I r I

w-- MTIposo

CO(iE~ERATION

COP ANY

RECEIVED

-.:> I

AUG bt.. 2009

Permits Uttice Air-3

u.s. EPA. Region 9

August 28, 2009

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Ms. Laura Yannayon

United States EPA, Re ion 9

Air Division Permits ffige (Air-3)

75 Hawthorne Street I II ' San Francisco, CA. 94

1

05-

1

3901

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.," '. Subject: Mt. Poso Cogeneration Company; Minor Modification to '. '. f. I I I

'n :::M:o:::::~ i'e=i~~:~ ~::: N~~::: conslli~t I r. Ted Guth Tills lettcr is

"" ",.,""" written to respond to y ur request for additiohaJ information. r ..:::,.~ -:. - ' Mt. Poso Cogeneratio Jl ~ompany is apP1Yin~ for a PSD Minor Modification that consists of the

following: In Section IX.F, add the words '~r biomass up to 110,800 pounds per hour on a dry

basis". The facility d siI;es to have the flexlbility to combust in any combination: up to 100%

,.~~.' r., :'.;'. coal, petroleum coke, r tire derived fuel (TPF) or biomass. The facility is currently permitted

'ii.:;~"" to combust any comb· ation of coal, PetrollUm. cOke. or TDF. Hence, the only physical change

~:'ilt. to the PSD r~ll ri1ional !'orjg

r·· 1'" This minor modifi~ati ,n ~ll give us the abrty to add biomass 1<j the fuel blend or bum 100%

_

.,:..·.·~,~·cf~~.::~ ..f':.~~v~..,.J:,;:,.,':~~:.·::t.;.•~.·.:.~,i.:•._,~,~.: ,.: :.'..

: to

:~:~~s combust S:t~~~~t~:U~{dr~ 100% bio r Js is:~::::~: very importan~;::~~e::~·m:s~~dO;:~:~ to the electric utilitiek who, as you~:v:::~i:~i~~ are aware, will

need to have a signi ~callt percentage of tHeir portf6lio represented by renewable fuels. The

.. website was written I··th them in mind. while eventually the 100% biomass firing scenario is

likely, we must kee the existing three JIrmitted fuels in the permit to ensure maximum

fle~ibility. I, 1. f " : I

.. Mt. Poso has experie 1cJ with blending an independently firing the three currently permitted

. ,fuels and up to 30% b omass, by weight as ~art ofthe conducted "trial bum" program. Per your

".:' .".'suggestion in your r9 ief of our San Joa4uin Valley Air Pollution Control District (APCD)

_"'~.'~. -'~_~.;.~'Auth?rity to constru1t a.PPli~ation (to effe t the same chang~ w~ are re~uesting to our PSD

;: ..y, . permIt), Mt. Poso C eneratlon Company greed to a reductIOn III permItted CO levels from

!-;.">~::-i.:400ppm to 183ppm. I f r I: . :::~, Fi' " " .." ,I ! I t .. i.';if2.-:- ';~. • ..-:. . r i

.~~. :~r..'· In summary, Mt. POStCogeneration Comp I y desirrs to have th ability to combust any of the

:it·<·f following f?ur fuels, ,i~er by itself or ~n fblend with one or more of these permitted fuels:

;1:;- f' . . coal, petroleum coke, idmass and tire deriv d fuel. I I

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8302 Espresso Drlv~. SUite 130 Bakersfle,ld. CA 9331 f 661/663-3155 Fax; 661/663-3164 .------ -·-r~--o-·_··----····_'-·----·T---T---r--------···
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There is no "worst casr" fuel or combination of fuels from an air emissions standpoint. In the

case of NOx, when a rse~ point" slightly bJlow the Ipermitted co~centration limit is reached,

additional ammonia injection (for the Thetmal De~Ux reaction) is automatically triggered.

Thus, the NOx concenb-atibns for each fuellblend arel equal. LikeWise with 802, the set point

automatically injects ~otJ limestone, so that equal 802 pollutant .levels are achieved for each

fuellblend. I I I

The baghouse controls theI Particulate Matterl (PM) er¢ssions which are comprised primarily of

ash from the fuel and g~psum (calcium sulfate), the product ofthe r~action oflimestone and S02.

Biomass typically has k $h concentration ~tween that of coal and petroleum coke, which will

result in equal or lower P¥ emissions. I

The extended combUstionilone residence time in a cirlulating fluidized bed combustor results in

minimization ofcarb~1 m~nox~deand hYdr0i~bOns, ih~ependent Ofthe fuel/blend. ..

