San Joaquin Valley AIR POLLUTION CONTROL DISTRICT

Transcription

1 San Joaquin Valley AIR POLLUTION CONTROL DISTRICT qmq LL HEALTHY AI R LIVINGm MAR John Dean Spreckels Sugar Company P Box 68 Mendota, CA 9364 Re: Notice of Preliminary Decision - Emission Reduction Credits Project Number: C-1999 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 4 MMBtuIhr fuel oil fired lime kiln and one 311 NIMBtuIhr natural gas fired boiler, located at 394 Whitesbridge Road in Mendota, CA. The quantity of ERCs proposed for banking is 2,253 Ib-VOClyear, 1,924 Ib-NOxIyear, 32,596 Ib-COlyear, 16,958 Ib-PMl Olyear, and 8,882 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 3-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) Sincerely, ---' - " David Warner Director of Permit Services d Enclosures Seyed Sadredin Executive DirectorIAir Pollution Control Office1 Northern Region Central Region (Main Office] Southern Region 48 Enterprise Way 199 E. Gettysburg Avenue Flyover Court Modesto, CA Fresno, CA Bakersfield, CA Tel: FAX: (29) Tel: (559) 23.6 FAX: ( Tel: FAX: rar~rled paper

2 BnE HEALTHY AIR LIVING" MAR Gerardo C. Rios (AIR 3) Chief, Permits Office Air Division U.S. E.P.A. - Region IX 75 Hawthorne Street San Francisco, CA Re: Notice of Preliminary Decision - Emission Reduction Credits Project Number: C-1999 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 4 MMBtuIhr fuel oil fired lime kiln and one 311 MMBtuIhr natural gas fired boiler, located at 394 Whitesbridge Road in Mendota, CA. The quantity of ERCs proposed for banking is 2,253 Ib-VOClyear, 1,924 Ib-NOdyear, 32,596 Ib-COlyear, 16,958 Ib-PMlOIyear, and 8,885 Ib-Sodyear. 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 3-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) Sincerely, Director of Permit Services Enclosure Seyed Sadredin Executive DirectorlAir Pollution Control Officer Northern Region Central Region [Main Office) Southern Region 48 Enterprise Way 199 E. Gettysburg Avenue Flyover Court Modesto, CA Fresno, CA Bakersfield, CA Tel: 129) FAX: 129) Tel: 1559) 23-6 FAX: (559) Tel: FAX: Prcnled on rerycled paper.

3 San loaqlein Valley AIR POLLUTION CONTROL DISTRICT mmm HEALTHY All R LIVING" MAR Mike Tollstrup, Chief Project Assessment Branch Stationary Source Division California Air Resources Board PO Box Sacramento, CA Re: Notice of Preliminary Decision - Emission Reduction Credits Project Number: C-1999 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 4 MMBtuIhr fuel oil fired lime kiln and one 311 MMBtuIhr natural gas fired boiler, located at 394 Whitesbridge Road in Mendota, CA. The quantity of ERCs proposed for banking is 2,253 Ib-VOCIyear, 1,924 Ib-NOxIyear, 32,596 Ib-COIyear, 16,958 Ib-PMlOIyear, and 8,885 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 3-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) David Warner Director of Permit Services Enclosure Seyed Sadredin Executive DirectorlAir Pollution Control Officer Northern Region Central Region (Main Office) Southern Region 48 Enterprise Way 199 E. Gettysburg Avenue Flyover Court Modesto, CA Fresno. CA Bakersfield, CA Tel: (29) FAX: (29) Tel: (559) 23.6 FAX: (559) Tel: FAX: Pt~nred on recycled paper.

4 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 4 MMBtuIhr fuel oil fired lime kiln and one 311 MMBtuIhr natural gas fired boiler, located at 394 Whitesbridge Road in Mendota, CA. The quantity of ERC1s proposed for banking is 2,253 Ib-VOClyear, 1,924 Ib-NOxlyear, 32,596 Ib-COlyear, 16,958 Ib-PM~~lyear, and 8,885 Ib- SOxlyear. The analysis of the regulatory basis for this proposed action, Project #C- 1999, is available for public inspection at and the District office at the address below. Written comments on this project must be submitted within 3 days of the publication date of this notice to DAVID WARNER, DIRECTOR OF PERMIT SERVICES, SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT, 199 EAST GETTYSBURG AVENUE, FRESNO, CA

5 Emission Reduction Credit Ban,king Application Review Shutdown of Beet Sugar Manufacturing Operations Processing Engineer: Dustin Brown Lead Engineer: Joven Refuerzo Date: March 24,21 1 Facility Name: Mailing Address: Primary Contact: Phone: Spreckels Sugar Company P Box 68 Mendota, CA 9364 John Dean - Regional Manager (559) Ext. 273 John~Dean@spreckelssugar.com Alternate Contact: Anne Ogrey Phone: (29) Anne~Ogrey@spreckelssugar.com Facility Location: 294 Whitesbridge Road Fresno, CA 9364 Deemed Complete Date: December 11,29 Project Number: C-I999 I. Summary: Spreckels Sugar Company operated a sugar beet processing facility in Fresno, CA. The facility ceased production operations in August of 28 and began disassembling and removing the equipment associated with the beet sugar manufacturing process (PTO C-1179-I), one 4. MMBtuIhr natural gas or fuel oil fired lime kiln (PTO C ) and one MMBtuIhr natural gas fired boiler (PTO C ) from the site in May of 29. 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, 29 and should have been processed and sent out for preliminary notice within 6 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 , '-2-3 and '-6-8. A copy of the surrendered PTO's is included in Attachment A of this document.

