1 Kelly, Shaheerah

From: Shane Young [SWyoung@spi-ind.com]
Sent: Thursday, December 19, 2013 3:12 PM

To: Kelly, Shaheerah
Cc: Tony Jaegel; wsloan@mofo.com; Dave Dun; Er ic Albright (ealbright@environcorp.com) Subject: EPA Ltr Kelly 12 18 13

Attachments: EPA Ltr Kelly 12 18 13.pdf

Shaheerah,

The attached letter represents additional comments to the Draft PSD permit. If you have any questions or if I can be of

further assistance please feel free to contact me.

Regards

Shane Young

Sierra Pacific Industries

19758 Riverside Ave

Anderson Ca. 96007

P 530

‐ 378

‐ 8356

C 530

‐ 604

‐ 0025
swyoung@spi

‐ ind.comDecember 18, 2013

Ms. Shaheerah Kelly U.S. Environmental Protection Agency, Region 9

75 Hawthorne Street San Francisco, CA 94105

- 3901

Re: Request for Public Comment

– PSD Application SAC 12

- 01 Sierra Pacific Industries, Anderson Division

– Cogeneration Project Shasta County, California, Region IX

Ms. Kelly:

Thank you for your time on December 10 th in putting on an informative and successful workshop and hearing. In follow

- up, we have additional comments below that are in addition t o my previous comments submitted on December 6, 2013. The comments below are with respect to the Prevention of Significant Deterioration (PSD) permit language itself. For purposes of coordination, we have shown the PSD permit language italicized with the corresponding permit section and with suggested changes in

bold and underlined . We have also described a brief rationale for each change below each respective permit item.

X.H.7 The Permittee shall submit a CEMS performance test protocol to the EPA no later than 30 days prior to the test date to allow review of the test plan and to arrange for an EPA observer to be present at the test. The performance test shall be conducted in accordance with the submitted protocol and any changes required by EPA.

Co mment: The term “observer” by itself does not clearly distinguish or limit the type of person that may qualify as an observer. This is understood to be an EPA representative or contracted individual with EPA to provide observations and not a 3 rd party or non

- EPA representative that may interpret this condition otherwise to entitle them to be present at the test. The addition of “EPA” to observer does not limit or modify any other permits for the facility or the respective person(s) that are allowed acces s by those permits. As a second comment pertaining to this language, this item (X.H.7) is redundant in its entirety and duplicative with I.2.D (Performance Test). We suggest removing from the “Monitoring Conditions” section (X.H.7) and leave with the su ggested language change above within the “Performance Test” section only (I.2.D) 

# Sierra Pacific Industries

Anderson Division | P.O. Box 10939 | Anderson, CA 96007 | (530) 378

- 8350X.H.11 The Permittee shall furnish the EPA with a written report of the results of performance tests as

identified in this Permit within 60 days of completion.

Comment: Thi s item should limit the requirement to relate to the PSD permit. Suggest to add the language above to clearly distinguish and identify the „tests‟ required for the facility to submit to EPA. There are other „tests‟ that may and will be performed at the f acility that are not required or related to the PSD permit. The above clarity is intended to minimize confusion.

I.2.C Annual performance tests of PM10, CO, CO2, and NOx, shall be conducted at no less than 90%

of the facility’s maximum steam production r ate of 250,000 lb/hr . The performance test requires for CO, NOx, and CO2 shall be demonstrated using the annual relative accuracy test auditing of the CEMS, for each applicable pollutant, required in Condition X.H.6. Comment: It is impractical from a co mpliance/enforcement perspective to require a facility to conduct performance testing at 100% of design. Typically the requirement is to be within 10% of the design (or 90% of the maximum heat or design steam for the facility). It is also important to cl early distinguish that the design steam production rate is 250,000 lb/hr for performance testing purposes.

J.2 The Permittee shall record the efficiency of U1 daily. The heat input, as determined from the U1 efficiency and steam production rate, shall not exceed 468 MMBtu/hr on a monthly basis. This condition is confusing and uncertain as to the intent. It appears the intent is to compare the maximum heat rating design value (468 MMbtu/hr) with actual heat average on a daily basis, also in mmbtu/hr ( 24

- hr average). If this is correct, then „efficiency‟ is the incorrect term for this item and design heat would be more appropriate. The calculation of daily boiler heat in MMbtu/hr units is performed by multiplying the

manufacturer ratio of maximum hea t design to design steam (468 MMbtu/hr divided by 250,000 lb/hr) by the total steam generated each day (lbs/day), then dividing by 24 (hours). Suggest to strike J.2 above in its entirety and replace with condition below:

The Permittee shall calculate and record on a daily basis, the average boiler heat ( MM btu/hr). The calculation shall be based on manufacturer ratio of maximum design heat rating to design steam [max design ( MM btu/hr) divided by design steam (lb/hr)]. The heat input, as determined fro m this, shall not exceed 468 MMbtu/hr on a monthly basis.

J.3 By the last 30 th day of each month, the Permittee shall calculate and record the 12

- month rolling sum of CO, NOx, PM, PM10 and PM2.5 emissions in tpy for U1 for the previous 12 months in

accor dance with Condition X.A.1

. Comment: The month of February does not have 30 days and many months have 31. It appears the intent of the condition is to have the report on the last day of a month.J.4 same as J.3

SPI respectfully requests that these corrections and clarifications be incorporated into the final PSD permit . It is our understanding that these comments result in no change to the AAQIR for the cogeneration project. Please do not hesitate to contact me if you have any questions or concerns about these comments, or any issue related to the cogeneration project.

Sincerely,

Shane Young Division Manager