19020 33rd Avenue W, Suite 310, Lynnwood, WA 98036-4748 

Tel: +1 425.412.1800 Fax: +1 425.412.1840 

www.environcorp.com 

September 7, 2010 

Project No. 29-23586A 

Mr. Gerardo Rios 

U.S. Environmental Protection Agency, Region 9 

75 Hawthorne Street 

San Francisco, California 94105 

Subject: Response to Second Incompleteness Determination 

Sierra Pacific Industries Biomass-Fired Cogeneration Project 

Anderson, California 

Dear Mr. Rios:

The U.S. Environmental Protection Agency, Region 9 (USEPA) office issued a letter on May 

11, 2010 indicating that the Prevention of Significant Deterioration (PSD) permit application 

submitted on March 26, 2010 in support of the biomass-fired cogeneration project proposed 

by Sierra Pacific Industries, Inc. (SPI) for their Anderson facility is incomplete, and that 

additional information was needed to determine that the application is complete. ENVIRON 

submitted a letter on July 1, 2010 that contained additional information intended to address 

the issues raised in the May 11 letter. A second letter from USEPA was issued on August 16, 

2010 requesting additional information beyond that requested in the May 11 letter. This 

letter intends to provide the information requested in the August 16 letter, as well as during 

the August 19, 2010 conference call between USEPA, SPI, and ENVIRON, and enable 

USEPA to deem the permit application complete. Responses are organized in the same order 

as that of the enclosure to your letter, and the information requests are summarized as an 

italicized introduction to the response. 

Best Available Control Technology (BACT) Analysis:

Outline energy and environmental impacts for each pollutant for which a BACT analysis was 

provided, and economic impacts for each BACT analysis that does not result in selection of 

the most stringent control technology. 

Energy and Environmental Impacts: 

NOX

No additional significant environmental or energy impacts from employing either SNCR or 

SCR technology are anticipated. Both SNCR and SCR systems use ammonia in some form 

as a reagent: anhydrous ammonia, aqueous ammonia, or urea mixed with water (which 

hydrolyzes in the hot exhaust to form ammonia). In the case of aqueous ammonia or urea 

mixed with water, additional fuel must be combusted to evaporate the water associated with 

the reagent. The proposed SNCR system will use anhydrous ammonia. Energy is required to 

operate the injectors used by either technology to introduce the reagent to the exhaust. With 

either technology, the exhaust leaving the boiler stack will contain some quantity of 

unreacted ammonia. 
CO

No additional significant environmental or energy impacts from employing proper 

combustion techniques or an oxidation catalyst would be anticipated. An oxidation catalysts 

may slightly increase the pressure drop, and require some additional energy, but this effect is 

assumed to be minimal. The control systems associated with proper combustion techniques 

use some energy, but the savings in achieving more complete combustion undoubtedly 

outweighs the costs. 

PM/PM10/PM2.5

A wet scrubber is the most energy intensive of the feasible control technologies, and creates a 

liquid waste stream. A baghouse requires additional energy to overcome the increased 

pressure drop. An electrostatic precipitator (ESP) system uses electricity to create an electric 

field, but has the lowest overall energy use of the three feasible technologies. 

Reassess the technical feasibility of EMx for control of NOX and CO. 

EMx is considered the most effective ammonia-free reduction technology available for 

combustion turbines, reciprocating engines, and industrial or utility boilers firing gaseous or 

liquid fuels. EMx has never been utilized with a biomass-fired boiler. Similar to SCR, the 

potential for poisoning and plugging of the catalyst from trace elements and ash in the 

exhaust makes EMx not technically feasible for use with a biomass-fired boiler. 

Consider a baghouse or fabric filter in combination with a multiclone or ESP for control of 

PM/PM10/PM2.5.

The BACT analysis provided with the permit application indicated that the ESP considered 

as a control alternative would be preceded by a multiclone. The analysis should have 

indicated that the baghouse considered as a control alternative would also be preceded by a 

multiclone. Multiclones are a low-cost way to remove larger particulates and reduce the cost 

associated with operating higher cost control systems such as an ESP or baghouse. 