6 ~ Spreckels Sugar Company C , 1999 Based on the historical operating data prior to the shutdown, the amounts of bankable Actual Emission Reductions (AER's) for NOx, CO, VOC, PM1 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) 1' Qtr. ERC's Pollutant znd Qtr. ERC's 3rd Qtr. ERC's 4th Qtr. ERC's (I blq t r) (I blq tr) (I blq t r) (I blq t r) 1 VOC 767 1, II. Applicable Rules: Rule New and Modified Stationary Source Review Rule (912116) Rule Emission Reduction Credit Banking ( ) Rule Particulate Matter Concentration ( ) Rule Particulate Matter - Emission Rate ( ) Rule Fuel Burning Equipment ( ) Rule Boilers, Steam Generators and Process Heaters - Phase 3 ( ) Rule Lime Kilns (312713) Rule Advanced Emission Reduction Options for Boilers, Steam Generators, and Process Heaters Greater than 5. MMBtuIhr (111618) Rule Sulfur Compounds ( ) Ill. Location of Reductions: Physical Location of Equipment: 294 W. Whitesbridge Road in Mendota, CA. IV. Method of Generatinq Reductions: The AER's were generated by shutting down the beet sugar manufacturing process, one 4. MMBtuIhr natural gas or oil fired lime kiln and one MMBtuIhr natural gas fired boiler. The equipment description for each unit is as follows: 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

7 Spreckels Sugar Company C , 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 VU6 N.516, EQUIPPED WITH FOUR COEN 4-DAF-3 LOW NOX GASIOIL BURNERS AND A FLUE GAS RECIRCULATION SYSTEM V. Calculations: A. Assumptions C (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 (4 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 15, Btulgallon (typical District value) - 1 therms = 1 MMBtu of heat output (conversion factor received from Pacific Gas and Electric Company) C (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, Btulscf (typical District value) - 1' therms = 1 MNlBtu of heat output (conversion factor received from Pacific Gas and Electric Company)

8 Spreckels Sugar Company C , 1999 B. Emission Factors (EF's) C-I (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 , 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 , dated March 1997, shows the following total particulate matter (Filterable plus condensable PM) emission factors for these types of operations: Sugar Granulator PM EF:.677 Ib-PMIton of sugar output Sugar Cooler PM EF:.1343 Ib-PMlton of sugar output Total PM EF:.22 Ib-PMIton of sugar output District Rule 221, section , states that in the absence of PMlo err~ission factors or speciation data, 5% 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.5 Ib-PMldlb-PM Total PMIO EF =.22 Ib-PMIton of sugar output x.5 Ib-PMldlb-PM Total PMlo EF =.11 Ib-PM4/ton of sugar output C (4 MMBtu/hr lime kiln): NOx Emissions: This lime kiln was source tested for NOx emissions two times, May 13, 24 and May 3, 27 (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.

9 Spreckels Sugar Company C , 1999 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 (9/98), Boilers less than 1 MMBtuIhr, as presented in the table below. Pollutant Permitted EF (IblMMBtu) AP-42 EF (I blmmbtu) HAE EF (I b1mmbtu) CO.33.33*.33 * 5. 1b11' gallons converted to IblMMBtu using the following equation: (5 1b11' gallon) x (gallon115, Btu) x (lo6 BtulMMBtu3 =.33 IblMMBtu.

10 Spreckels Sugar Company C , 1999 VOC Emissions: This lime kiln was never source tested for VOC emissions. AP-42, Section , 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 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 (9/98), Industrial Boilers, as presented in the table below. Pollutant VOC.2.19*.19 *.28 1b11' gallons converted to IbIMMBtu using the following equation: (.28 1b11' gallon) x (gallon115, Btu) x (lo6 BtuIMMBtu) =.19 IbIMMBtu. PMlo Emissions: Permitted EF (I b/m MBtu) AP-42 EF (I b/mmbtu) HAE EF (I b/mmbtu) This lime kiln was source tested for PMlo emissions on September 23, 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 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 cannot be used to reference emission factors for an oil fired lime kiln.

11 Spreckels Sugar Company C , 1999 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 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 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 (9/98), Boilers less than 1 NINIBtuIhr, as presented in the table below. Permitted EF AP-42 EF") HAE EF Pollutant (I b1mmbtu) (I blmmbtu) (I blm M Btu) PMqn * I1 * bll~ gallons converted to IbIMMBtu using the following equation: (.28 1bl1' gallon) x (gallon/15, Btu) x (lo6 BtuIMMBtu) =.38 IbIMMBtu. SOx Emissions: This lime kiln was never source tested for SOx emissions. AP-42, Section 11.I 7, Table 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. 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 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 (1 lb/13 gallons lb11~ gallons = 11.5 lb/13 gallons). In accordance with District Rule 221, Section , since the AP-42 emission factor only totals the PM and not PMIo, 5% of the total PM emission factor will be used for the purposes of these HAE calcualtions: 11.5 I~-PM/IO~ gallons x.5 Ib-PM,dlb-PM = 5.75 I~-PM,~IO~ gallons.

12 Spreckels Sugar Company C , 1999 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 (9/98), Boilers less than 1 MMBtuIhr, as presented in the table below. Permitted EF AP-42 EF") HAE ElF 11 Pollatant I IlblMMBtuJ I IlblMMBtu, I IlblMMBtu, I *.628 sox I] * b11' gallons converted to IblMMBtu using the following equation: (.28 1b11' gallon) x (gallon/i15, Btu) x (lo6 BtuIMMBtu) =.628 IbIMMBtu. C- 1 I 79-6 (3 1 1 MMBtu/hr boiler): NOx and CO Emissions: This boilerloxidizer system was source tested for NOx and CO emissions two times, May 4,25 and May 14,28 (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. ") 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 25 through 28, the actual fuel certifications for the fuel oil #6 used in this lime kiln show that the sulfur content was.6%. Therefore, as a conservative estimate, the AP-42 emission factor will be determined using a fuel sulfur content of.6%.

13 Spreckels Sugar Company C , 1999 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 and (7/98), as presented in the table below. Pollutant VOC Permitted EF (IblMMBtu).2 AP-42 EF (I blmmbtu).55 HAE EF (I blmmbtu).2 PMlo Emissions: 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 and (7/98), as presented in the table below. Pollutant PMIO Permitted EF (I blmmbtu).5 AP-42 EF (I b1mmbtu).76 HAE EF (I b1mmbtu).5 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 172, Generally Accepted SOx Emission Factor for Combustion of PUC-Quality Natural Gas, as presented in the table below. Pollutant sox Permitted EF (I binimbtu).1 District Policy APR 172 (IblMMBtu).285 HAE EF (IblMMBtu).1

14 Spreckels Sugar Company C , 1999 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 4 MMBtuIhr lime kiln, and natural gas usage records for the 31 1 MMBtulhr boiler dating from January 24 through December 28. 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 24 through December 29. As shown above, this ERC banking application was not deemed complete until December 29. However, the facility ceased operation in December of 28. Therefore, the production records from 29 are all zeros. Since the normal operation of this facility did not resl-~lt in zero sugar production, the 29 data will not be include in the NSO determination. Year Q1 Sugar Production (tonlqtr) Normal Source Operation (NSO) Determination Q2 Sugar Production (tonlqtr) 53,712 45,97 37,87 29,254 27, Sugar Production (tonlqtr) 48,65 45,258 33,115 45,614 29, Sugar Production (tonlqtr) 12, ,255 9,9 Average Sugar production (tonlqtr) 28,662 27,93 2,16 18,717 14,168 I I I I Average I 38,638 4,292 8,643 21, In accordance with District Rule 221, 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). As discussed above, the two consecutive years prior to the submission of the complete application are not representative of NSO since 29 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.

