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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; Eric 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.com
December 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 10th in putting on an informative and successful workshop and 

hearing. In follow-up, we have additional comments below that are in addition to 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.

Comment: 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 3rd 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 access 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 suggested 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) 378-8350

 
X.H.11The 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: This 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 facility 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 rate 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 compliance/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 clearly 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 heat 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 

(MMbtu/hr). The calculation shall be based on manufacturer ratio of maximum design 

heat rating to design steam [max design (MMbtu/hr) divided by design steam (lb/hr)]. The 

heat input, as determined from this, shall not exceed 468 MMbtu/hr on a monthly basis.

J.3 By the last 30th 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 

accordance 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