Re: SPI-Anderson Cogeneration Project-Class II Additional Impacts Analysis

Cleveland Holladay 

to: 

Eric Albright, Kyle Heitkamp 

07/06/2012 02:08 PM 

Cc: 

Dave Brown, George Emmerson, Omer Shalev, Shane Young, Shirley Rivera 

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From: Cleveland Holladay/R9/USEPA/US Sort List... 

To: Eric Albright <ealbright@environcorp.com>, Kyle Heitkamp <kheitkamp@environcorp.com>

Cc: Dave Brown <DBrown@spi-ind.com>, George Emmerson <GEMMERSON@spi-ind.com>, Omer 

Shalev/R9/USEPA/US@EPA, Shane Young <SYoung@spi-ind.com>, Shirley 

Rivera/R9/USEPA/US@EPA 

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Eric, Kyle, 

As part of preparing the Fact Sheet and Ambient Air Quality Impact Report for SPI-Anderson 

(SPIA), EPA is requesting the following information, which is lacking, pertaining to the Class II 

additional impacts analysis, especially to visibility impairment. The Class II visibility analysis is 

independent of the Class I visibility Air Quality Related Values (AQRV) analysis. The PSD 

application (March 2010) is not responsive to the intent of 40 CFR Part 52.21(o). 

Therefore, identify Class II federal and state areas (e.g., potentially sensitive 

parks, forests, monuments, and recreational areas) within 50 km of SPIA. Discuss 

the potential visual impacts of the SPIA project on these areas. Consider 

information presented in the EPA 1992 workbook - 

“Workbook for Plume Visual Impact Screening and Analysis (Revised)”, EPA, 

EPA–454/R–92–023, 

1992.

Then based upon your evaluation, conduct a VISCREEN Level 1 analysis for any identified areas, 

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and if necessary, a Level 2 analysis if the Level 1 impacts are exceeded. If there is a valid 

reason not to conduct an analysis, SPIA/Environ should provide that narrative.

In addition, for the soils and vegetation analysis, provide the time frame the soils 

information was based (e.g., 2010, 2006, other recent review?) on. 

If you have questions, call me at the number below or Shirley Rivera at 415-972-3966.

Thanks,

Cleve Holladay

415-947-4140 

U.S. EPA, Region 9, AIR-07 

75 Hawthorne Street 

San Francisco, CA 94105 

-----Eric Albright <ealbright@environcorp.com> wrote: -----

To: Omer Shalev/R9/USEPA/US@EPA, Cleveland Holladay/R9/USEPA/US@EPA 

From: Eric Albright <ealbright@environcorp.com>

Date: 06/29/2012 02:55PM 

Cc: Dave Brown <DBrown@spi-ind.com>, George Emmerson 

<GEMMERSON@spi-ind.com>, Shane Young <SYoung@spi-ind.com>

Subject: SPI-Anderson Cogeneration Project 

Omer & Cleveland: 

 

As I mentioned previously, I’m going to be out of the office from July 2 until July 

16. In my absence, Kyle Heitkamp (425.412.1803) may be able to help you if 

you have any questions or need additional information while I am away. I will 

check e-mail as often as possible, but I don’t know in advance what my 

connectivity will be; I will almost certainly not be receiving voice mails. 

 

If possible, it would be helpful if you could send brief e-mails notifying SPI when 

internal milestones have been reached (e.g., modeling review is complete, draft 

permit has been finalized for internal review, internal review is complete, etc.). 

Assuming it is possible for you to send such communications, please copy 

everyone on the distribution list for this message. This will help SPI to forecast 

future activities related to this project, which is, as you know, “shovel ready,” 

and critical to the ongoing viability of the Anderson facility. 

 

Thanks, and please do not hesitate to contact me or Kyle if we can provide 

anything to help get the draft permit out for public comment. 

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Eric 

 

Eric Albright, PE | Senior Manager

ENVIRON International Corporation

19020 33rd Avenue W, Suite 310 | Lynnwood, WA 98036

T: +1 425 412 1804 | F: +1 425 412 1840 | M: +1 206 909 0591

ealbright@environcorp.com

 

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