c

ud

g the numbers below. Our modeler, Cleveland Holladay, would like to verify those results and we

do not have a copy of the updated modeling with those numbers.

Proposed Startup! Shutdown Emission

Rate (lb/hr)

NO (1-hour) 94.3 lb/hr

CO (1-hour) 400 lb/hr V

PM! PM10!PM5(24-Hour) 18.7 lb/hr

SO2(1-hour) 4.68 lb/hr

Environ provided these numbers and said that they demonstrated compliance with the NAAQS through amodeling demonstration, do you have a copy of those files available for our review?Can you provide an isopleth analysis of the cumulative N02 1 hr analysis for both the normal operation

startup/shutdown modes? The isopleth analysis should be based on the values used for comparison tothe 1 hr N02 standard.

Can you also provide the same for PM2.5 annual and 24-hour analyses, along with the CO isopleths for

both modes.

I believe the March 2010 submission contains only the impacts from the proposed new boiler and not the

cumulative impacts. Please discuss further with Cleveland Holladay, copied here and at (415) 947-4140,

if you have comments or questions. . V

Thanks.

Omer Shalev

Environmental Engineer

Air Permits Office (Air-3)

Environmental Protection Agency, Region 9

75 Hawthorne St.

San Francisco, CA 94105(415)972-3538 V

“Dave Brown” 0mm -good question -comes down to ecoriorni... 03/19/202 09.48:14 AM

From: “Dave Brown” <DBrown@spi-ind.com>

To: Omer Shalev/R9/USEPAJUS@EPA, “Eric Albright” <ealbright@environcorp.com>

Date: 03/19/2012 09:48 AM

Subject: RE: FW: EPI Boiler performance question
The second part of the question on variability in steam still occurs at facilities where nearly all the onsite

material is consumed at the boiler. This is due to the moisture content and variety of fuel (e.g. hogged

‘green’ material, planer (kiln-dried) shavings, bark, etc). Seasonal fluctations with covered and uncovered

fuel piles add to the moisture content variability. Yes, to an extent there is more consistency when fuel is

solely supplied from a sawmill — however, the variability remains.

Let me know if you want to chat more on the phone about this.

Dave

..

From: Omer Shalev [mailto:Shalev.Omer@epamail .epa .govj

Sent: Thursday, March 15, 2012 1:52 PM

To: Eric Albright

Cc: Dave BrownSubject: Re: FW: EPI Boiler performance question

Eric or Dave, I was hoping you could provide another point of clarification. The application states the

following:

The Anderson facility currently produces 160,000 BDT of wood waste per year. Approximately60,000 BDT are consumed by the existing cogeneration facility, 20,000 BDT are trucked to other

biomass power plants, and the roughly 80,000 BDT balance is trucked to other markets (e.g.

wood chips to pulp mills). The new proposed boiler will have the capacity to consume a

maximum of 219,000 BDT per year. Roughly 80,000 will be generated by the facility’s existinglumber operations at its current output, and additional wood fuel will be transported by truck to

the facility from other SPI sources.Why not shift all of the wood produced on site to the proposed new boiler and have additional wood waste

generated or trucked in go to the existing boiler? Wouldn’t this reduce the variability in steam

requirements for the new boiler? Why is this not possible or appropriate for facility operations?

Thanks.

Omer Shalev

Environmental Engineer

Air Permits Office (Air-3)

Environmental Protection Agency, Region 9

75 Hawthorne St.

San Francisco, CA 94105(415) 972-3538