In summary, the addItion, lof bIOmass fuel Will result III equal or 'ower amounts of all cntena

pollutant emissions. ~t. Poso CogenerationlCompany will ensure!that only clean biomass will

be combusted at the fa(Cili~. In accordance with the eXisting Authonty to Construct Permit from

the APCD, Permit Nubber: 8-91-3-12, thd plant is limited to the following materials in the

biomass: II I

II I

• Biomass intro'du~ed into the combustor shall not contain m~re than 2% by weight nonbiomass mate~iall (plastics, metal, phinted an~preservativJ-treatedwood, roofing

material,fibe~ girS, etc.). [DistricjRule 4102]

To comply with this Ilit:the facility has included the ~OllOwing requirement as part of all ofits

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II I

biomass procurement aJgr~ements: I

. Excluded MatJia)l The Wood Waste shallno~ contain any1ee ash, soil, cinder,

residual ofpalm, or mJlbe~ry and shall be free offoreign material, including, but not limited to, I ,I I I I

sand, stone, metal, glass, rubber, plastics, pressure treated or lead basedpainted wood,

chemicals and any hazhrd,bus or toxic substanl

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ces as d~fined under California orfederallaw.

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The Wood Waste shall ~e substantiallyfree 0]grass and leaves.

The Wood Waste ash s~al}lnot exceed the ca~ifornia Jtablished thrf!sholdfor classification of

the ash as a hazardousl waste per §66261.24(a)(2). THese thresholds are listed in Table B1

below.

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TABLE B-1 STAITE OF CALIFORNIA

REGULAIfORY LEVEL CONCENTRATION OF METALS

! I PER TITLE 22l SECTION 66261.241

C~LIFORNIA CODE OF REGULATIONS

I I

~J ~_~ ~~~L~C~2J~) TI~~~

Antimony 15 500

Arsenic 5.0 500

Asbestos (all forms) 1.0 (as %)

Barium (except barite) 100 10,000

Cadmium 1.0 100

Chromium (VI) 5 500

Chromium (III) 5 2,500

Cobalt 80 8,000

Copper 25 2,500

Lead 5.0 1,000

Mercury 0.2 20

Molybdenum 350 3,500

Nickel 20 2,000

Selenium 1.0 100

Silver 5 500

Thallium 7 700

Vanadium 24 2,400

Zinc 250 5,000

1 Include elemental metal and/or metal compounds

2 Soluble Threshold. L~fitiFoncent~ation 3 Total Threshold LImIt qmcentratton

Allspecifications will 't"J, or exceed the requirements definedforIRenewable Fuel in order to

ensure that the Projec' will qualify as an Eligible ReJewable Energy Resource as defined by

the California Energy Coinmission. II

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Each load offuel will li>e ~isually inspected when received. It will be rejected iffound to contain

non-biomass material. I ~dditionally, fuel ~uppliers lwill receive Isurprise inspections at their

loading sites, to ensure I they are conscientiously providing bi6mass that meets the plant

specifications. I

When the plant was origirihlly permitted in 1986, the entire property was inspected by a biologist

who did not find any e11ndffil .. 1 gered species. Ais part Ofl,Mt. Poso's r~cent Conditional Use Pennit

process with the Kern CoJnty Planning Depbment, the portion o£ the plant's existing property

to be designated for u~e J part of the propo:sed physical modifications (fuel yard and ancillary

equipment) was reinsPtct~~by a biologist. A separatJ pennit applihation has been filed with the

APCD for these modifications. The land is tilled for Ifire protectioh and no endangered species

were encountered by the *ologist, whose rePort is attached. To ok knowledge, this report has

been seen only by the Kern County Planning Departfnent; it has not been submitted to the US

Department of Fish an; Wildlife.

Apart from the Kern lojty Planning Depanment and the APCD,Iwe are not aware of another

local agency to which Iciry ofthe proposed PSD mollification ShOrld be sent.

Please refer any furthe~ questions you may have to Dr. Ted Guth at (619) 987 - 1111 or Mr. R.

Wayne Terry at (661) 6631L3155. Thank yoJ for you continued gui(tance.

