessary.

However, the NOx emission factor used to calculate the HAE's from this boiler does not meet the current requirements of this rule. Therefore, in accordance with District Rule 2201, Section 3.22, the NOx HAE's must be discounted for the emissions reduction which are required by this rule. The discounted NOX HAE's will be calculated using the Rule 4320 emission limit of 0.008 IbIMNIBtu (7 ppmvd @ 3% 02) and the fuel usage rates listed above.

NOx HAEAdjusted = 0.008 IblMMBtu x NG Usage (thermslqtr) x 1 MMBtu I 10 therms

Average 0 3,046 4,083 1,798 11

NOX HAE~djusted

Adjustment for Rule 4801 - Sulfur Compounds:

Year

2005 2006 2007

District Rule 4801 requires that a person shall not discharge into the atmosphere sulfur compounds, which would exist as a liquid or gas at standard conditions, exceeding in concentration at the point of discharge: 0.2 % by volume calculated as SO2, on a dry basis averaged over 15 consecutive minutes.

Q1 (Iblquarter)

NIA 0 0

4 2 (Iblquarter)

NIA 3,336 2.755

Q3 (Iblquarter)

4,409 3,756 NIA

Q4 (Iblquarter)

2,425 1,170 NIA


Using the ideal gas equation and the emission factors presented in Section VII, the sulfur compound emissions are calculated as follows:

Volume SO2 = n RT P

With:

N = moles SO2 T (Standard Temperature) = 60°F = 520°R P (Standard Pressure) = 14.7 psi

R (Universal Gas Constant) = 10.73psi. ft3 Ib .mol. O R


0.00285 lb - SOX MMBtu 1 lb . mol 10.73 psi. f t 3 520°R 1,000,000~ parts X X X X X

MMBtu 8,578 dscf 6416 lb . mol OR 14.7psi million

parts SulfurConcentration = 1.97

million < 2,000 ppmv (or 0.2%)

C-1179-6 (31 1 MMBtu/hr boiler):

0.001 lb - SOX MMBtzr 1 lb . mol 10.73 psi. f t3 520°R 1,000,000. parts X X X X X

MMBtu 8,578 dscf 64 Ib lb . rnol .OR 14.7psi million

SulfurConcentration = 0.69 parts

million (or 0.2%)

Therefore, the HAE's for SOx emissions from both of these units were determined using emission factors that were in compliance with the requirements of this rule and adjustments are not necessary.

Total Adiusted Historical Actual Emissions

Based on the discussions here in Section V.E, adjustments only need to be made to the NOx emission factor for the 31 1 MMBtulhr natural gas fired boiler. All necessary adjustments have been made and the emission values in the remainder of this document below will reflect the corrected NOx emission values. No additional adjustments to the other emission factors need to be made for the purposes of this project.

Spreckels Sugar Company C- I I 79, 1090909

F. Actual Emissions Reductions (AER's):

The AER's for each unit are shown in the tables below:

C-I 179-1 (sugar beet processing):


C-1179-6 (31 1 MMBtu/hr boiler):


The combined total AER's from these units are shown in the table below:

G. Air Quality Improvement Deduction

In accordance with District Rule 2201, Sections 3.5 and 4.12.1, prior to banking, all AER's shall be discounted by 10 percent (1 0%) for Air Quality Improvement Deduction (AQID). The AQID for the AER's associated with this project are shown in the table below:

H. Bankable ERC's

The bankable emission reduction credits (ERC's) are determined by subtraction of the AQID's from the AER's and are summarized in the table below.

spreckels Sugar Company C- I 1 79, 1090909

VI. Compliance:

To comply with the definition of Actual Emissions Reductions (Rule 2201, Section 3.2.1 and Rule 2301, Sections 3.6 and 4.2.1), the reductions must be:

A. Weal

The emissions reductions were generated by the shutdown of Spreckels Sugar Company's sugar beet processing operations. The associated permits for these units have been surrendered to the District. The emissions reductions were calculated based on actual historic production data, manufacturer's specifications, and source test results. Therefore, the allowed reductions are real.

B. Enforceable

The PTO's for Spreckels Sugar Company sugar beet processing operations at this facility have been surrendered to the District. Operation of any of the equipment without a valid permit would subject the permittee to enforcement actions. Therefore, the reductions are enforceable.

C. Quantifiable

The reductions are quantifiable since they were calculated from historic production and fuel use data, source testing data, established EF's, permitted limits, and methods according to Dist1:ict Rule 2201.

D. Permanent

The reductions will be permanent since the changes are major physical changes where the facility cannot revert back to the old technology. Further, any change in operation, including an increase in emissions, would require a permit from the District. If the facility were to propose an increase in emissions in the future, offsets (as ERCs) will be required for 100% of the potential increase.

E. Surplus

To be considered sutiplus, Actual Emission Reductions shall be in excess, at the time the application for an Emission Reduction Credit or an Authority to Construct authorizing such reductions is deemed complete, of any emissions reduction which:


a Is required or encumbered by any laws, rules, regulations, agreements, orders, or

No laws, rules, regulations, agreements or orders were responsible for the surrendering the facility's permits or their subsequent application for Emission Reduction Credits (ERC 's).

Is attributed to a control measure noticed for workshop, or proposed or contained in a State lmplementation Plan, or

Currently there are no control measures noticed for workshop, or proposed or contained in a State lmplementation Plan that require the reduction of the emissions at this facility.

Is proposed in the APCO's adopted air quality plan pursuant to the California Clean Air Act.

The shutdown of thse sugar beet processing operations is not proposed in the APCO's adopted air quality plan.

Shutdown of these sugar beet processing operations was voluntary and not required by any law, rule, agreement, or regulation. The ERC's are not needed for their current or proposed operations. The ERC's are not in excess of Spreckels Sugar Company's permitted emission levels. Therefore, the reductions are surplus.

Not used for the approval of an Authority to Construct or as offsets

The ERC's generated by the proposed modifications were not used for the approval of any ATC or as offsets.

Timely submittal

Section 5.5 of Rule 2301 - Emissions Reduction Credit Banking (12/17/92) states that ERC certificate applications for reductions shall be submitted within 180 days after the emission reduction occurs. The ERC application was received on February 25, 2009. The sugar beet processing equipment permanently ceased operations at this location on August 31, 2008, and the determination was made at that time that the factory would no longer operate as a sugar beet processing facility. 'Therefore, the application was submitted in a timely fashion.


VII. Recommendation:

Pending a successful Public Noticing period, issue Emission Reduction Credit certificates C-1072-1 (VOC), C-1072-2 (NOx), C-11072-3 (CO), C-1072-4 (PMqo), and C- 11072-5 (SOx) to Spreckels Sugar Company in accordance with the amounts specified on the dvaft ERC certificates in Attachment H.