Baghouses and ESPs are considered to be equally effective at reducing PM/PM10/PM2.5 from 

biomass-fired boilers. ESPs are typically preferred because they are less prone to catching 

fire. ESPs tend to have higher initial costs, but lower operating costs when compared to a 

baghouse. 

Combining an ESP and a baghouse in series would result in increased removal of 

PM/PM10/PM2.5 from the exhaust, but the incremental cost effectiveness would be extremely 

high. Assuming that a baghouse would cost approximately $500,000 per year to operate, and 

would remove an additional 35 tons per year of PM/PM10/PM2.5 from the exhaust (this 

assumes that the baghouse would remove 96 percent of the PM/PM10/PM2.5 from the exhaust 

even though the majority of the remaining PM/PM10/PM2.5 would be PM2.5 and condensable 

PM, which is most likely a generous assumption), the incremental cost effectiveness would 

be over $14,000 per additional ton of PM/PM10/PM2.5 removed. This is clearly outside the 

envelope of reasonable cost effectiveness. 

Address BACT during startup and shutdown periods. 
During startup and shutdown, CO and VOC concentrations in the flue gas will exceed those 

experienced under normal operation. This is a characteristic of all biomass-fueled 

combustion devices because the temperature required for optimum combustion conditions is 

not achieved immediately after startup commences, or as shutdown proceeds. Similarly, 

SNCR systems require an exhaust gas temperature above approximately 1,500°F before asdesigned NOX emission abatement will occur. During startup and shutdown it is not 

technologically feasible to meet CO, VOC, or NOX BACT limits that are specified on the 

basis of normal boiler operation. SPI proposes that, during startup and shutdown periods, 

BACT for CO, VOCs, and NOX is to limit the frequency and duration of startups, shutdowns 

and periods of upset through the implementation of best practices and training. 

Provide averaging periods for the proposed NOX and CO BACT limits. 

SPI proposes that the bases for the BACT limits presented in the permit application be block 

24-hour averages. A block average is defined as the arithmetic average of the hourly 

emission rates of a unit as measured over 24 one-hour periods, daily, from 12:00 AM to 

11:59 PM, excluding periods of system calibration. 

Proposal to Revise 40 CFR Part 63, Subpart DDDDD:

SPI acknowledges that the emission limits proposed in the submitted PSD permit application 

may not be less than the limits in the National Emissions Standard for Hazardous Air 

Pollutants (NESHAP) for Industrial/Commercial/Institutional Boilers and Process Heaters 

proposed by USEPA on June 4, 2010 (a.k.a. “Boiler MACT”). SPI would like to point out 

that the submitted permit application was intended to address the requirements of the PSD 

program, and not proposed NESHAP requirements. SPI intends to operate the proposed 

boiler in a manner that complies with all applicable Boiler MACT requirements at the 

appropriate times, following promulgation of the final rule. 

Nitrogen Dioxide (NO2) Air Quality Impact Analysis

Include all competing industrial sources of NOX 50 kilometers beyond the Significant Impact 

Area, as defined by the USEPA-recommended interim Significant Impact Level (SIL). 

The ambient 1-hour NO2 standard compliance assessment that was provided in the July 1 

letter included competing industrial sources of NOX within 50 kilometers (km) of the 

Anderson facility. On June 28, 2010, three days before that letter was finalized, a 

memorandum from Anna Marie Wood, Acting Director of USEPA’s Air Quality Policy 

Division indicated that USEPA recommended that an interim 1-hour average NO2 SIL of 4 

parts per billion (ppb). Revisiting the 1-hour NO2 standard compliance analysis, and using 

the interim SIL to determine the Significant Impact Area (SIA), the most distant receptor that 

equals or exceeds the interim SIL is approximately 6.1 km from the Anderson facility. 

ENVIRON contacted John Waldrop of the Shasta County Air Quality Management District 

(SCAQMD), Joe Sunday of the Tehama County Air Pollution Control District (TCAPCD), 

and Brian Wilson of the North Coast Unified Air Quality Management District (NCUAQMD 

– which includes Trinity County) to request emission rates and release parameters for 

industrial sources of NOX within 56.1 km, but beyond 50 km of SPI’s Anderson facility. 