15 Spreckels Sugar Company C-1179, 1999 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 25 to the end of the 2"d quarter in 27. Therefore, baseline period has been determined to be the two year period dating from the start of the 3rd quarter in 25 to the end of the 2nd quarter in 27 (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 (Sugar Produced): Year Quarter I (tonslqtr)13) Quarter 2 (tons/qtr)(') 37,87 29,254 Quarter 3 (t~nslqtr)'~) 45,258 33,15 Quarter 4 (tons/qtr)(') 21,255 9,9 C- I (4 MMBtu/hr Lime Kiln): Year Quarter I (thermslqtr) Quarter 2 (thermslqtr) Quarter 3 (thermslqtr) 72, Quarter 4 (thermslqtr) 41,I C-I (31 1 MMBtu/hr Boiler): Year Quarter I (thermslqtr) Quarter 2 (thermslqtr) 4,169,952 3,443,7 Quarter 3 (thermslqtr) 5,511,829 4,694,896 Quarter 4 (thermslqtr) 3,31,524 1,462,673 '3' Applicant's records are in units of Cwt. C is a multiplication factor of 1 and wt is pounds. Therefore, the sugar production records were converted to tons using the following equation: tons produced = (wt (Ib) x 1) I 2, (Iblton).

16 Spreckels Sugar Company C , 1999 D. Historical Actual Emissions (HAE's) C (beet sugar processing): As shown above, a PMIO emission factor of.11 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 =.1 1 Iblton of sugar output x Throughput (tons of sugarlquarter) Year Q1 (Iblquarter) PMlo HAE Q2 (lblquarter) 3, Q3 (Iblquarter) 4,571 3,344 Q4 (Iblquarter) 2, Average 3,39 3,958 1,533 C- I I 79-2 (4 MMBtu/hr lime kiln): NOx Emissions: As shown above, a NOx emission factor of.227 IbIMMBtu (17.2 3% 2) 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. NOx HAE =.227 IbIMMBtu x Fuel Oil Usage (thermslqtr) x 1 NlMBtu I 1 therms Year Q1 (I blq uarter) NOx HAE Q2 (I blq uarter) 1,1'92 Q3 (Iblquarter) 1,637 1,358 Q4 (Iblquarter) I I I I I Average 11,66 1,,

17 Spreckels Sugar Company C , 1~999 CO Emissions: As shown above, a CO emission factor of.33 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 =.33 IbIMMBtu x Fuel Oil Usage (thermslqtr) x 1 NlNlBtu / 1 therms Year Q1 (I blquarter) N/A CO HAE Q2 (I blquarter) N/A 1,733 1,365 Q3 (Iblquarter) 2,379 1,974 Q4 (I blquarter) 1, N/A Average 1,549 2, VOC Emissions: As shown above, a VOC emission factor of.19 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. VOC HAE =.19 IbIMMBtu x Fuel Oil Usage (thermslqtr) x 1 MMBtu / 1 therms Year Ql (I blquarter) N/A VOC HAE Q2 (I blquarter) N/A 1 79 Q3 (I blquarter) N/A Q4 (I blquarter) Average PMlo Emissions: As shown above, a PMlo emission factor of.31 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.

18 Spreckels Sugar Company C , 1999 PMqo HAE =.31 IblMMBtu x Fuel Oil Usage (thermslqtr) x 1 MMBtu I 1 therms Year Q1 (I blquarter) PMlo HAE 42 (Il blquarter) 1,628 1,282 Q3 (Il blquarter) 2,235 1, (I blquarter) 1, Average 1,455 2, SOx Emissions: As shown above, a SOx emission factor of.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. SOx HAE =.628 IbIMMBtu x Fuel Oil Usage (thermslqtr) x 1 MMBtu 1 1 therms II SOX -. HAE II Year , Average 29,48 41,422 17,851 1 C (311 MMBtu/hr boiler): NOX Emissions: Ql (Iblquarter) Q2 (Iblquarter) 32, Q3 (Ilblquarter) 45,277 37,567 Q4 (I blquarter) 25,191 As shown above, a surplus NOx emission factor of.37 IblMMBtu (25.2 3% 2) 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 =.37 IbIMMBtu x NG Usage (thermslqtr) x 1 MMBtu I 1 therms

19 Spreckels Sugar Company C , 1999 Year Q1 (I blquarter) NOx HAE Q2 (I blquarter) 12,82 1,572 Q3 (I blquarter) 16,921 14,4183 Q4 (Iblquarter) 9,37 4,49 Average 11,687 15,667 6,899 CO Emissions: As shown above, a CO emission factor of.282 IblMMBtu (38.5 3% 2) 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. CO HAE =.282 IbINIMBtu x NG Usage (thermslqtr) x 1 MMBtu I 1 therms Year Q1 (Iblquarter) CO HAE 42 (Iblquarter) 11,759 9, (Iblquarter) 15,543 13,24 Q4 (Iblquarter) 8,549 4,125 Average 1,735 14,392 6,337 VOC En-rissions: As shown above, a VOC emission factor of.2 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. VOC HAE =.2 IbIlVIMBtu x NG Usage (thermslqtr) x 1 MMBtu I 1 the~ms Year Q1 (Iblquarter) VOC HAE Q2 (Iblquarter) Q3 (Iblquarter) 1, (Iblquarter) Average 762 1,21 45

20 Spreckels Sugar Company C , 1,999 PMlo Emissions: As shown above, a PMlo emission factor of.5 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. PMI HAE =.5 IbIMMBtu x NG Usage (thermslqtr) x 1 MMBtu 1 1 therms Year Q1 (I blquarter) PMlo HAE 42 (I blquarter) 2,85 1, (I blquarter) 2,756 2, (I blquarter) 1, Average 1,94 2,552 1,124 SOx Emissions: As shown above, a SOx emission factor of.1 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. SOx HAE =.1 IbIMMBtu x NG Usage (thermslqtr) x 1 MMBtu 1 1 therms Year Q1 (Iblquarter) SOx HAE Q2 (Iblquarter) Q3 (Iblquarter) Q4 (Iblquarter) Average E. Adjustments to HAE's Pursuant to Section 3.22 of Rule 221, Historical Actual Emissions must be discounted for any emissions reduction which, is: e required or encumbered by any laws, rules, regulations, agreements, orders, or 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.