Attachments:

Attachment A, Attachment B, Attachment C, Attachment Dl

Attachment El Attachment F, Attachment G,

Attachment H,

Surrendered PTO's C-1179-1-3, '-2-3 and '-6-8 ERC Application Baseline Period Determination Spreckels Sugar Company Sugar Production, 40 MMBtuIhr Lime Kiln Fuel Oil Usage and 31 1 MMBtuIhr Boiler Natural Gas Usage Records 40 MMBtuIhr Lime Kiln NOx Source Test Result Summaries 31 1 MMBtuIhr Boiler NOx and CO Source Test Result Summaries Lime Kiln AP-42 Emission Factor to Combustion AP-42 Emission Factor Corr~parisons Draft ERC Certificates

Attachlment A

Surrendered PTO's C-1179-1-3, '-2-3 and '-6-8

San Joaquin Valley Air Pollution Control District

PERMIT UNIT: C-1 179-1-3 EXPIRA'TION DATE: 08/31/2008

EQI-IIPMENT DESCRIPTION: BEET SUGAR MANUFACTURING PROCESS WITH FIRST CARBONATION, SETTLING AWD FILTRATION; SECOND CARBONATION, SULFITATION, CARBON ABSORPTION, GRYSTALLINE SUGAR MELTING, SUGAR DRYING, AND CARBON REGENERATION WITH 2.4 MMBTUIHR CARBON KILN SERVED BY VENTRISLOT SCRUBBER AND CYCLONE

PERMIT UNIT REQU'IREMENTS - - - - - -

VentriSlot scrubber venturi throat pressure differential shall be maintained at a minimum of 14" of water. [District Rule 41 02,4.1]

Particulate matter emissions shall not exceed 0.1 grainldscf in concentration. [District Rule 42011 Federally Enforceable Through Title V Permit

Particulate matter emissions shall not exceed the hourly rate as calculated in District Rule 4202 ( I 2/17/92) using the equation E=3.59PA0.62 (P< 30 tph) or E=17.3 1 P A . 16 (P> 30 tph). [District Rule 42021 Federally Enforceable Through Title V Permit

Visible emissions from either the carbonator stacks or the VentriSlot scrubber stack shall not exceed 0% opacity (except for uncombined water vapor). [District Rule 2520, 9.3.21 Federally Enforceable Through Title V Pern~it

The VentriSlot scrubber venturi throat pressure differential shall be observed and recorded weekly during operation of this unit. These records shall include identification of the equipment, date of inspection, any corrective actions taken, and identification of the individual performing the inspection. [District Rule 2520, 9.3.21 Federally Enforceable Through Title V Permit

Visible emissions from exhaust stacks shall be checked and recorded weekly. If visible emissions are observed, corrective action shall be taken to eliminate visible emissions. If visible emissions cannot be corrected, a visible emissions test using EPA Method 9 shall be conducted within 24 hours of detecting the visible emissions. [District Rule 2520, 9.3.21 Federally Enforceable 'Through Title V Permit

If visible en~issions from either the carbonator stacks or VentriSlot scrubber stack equals or exceeds 5% opacity and cannot be corrected, permittee shall conduct a source test to determine PM emissions within 60 days of the visible emissions exceedance. [District Rule 2520, 9.3.21 Federally Enforceable Through Title V Perinit

Source testing for PM shall be performed using EPA Method 5 modified to include the back-half catch. [District Rule 108 1 ] Federally Enforceable Through Title V Permit

All required source testing shall conform to the compliance testing procedures described in District Rule 1081 (1 211 6/93). [District Rule 108 11 Federally Enforceable Through Title V Permit

Emissions for this unit shall be calculated using the arithmetic mean, pursuant to District Rule 1081 (1211 6/93), of 3 one-hour test runs for PMI 0. [District Rule 2520, 9.3.21 Federally Enforceable Through Title V Permit

These terms and conditions are part of the Facility-wide Permit to Operate. Facility Name: SPRECKELS SUGAR COMPANY Lccation: 29400 W WHITESBRIDGE RD,MENDOTA, CA 93640 C.:179-1-3 Mar 25 2009 405PM - BROWN0

San Joaquin Valley Air Poll~ltion Control District

PERMIT UNIT: C-1179-2-3 EXPIRATION DATE: 08/31/2008

SECTION: 3 TOWNSHIP: 1 4 s RANGE: 15E

EQUIPMENT DESCRIPTION: 40 MMBTUIHR ROTARY DRUM LIME KILN DIRECT-FIRED COEN OIL BURNER USING #6 FUEL OIL OR NATLIRAL GAS, EXHAUSTING TO WATER SPRAY SCRUBBER, PEABODY TRAY SCRUBBER, AND TO CARBONATION TANK.

PERMIT UNllT REQUIREMENTS 1. When firing on natural gas, emissions shall not exceed any of the following: 0.100 Ib NOx/MMBtu, 0.0006 Ib

SOdMMBtu, 0.03 1 Ib PMlOIMMBtu, 0.035 Ib CO/MMBtu, or 0.003 Ib VOCIMMBtu. All emissions are 15 minute averages. [District Rules 43 13,4.1 and 5.3; and District NSR Rule] Federally Enforceable Through Title V Permit

2. #6 fuel oil consumption shall not exceed 1.57 million gallons per year. [District NSR Rule] Federally Enforceable Through Title V Permit

3. Sulfur content of #6 fuel oil shall not exceed 1.5% by weight. [District NSR Rule] Federally Enforceable Through Title V Permit

4. When firing on #6 fuel oil, emissions shall not exceed any of the following: 0.200 Ib NOdMMBtu, 1.57 Ib SOdMMBtu, 0.03 1 Ib PM 1 OIMMBtu, 0.033 Ib CO/MMBtu, or 0.002 Ib VOCIMMBtu. All emissions are 15 minute averages. [District Rules 43 13, 4.1 and 5.3; and District NSR Rule] Federally Enforceable Through Title V Permit

5 . All emissions from this unit shall be vented to C-l 179-1. [District Rule 2520, 9.3.21 Federally Enforceable Through Title V Permit

6. Scrubber sprays andlor nozzles shall be maintained in optimum working condition. [District NSR Rule] Federally Enforceable Through Title V Permit

7. The permittee shall monitor and record the stack concentration of NOx (as N02) and 0 2 at least once every month using a portable emission monitor that meets District specifications. Monitoring shall not be required if the unit is not in operation, i.e. the unit need not be started solely to perform monitoring. Monitoring shall be performed within 1 day of restarting the unit or switching fuel source unless monitoring has been performed within the last month. [District Rule 43 13, 4.2.2 and District Rule 2520, 9.3.21 Federally Enforceable Through Title V Permit

8. If the NOx concentration corrected to 3% 02 , as measured by the pol-table analyzer, exceed the allowable emissions concentration, the permittee shall return the emissions to within the acceptable range as soon as possible, but no longer than 1 hour of operation after detection. If the portable analyzer readings continue to exceed the allowable emissions concentration after 1 hour of operation after detection, the permittee shall notify the District within the following 1 hour and conduct a certified source test within 60 days of the first exceedance. In lieu of conducting a source test, the permittee may stipulate a violation has occurred, subject to enforcement action. The permittee must then correct the violation, show compliance has been re-established, and resume ~nonitoring procedures. If the deviations are the result of a qualifying breakdown condition pursuant to Rule 1 100, the permittee may fully comply with Rule 1 100 in lieu of the performing the notification and testing required by this condition. [District Rule 43 13, 4.2.2 and District Rule 2520, 9.3.21 Federally Enforceable Through Title V Permit

PERMIT UNIT REQUIREMENTS CONTINUE ON NEXT PAGE These terms and conditions are part of the Facility-wide Permit to Operate.

Facility Name: SPRECKELS SUGAR COMPANY Location: 29400 W WHITESBRIDGE RD,MENDOTA. CA 93640 C-117S2-3: Mar 30 2009 1139AM - BROWND

Permit anit Requirements for C-1179-2-3 (continued) Page 2 of 2

9. This unit shall be tested for compliance with the NOx limit using the primary fuel source (#6 fuel oil) at least once every 12 months. After demonstrating compliance on two consecutive annual source tests, the unit shall be testednot less than once every 36 months. If a 36 month NOx source test fails to show compliance, 12 month testing shall resume. Source shall test the unit for compliance with NOx limit for natural gas combustion within 60 days of switchover if the unit's fuel source is changed to natural gas (secondary fuel). [District Rule 43 13, 5.3 and District Rule 2520, 9.3.21 Federally Enforceable Through Title V Permit

10. The permittee shall maintain records of: (1) the date and time of NOx and 0 2 measurements, (2) the 0 2 concentration in percent and the measured NOx concentration corrected to 3% 0 2 , (3) make and model of exhaust gas analyzer, (4) exhaust gas analyzer calibration records, and (5) a description of any corrective action taken to maintain the emissions within the acceptable range: [District Rule 43 13,4.2.2 and District Rule 2520,9.3.2] Federally Enforceable Through Title V Pennit

