1

Kelly, Shaheerah

From: Shane Young [SWyoung@spi-ind.com]

Sent: Friday, December 06, 2013 8:51 AM

To: Kelly, Shaheerah

Cc: wsloan@mofo.com; Dave Dun; Tony Jaegel; George Emmerson; Eric Albright 

(ealbright@environcorp.com)

Subject: Ltr EPA 12 6 13

Attachments: Ltr EPA 12 6 13.pdf

Shaheerah,

The attached letter represents Sierra Pacific Industries comments related to the Draft PSD Permit and the Draft AAQIR. If

you have any questions or I can be of 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 6, 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:

Sierra Pacific Industries (SPI) appreciates the opportunity to comment on the proposed Prevention of 

Significant Deterioration (PSD) permit modification, and supporting Ambient Air Quality Impact Report 

(AAQIR) for the cogeneration project. We have provided comments in this letter on both the draft PSD 

permit modification, and the draft AAQIR. All comments are intended to correct minor inaccuracies and 

inconsistencies, and we do not expect them to require significant revisions to either document.

PSD Permit

Page 3, Table 1. In the “Description” column, please change “Maximum annual average heat input of 

approximately 468 MMBtu/hr and steam generation rate of 250,000 lbs/hr” to “Maximum heat input of 

approximately 468 MMBtu/hr, a maximum annual average heat input of 425 MMBtu/hr, and a nominal 

steam generation rate of approximately 250,000 lbs/hr.”

Page 4, Table 2. In the “Description” column, please change “Biomass-fired with natural gas burners for 

start-up” to “Biomass-fired.” The existing boiler does not include natural gas-fired burners.

Page 4, Table 2. In the “Description” column, please change “Equipped with one 30,400 ft3, 2 hog fuel 

bins, 2 wood chip fuel bins” to “Equipped with one 30,400 ft3 fuel storage bin, 2 hog fuel bins, 2 wood 

chip fuel bins.”

Sierra Pacific Industries

 Anderson Division | P.O. Box 10939 | Anderson, CA 96007 | (530) 378-8350

 
AAQIR

Page 10, Table 3-1. In the “Unit” column, please change “Stoker Boiler with Vibrating Grate” to “Stoker 

Boiler with Reciprocating Grate.”

Page 10, Table 3-1. In the “Description” column, please change “Biomass-fired with natural gas burners 

for start-up and shutdown” to “Biomass-fired with natural gas burners for startup, shutdown, and flame 

stabilization.”

Page 10, Table 3-1. In the “Description” column, please change “Composed of two-cells with an 

expected water load of 4.24 gallons per minute per square foot” to “Composed of three cells with an 

expected water load of 4.24 gallons per minute per square foot.”

Page 10, Table 3-1. In the “Description” column, please change “Biomass-fired with natural gas burners 

for start-up” to “Biomass-fired.” The existing boiler does not include natural gas-fired burners.

Page 10, first paragraph, first sentence. Please change “The proposed biomass boiler of the 

cogeneration unit is expected to have a maximum annual average heat input of 468 million British 

thermal units per hour (MMBtu/hr), and an annual average heat input of 425 MMBtu/hr” to “The 

proposed biomass-fired boiler that is part of the cogeneration unit is expected to have a maximum heat 

input of 468 million British thermal units per hour (MMBtu/hr), and an annual average heat input of 425 

MMBtu/hr.”

Page 30, under “Clean Fuels”, last sentence. Please change “This control option is technically feasible 

only for natural gas since already SPI proposes to use this fuel in the engine” to “This control option is 

technically feasible only for natural gas since SPI already proposes to use this fuel in the engine.”

SPI respectfully requests that these corrections and clarifications be incorporated into the final PSD 

permit and AAQIR for the cogeneration project. SPI and our consultants stand ready to assist with 

responding to any and all comments received during the public comment period and public hearing to 

be held on December 10, 2013. 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