SCAQMD and TCAPCD reported that no additional sources were located in those areas. 
NCUAQMD reported that a single source in Trinity County was within 56.1 km of the 

facility: a 102 horsepower diesel engine associated with an emergency generator owned by 

Pacific Bell in Lewiston, California. 

The Pacifc Bell generator in Lewiston was subjected to the same air dispersion modeling 

simulation methodology described in the July 1 letter that was used to determine whether or 

not sources of NOX were significant within the SIA. Using the location (516992.25 m 

easting, 4506091.85 m northing, UTM Zone 10) and maximum 1-hour average NOX

emission rate provided by NCUAQMD (3.162 pounds per hour) and representative stack 

parameters for a diesel engine of similar size (stack height – 6.6 ft above grade, stack exhaust 

temperature – 972 °F, stack exhaust flow rate -663 cubic feet per minute, and an inside stack 

diameter of 4 inches). Based on these model inputs, the source was predicted by the model 

to have a maximum concentration within the SIA of 1.45 μg/m3, which is less than the 

interim 1-hour average NO2 SIL. As a result, the 1-hour average NO2 compliance analysis, 

as provided in the July 1 letter, does not need to be changed or amended to reflect the impact 

of sources within 56.1 km of the Anderson facility. 

Provide a rationale for using data collected by the ambient NO2 monitor in Chico, California 

to determine the NO2 background concentration. 

Monitor locations for which recent ambient NO2 data were available included Yuba City – 

Almond Street, Ukiah – E. Gobbi Street, Willits – S. Main Street, and Chico – Manzantia 

Avenue. The Willits and Ukiah monitors were rejected because they are located west of the 

Coastal Range, and therefore in an entirely different airshed from that of the Anderson 

facility. The Yuba City and Chico monitors are both located in the foothills that make up the 

east side of the Sacramento Valley, and are therefore in the same airshed as the Anderson 

facility. Both Yuba City and Chico have considerably larger populations, and are more 

urban, than Anderson; the Chico monitor was chosen because it is physically closer to 

Anderson. 

Provide clarification that 1-hour NO2 impact analysis included short-term emission limits for 

the competing industrial sources of NOX. 

ENVIRON requested that SCAQMD, TCAPCD, and NCUAQMD provide maximum 

allowable hourly emission rates for each source within 56.1 kilometers of the Anderson 

facility. SCAQMD provided a spreadsheet with permitted short-term NOX limits for each 

source, and TCAPCD provided a similar spreadsheet with hourly maximum emission rates. 

NCUAQMD provided the maximum hourly NOX emission rate for the single source within 

its jurisdiction. 

Provide a discussion of whether startup or shut-down emission rates associated with the 

proposed boiler were included in the 1-hour NO2 impact analysis. 

The 1-hour average NO2 compliance analysis was repeated, changing only the proposed 

boiler emission rate and stack parameters to reflect startup conditions. The stack parameters 

were the same as those used for the 1- and 8-hour average CO startup analysis described in 

the submitted PSD permit application. The worst-case NOX startup emission rate was 

estimated to be 55 percent higher than the maximum expected during normal operation (94.3 

pounds per hour). The maximum model-predicted 1-hour NO2 concentration (assuming 100 
percent conversion of NO to NO2) from the cumulative analysis was 89.9 μg/m3

, and the 

five-year average of the 98th percentile of the annual distribution of the daily maximum 1-

hour average NO2 concentrations was 69.5 μg/m3. Combining the 98th percentile 

concentration with the representative background concentration used in the submitted PSD 

permit application (80.9 μg/m3

) results in a total concentration of 170.8 μg/m3, which is less 

than the ambient standard (188 μg/m3

), indicating that the proposed project would neither 

cause nor contribute to an exceedance of the Federal 1-hour average NO2 standard, even 

during startup. 