1 1 . The permittee shall keep monthly records of total hours of operation, the amount of natural gas and #6 fuel oil combusted, and of NOx emissions/emissions rates, f i~ r a period of five years, and shall make records available for inspection upon request. [District Rule 43 13, 5.1 and District Rule 2520, 9.3.2) Federally Enforceable Through Title V Permit

12. The operator shall maintain daily records of fuel oil consumption and percent of sulfur in each batch of fuel oil. Records shall be retained on site for at least five years and made available for District inspection upon request. [District Rule 2520, 9.3.2 & 9.4.21 Federally Enforceable Through Title V Permit

13. The following test methods shall be used: NOx (ppmv) - EPA Method 7E or ARB Method 100, NOx (Ib/MMBtu) - EPA Method 19, CO (ppmv) - EPA Method 10 or ARB Method 100, and stack gas oxygen - EPA Method 3A or ARB Method 100. Fuel higher heating value (hhv) shall bc certified by a third party fuel supplier or determined by ASTM Dl 826 or Dl945 in conjunction with ASTM D3588 for gaseous fuels, ASTM D240 or D4809 for liquid hydrocarbon fuels. [District Rules 1081 and 43 13, 5.21 Federally l',nforceable Through Title V Permit

These terms and conditions are part of the Facility-wide Permit to Operate. Facility Name: SPRECKELS SUGAR COMPANY Location: 29400 W WHITESBRIDGE RD,MENDOTA, CA 93640 C-11782.3 Mar 30 2OL 11 39AM - BROWN0


PERMIT UNIT: C-1179-6-8 EXPIRATION DATE: 08/31/2008

EQUIPMENT DESCRIPTION: 31 1 IVIIVIBTUIHR COMBUSTION ENGINEERING BOILER, MODEL VU60 N0.0516, EQUIPPED WITH FOUR COEN 4- DAF-30 LOW NOX GASIOIL BURNERS AND A FLUE GAS RECIRCULATION SYSTEM.

PERMIT UNIT REQUilREiMENTS Sulfur content of fuel oil shall not exceed 1.5% by weight. [District NSR Rule] Federally Enforceable Through Title V Permit

Fuel oil usage shall not exceed 336 cumulative hours per calendar year nor 48 hours per calendar year for equipment testing. [District NSR Rule and District Rule 435 1, 4.21 Federally Enforceable Through Title V Permit

O\vnerloperator shall record cumulative annual hours of operation on fuel oil. Records shall be retained for at least 5 years and shall be made available to the District upon request. [District Rules 2520, 9.4.2; 4306, 6.1; 435 1,6. l] Federally Enforceable Through Title V Permit

Flue gas recirculation system shall be operated in accordance with the manufacturer's specifications whenever the boiler is operating. [District NSR Rule] Federally Enforceable Through Title V Permit

Continuous Emissions Monitoring (CEM) equipment shall be in place and operating whenever the boiler is operating, except for CEM systems breakdowns, repairs, and required calibration checks and zero and span adjustments, in accordance with 40 CFR 60.13(e). NOx (as N02) and 0 2 must be recorded continuously when the CEM equipment is operating. [District Rule 1080 and 40 CFR Part 641 Federally Enforceable Through Title V Permit

Operation, calibration and data reduction for the CEM equipment shall be in accordance with the requirements of 40 CFR, Appendix P of Part 5 1 and Appendix B of Part 60. [District Rule 1080 and 40 CFR Part 641 Federally Enforceable Through Title V Permit

CEM equipment must be linked to a data logger which is compatible with the District's data acquisition system. [District NSR Rule] Federally Enforceable Through Title V Permit

CEM records shall be retained for at least 5 years. Records shall include occurrence and duration of start-up, shutdown or malfunction; performance testing, calibrations, checks, and maintenance of CEM; and emission measurements. [District Rule 1 0801 Federally Enforceable Through Title V Permit

Daily summaries of CEM records for each calendar quarter shall be submitted to the District within 30 days of the end of the calendar quarter. Hourly fuel stack gas flow rates and/or hourly fuel flow rates shall be measured during operation and il~cluded in quarterly reports. [District Rule 10801 Federally Enforceable Through Title V Permit

A report shall be sublnitted to the District within 30 days of the end of each calendar quarter identifying the time and date of each exceedance of emission limits, the excess emissions generated, and any conversion factor used to calculate emissions. [District Rule 10801 Federally Enforceable Through Title V Permit

The quarterly report shall identify each period of excess emissions that occurs during startups, shutdowns, or malfunctions. The nature and cause of each malfunction, corrective action taken, and preventative measures adopted shall also be reported. [District Rule 1080 and 40 CFR Part 641 Federally Enforceable Through Title V Permit


Facility Name: SPRECKELS SUGAR COMPANY Location: 29400 W WHITESBRIDGE RD,MENDOTA. CA 93640 C-117968, Mar 25 2D09 405PM - BRWVND

Permit Unit Requirements for C-1179-6-8 (continued) Page 2 of 4

12. When firing on natural gas, CO emissions shall not exceed 400 ppmv @ 3% 02,0.036 Ib NOdMMBtu (or 30 ppmv @ 3% 02) , 0.005 Ib PM IOIMMBtu, 0.001 Ib SOdMMBtu, nor 0.002 Ib VOCIMMBtu. [District Rules 4305, 5.1; 435 1, 5.0 and District NSR Rule] Federally Enforceable Through Title V Permit

13. When firing on fuel oil, emissions shall not exceed 0.009 Ib COIMMBtu, 0.535 Ib NOdMMBtu, 0.04 Ib PM I~OIMMBtu, 1.273 Ib SOdMMBtu, nor 0.002 lb VOCIMMBtu. [District Rules 4305, 5. I ; 435 I, 5.0 and District NSR Rule] Federally Enforceable Through Title V Permit

14. Particulate matter emissions shall not exceed 0.1 grainsldscf in concentration. [District Rule 42011 Federally Enforceable Through Title V Permit

15. This unit shall be source tested while firing on natural gas to measure NOx and CO emissions at least once every 12 months. After demonstrating compliance on two consecutive annual source tests, the unit shall be tested not less than once every 36 months. [District Rule 2520, 9.3.2; District Rule 4305, 6.3; District Rule 435 1, 5.01 Federally Enforceable Through Title V Permit

16. Source testing shall be conducted using the methods and procedures approved by the District. The District must be notified 30 days prior to any compliance source test, and a source test plan must be submitted for approval 15 days prior to testing. [District Rule 108 1 ] Federally Enforceable Through Title V Permit

17. The results of each source test shall be submitted to the District within 60 days thereafter. [District Rule 10811 Federally Enforceable Through Title V Permit

18. CO emissions for source test purposes shall be measured using EPA Method 10 or ARB Method 100. [District Rule 108 11 Federally Enforceable Through Title V Permit

19. NOx emissions for source test purposes shall be measured using EPA Method 7E or ARB Method 100 on a ppmv basis, or EPA Method 19 on a heat input basis. [District Rules 108 1 ; District Rule 4305; District Rule 435 I] Federally Enforceable Through Title V Permit

20. Stack gas oxygen for source test purposes shall be measured using EPA Method 3 or 3A or ARB Method 100. [District Rules 1081 ; District Rule 4305; District Rule 435 I] Federally Enforceable Through Title V Permit

2 1. Stack gas velocities for source test purposes shall be measured using EPA Method 2. [District Rules 108 1 ; District Rule 4305; District Rule 435 I] Federally Enforceable Through Title V Permit

22. Stack gas moisture content for source test purposes shall be measured using EPA Method 4. [District Rule 10811 Federally Enforceable Through Title V Permit