I

Roger . Allred

General Manager II

Mt. Poso Cogeneration Company

Title V Responsible 0rCiW

Enclosures: Quad Knopf~iOIOgiCalPre-Consf!ction Survey

Original L~tter ofApplication fOIi Minor Modification

II

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cc: R. Wayne TerryNt.~illenniumEnergYiI' LLC

Dr. Ted GuthlPermit {Consultant I

Kristopher RiCkards/rill Joaquin Valley 1\.ir POllUrion Control District

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MT. POSO

COGENERATION

RECE\VED

AUG - 7 2009

COMPANY

Perm,ts vance Air-3

U.S. EPA. Relton 9

August 3, 2009

Ms. Laura Yannayon

Environmental Protection Agen y Region IX

Attn: Air-3 ! I

75 Hawthorne Street I I

San Francisco, CA 94]05 I

Ref: PSD Permit SJ-86-09 (Amended IX.H January 9, 2009)

I I Dear Ms. Yannayon; I j

Mt. Poso Cogeneration Company accepts the EPA proposed reduction in site PMIO emissions

from the current permitted bo+t o~ 34.7 tons per year to 26.7 tons per year. Please continue to

process our applicatioJ fori a minor modification to our existing PSD Permit with the reduction

indicated. I I I I

... .i.

Your cooperation in t matter s greatly appreciated and iffurther information is needed please I I ' ,

contact me by phone at (661) ,663 :3,155 or email: allred@2000energy.com.

I I I I

Sincerely, , I I

( t4Il;

"Roge C. Allred ; ,

General Manager i

Mt. Poso Cogeneration ~ompanl

Title V Responsible0iCi1i !

cc: Wayne TerryNice Plr9si~ r;'t/Millennium Energy, LLC I i I

Dr. Ted Guth I ! I I I : :

William DicksoWPlant Manager/Mt. Poso Cogeneration Comp~y i :.-...'

8302 Espresso Drive, Suite 13q Bakersfield, CA 93312 661/663-3155 ----'-------------..-1-1-\---- Fax: 661/663-3164
--

- - MT. POSO

COCENERATION

COM PAN Y

July 8, 2009

Ms. Laura Yannayon

Environmental Protection Agency Region IX

Air Division Permits Office (Air-3)

75 Hawthorne Street

San Francisco, CA 94105-3901

Dear Ms. Yannayon;

RECEIVED

JUL 14 2009

Permits uttice Air-3

U.S. EPA. Region 9

j:

Thank you for assisting Mr. Wayne Terry and Dr. Ted Guth with the Mt. Poso

Cogeneration Company permit modification to include "and or biomass" in the EPA

Prevention of Significant Deterioration (PSD) permit. This letter is written per your

suggestion to Dr. Guth in your telephone conversation last week.

Mt. Poso Cogeneration Company formally requests a 180 day extension to the biomass

co-firing test bum that commenced on January 19,2009. The data we are obtaining and

sharing with EPA continues to be extremely important in determining our ability to

quantify our projected emissions and correctly identify any new equipment needed. We

appreciate your guidance in this matter and look forward to continuing the biomass cofiring test bum while our PSD application remains under review.

I

i

Roger . Allred

Mt. Poso Cogeneration Company

General Manager

Title V Responsible Official

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i

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cc: Wayne TerryNice PresidentlMillennium Energy, LLC

Dr. Ted Guth I

William DicksonIPlant Manager/Mt. Poso Cogeneration Company

~~93..~spresso Drive, Suite 130 Bakersfield, CA 93312 661/663-3155 Fax: 661/663-3164
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MT. POSO

COGENERATION

COMPANY

May 12,2009

Ms. Laura Yannayon

Environmental Protection Agency Region IX

Attn: Air-3 'I

75 Hawthorne Street

San Francisco, CA 94105 .

Dear Ms. Yannayon;

RECEIVED

MAY 14 2009

PermI l~ ..... riICe Air-3

u.s. EPA. Region 9

I express my sincere appreciation for your suggestions and guidance regarding the Minor

PSD Permit Modification for the Mt. Poso Cogeneration Company facility.

This letter is written per yoJ instructions to Dr. Ted OJth and Wayne Terry. Under

separate cover you should have received two additional teports (for March and April)

following the one you received for the month of Februabr, summarizing the biomass

testing/emissions measurements for these months. During this time we have evaluated a

number oftypes of biomass fuel, including shells (pistachid and almond) as well as small

"one inch minus" agricultural wood waste, all with varying ~oisture content.