21 Spreckels Sugar Company C , 1999 Adjustment for Rule New and Modified Stationary Source Review Rule: Section 2. 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 (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 221 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 221. Therefore, no adjustment to the calculated HAE's above is necessary. C (4 MMBtu/hr lime kiln): 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 221 does not apply at this time. In accordance with information in the facility files, this operation was previously subject to District Rule 221 when the original permits were issued and subsequently modified in Based on the actual production records provided by Spreckels Sugar Company, this operation demonstrated compliance with alj of the Rule 221 requirements (best available control technology (BACT), daily emission limits, etc.). Therefore, no adjustment to the calculated HAE's above is necessary. C-I (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 221 does not apply at this time.

22 Spreckels Sugar Company C , 1999 In accordance with information in the facility files, this operation was previously subject to District Rule 221 when the original permits were issued and subsequently modified in 24.. Based on the actual production records provided by Spreckels Sugar Company, this operation demonstrated compliance with all of the Rule 221 requirements (best available control technology (BACT), daily emission limits, etc.). Therefore, no adjustment to the calculated HAE's above is necessary. Adjustment for Rule 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.1 grain per dry standard cubic foot. C (sugar beet processing): PM Conc. (grlscf) = (PM emission rate) x (7, grllb) (Air flow rate) x 66 minlhr) x (24 hrlday) PMlo emission rate = 49.7 ~b/da~(~) PM emission rate = 99.4 lblday (assuming 5% of the PM is PMlo) Exhaust Gas Flow = 11, scfm (provided by the applicant for this project) PM Conc. (grlscf) = [(99.4 lblday) * (7, grllb)] + [(I 1, ft3/min) * (6 minlhr) * (24 hrlday)] PM Conc. =.44 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. C (4 MMBtu/hr lime kiln): F-Factor for Fuel Oil #6: 9,116 dscf1mmbtu at 6 O F PMlo Emission Factor:.31 Ib-PMlo/MMBtu Percentage of PlVl as PMlo in Exhaust: 1% Exhaust Oxygen (2) Concentration: 3% Excess Air Correction to F Factor = 2.9 = 1.17 (2.9-3).31lb-PM 7,grain 9,16fr3x,.17 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 25 and the maximum number of operating days in that quarter: (4,571 Ib-PMldqtr / 92 daysl3rd qtr = 49.7 Ib-PM,dday). 18

23 Spreckels Sugar Company C , 1999 GL =.2 grainldscf <.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.29 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 (31 1 immbtu/hr boiler): F-Factor for Natural Gas: 8,578 dscf1mmbtu at 6 OF PMlo Emission Factor:.5 Ib-PMlo/MMBtu Percentage of PM as PMlo in Exhaust: 1% Exhaust Oxygen (2) Concentration: 3% Excess Air Correction to F Factor = 2.9 = 1.17 (2.9-3).5lb-PM 7,grain 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 Particulate Matter Emission Rate: C (sugar beet processing): Section 4.1 of this rule contains the following equations for the allowable PM emissions: 6 E = 3.59~'~~ P less than or equal to 3 tonslhr) E = PO (P greater than 3 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 25. Based on the additional information provided by the applicant for this project, during the 3rd quarter of 25, 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:

24 Spreckels Sugar Company C , 1999 P = 368,856 (tons-3rd quarter) 1 [92 (days/3rd quarter) x 24 (hourslday)] P = tonslhour Therefore, the allowable PM emission rate is: During the 3rd quarter of 25, the historical actual PMlo emissions were 4,571 pounds. Assuming as a worst case that the PMlo emissions only accounted for 5% of the total PM emissions from this operation (Rule 221, ) 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.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 Fuel Burning Equipment: C-1,179-2 and '-6 (lime kiln and boiler): This rule specifies maximum emission rates in Iblhr for S2, N2, and combustion contaminants (defined as total PM in Rule 12). Therefore the emission factors used to calculate the historical actual emissions from the 4 MMBtuIhr lime kiln and the 31 1 MMBtuIhr boiler meet the requirements for this rule and no adjustment is necessary.

25 Spreckels Sugar Company C , 1999 Adjustment for Rule Boilers, Steam Generators and Process Heaters - Phase 3: C- I (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 436, Section 5.1, Category G requires a 31 1 MMBtuIhr natural gas fired, load following boiler to comply with the following limits: NOx: 15 3% 2; and CO: 4 3% 2. As discussed in the adjustments for Rule 432 below, the historical actual NOx emissions from the boiler will be calculated based on an adjusted emission factor of 7 3% 2. In addition, the historical actual CO emissions for the boiler will be calculated using an emission factor of % 2. 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 Lime Kilns: C-I (4 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: -.1 pound per million Btu when burning gaseous fuel; -.12 pound per million Btu when burning distillate fuel oil; or -.2 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.227 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.

26 Spreckels Sugar Company C , 1999 Adjustment for Rule Advanced Emission Reduction Options for Boilers, Steam Generators and Process Heaters Greater than 5. MMBtulhr: C (37 7 MMBtu/hr boiler): District Rule 432, Section 5.2 requires a 311 NIMBtuIhr natural gas fired boiler to comply with the following lirti~its: NOx: 7 3% 2 (.8 IblMMBtu); and CO: 4 3% 2. ltil addition, Section 5.4 states that to limit particulate matter emissions, all boilers shall fire exclusively on PUCquality natural gas. As shown above, the HAE's for the boiler were determined using the following emission concentrations: NOx: % 2 (.37 IblMMBtu); and CO: % 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 221, 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 432 emission limit of.8 IbIMNIBtu (7 3% 2) and the fuel usage rates listed above. NOx HAEAdjusted =.8 IblMMBtu x NG Usage (thermslqtr) x 1 MMBtu I 1 therms NOX HAE~djusted Year Q1 42 Q3 Q4 (Iblquarter) (Iblquarter) (Iblquarter) (Iblquarter) 25 4,49 2, ,336 3,756 1, Average 3,46 4,83 1, Adjustment for Rule Sulfur Compounds: District Rule 481 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:.2 % by volume calculated as SO2, on a dry basis averaged over 15 consecutive minutes.