23. Fuel hhv for source test purposes shall be certified by a third party fuel supplier or measured using ASTM D 1826 or D 1945 in co~ijunction with ASTM D 3588 for gaseous fuels, or ASTM D 240 or D 2382 for liquid hydrocarbon fuels. [District Rule 108 1 ; District Rule 435 I] Federally Enforceable Through Title V Permit

24. Emissions measurements from CEMS for compliance determination shall be averaged in accordance with the requirements of 40 CFR Part 60.13. [District Rule 1 08 1 ] Federally Enforceable Through Title V Permit

25. Copies of all fuel invoices, gas purchase contracts, supplier cer-tifications, and test results used to determine compliance with the conditions of this permit shall be maintained. The operator shall record daily amount and type(s) of fuel(s) combusted and all dates on which unit is fired on any noncertified fuel [District Rule 2520,9.3.2] Federally Enforceable Through Title V Permit

26. When complying with sulfur emission limits by fie1 analysis or by a combination of source testing and fuel analysis, each fuel source shall be tested weekly for sulfur content and higher heating value. If compliance with the fuel sulfur content limit and sulfur emission limits has been demonstrated for 8 consecutive weeks for a fuel source, then the fuel testing frequency shall be semi-annually. If a semi-annual file1 content source test fails to show co~npliaoce, weekly testing shall resume. [District Rule 2520, 9.3.21 Federally Enforceable Through Title V Permit

PERMIT UNIT REQUIREMENTS CONTINUE ON NEXT PAGE These terms and conditions are part of the Facility-wide Perm~t to Operate.

Fac~l~ty Name SPRECKELS SUGAR COMPANY Location 29400 W WHITESBRIDGE RD-MENDOTA. CA 93640 C-117- Me, 25 2009 4 05PM - BROWND

Permit Unit Requirements for C-1179-6-8 (continued) Page 3 of 4

27. When co~nplying with SOX emission limits by testing of stack emissions, testing shall be performed not less than once every 12 months using EPA Method 6B; or Method 8; or, for units using gaseous fuel scrubbed for sulhr pre- combustion, a grab sample analysis by GC-FPDITCD performed in the laboratory and EPA Method 19 to calculated emissions. Units demonstrating compliance on two consecutive annual source tests shall be tested not less than once every thirty-six months, however annual source testing sliall resume if any test fails to show compliance. [District Rule 2520, 9.3.21 Federally Enforceable Through Title V Permit

28. If the unit is fired on noncertified gaseous fuel and compliance with SOX emission limits is achieved through fuel sulhr content limitations, then the sulfur content of the gaseous fuel being fired in the unit shall be determined using ASTM D 1072, D 303 1, D 4084, D 3246 or grab sample analysis by GC-FPDITCD performed in the laboratory. [District Rule 2520, 9.3.2 and District Rule 43511 Federally Enforceable Through Title V Permit

29. If the unit is fired on noncertified liquid fuel and compliance with SOX emission limits is achieved through fuel sulfur content limitations, then the sulfur content of each batch delivered of the liquid fuel being fired in the unit shall be determined using ASTM D2880. If the unit is fired on certified liquid fuel, certification for each batch delivered shall be obtained and maintained. [District Rule 2520,9.3.2; District Rule 435 I ] Federally Enforceable Through Title V Permit

30. The concentration of sulfur conlpounds in the exhaust from this unit shall not exceed 0.2% by volume as measured on a dry basis over a 15 minute period. [District Rule 4801 and Fresno County Rule 4061 Federally Enforceable Through Title V Permit

3 1. If the unit is fired on fuel oil for more than 336 hours in any one calendar year, source testing shall be performed while firing on fuel oil to determine PM emissions. If source testing is required, it shall be performed within 60 days of firing on oil. [District Rule 2520, 9.3.2, 4305, 4306 and 435 11 Federally Enforceable Through Title V Permit

32. Source testing for PM shall be performed using EPA Method 5 modified to include the back-half catch. [District Rule 1 08 11 Federally Enforceable Through Title V Permit

33. A violation of emission standards indicated by the CEMS shall be reported by the operator to the APCO within 96 hours. [District Rule 10801 Federally Enforceable Through Title V Permit

34. Operator shall notify the APCO no later than eight hours after the detection of a breakdown of the CEM. Operator shall inform the APCO of the intent to shut down tlie CEM at least 24 hours prior to the event. [District Rule 10801 Federally Enforceable Through Title V Per~liit

35. The operator shall do one of the following: fire the unit only on PUC or FERC regulated natural gas; or test the sulfur content of each fuel source and demonstrate the sulfur content does not exceed 1.2% by weight for No. 6 fuel oil; or determine that the concentration of sulfur compounds in the exhaust does not exceed the concentration limit by a combination of source testing and fuel analysis. [District Rule 2520, 9.3.21 Federally Enforceable Through Title V Permit

36. The operator shall either fire the unit on PUC regulated natural gas or shall test the sulfur content of each fuel source and determine the maximum sulfur content of each fuel in units of IbIMMBtu and then calculating the resultant emissions in units of Ib SOdMMBtu. [District Rule 2520, 9.3.21 Federally Enforceable Through Title V Permit

37. When firing on fuel oil, daily visible emissions tests using EPA method 9 shall be required. If compliance is demonstrated for 10 consecutive days, the test frequency shall be weekly. If the unit fails any weekly visible emissions test, test frequency shall return to daily. [District Rule 2520, 9.3.21 Federally Enforceable Tlirough Title V Permit

38. Emissions for this unit shall be calculated by using the arithmetic mean, pursuant to District Rule 1081 (12/16/93), of 3 one-hour test runs for PM 10; and the arithmetic mean of 3 forty-minute test runs for NOx and CO. [District Rule 2520, 9.3.2; District Rule 4305, 5.0, 8.1; District Rule 435 I] Federally Enforceable Through Title V Per~iiit

39. Ownerloperator shall comply with the requirements of Rule 4306 (adopted September 18, 2003) by the dates as specified in Table 2 of the Rule. [District Rule 4306, 7.01 Federally Enforceable Through Title V Permit

40. The permittee shall comply with the compliance assurance monitoring operation and maintenance requirements of 40 CFR part 64.7. [40 CFR part 641 Federally Enforceable Through Title V Permit


Facility Name: SPRECKELS SUGAR COMPANY Location: 29400 W WHITESBRIDGE RD,MENDOTA. CA 93640 C-11796.8 ~ a r 25 2009 4 05PM - BROWND

Permit Unit Requirements for C-117.9-6-8 (continued) Page 4 of 4

4 1. The permittee shall colnply with the recordkeeping and reporting requirements of 40 CFR part 64.9. [40 CFR part 641 Federally Enforceable Through Title V Pertnit

42. If the District or EPA determine that a Quality improvement Plan is required under 40 CFR 64.7(d)(2), the permittee shall develop and imple~iient the Quality Improvement Plan in accordance with 40 CFR part 64.8. [40 CFR part 641 Federally Enforceable Through Title V Permit

These terms and conditions are part of the Facility-wide Permit to Operate. Facility Name. SPRECKELS SUGAR COMPANY Location: 29400 W WHITESBRIDGE RD.MENDOTA. CA 93640 GI 179.68 Mar 25 2009 4 05PM - BROWND

Attachment B

ERC Application

San Joaquin Valley Air Pollution Control D,istrict Application for

E\IISSIO\ REDIIC.I.IOI CREl)ll' (,KC) I I CONSOLII).-\?'ION OF EKC CERT1FIC.-\TICS

I. I<RC TO I1E ISSlIED TO: :LC. Facility 11): C- 11 7 ~ ~ i ~ ~ k ~ l ~ 5dy Cum pal1 Y d (if lino\\.n)

2. A,I-III,INC .IDDRESS: Streetm.O. nor: p.0. BOX b 2

II 3. L,OC.ATIOK OF REDIICI'IOX: Street: 3q~t.00 ~ h l k5 br ;C!C& Rd

4. DATE OF REDlICTIOS:

%/3i 10s I4 S E C T I O N TO\\'XSIIIP I(:\NCE I I I

I1 5. PEKAIIT NO(S): EXISTING EliC NO(S): C1_-i1'74 - I I I

6. XIETIIOI) RESlrLTlNG I N EnllSSlOS I1b:I)lICTIOS:

SI~IlJl'DO\!'N I I liETI1OFIT I I PROCESS CI-IANGE I I OTHER

DESCRIPTIOR::