It should be noted that the cumulative impact modeling is conservative in that, in addition to 

assuming that all NOX is converted to NO2, the analyses of receptors exceeding the interim 

SIL were not restricted to only the time periods in which the proposed source was predicted 

to have a significant impact at each receptor. The less conservative, but more accurate, 

approach, which is to develop individual modeling runs for each receptor and time period 

combination for which the proposed source was predicted to be significant, is much more 

resource intensive. The results of the easier, but more conservative analysis are presented 

because they indicate compliance with the ambient standard in question, but it should be kept 

in mind that the more labor-intensive methodology would most likely predict lower 

concentrations. 

Provide justification that the meteorological data used in the dispersion modeling is 

representative of conditions at the Anderson facility. 

The Redding Municipal Airport, where the meteorological tower from which the data used in 

the air dispersion modeling analyses is located, is approximately 4.5 km (2.8 miles) northnorthwest of SPI’s Anderson facility. Both the station and the facility lie in the broad 

Sacramento Valley, and, considering the proximity of the facility and the station, it is 

unlikely that the wind and weather patterns experienced by one differ greatly from that of the 

other. For your consideration, a table is attached to this letter that presents the seasonal 

surface parameters calculated by AERSURFACE for the area surrounding the meteorological 

tower at the airport (which were used by AERMET to create the meteorological dataset used 

by AERMOD), and, for comparison, the surface parameters surrounding the Anderson 

facility. 

Biological Resources Practices

Provide current and proposed best management practices. 

The enclosed National Pollutant Discharge Elimination System (NPDES) permit and Storm 

Water Pollution Prevention Plan (SWPPP) identify specific Best Management Practices that 

are currently being implemented for mill operations. Many of the erosion control and spill 

prevention measures identified in the existing SWPPP will be implemented for the proposed 

project. Discharge points identified in the existing SWPPP will not change for the proposed 

project, and all storm water runoff will be contained on the mill site. 

Specify the distance from construction activities and the elderberry shrubs.

The valley elderberry longhorn beetle will not be directly or indirectly affected, as SPI has 

confirmed that construction activities would not occur within 100 feet of elderberry shrubs 
that are in the Pacific Gas and Electric power line Right of Way. The nearest construction 

activity to the existing elderberry plants will be the erection power poles at the existing 

electrical sub-station. As shown in the attached site map, the erection of the electrical power 

poles will be approximately 137 feet from the nearest elderberry shrub. This construction 

will be limited to the auguring three holes adequately sized holes for the erection of these 

power poles, stringing the necessary power cables and miscellaneous tasks associated with 

making the intertie complete. The main construction area, where the boiler, turbine building, 

fuel shed, electrical substation, cooling tower, and ESP will be built, is approximately 800 

feet further north from these three power poles. 

Specify changes in fuel consumption, handling, and storage, and resulting construction 

activities.

The majority of fuel will be stored in a new fuel storage shed to be built on land that has 

previously been developed for use in support of mill operations. All fuel storage will be 

confined to the existing mill site, and will not result in the loss of natural communities. 

Although more fuel will be stored on site, changes to the fuel handling system will include a 

hydraulic truck dump and fuel reclaimers used to feed the boiler, both of which will increase 

work efficiencies and reduce emissions from transport and fuel handling vehicles. 

Provide a description of proposed traffic increases and transportation-related construction 

activities.

The proposed project would utilize existing roads and infrastructure. No additional roads or 

transportation infrastructure are proposed to be built. Daily traffic volume is expected to 

increase as a result of the proposed project, but is not expected to adversely affect biological 

resources in the project vicinity. 

We believe that the information provided in this letter addresses the issues raised by USEPA, 

and should be considered to amend the submitted PSD permit application. Please let me 

know if USEPA requires any additional information to deem the permit application 

complete. If you or your staff has any additional questions or need additional information, 

please do not hesitate to contact me at 425.412.1804. 

Sincerely yours, 

ENVIRON INTERNATIONAL, INC. 