27 Spreckels Sugar Company C , 1999 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) = 6 F = 52 R P (Standard Pressure) = 14.7 psi 1.73psi. ft3 R (Universal Gas Constant) = Ib.mol. O R C (4 MMBtu/hr lime kiln):.285 lb - SOX MMBtu 1 lb. mol 1.73 psi. ft3 52 R 1,,~ parts X X X X X MMBtu 8,578 dscf 6416 lb. mol OR 14.7psi million parts SulfurConcentration = 1.97 million < 2, ppmv (or.2%) C (31 1 MMBtu/hr boiler):.1 lb - SOX MMBtzr 1 lb. mol 1.73 psi. ft3 52 R 1,,. parts X X X X X MMBtu 8,578 dscf 64 Ib lb. rnol.or 14.7psi million SulfurConcentration =.69 parts million (or.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.

28 Spreckels Sugar Company C- I 79, 1999 F. Actual Emissions Reductions (AER's): The AER's for each unit are shown in the tables below: C-I (sugar beet processing): C (4 MMBtu/hr lime kiln): C (31 1 MMBtu/hr boiler):

29 Spreckels Sugar Company C , 1999 The combined total AER's from these units are shown in the table below: G. Air Quality Improvement Deduction In accordance with District Rule 221, Sections 3.5 and , prior to banking, all AER's shall be discounted by 1 percent (1 %) 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.

30 spreckels Sugar Company C- I 1 79, 1999 VI. Compliance: To comply with the definition of Actual Emissions Reductions (Rule 221, Section and Rule 231, 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 221. 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 1% 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:

31 Spreckels Sugar Company C , 1999 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 Emissions Reduction Credit Banking (12/17/92) states that ERC certificate applications for reductions shall be submitted within 18 days after the emission reduction occurs. The ERC application was received on February 25, 29. The sugar beet processing equipment permanently ceased operations at this location on August 31, 28, 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.

32 Spreckels Sugar Company C , 1999 VII. Recommendation: Pending a successful Public Noticing period, issue Emission Reduction Credit certificates C (VOC), C (NOx), C (CO), C (PMqo), and C (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 , '-2-3 and '-6-8 ERC Application Baseline Period Determination Spreckels Sugar Company Sugar Production, 4 MMBtuIhr Lime Kiln Fuel Oil Usage and 31 1 MMBtuIhr Boiler Natural Gas Usage Records 4 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

33 Attachlment A Surrendered PTO's C , '-2-3 and '-6-8

34 San Joaquin Valley Air Pollution Control District PERMIT UNIT: C EXPIRA'TION DATE: 8/31/28 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 2,4.1] Particulate matter emissions shall not exceed.1 grainldscf in concentration. [District Rule 4211 Federally Enforceable Through Title V Permit Particulate matter emissions shall not exceed the hourly rate as calculated in District Rule 422 ( I 2/17/92) using the equation E=3.59PA.62 (P< 3 tph) or E= PA. 16 (P> 3 tph). [District Rule 4221 Federally Enforceable Through Title V Permit Visible emissions from either the carbonator stacks or the VentriSlot scrubber stack shall not exceed % opacity (except for uncombined water vapor). [District Rule 252, 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 252, 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 252, 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 6 days of the visible emissions exceedance. [District Rule 252, 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 18 1 ] Federally Enforceable Through Title V Permit All required source testing shall conform to the compliance testing procedures described in District Rule 181 ( /93). [District Rule Federally Enforceable Through Title V Permit Emissions for this unit shall be calculated using the arithmetic mean, pursuant to District Rule 181 (1211 6/93), of 3 one-hour test runs for PMI. [District Rule 252, 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: 294 W WHITESBRIDGE RD,MENDOTA, CA 9364 C.: Mar PM - BROWN

35 San Joaquin Valley Air Poll~ltion Control District PERMIT UNIT: C EXPIRATION DATE: 8/31/28 SECTION: 3 TOWNSHIP: 14s RANGE: 15E EQUIPMENT DESCRIPTION: 4 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:.1 Ib NOx/MMBtu,.6 Ib SOdMMBtu,.3 1 Ib PMlOIMMBtu,.35 Ib CO/MMBtu, or.3 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:.2 Ib NOdMMBtu, 1.57 Ib SOdMMBtu,.3 1 Ib PM 1 OIMMBtu,.33 Ib CO/MMBtu, or.2 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 [District Rule 252, 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 N2) and 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, and District Rule 252, Federally Enforceable Through Title V Permit 8. If the NOx concentration corrected to 3% 2, 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 6 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 1, the permittee may fully comply with Rule 1 1 in lieu of the performing the notification and testing required by this condition. [District Rule 43 13, and District Rule 252, 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: 294 W WHITESBRIDGE RD,MENDOTA. CA 9364 C-117S2-3: Mar AM - BROWND

36 Permit anit Requirements for C (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 6 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 252, Federally Enforceable Through Title V Permit 1. The permittee shall maintain records of: (1) the date and time of NOx and 2 measurements, (2) the 2 concentration in percent and the measured NOx concentration corrected to 3% 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 252,9.3.2] 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, fi~r a period of five years, and shall make records available for inspection upon request. [District Rule 43 13, 5.1 and District Rule 252, 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 252, & Federally Enforceable Through Title V Permit 13. The following test methods shall be used: NOx (ppmv) - EPA Method 7E or ARB Method 1, NOx (Ib/MMBtu) - EPA Method 19, CO (ppmv) - EPA Method 1 or ARB Method 1, and stack gas oxygen - EPA Method 3A or ARB Method 1. 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 D24 or D489 for liquid hydrocarbon fuels. [District Rules 181 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: 294 W WHITESBRIDGE RD,MENDOTA, CA 9364 C Mar 3 2OL 11 39AM - BROWN