(Use a d d l t ~ o l l a l sll~.ets i f l ~ c c e s s a ~ y )

7. KEQIJESTED EKCs (In Pounds Per Calendar Quarter):

\'OC RO\ CO - pp

I'h110 - --

0 l l l t H

ISI QUARTER -6- -8- -6- 0- &?--

2NDQUARTER / b 89 3RD QUARTER

JTH QUARTER -e-- a- 3YY6.45 -e-

l/ 9. TlrPEoR PRINT NAME OF PI 'LIC1NT:

I

D:\I'E: TELEPIIONE NO:

Northern Regional Office * 4800 Enterprise \+lay * Rlodesto, California 95356-8718 * (209) 557-6400 * FAX (209) 557-6475 Central Regional Office * 1990 East Gettysburg Avenue * Fresno, California 93726-0244 * (559) 230-5900 * FAX (559) 230-6061

Southern Regional Office * 34946 Flyover Court * Bakersfield, California 93308 * (661) 392-5500 * FAX (661) 392-5585

DATE STAMP FE? 1, ;: ,..-,,.i

a3 c. 2 (,. . .#

GUFCLG: F a ~ C X . G \ V ~ : o ~ D Z " /~tro&W

ERC Spreadsheet for Spreckels Sugar Mendota Facility Emission Factors (from AP-42) Sugar cooler, rotoclone Filterable PM 0.13 Sugar cooler, rotoclone condensible organic PM 0.0043 Sugar granulator, rotoclone Filterable PM 0.064 Sugar granulator, rotoclone Condensible Organic PM 0.0037 Total Emission Factor1 Ib PM Iton sugar 0.202

PM Permit # I Equipment Throughput, quarter Ibslqtr Sugar Beet Manufacturing Process C-1179-1

Qtrl 2005 0 ton 0 Qtrl 2004 0 ton 0 Qtrl Avg 0 ton 0

QtR 2005 45097.00 ton 9109.59 QtR 2004 5371 2.1 0 ton 10849.84 Qtr2 Avg 49404.55 ton 9979.72

Qtr3 2005 45258.35 ton 9142.19 Qtr3 2004 48065.25 ton 9709.1 8 Qtr3 Avg 46661.80 ton 9425.68

Qtr4 2005 21254.75 ton 4293.46 Qtr4 2004 12868.50 ton 2599.44 Qtr4 Avg 17061.63 ton 3446.45

San Joaquin Valley Air Pollution Control District Application for

NI.;~IISSION ItC:I)IICTIOX CItEI)II' (EIlC) I I CONSOl,lDATlOi\: 01: I:RC CERTIFIC::\TI<S -

I . EllC 1'0 BE ISSCIC:I) TO: &- Facility ID: C- I k' C? 3 p r r c k ~ ( 5 ~ L ) ~ ~ C L C C O ~ P & ~ , 'Tt')c. (i f known)

2. hl.+lLING .AI)DKESS: Street/P.O. Box: ? c 30.4 ba

- f % ~ ~ \ d ~ k - State: C A Zilr Code: Ci 3 G 0

Northern Regional Office * 4800 Enterprise \\lay * Modesto, California 95356-8718 * (209) 557-6400 * FAX (209) 557-6175 Central Regional Office * 1990 East Cettysburg Avenue * Fresno, California 93726-0244 * (559) 230-5900 * FAX (559) 230-6061


3. LOC.4TIOX OF ItED[ICTION: 39 902 b r i d q ~ Raced Street: - d

c i ty : Menc4o.b , LA C13bq0 J

N S E C T I O K TO\\'KSI Ill' RANGE

FOR AI'CD USE ONLY:

4. D:\TE OF REDI!CTIOK:

8 13\ /08

DATE STAMP

RE(~E? tGU P . . : Vi b-. .

FEB 2 5 ;gi;j

c. ,, I ? .-. -

FILING FEE RECEI\'ED: S qmE / 7 7 ~ b . 3 0 D,\.fE P.411):

I'ItOJECT NO.: ' F:\cILIT~ ID.: \ 179

5. PERhIIT iVO(S): C - li '7q .-% EXISTING ERC NO(S):

6. hIICTIIOD 1tk:SClLTlNC. IN EhllSSlON KE1)liCI'IOS:

I)( SH[~TDO\\.N I I RETROFl'f I I PROCESS CH..\NCE I I 01-IiElt

DESCRIPTION:

(Usr additrotrnl slrcets ifrrscessaq)

7. REQCIESTED ERCs (In Pounds Per Calenclar Quarter):

Tl'PE OR IDKINI'l'ITLE OF APPLIC.AN'I':

ney;afl~l MT-

W L ' . 2 -. .. &()KT;+z,:;i.,; , - ..., . .-. ,

/ 9. 1'l.PE OK PRINT NARlE OF .APPLICANT:

Tahn &c*

DATE: TELEPCIONE NO: ~ 3 = t - 6 5 S - ~ c t b l

A 273

ERC Spreadsheet for Spreckels Sugar Mendota Facility Emission Factors (from Emission Statement) 30.00 0.60 0.30 4.95 4.65

Ib per 1000 Ib per 1000 Ib per 1000 Ib per 1000 Ib per 1000

gal fuel o ~ l gal fuel oil gal fuel 011 gal fuel o ~ l gal fuel 011

NOx Sox VOC CO PMlO Permit # I Equi~rnent Throuqhput, quarter Ibslatr Ibslqtr Ibslatr Ibslqtr Ibslatr Lime Kiln 40 NIMBtuIhr Qtrl 2005 0 gallons 0 0 0 0 0 C- 1 179-4 Qtr l 2004 0 gallons 0 0 0 0 0

Qtrl Avg 0 gallons o 0 0 0 0

Qtr2 2005 40521 6 gallons 12156.48 243.13 121.56 12156.48 1884.25 Qtr2 2004 471072 gallons 14132.16 282.64 141.32 2331.81 2190.48 Qtr2 Avg 438144 gallons 13144.32 262.89 131.44 7244.14 2037.37

Qtr3 2005 480270 gallons 14408.1 0 288.16 144.08 2377.34 2233.26 Qtr3 2004 459774 gallons 13793.22 289.66 137.93 2275.88 2137.95 Qtr3 Avg 470022 gallons 14100.66 288.91 141.01 1146.94 2185.60

Qtr4 2005 267246 gallons 8017.38 160.35 80.17 1322.87 1242.69 Qtr4 2004 188496 gallons 5654.88 113.10 56.55 933.06 5654.88 Qtr4 Avg 227871 gallons 6836.1 3 136.72 68.36 1127.96 3448.79

San Joaquin Valley Air Pollution Control District Application for

1 ~E\IISSIO\ #ED~lCIlO;\r CREDIT (ERC') I 1 CO\SOI,II) \l'101\ 01. ERC CEItTIFICATES

I. I:HC 1'0 UE ISSliEI) TO: Facility 10: c- I l7 c1 SgczLte h Su nr C ~ r f l p ~ y , LC. 3 (if knorvn)

2. 3I:\ILIYG ,ADDRESS: Streer/lB.O. tior: i>. o. 130~

Cih: - k t e ~ d 0 . c . ~ State: C 6 Zip Code: 7 36Vm

- - NORTHERN i7E ,::;!GN

3. I.OC:\TION OF KI:D[!CTION: 3qL(00 l d ~ 1 t e . 5 b ~ t d c j ~ iU Street:

V

City: & ( Q Y ~ O + C ~ ~ i . 3 q Q I

N S E C T I O N T O \ \ N S I I I P RANGE

FOR 411C1) IJSE ONL\': \

Northern Regional Office * 4800 Enterprise Way * hlodesto, California 95356-8718 * (209) 557-6400 * FAX (209) 557-6475 Central Regional Office * 1990 East Gettysburg Avenue * Fresno, California 93726-0244 * (559) 230-5900 * FAX (559) 230-6061


4. D:\TE OF REDIJCTIOK:

RFB>E~ VE D FEB 2 5 2 2 ~ 9

c- I\ / 4 I-,,.,-, -- ., , .,. >

5. IIElc\llT NO(S): - , ,., - ,L- EXISTING I.lRC NO(S):

6. AIEI'IIOD RESUCI'INC I N ERfISSION REDI;CTION:

. .