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In summary, to date, up to 30% by volume (20% by weight) biomass fuel has been cofired with the previously permitted coal/petroleum coke/tire-derived fuel blend of fuel,

with no discernable change (increase or decrease) in any o~ the measured pollutants: CO

(also a surrogate for VOCs), NOx, S02 and opacity (indicative of particulateslPM-10).

As Dr. Outh discussed in your meeting, the reasons for this ~e as follows:

The circulating fluidld bed boiler employs eJended residence time in the

combustor zone to effect complete combustion, which ensJres that carbon monoxide and

hydrocarbon levels are minimized, regardless ofthe fuel. Vte NOx emissions are "set" at

roughly ten percent (10%) below the permitted level (58 ppm vs 65 ppm respectively).

That is, when emissions of NOx start to climb above 58 ppm, more ammonia (for the

Thermal DeNOx reaction) is automatically introduced into ithe boiler. Likewise with the

S02; when sulfur dioxide levels start to exceed the "set pqint" (below the permit limit),

additional limestone is automatically injected. In thi~ manner, emissions can be

maintained at similar levels for different fuels, and the results observed over the last three

months are not unexpected.

8302 Espresso Drive, Suite 130 Bakersfield, CA 93312 661/663-3155

I

Fax: 661/663-3164
Ms. Laura Yannayon

Environmental Protection Agency Region IX

May 12,2009

Page 2

As Mr. Terry discussed with you in your meeting, we have been able to feed up to 30%

by volume (20% by weight) biomass utilizing the existing fuel feed system. We

anticipate increasing the feed up to approximately 30% (or more) by weight as plant

personnel become accustomed to the intricacies of handling biomass. However, we are

limited to the amount of biomass we can physically feed with the existing truck

unloading system. At this time, we are only pennitted to burn "and/or biomass" with our

fuel blend; we cannot make any physical modifications to the plant. (Note: an

application to the San Joaquin Valley APCD for an authority to construct to make the

modifications required to achieve a 100% biomass feed rate conveyers, truck dumpers,

etc. has been submitted and is currently under review by the Air District.) Utilizing the

explanations provided above, we are able to extrapolate that emissions at the 100%

biomass feed rate would not be significantly changed from the observed emission levels

at 20% biomass.

In closing, we do not expect a change in emission levels from current emissions (within

permit limits) under a 100% biomass firing scenario. As Mr. Terry reiterated, we are

amenable to accepting a 1400 ton per day limit on biomass in our PSD pennit. We

appreciate your continued expeditious review of our PSD application and promise to

respond immediately to any additional questions you may have, all with the goal of

meeting the mid-July PSD modification approval date you suggested. Thank you in

advance for you assistance.

~YO~( /

ROg~ed Mt. Poso Cogeneration Company

General Manager

Title V Responsible Official

cc: Wayne TerryNice PresidentlMillennium Energy, LLC

Dr. TedGuth

William DicksonIPlant Manager/Mt. Poso Cogeneration Company
--- - ... ... MT. POSO

COGENERATION

COM PAN Y

January 15,2009

Director, Air Division (Attn: Air-3)

United States Environmental Protection Agency

Region IX

75 Hawthorne Street

San Francisco, CA 94105-3901

'Subject; Commencement of Trail Bum Using Biomass as Fuel

RECEIVED

JAN 2 3 REC'D

Air Division, AIR -.3

U.S. EPA, REGION 9

.MH 2 3 ~:\l;~

I

Ref: U.S. EPA Letter Dated January 9, 2009, PSD Permit SJ-86-09 (Amended January 9,

2009)

Dear Sirs,

This letter is to inform you that Mt. Poso Cogeneration Company intends to commence

test burning of biomass fuels, on January 19,2009, in accordante with PSD Permit SJ86-09 as amended on January 9, 2009. I

Mt. Poso Cogeneration Company will keep records of all fuels burned and will sample

and test per section IX.H. ofsubject permit.

Data will also be compiled per this section and forwarded to your office on a monthly

basis, unless otherwise directed, for review.

Mt. Poso Cogeneration Company understands the maximum length ofthis test is 180

day, and intends to utilize this period to test bum on a continuo~s basis the biomass fuels

for evaluation. Upon such time that adequate test data is gathered for your review, a

request will be made to add biomass fuels to PSD Permit SJ 86~09 on a permanent basis.

PO. Box81256 Bakersfield, CA 93380 36157 Famoso Road, 93308 661/393-8891 Fax: 661/393-6865
Yout cooperation in this matter is greatly appreciated and if further information is needed

plea~e contact me by phone at (661) 393-8891 or email: bdickson@mtposo.org.