37 San Joaquin Valley Air Pollution Control District PERMIT UNIT: C EXPIRATION DATE: 8/31/28 EQUIPMENT DESCRIPTION: 31 1 IVIIVIBTUIHR COMBUSTION ENGINEERING BOILER, MODEL VU6 N.516, EQUIPPED WITH FOUR COEN 4- DAF-3 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 252, 9.4.2; 436, 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 4 CFR 6.13(e). NOx (as N2) and 2 must be recorded continuously when the CEM equipment is operating. [District Rule 18 and 4 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 4 CFR, Appendix P of Part 51 and Appendix B of Part 6. [District Rule 18 and 4 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 81 Federally Enforceable Through Title V Permit Daily summaries of CEM records for each calendar quarter shall be submitted to the District within 3 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 181 Federally Enforceable Through Title V Permit A report shall be sublnitted to the District within 3 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 181 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 18 and 4 CFR Part 641 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: 294 W WHITESBRIDGE RD,MENDOTA. CA 9364 C , Mar 25 2D9 45PM - BRWVND

38 Permit Unit Requirements for C (continued) Page 2 of When firing on natural gas, CO emissions shall not exceed 4 3% 2,.36 Ib NOdMMBtu (or 3 3% 2),.5 Ib PM IOIMMBtu,.1 Ib SOdMMBtu, nor.2 Ib VOCIMMBtu. [District Rules 435, 5.1; 435 1, 5. and District NSR Rule] Federally Enforceable Through Title V Permit 13. When firing on fuel oil, emissions shall not exceed.9 Ib COIMMBtu,.535 Ib NOdMMBtu,.4 Ib PM I~OIMMBtu, Ib SOdMMBtu, nor.2 lb VOCIMMBtu. [District Rules 435, 5. I ; 435 I, 5. and District NSR Rule] Federally Enforceable Through Title V Permit 14. Particulate matter emissions shall not exceed.1 grainsldscf in concentration. [District Rule 4211 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 252, 9.3.2; District Rule 435, 6.3; District Rule 435 1, 5.1 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 3 days prior to any compliance source test, and a source test plan must be submitted for approval 15 days prior to testing. [District Rule 18 1 ] Federally Enforceable Through Title V Permit 17. The results of each source test shall be submitted to the District within 6 days thereafter. [District Rule 1811 Federally Enforceable Through Title V Permit 18. CO emissions for source test purposes shall be measured using EPA Method 1 or ARB Method 1. [District Rule Federally Enforceable Through Title V Permit 19. NOx emissions for source test purposes shall be measured using EPA Method 7E or ARB Method 1 on a ppmv basis, or EPA Method 19 on a heat input basis. [District Rules 18 1 ; District Rule 435; District Rule 435 I] Federally Enforceable Through Title V Permit 2. Stack gas oxygen for source test purposes shall be measured using EPA Method 3 or 3A or ARB Method 1. [District Rules 181 ; District Rule 435; 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 18 1 ; District Rule 435; 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 1811 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 24 or D 2382 for liquid hydrocarbon fuels. [District Rule 18 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 4 CFR Part [District Rule ] 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 252,9.3.2] 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 252, 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 294 W WHITESBRIDGE RD-MENDOTA. CA 9364 C-117- Me, PM - BROWND

39 Permit Unit Requirements for C (continued) Page 3 of 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 precombustion, 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 252, 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 172, D 33 1, D 484, D 3246 or grab sample analysis by GC-FPDITCD performed in the laboratory. [District Rule 252, and District Rule 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 D288. If the unit is fired on certified liquid fuel, certification for each batch delivered shall be obtained and maintained. [District Rule 252,9.3.2; District Rule 435 I] Federally Enforceable Through Title V Permit 3. The concentration of sulfur conlpounds in the exhaust from this unit shall not exceed.2% by volume as measured on a dry basis over a 15 minute period. [District Rule 481 and Fresno County Rule 461 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 6 days of firing on oil. [District Rule 252, 9.3.2, 435, 436 and 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 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 181 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 181 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 252, 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 252, 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 1 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 252, Federally Enforceable Tlirough Title V Permit 38. Emissions for this unit shall be calculated by using the arithmetic mean, pursuant to District Rule 181 (12/16/93), of 3 one-hour test runs for PM 1; and the arithmetic mean of 3 forty-minute test runs for NOx and CO. [District Rule 252, 9.3.2; District Rule 435, 5., 8.1; District Rule 435 I] Federally Enforceable Through Title V Per~iiit 39. Ownerloperator shall comply with the requirements of Rule 436 (adopted September 18, 23) by the dates as specified in Table 2 of the Rule. [District Rule 436, 7.1 Federally Enforceable Through Title V Permit 4. The permittee shall comply with the compliance assurance monitoring operation and maintenance requirements of 4 CFR part [4 CFR part 641 Federally Enforceable Through Title V Permit Facility Name: SPRECKELS SUGAR COMPANY Location: 294 W WHITESBRIDGE RD,MENDOTA. CA 9364 C ~ a25 r PM - BROWND PERMIT UNIT REQUIREMENTS CONTINUE ON NEXT PAGE These terms and conditions are part of the Facility-wide Permit to Operate.

40 Permit Unit Requirements for C (continued) Page 4 of The permittee shall colnply with the recordkeeping and reporting requirements of 4 CFR part [4 CFR part 641 Federally Enforceable Through Title V Pertnit 42. If the District or EPA determine that a Quality improvement Plan is required under 4 CFR 64.7(d)(2), the permittee shall develop and imple~iienthe Quality Improvement Plan in accordance with 4 CFR part [4 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: 294 W WHITESBRIDGE RD.MENDOTA. CA 9364 GI Mar PM - BROWND

41 Attachment B ERC Application

42 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: ~ ~ i ~ ~ k ~ :LC. l ~ 5dy Cum pal1 Y d (if lino\\.n) Facility 11): C II 2. A,I-I,INC.IDDRESS: Streetm.O. nor: p.. BOX b2 3. L,OC.ATIOK OF REDIICI'IOX: Street: 3q~t. ~ hk5 l br ;C!C& Rd 4. DATE OF REDlICTIOS: %/3i 1s I4 SECTION TO\\'XSIIIP I(:\NCE I I I I1 5. PEKAIIT NO(S): EXISTING EliC NO(S): C1_-i1'74 - I 6. XIETIIOI) RESlrLTlNG IN EnllSSlOS I1b:I)lICTIOS: DESCRIPTIOR:: SI~IlJl'DO\!'N I I lieti1ofit I I PROCESS CI-IANGE I I OTHER I I 7. KEQIJESTED EKCs (In Pounds Per Calendar Quarter): (Use addlt~ollal sll~.ets if l~ccessa~y) \'OC RO\ CO I'h11 - pp - -- ISI QUARTER &?-- 2NDQUARTER /b 89 l llth 3RD QUARTER JTH QUARTER -e-- a- 3YY6.45 -e- l/ 9. TlrPEoR PRINT NAME OF PI'LIC1NT: I D:\I'E: TELEPIIONE NO: DATE STAMP FE? 1, a3 c. 2 (,...# ;:,..-,,.i GUFCLG: F a ~CX.G\V~ : o ~DZ" /~tro&w Northern Regional Office * 48 Enterprise \+lay * Rlodesto, California * (29) * FAX (29) Central Regional Office * 199 East Gettysburg Avenue * Fresno, California * (559) * FAX (559) Southern Regional Office * Flyover Court * Bakersfield, California 9338 * (661) * FAX (661)