~ ( S I I ~ J T D ~ ~ ~ X I I RETROFIT I I PROCESS CH,\NCE I 1 OTHER

DESCRI IDTION:

(Use additional slleers if neccssag)

7. I1EQCIESTEU EHCs (In Pounds Per Calendar Quarter):

VOC NOa CO l'h110 Sox OTHER

I'M" OR P1tINI' TI.I'I,E 01: APPLIC.4NT:

9. TI'FE O l i PRINT NAhlE OF APP1,ICANT: DATE: I'ELEPIIOKE NO:

55q.-G5 - '+ct b 1

I:ILIN(; FEE , L%

wcE1i7ED: s 7 0 ~ 7 2 1 ; 0 ~ 7 q D ~ T E P \ID: ~25109 ̂us I'ROJEC r NO.: C l W C 9 a F \ c I LIT! In.: ClL I 7q

ERC Spreadsheet for Spreckels Sugar, Mendota C-1179-6 311 MMBtulhr, Low Nox Burners, FGR

NOx Emissions, lblhr = (ppm)(MW)(2.63~10-9)(ff)(quarterly fuel usage)(20.9-3)) lblhr Nox 2005 2004 ;um2004,200 vg2004,2005 Qtrl 0 0 0 0 Qtr2 5678.34 6078.78 11 757.1 2 5878.56 Qtr3 601 1.79 6065.08 12076.87 6038.44 Qtr4 3306.23 231 8.83 5625.06 2812.53 Total, Ibs 14729.52 Total, tons 7.36

CO Emissions, lblhr = (ppm)(MW)(2.63~10-9)(ff)(quarterly fuel usage)(20.9-3)) lblhr CO 2005 2004 ;um2004,200 vg2004.2005 Qtrl 0 0 0 0 Qtr2 16206.58 17349.48 33556.06 16778.03 Qtr3 171 58.28 17310.39 34468.67 17234.34 Qtr4 9436.33 6618.17 16054.51 8027.25 Total, Ibs 42039.62 Total, tons 21.02

VOC Emission Factor 2.81bl' VOC emrn = (2.8/100000)'(fuel usage '1000scf) VOC 2005 2004 ;um2004,200vg2004,2005 Qtrl 0 0 0 0 Qtr2 1457.95 1560.77 301 8.72 1509.36 Qtr3 1543.57 1557.25 3100.82 1550.41 Qtr4 848.90 595.38 1444.27 722.14 Total, Ibs 3781.91 Total, tons 1.89

Sox Emission Factor 1.01b/lOE6 scf SOX em = (l.OlbllOE6 scf)(fuel x 1000 scf) Sox 2005 2004 ~um2004,200vg2004,2005 Qtrl 0 0 0 0 Qtr2 520.70 557.42 1078.1 2 539.06 Qtr3 551.28 556.1 6 11 07.44 553.72 Qtr4 303.1 8 212.63 51 5.81 257.91 Total, Ibs 1350.68 Total, tons 0.68

PMIO Emission Factor 7.5 IbllOxE6 scf PMIO 2005 2004 ~urn2004,200vg2004,2005 Qtrl 0 0 0 0 Qtr2 3905.24 41 80.64 8085.87 4042.94 Qtr3 41 34.56 4171.22 8305.78 4152.89 Qtr4 2273.84 1594.76 3868.59 1934.30 Total, Ibs 10130.12 Total, tons 5.07

Spreckels Sugar Company, Inc. P.O. Bos 68

39400 Whitesbridge Rd. Mendola, CA 93640

Permitting Services San Joaquin Valley Air Pollution Control District 1990 E. Geltysburg Aveti~le Fresno, CA 93 726-0244

February 24, 2009

Re: C-1179 ERC Applications for Spreckels Sugar Company, Inc.

Dear Pemiitting Services,

Please find the attached ERC applications for equipment shutdowns due to the pertnanent cessation of sugar beet processing operations at the Spreckels Sugar Company, Inc. facility in Mendota, for pernlits C-1 179-1, 4, 6 and 14 (ERC applications are submitted separately for each of these pernlits). Plcase note tlie ERC applications are based on calendar years 2004 and 2005, as these two years are tlie most representative consecutive years (within the last five years) based on historical processing as shown in tlie following table:

Year 2008 2007 2006 2005 2004 2003 2002 200 1 2000 1999

Tons of Sugar Beets Processed 419,186 531,271 65 1,795 900,925 860,023 863,275 855,405 746,3 12

1,063,687 998,333

Please contact me at 559-655-4961 x 258 or Anne Ogrey at 559-655-4961 x207 if yo11 have any questions regarding this application.

Sincerely,

John Dean District Manager

srl, .!>Cd, lm, %= P-d. C*l Bollal gas. Mcl Boll., gas. lnom. Bo11.r gas. mmBlu F ~ l 0 1 1 . rnl. Fuel 0,. thrms Bulk i m a a,". ID. CAP KIln gar. Imrms CAP Kln oai. Mcl

Bum sllca, ton, Sug' PrmuSOd. cw, L l l c r gas. Mcl Balm gar. ,nnm, &,,a, 90%. mms,u Fusl 011. DM. F".l Oii, lMIrn, edk rod! as". Ib. CAP ffiln unr, ihorms CAP Kim pas. Mcl

srll S1lc.b. ID".

sugar pmusoa. Cwl Bomlrc gas. Mcl Bollor gar, m.rmJ hi,., d.,. rnrnBtu Fud OfI. MIS FW a!. tmrm. BUI~ ,ma ash, ~ a r CAP Kaln om., fn.rms CAP Nm gas. Mcl

Be.,. .l,cad. ,on, S u p l prMUud. CW Bal* Qsr. M1 Bo~lar gar, Inarms Bollv g w . -BLU FwI 01, w,. Fval Oil. tlim'rn. Bulk rms ash. Ib, CAP ffil" g m . Vlsrm. CAP ffiln gar. Mcl

srl. .!tCDd. 100.

Suga produced. Crrl Bn\.r 9". ME( Bo1.r gas. tn.,m, &la, pa,, rnrnBl" Fuel 011 1M. Fu., 08, ,m.tm. &11h .ma arn ~ b s CAP Kdn par, lnsrms CAP Klin Oar. Mcl

2005 ar yta a 2 ytd 0 3 yla ol yta Be13 sl~ced, Ions 0 335640 704496 900.925 S q l produced. Cwl 0 901940 1M7107 2.232.202 Baler gss. Mcl 0 510989 1051985 1.349.510 Boiler mar. msrms 0 5206978 10719727 13.751 507 - . Bollsr gss, mmBtu 520.698 1,071,971 1.375.151 Fvsl Oil. ~MDI I 0 9648 21083 27.A46 F w l h 1 , fhsrms 0 Ma216 1326200 1,727,332 B U I ~ s ~ a ash ~ b s 0 CAP Kmgar (htms 0 0 0 CAP Nln gal Mcf 0 0 0 .