Eric Albright 

Senior Manager 

Enclosures 

cc: Omer Shalev, USEPA, Region 9 

Shane Young, Sierra Pacific Industries 

Dave Brown, Sierra Pacific Industries 

Cedric Twight, Sierra Pacific Industries 
Table 1. Comparison of Surface Characteristics Surrounding 

SPI’s Anderson Facility and Redding Airport 

SPI’s Anderson Facility Redding Airport 

Season Sector Albedo Bowen Ratio Zo (m) Albedo Bowen Ratio Zo (m) 

1 0.51 0.48 0.043 0.52 0.48 0.37 

2 0.51 0.48 0.043 0.52 0.48 0.205 

3 0.51 0.48 0.037 0.52 0.48 0.205 

4 0.51 0.48 0.034 0.52 0.48 0.052 

5 0.51 0.48 0.026 0.52 0.48 0.027 

6 0.51 0.48 0.024 0.52 0.48 0.019 

7 0.51 0.48 0.09 0.52 0.48 0.008 

8 0.51 0.48 0.166 0.52 0.48 0.008 

9 0.51 0.48 0.017 0.52 0.48 0.008 

10 0.51 0.48 0.01 0.52 0.48 0.007 

11 0.51 0.48 0.015 0.52 0.48 0.006 

Winter 

12 0.51 0.48 0.009 0.52 0.48 0.094 

1 0.16 0.52 0.113 0.16 0.51 0.64 

2 0.16 0.52 0.097 0.16 0.51 0.452 

3 0.16 0.52 0.092 0.16 0.51 0.456 

4 0.16 0.52 0.081 0.16 0.51 0.17 

5 0.16 0.52 0.101 0.16 0.51 0.112 

6 0.16 0.52 0.105 0.16 0.51 0.101 

7 0.16 0.52 0.22 0.16 0.51 0.047 

8 0.16 0.52 0.282 0.16 0.51 0.035 

9 0.16 0.52 0.064 0.16 0.51 0.037 

10 0.16 0.52 0.052 0.16 0.51 0.048 

11 0.16 0.52 0.045 0.16 0.51 0.05 

Spring 

12 0.16 0.52 0.046 0.16 0.51 0.242 

1 0.17 0.55 0.154 0.17 0.61 0.776 

2 0.17 0.55 0.128 0.17 0.61 0.62 

3 0.17 0.55 0.123 0.17 0.61 0.592 

4 0.17 0.55 0.112 0.17 0.61 0.303 

5 0.17 0.55 0.171 0.17 0.61 0.22 

6 0.17 0.55 0.168 0.17 0.61 0.184 

7 0.17 0.55 0.295 0.17 0.61 0.127 

Summer 

8 0.17 0.55 0.393 0.17 0.61 0.134 
SPI’s Anderson Facility Redding Airport 

Season Sector Albedo Bowen Ratio Zo (m) Albedo Bowen Ratio Zo (m) 

9 0.17 0.55 0.139 0.17 0.61 0.128 

10 0.17 0.55 0.116 0.17 0.61 0.12 

11 0.17 0.55 0.143 0.17 0.61 0.109 

Summer 

12 0.17 0.55 0.1 0.17 0.61 0.401 

1 0.17 0.89 0.154 0.17 0.9 0.776 

2 0.17 0.89 0.128 0.17 0.9 0.62 

3 0.17 0.89 0.123 0.17 0.9 0.592 

4 0.17 0.89 0.112 0.17 0.9 0.303 

5 0.17 0.89 0.171 0.17 0.9 0.22 

6 0.17 0.89 0.168 0.17 0.9 0.184 

7 0.17 0.89 0.295 0.17 0.9 0.127 

8 0.17 0.89 0.393 0.17 0.9 0.134 

9 0.17 0.89 0.139 0.17 0.9 0.128 

10 0.17 0.89 0.116 0.17 0.9 0.12 

11 0.17 0.89 0.143 0.17 0.9 0.109 

Fall 

12 0.17 0.89 0.1 0.17 0.9 0.401 
Figure 1 SPI-Anderson Site Plan Showing Location of 

Elderberry Shrubs in Relation to Proposed New Structures 
Enclosures