43 ERC Spreadsheet for Spreckels Sugar Mendota Facility Emission Factors (from AP-42) Sugar cooler, rotoclone Filterable PM.13 Sugar cooler, rotoclone condensible organic PM.43 Sugar granulator, rotoclone Filterable PM.64 Sugar granulator, rotoclone Condensible Organic PM.37 Total Emission Factor1 Ib PM Iton sugar.22 PM Permit # I Equipment Throughput, quarter Ibslqtr Sugar Beet Manufacturing Process C Qtrl 25 ton Qtrl 24 ton Qtrl Avg ton QtR ton QtR ton Qtr2 Avg ton Qtr ton Qtr ton Qtr3 Avg ton Qtr ton Qtr ton Qtr4 Avg ton

44 San Joaquin Valley Air Pollution Control District Application for NI.;~IISSION ItC:I)IICTIOX CItEI)II' (EIlC) I I CONSOl,lDATlOi\: 1: I:RC CERTIFIC::\TI<S - I. EllC 1' BE ISSCIC:I) TO: &- Facility ID: C- I k' C? 3prrck~(5 ~ L ) ~ ~ C LCO~P&~, 'Tt')c. 2. hl.+lling.ai)dkess: Street/P.O. Box:? c 3.4 ba 3. LOC.4TIOX OF ItED[ICTION: Street: - city: (if known) - f%~~\d~k- State: C A Zilr Code: Ci 3G bridq~ Raced d Menc4o.b, LA C13bq J N SECTIOK TO\\'KSI Ill' RANGE 4. D:\TE OF REDI!CTIOK: 8 13\/8 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 1-IiElt DESCRIPTION: (Usr additrotrnl slrcets ifrrscessaq) 7. REQCIESTED ERCs (In Pounds Per Calenclar Quarter): / 9. 1'l.PE OK PRINT NARlE OF.APPLICANT: Tahn &c* Tl'PE OR IDKINI'l'ITLE OF APPLIC.AN'I': ney;afl~l MT- DATE: TELEPCIONE NO: ~3=t-65S-~ctbl A 273 FOR AI'CD USE ONLY: DATE STAMP RE(~E? tgu P..: Vi b-.. FEB 2 5 ;gi;j - c.,, I?.-.- WL' &()KT;+z,:;i.,;,...,..-., FILING FEE RECEI\'ED: S D,\.fE P.411): qme /77~b.3 I'ItOJECT NO.: ' F:\cILIT~ ID.: \ 179 Northern Regional Office * 48 Enterprise \\lay * Modesto, California * (29) * FAX (29) Central Regional Office * 199 East Cettysburg Avenue * Fresno, California * (559) * FAX (559) Southern Regional Office * Flyover Court * Bakersfield, California 9338 * (661) * FAX (661)

45 ERC Spreadsheet for Spreckels Sugar Mendota Facility Emission Factors (from Emission Statement) Ib per 1 Ib per 1 Ib per 1 Ib per 1 Ib per 1 gal fuel o ~l gal fuel oil gal fuel 11 gal fuel o~l gal fuel 11 NOx Sox VOC CO PMlO Permit # I Equi~rnent Throuqhput, quarter Ibslatr Ibslqtr Ibslatr Ibslqtr Ibslatr Lime Kiln 4 NIMBtuIhr Qtrl 25 gallons C Qtrl 24 gallons Qtrl Avg gallons o Qtr gallons Qtr gallons Qtr2 Avg gallons Qtr gallons Qtr gallons Qtr3 Avg 4722 gallons Qtr gallons Qtr gallons Qtr4 Avg gallons

46 San Joaquin Valley Air Pollution Control District Application for 1 ~E\IISSIO\ #ED~lCIlO;\r CREDIT (ERC') I 1 CO\SOI,II) \l'11\ 1. ERC CEItTIFICATES I. I:HC 1' UE ISSliEI) TO: Facility 1: c- I l7 c1 SgczLte h Su nr C~rflp~y, 3 LC. (if knorvn) 2. 3I:\ILIYG,ADDRESS: Streer/lB.O. tior: i>. o. 13~ Cih: - kte~d.c.~ State: C 6 Zip Code: 7 36Vm 3. I.OC:\TION OF KI:D[!CTION: Street: 3qL( ld~1te.5b~tdcj~ iu City: &(QY~O+C~ ~i.3 I V q Q 4. D:\TE OF REDIJCTIOK: N SECTION TO\\NSIIIP RANGE 5. IIElc\llT NO(S): -,,., -,L- EXISTING I.lRC NO(S): 6. AIEI'IIOD RESUCI'INC IN ERfISSION REDI;CTION:.. ~(SII~JTD~~~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'h11 Sox OTHER I'M" OR P1tINI' TI.I'I,E 1: APPLIC.4NT: 9. TI'FE Oli PRINT NAhlE OF APP1,ICANT: DATE: I'ELEPIIOKE NO: 55q.-G5 - '+ct b 1 FOR 411C1) IJSE ONL\': \ RFB>E~ VE D FEB ~9 c- I\ / 4 I-,,.,-, --.,,.,. - - > NORTHERN i7e,:;!gn I:ILIN(; FEE, L% wce1i7ed: s7~ 721;~7q D~TE P \ID: ~2519 ^us I'ROJEC r NO.: ClWC9a F\cI LIT! In.: ClL I 7q Northern Regional Office * 48 Enterprise Way * hlodesto, California * (29) * FAX (29) Central Regional Office * 199 East Gettysburg Avenue * Fresno, California * (559) * FAX (559) Southern Regional Office * Flyover Court * Bakersfield, California 9338 * (661) * FAX (661)