XK)4 0 1 yfS 0 2 ytd 0 3 y l l 04 yld s r t r KILCW, lmr 0 376246 7519a1 850,023 Svpa p r m u c d Cwl 0 1074242 2035567 2,292,917 Bo8l.r gac. Msl 0 565M1 lQ69892 1,298,561 blu o&. Ih.rms 0 551.1178 lll3YV12 13,262139 Baler oar, mmBlv . 557.418 1,113,560 1,326,211 Fud hl. Wir 0 11216 22163 26,651 ~u.1 01. !harm. 0 707080 1397182 1.6M.120 Bulk .ma arb, la* 0 CAP Kln gal. Iherms 0 1689 28280 28.280 CAP Klln gar. Msl 0 163 2.762 2.762

Beet Sugar Process Flow Diagram

Attachment C

Baseline Period Determlination

Baseline Period Determination

Example 8-Qtr Block Calculation (Q2 - 2007):

Non-Seasonal Source (Sugar Beet Manufacturing)

8-Qtr Block = Absolute[NSO - Average(Q3-2005 through Q2-2007)l 8-Qtr Block = Absolute[21,893 - ((45,258+21,255+0+37,870+33,105+9090+0+29,254) 1 8)]

8-Qtr Block = 86

,Calendar Quarter

Q1 - 2005 Q2 - 2005 Q3 - 2005 Q4 - 2005 Q1 - 2006 Q2 - 2006

Example 16-Qtr Block Calculation (Q4 - 2009):

Sugar Produced (ltons/qtr)

0 45,097 45,258 ,

21,,255 .O

37,8,70

16-Qtr Block = Absolute[NSO - Average(Q1-2006 through Q4-2009)l 16-Qtr Block = Absolute[21,893 - ((0+37,870+33,105+9,090+0+29,254+45,614+0+0+27,256+

29,417+0+0+0+0+0) / 16)] 16-Qtr Block = 8,668

8-Qtr Block Differences vs

NSO


NSO ..............................................................................................................................................................................


NSO


NSO " ....................................................... -

j ~ h i s value is the smallest "difference" compared to the Normal Source '/ :

loperation (NSO) average. Therefore, the 8 consecutive quarters r

. ..................................................................... {associated with it (Q3 2005 - Q2 2007) most closely represent NSO. - ......................................................... ......................................................................................................... "

Spreckels Suga~r Compalny Sugar Production, 40 MMBtulhr Litme Ki~ln Fuel Oi~l Usage and 31 1 MMBtulhr

Boiler Natural Gas Usage Records

SPRECKELS SUGAR COMPANY Monthly Factory Throughput from 2004 - 2008

EKC Banking Applications Project Number C-1090909

Jan-04 Feb-04 Mar-04 Apr-04 May-04

L~me K~ln Fuel 011, bbls

3925 3734

Bo~ler Gas, therrns

1848368 1886568

Lime Kiln Fuel 011, therrns

247470 235416

Gas Purchase d, Mcf

181475 184717

Boiler Gas, MMBtu

184837 188657

Carbon K~ln Gas, therrns

0 1684

Carbon K~ln Gas, MMBtu

0 168

Sugar Produced, Cwt

319614 383592

SPRECKELS SUGAR COMPANY Monthly Factory Throughput from 2004 - 2008

ERC Banking Applications Project Number C-PO90909

Produced,

SPRECKELS SUGAR MONTHLY TONS SUGAR BEETS SLICED FROM 1999 - 2008

Attac,h,men t E

Lime Kiln NOx Source Testing Result Summaries

Spreckels Sugar Company Mendota, CA

RDLK - 40 MMBtulhr

Permit Number: C-1179-2-3

SJVAPCD COMPLIANCE TESTING

COMPLlANCE

TEST-RUN #

Test Location

Test Date

Test Start-Time

Test End-Time

RDLK Rat~ng. MMBtulhr

F-Factor dscflMMBtu

DEFINITIONS:

RDLK. MMBtulhr

RDLK Load DCo

Flow Rate dyfm

02, %

NOx. ppm

NOx, pprn @ 3% 0 2

NOx, IbslMMBtu

ppm = Parts Per Million by Volume

1

Outlet

5/3/2007

8:15

8:45

4010

6

MW = Molecular Weight

F-Factor= Dry Standard Cubic Feet (dscf)!Per MMBtu @ 0% 02 8 T(sld)

NOx = Oxides of Nitrogen as NO2 (MW = 46)

I

27.9

69 8

6.010

5.9

17 9

21.4

0.0281 J

CO = Carbon Monoxide (MW = 28)

IbslMMBtu = Emission Factor - Pounds Per Million Btu of Heat Input

2

Outlet

5/3/2007

10:M

1034

Test Duration, mlnutae

Standard Temperature, O F

RDLK Fuel Rate. GPH 1

40.0

p2es8

dscfm = Dry Standard Cubic Feet Per Minute

0 3 0

60.

182.0

27.9

60.8

5.449

4.4

16 3

17.6

0.0231 -/

CALCULATIONS:

0:30

N A

182.0

3

Outlet

51312007

1057

11:27 ---- 0:30

60

182:O

40.0

/Q2lW8-

ppmv @ 3% = ppmv ' (17 9 l (20 9 - %02)) IbslMMBtu

@ dscfm = F-Factor \

0:30

60

182.0

27.9

69 8

5,341

4.0

20.0

21.3

0.0279 4'

Averages

Outlet

5/3/2007

N A

N A

40.0

Llmit

/-q<\l- 27.9

69.8

5,600

4.8

18.1

20.1

0.0264 J 0.2006

Spreckels Sugar Company Mendota, CA

RDLK - Steffen 40 MMBtulhr

Permit Number. C-1119-24

SJVAPCD COMPLIANCE TESTING FOR SJVAPCD RULE 4313

COMPLIANCE

DEFINITIONS:

ppm = Parts Per Milton by Volume

MW = Molecular Weight

F-Factor = Dry Standard Cubic Feet (dsd) Per MMBtu @ 0% 0 2 8 T(sld)

NOx = Oxides of Nitrogen as NO2 (MW = 46)

CO = Carbon Monodde (MW = 28)

WMMBtu Emissbn Factor - Pounds Per Mlltion Btu of Heat Input

dsdm = Dry Standard Cubic Feet Per Minute

ppmv @ 3% = ppmv * (17.0 t(20.0 - 9602))

bs!MMBtu z ppmv ' F-Fact

dsdm F-Factor ' MMBW

Attachment F

Boiler NOx and CO Source Testing Result Summaries

I & Associates

I Spreckels Sugar Company

Mendota, CA

E Boiler No. 1 - Combustion Engineering 31 1 MMBtulhr

Permit Number: C-1179-6-8

E SJVAPCD COMPLIANCE TESTING

I TEST-RUN # 1 2 3 Averages Limit

Test Location Outlet Outlet Outlet Outlet

Test Date 511412008 5/14/2008 511412008 511412008

Test Start-Time 8 23 9.08 952 NA

Test End-Time 8: 53 9.38 10:22 NA

Test Duration, minutes 0 3 0 0:30 0:30 0:30

Standard Temperature, O F 60 60 60 N A

Boiler Rating, MMBtuIhr 31 1 .O 311 0 311 0 31 1 .O

F-Factor, dscflMMBtu 8578 0 8578.0 8578.0 8578.0

Boiler Load, MMBtulhr 202.2 202.2 202.2 202.2

Boiler Load, % 65.0 65 0 65 0 65.0

Flow Rate, dscfm 32,075 32,012 31,986 32,024

02 , % 2.1 2.0 2.0 2.0 a 1 c u - i

NOx, P P ~ 26 6 26 9 26 1 26.5

NOx, ppm @ 3% 0 2 25.3 25.5 24.8 25.2 v' 30.0

NOx, IbslMMBtu 0.0307 0.031 0 0.0301 0.0306 J 0.0360

CO, PPm 42.9 47 1 43.5 44.5

CO, ppm @ 3% 0 2 40.8 44.7 41.3 42.2 v 400.0

CO, IbsIMMBtu 0.0301 0.0331 0 0305 0.031 2

Spueckels Sugar Company Mendote, CA

Boller - Comburstlon Englneerlng 311 MMBtulhr

Penntt Number: C-117OB-8

SJVAPCD COMPLIANCE TESTING

DEFINITIONS:

COMPLIANCE

Durn = Parts Per MilNon by Volume

MW - Molecular Weight

F-Factor = Dry Standard Cubic Feet (dscf) Per MMBtu QD 0% 0 2 a T(s1d)

NOx = OxMee of Nitrogen as NO2 (MW r 46)

CO $ Carbon MonoxWe (MW a 28)

IbslMMBtu = Emission Factor - Pwnds Pet MilLion Btu of Heat Input

dsdm a Dry Standard Cublc Feet Per Minute

TEST-RUN II

eat ~ocemn

T e ~ t Date

Test Start-Tlme

Test End-Time

Test Duration, mlnutea

Stondard Temperature, 'F

Bobr Ratng, MMBWhr

F-Fector, dedlMMBbr

Boller Loed, MIWBtulhr

Boiler Loed, %

Flow Rete, dachn

02, %

CALCULATIONS:

9

Outkt

U4tZmS

8:W

8:38

0:SO

BO

31 1 .O

8678.0

276.0 J

88.8 V'

44,604 v' zA 2 . Y '

1 2

Outlet

WUZMW

8:61

8:21

0:W

60

311.0

Bb78.0

273.0

87.8

4 4 , a 28 3,'46

I

A v e r a ~ w

Outlbt

WllOO6

NA

NA

0:W

PU

311.0

8618.0

270.3

86.0

43,763

2.4

3

Outlst

5!4/2005

9:s

10:DB

0:W

60

311.0

8676.0

282.0

84.2 /

42,427 fl 1.Y<

Umlt

.

Lime Killn AP-42 Emission Factor to Combustion AP-42 Emission Factor Comparisons

AP-42, Section 11 .I 7, applies to lime manufacturing. Table 11 .I 7-6 contains emission factors for coal fired rotary lime kilns and gas fired rotary lime kilns. However, it does not contain any emission factors for oil fired rotary lime kilns like the one that Spreckels Sugar operated under PTO C-1179-2-3. Since lime kiln section of AP-42 does contain emission factors for gas fired rotary lime kilns, those emission factors will be compared to the emission factors from natural gas combustion in AP-42, Section 1.4. If the emission factors are comparable, then it will be assumed that the emission factors from fuel oil combustion in AP-42, Section 1.3, are a conservative estimate of the expected emissions from the fuel oil fired lime kiln operated at this facility.

Gas Fired Rotary Lime Kiln Emission Factors (AP-42, Table 11 .I 7-6, 2/98):

Gas Fired Rotary Lime Kiln With Venturi Scrubber Emission Factor (AP-42, Table 1 1 .I 7-2, 2/98):

Pursuant to information provided by the applicant for this project, the lime kiln could produce a maximum of 7.1 tons of lime per hour. Therefore, the above emission factors can be converted to the following Ib/hr mass emission rates:

Natural Gas Combustion Emission Factors (AP-42, Table 1.4-1, 7/98):

Natural Gas Combustion Emission Factors (AP-42, Table 1.4-1, 7/98):

Pursuant to information provided by the applicant for this project, the lime kiln operated at a maximum heat input rate of 40 MMBtuIhr. Therefore, the above emission factors can be converted~ to the following Iblhr mass emission rates:

Pollutant

PMtota~ -

Pollutant Emission Factor Iblhr

PM 0.3

Emission Factor (IbIMMBtu) 0.0076

Using the above values, the Iblhr natural gas combustion emission factors in AP-42, Section 1.4 are much lower than the lime kiln emission factors listed in AP-42, Section 11.17 for a natural gas Fired rotary lime kiln. Spreckels Sugar did not perform any source tests on their fuel oil fired lime kiln for CO, VOC, PMlo or SOx emissions. The last version of the permit for this unit did not contain any emission limits for CO, VOC, PMlo or SOx. No additional resources or information could be found on what the expected CO, VOC, PMlo and SOx emissions would be for a fuel oil fired rotary lime kiln. Since comparing the emission factors for natural gas combustion in AP-42, y. Sections 1.4 and 11.17 shows that the errrission factors are much lower and a very ::

conservative estimate, the same logic will be used to make the argument that the fuel oil combustion emission factors listed in AP-42, Section 1.3, will also represent much lower e

and more conservative estimates of what the actual CO, VOC, PMlo and SOx emissions 2 , were from the fuel oil fired lime kiln.

Attachment H

Draft ERC Certificates


Central Regional Office 1990 E. Gettysburg Ave. Fresno, CA 93726

Emissilon Reduction Credit Certificate

ISSUED TO: SPRECKELS SUGAR COMPANY

ISSUED DATE: <DRAFT>

LOCATION OF 29404) W WHITESBRIDGE RD REDUCTION: MENDOTA, CA 93640

For VOC Reduction On The Amount Of:

[ ] Conditions Attached

.

Method Of Reduction [ ] Shutdown of Entire Stationary Source [XI Shutdown of Emissions Units [ ] Other

Shutdown of sugar beet processing operation, 40 WIMBtu/hr oil fired lime kiln and 311 MMBtu/hr natural gas fired boiler

1 Quarter 1

Use of these credits outside the San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) is not allowed wlthout express written authorization by the SJVUAPCD.

Seyed .SBN@ r 1 APCO

David ner, Director of Permit Services

Mar 23 2011 8:31AM .. 8ROWND

1 Quarter 2

None

Quarter 3

1 767 Ibs

Quarter 4 1,032 I bs 454 Ibs



Emission Redluction Crediit Certificate C-1072-2

ISSUEDTO: SPRECKELS SUGAR COMPANY


LOCATION OF 29400 W WHITESBRIDGE RD REDUCTION: !iENDOTA, CA 93640

~ For NOX Reduction In The Amount Of:

Quarter I Quarter 2 Quarter 3 Quarter 4 None 3,701 Ibs 5,023 Ibs 2,200 I bs


Method Of Reduction [ ] Shutdown of Entire Stationary Source [X I Shutdown of' Emissions Units [ ] Other

Shutdown of sugar beet processing operation, 40 MMBtulhr oil fired lime kiln and 311 MMBtuIhr natural gas fired boiler

Use of these credits outside the San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) is not allowed without express written authorization by the SJVUAPCD.



Emission Rediuction Credit Certificate C-1072-3



LOCATION OF 29400 W WHITESBRIDGE RD REDUCTION: MENDOTA, CA 93640

For CO Reduction En The Amount Of:

Quarter 1 Quarter 2 Quarter 3 Quarter 4 None 1 1,056 Ibs 14,993 I bs 6,547 Ibs



Shutdown of sugar beet processing operation, 40 MMBtuIhr oil fired lime kiln and 31 1 MMBtuIhr natural gas fired boiler




Emission Reduction Ciredit Certificate C-1072-4


ISSLIED DATE: <DRAFT>

LOCATION OF 29400 W WHITESBRIDGE WD REDUCTION: MENDOTA, CA 93640

For PM10 Reduction In The Amount Of:

Quarter 1 Quarter 2 Quarter 3 Quarter 4 None 6,074 Ibs 7,699 Obs 3,185 Ibs



Shutdown of sugar beet processing operation, 40 MMBtulhr oil fired lime kiln and 311 MMBtulhr natural gas fired boiler


Seyed SadreRfii@or r - 7 n l A

- David Wkihner, Director of Permit Services

San Joaquin Valley LL qmq AIR POLLUTION CONTROL DISTRICT HEALTHY

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