Sincerely,

/

William Dickson I

Plan~ Manager

I

Mt. ~oso Cogeneration Company

I

Cc: Ghief, Stationary Resource Division

<talifomia Air Resources Board I

~.O. Box 2815

Sacramento, CA 95812

I

~oger Allred, President Millennium Energy

rayne Terry, Vice President Millennium Energy

I
CO<iENERA'1710N

M~PO$O COM PAN Y

November 25, 2008

Ms. Laura Yannayon

Environmental Protection Agency Region IX

75 Hawthorne Street

San Francisco, CA 94105

RECEI .:~: \"'i=D VI~

DEC -3 2008

Air Division, AIR -

U.S. EPA, REGION 9

Subject: Mt. Poso Cogeneration Company; Minor Modification to I

PSD Permit No. SJ86-09; NSR4-4-j

Dear Ms. Yannayon: I

Thank you for the assistance and guidance you have p~ovided to Wayne Terry and our permitting

consultant, Dr. Ted Guth. Per your direction, Mt. pos, Cogeneration Company (MPCC) will:

• Add biomass to the three currently allowed fuelS (coal and/or petroleum coke and tire

derive fuel).

• Continue to employ Best Available Control Te hnology (see recent assessment

perfoI1l1ed by the San Joaquin Valley Air pOllition Control District (SJVAPCD)).

• Agree to a reduction in the annual potential to emit (PTE) levels ofNOx, S02 and CO

(rolling averages) to new limits based on the a~erage ofMPCC's 2004 and 2005 annual

emission levels (see below).

• Agree to enforceable monthly recordkeeping t1 ensure rolling annual limits are met.

• Notify and obtain concurrence from Mr. Richard Edgehill at SJVAPCD ofMPCC's

intent to agree to reduce PTE's for NOx, S02, kd CO in the PSD/Title V permit. A copy

ofthe written request to SNAPCD will be prtided to you.

• Agree to conduct a six-month "trial bum" to cqn:firm that the proposed limits can be met

with biomass fuel. MPCC agrees to share all findings with EPA. MPCC's desire is to

commence this trial bum on or about Decembdr 15,2008.

8302 Espresso Drive, Suite 130 Bakersfield, CA 93312 661/663-3155 Fax: 661/663-3164
Ms. Laura Yannayon

Environmental Protection Agency Region IX I

Mt. Poso Cogeneration Company;

Minor Modification to PSD Permit No. SJ86-09; NSR4-4-8

November 25, 2008 I

P~e2

BACT for NOx is Selective Non- Catalytic Reduction ~ammonia injection). BACT for S02 is

sorbent (limestone) injection. BACT for CO is the circ1ulating fluidized bed combustion process

and natural gas as auxiliary fuel. I

Current PTE's for NOx, S02 and CO are 513,336Ib/year, 255,281Ib/year, and 440,628 lb/year

respectively. The annual emitted levels for 2004 and 2r05 are shown below:

Year 2004 2005 Average I

NOx 387,278 380,890 384,084

S02 125,576 134,455 130,016

CO 173,298 171,326 172,312

To have the desired.action - addition of biomass as a ~el - MPCC agrees to decrease its current

PTE's to levels equivalent to the averages ofNOx and $02 from 2004 and 2005 PLUS 39.5 tons \

(79,000 lbs) and for CO to the average from 2004 and 2005 PLUS 99.5 tons (199,000 lbs).

Thus the newly proposed PTE levels are as follows; I

NOx 384,084 + 79,000 = 463,084 pounds{year

S02 130,016 + 79,000 = 209,016 pounds{year

CO 172,312 + 199,000 = 371,312 poundsfyear

It is Mt. Poso's understanding that by agreeing to these I limits, this request can be processed as a

minor modification. As such, major New Source Review is not triggered and no emissions

modeling or public notice is required. I

Please refer any questions you have regarding this requFst during your review to Dr. Ted Guth at

619-987-1111. Mt. Poso thanks you in advance for the expeditious review ofthis request, as

well as your continued support and guidance.

c

Roger . Allred

Mt. P so Cogeneration Company

General Manager

Title V Responsible Officia~

cc: R. Wayne TerryN.P. Millennium Energy, LLC

Dr. Ted GuthlPermit Consultant

Richard Edgehill/San Joaquin Valley Air Pollution pontrol District

enclosures