47 ERC Spreadsheet for Spreckels Sugar, Mendota C MMBtulhr, Low Nox Burners, FGR NOx Emissions, lblhr = (ppm)(mw)(2.63~1-9)(ff)(quarterly fuel usage)(2.9-3)) lblhr Nox ;um24,2 vg24,25 Qtrl Qtr Qtr Qtr Total, Ibs Total, tons 7.36 CO Emissions, lblhr = (ppm)(mw)(2.63~1-9)(ff)(quarterly fuel usage)(2.9-3)) lblhr CO ;um24,2 vg24.25 Qtrl Qtr Qtr Qtr Total, Ibs Total, tons 21.2 VOC Emission Factor 2.81bl' VOC emrn = (2.8/1)'(fuel usage '1scf) VOC ;um24,2vg24,25 Qtrl Qtr Qtr Qtr Total, Ibs Total, tons 1.89 Sox Emission Factor 1.1b/lOE6 scf SOX em = (l.olblloe6 scf)(fuel x 1 scf) Sox ~um24,2vg24,25 Qtrl Qtr Qtr Qtr Total, Ibs Total, tons.68 PMIO Emission Factor 7.5 IbllOxE6 scf PMIO ~urn24,2vg24,25 Qtrl Qtr Qtr Qtr Total, Ibs Total, tons 5.7

48 Permitting Services San Joaquin Valley Air Pollution Control District 199 E. Geltysburg Aveti~le Fresno, CA February 24, 29 Spreckels Sugar Company, Inc. P.O. Bos Whitesbridge Rd. Mendola, CA 9364 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 , 4, 6 and 14 (ERC applications are submitted separately for each of these pernlits). Plcase note tlie ERC applications are based on calendar years 24 and 25, 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 Tons of Sugar Beets Processed 419, , ,795 9,925 86,23 863, ,45 746,3 12 1,63, ,333 Please contact me at x 258 or Anne Ogrey at x27 if yo11 have any questions regarding this application. Sincerely, John Dean District Manager

49 srl,.!>cd, lm, %= P-d. C*l Bollal gas. Mcl Bol., gas. lnom. Bo11.r gas. mmblu F~l11. rnl. Fuel,. thrms Bulk ima a,". ID. CAP KIln gar. Imrms CAP Kln oai. Mcl Bum sllca, ton, Sug' PrmuSOd. cw, Lllcr gas. Mcl Balm gar.,nnm, &,,a, 9%. mms,u Fusl 11. 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, ~ ar CAP Kaln om., fn.rms CAP Nm gas. Mcl Be.,..l,cad.,on, Supl prmuud. CW Bal* Qsr. M1 Bo~lar gar, Inarms Bollv gw. -BLU FwI 1, w,. Fval Oil. tlim'rn. Bulk rms ash. Ib, CAP ffil" gm. Vlsrm. CAP ffiln gar. Mcl srl..!tcdd. 1. Suga produced. Crrl Bn\.r 9". ME( Bo1.r gas. tn.,m, &la, pa, rnrnbl" Fuel 11 1M. Fu., 8,,m.tm. &11h.ma arn ~bs CAP Kdn par, lnsrms CAP Klin Oar. Mcl 25 ar yta a2 ytd 3 yla ol yta Be13 sl~ced, Ions S q l produced. Cwl M Baler gss. Mcl Boiler mar. -. msrms Bollsr gss, mmbtu ,71, Fvsl Oil. ~MDII A46 Fwlh1, fhsrms Ma ,727,332 BUI~ s ~ ash a ~bs CAP Kmgar (htms CAP Nln gal Mcf. XK)4 1 yfs 2 ytd 3 yll 4 yld srtr KILCW, lmr a1 85,23 Svpa prmucd Cwl ,292,917 Bo8l.r gac. Msl 565M1 lq ,298,561 blu o&. Ih.rms lll3yv12 13, Baler oar, mmblv ,113,56 1,326,211 Fud hl. Wir ,651 ~u.1 1.!harm M.12 Bulk.ma arb, la* CAP Kln gal. Iherms CAP Klln gar. Msl

50 Beet Sugar Process Flow Diagram

51 Attachment C Baseline Period Determlination

52 Baseline Period Determination,Calendar Quarter Q1-25 Q2-25 Q3-25 Q4-25 Q1-26 Q2-26 Non-Seasonal Source (Sugar Beet Manufacturing) Sugar Produced (ltons/qtr) 45,97 45,258, 21,,255.O 37,8,7 8-Qtr Block Differences vs 12-Qtr Block Differences vs 16-Qtr Block Differences vs 2-Qtr Block Differences vs... NSO NSO NSO NSO j~his value is the smallest "difference" compared to the Normal Source '/: - "... r loperation (NSO) average. Therefore, the 8 consecutive quarters {associated. with it (Q Q ) most closely represent NSO "... Example 8-Qtr Block Calculation (Q2-27): 8-Qtr Block = Absolute[NSO - Average(Q3-25 through Q2-27)l 8-Qtr Block = Absolute[21,893 - ((45,258+21, ,87+33, ,254) 1 8)] 8-Qtr Block = 86 Example 16-Qtr Block Calculation (Q4-29): 16-Qtr Block = Absolute[NSO - Average(Q1-26 through Q4-29)l 16-Qtr Block = Absolute[21,893 - ((+37,87+33,15+9,9++29,254+45, , , ) / 16)] 16-Qtr Block = 8,668

53 Spreckels Suga~r Compalny Sugar Production, 4 MMBtulhr Litme Ki~ln Fuel Oi~l Usage and 311 MMBtulhr Boiler Natural Gas Usage Records

54 Jan-4 Feb-4 Mar-4 Apr-4 May-4 L~me K~ln Fuel 11, bbls SPRECKELS SUGAR COMPANY Monthly Factory Throughput from EKC Banking Applications Project Number C Lime Kiln Fuel 11, therrns Gas Purchase d, Mcf Bo~ler Gas, therrns Boiler Gas, MMBtu Carbon K~ln Gas, therrns 1684 Carbon K~ln Gas, MMBtu 168 Sugar Produced, Cwt

55 SPRECKELS SUGAR COMPANY Monthly Factory Throughput from ERC Banking Applications Project Number C-PO999 Produced,

56 SPRECKELS SUGAR MONTHLY TONS SUGAR BEETS SLICED FROM