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

Tel: +1 425.412.1800 Fax: +1 425.412.1840 

www.environcorp.com

May 30, 2012 

Project No. 29-23586A 

Mr. Gerardo Rios 

U.S. Environmental Protection Agency, Region 9 

75 Hawthorne Street 

San Francisco, California 94105 

Subject: Updated Air Dispersion Modeling Analysis 

Sierra Pacific Industries Biomass-Fired Cogeneration Project 

Anderson, California 

Dear Mr. Rios:

This letter provides updated information regarding the air quality dispersion modeling 

analysis originally developed in support of the Prevention of Significant Deterioration (PSD) 

permit application submitted by Sierra Pacific Industries (SPI) to construct and operate a new 

biomass-fired cogeneration unit at the existing Anderson facility. It is necessary to update the 

modeling as a result of some aspects of the final project design differing from the description 

provided in the submitted permit application. In addition, the U.S. Environmental Protection 

Agency (USEPA) Region 9 requested, in an e-mail received by SPI on March 20, 2012, that 

SPI provide updated modeling results that could be used to assess the potential for startup 

and shutdown emission rates proposed by SPI for the cogeneration unit to comply with the 

short-term average National Ambient Air Quality Standards (NAAQS) established for 

nitrogen dioxide (NO2), carbon monoxide (CO), particulate matter (PM), and sulfur dioxide 

(SO2). 

Modeling Analysis Update 

Differences between the final project design, and that described in the originally submitted 

permit application, include: 

 The height, diameter, exhaust velocity, and exhaust temperature of the cogeneration 

unit stack; 

 The number of cells, height, diameter, exhaust velocity, and emission rate of the 

cooling tower; 

 The addition of an emergency boiler feedwater pump powered by a natural gas-fired 

engine; and 

 The locations of the new structures and emissions points within the facility and 

relative to one another. 

A new modeling site plan is provided in the attached Figure 1, and the attached Table 1 

provides updated emission point release parameters used for the updated simulations. Other 

than these changes, the updated modeling analysis followed the methodology outlined in the 

permit application. The criteria pollutant emission rates included in the modeling simulations 

are summarized in the attached Table 2. Design concentrations calculated by the model 
Mr. Gerardo Rios 

SPI-Anderson Biomass-Fired Cogeneration Project 

May 30, 2012 

Page 2 

associated with normal operation are summarized in the attached Table 3, where the results 

are compared to the Significant Impact Levels (SILs) and the Monitoring De Minimis 

Concentrations. Concentration isopleths for NO2, CO, and PM2.5 are presented in Figure 2 

through Figure 7, with the location of the design concentration indicated on each. The 1-hour 

average NO2 (Figure 2) and 24-hour average PM2.5 (Figure 6) concentrations are 5-year 

averages, and the 1-hour average NO2 concentrations (Figure 2) are based on the assumption 

that 80 percent of the NO is converted to NO2, while the annual average NO2 concentrations 

(Figure 3) are based on the assumption that 75 percent of the NO is converted to NO2. 

As shown in Table 3, the 1-hour and annual average NO2, and 24-hour average PM2.5 design 

concentrations were predicted to be greater than the applicable SILs.1 As a result, additional 

modeling was required to assess compliance with the applicable NAAQS and PSD 

increments. Details of that additional modeling effort are provided later in this letter. 

The attached Table 4 provides the maximum concentrations predicted by the model 

simulations, and combines them with background concentrations for comparison to the 

applicable California Ambient Air Quality Standards (CAAQS). As shown in Table 4, none 

of the total concentrations were predicted to exceed the CAAQS. 

Startup and Shutdown Emission Rates 

In the March 20 e-mail and subsequent conference call, Region 9 requested that modeling 

results be provided for NO2, CO, and PM2.5 that reflected worst-case conditions during 

startup. As described in the June 8, 2011 letter submitted by ENVIRON on behalf of SPI, the 

startup process takes approximately 12 hours. However, the startup and shutdown emission 

rates proposed in the June 8 letter were based on scaling previous modeling results, and, 

based on discussions with the boiler manufacturer, have been revised. During the startup 

process, CO and VOC emission rates are expected to exceed those experienced under normal 

operating conditions, while NO2, PM2.5, and SO2 emission rates are not. 

Startup modeling scenarios that incorporated the revisions described above were developed 

to assess compliance with short-term ambient standards during startup and shutdown. The 

startup and shutdown emission rates used in the modeling simulations are summarized in the 

attached Table 5. Only short-term ambient standards were addressed because the normal 

operation compliance assessment for annual average standards reflects the worst case 

scenario. SPI performs scheduled shutdowns of the cogeneration unit only once or twice a 

year, and each additional (unscheduled) shutdown-and-startup cycle actually decreases the 

annual emission rates of all criteria pollutants, as demonstrated by the attached Figures 2a 

and 2b. 

Figure 2a and Figure 2b show total annual emission rates for criteria pollutants plotted 

against the number of startup and shutdown cycle per year. The startup portion of each cycle 

was assumed to consist of approximately 6 hours of firing on natural gas, then approximately 

6 hours firing on biomass fuel. The shutdown portion of the cycle was assumed to consist of 

 

1

 The model receptor grid was extended from a 10-kilometer square to a 20-kilometer square when calculating 

1-hour average NOX concentrations to encompass all receptors predicted to exceed the SIL. 
Mr. Gerardo Rios 

SPI-Anderson Biomass-Fired Cogeneration Project 

May 30, 2012 

Page 3 

a 1-hour shutdown period when the criteria pollutant emission rates would be equivalent to 

those during startup, followed by 23 hours of no emissions (11 hours for the boiler to cool 

down, and 12 hours to make the repairs, etc. that necessitated the shutdown). Thus, each 

startup and shutdown cycle would reduce the maximum annual number of operating hours by 

36 hours. Figure 2a shows annual emissions of all pollutants and the number of operating 

hours per year versus the number of starts per year, while Figure 2b shows annual emissions 

of all pollutants except NOX and CO to more clearly show the trends for pollutants with 

lower annual emissions. These figures demonstrate that each additional start would reduce 

annual emissions, and therefore, development of one or more annual scenarios that 

incorporate startups and shutdowns to assess compliance with annual standards is not 

warranted. 

Startup and Shutdown Modeling 

To assess compliance with short-term ambient standards during startup and shutdown, the 

revised modeling described above was modified to reflect an increased CO emission rate, a 

flow rate equal to approximately 60 percent of that associated with full load (which results in 

a stack exhaust velocity of 36.7 ft/s or 11.2 m/s), and a reduced exhaust temperature (250 °F 

or 394 K). Design concentrations calculated by the model associated with startup and 

shutdown are summarized in the attached Table 6, where the results are compared to the SILs 

and the Monitoring De Minimis Concentrations. Concentration isopleths for NO2, CO, and 

PM2.5 are presented in Figure 9 through Figure 12, with the location of the design 

concentration indicated on each. The 1-hour average NO2 (Figure 9) and 24-hour average 

PM2.5 (Figure 12) concentrations are 5-year averages, and the 1-hour average NO2

concentrations (Figure 9) are based on the assumption that 80 percent of the NO is converted 

to NO2. 

As shown in Table 6, the 1-hour average NO2 and 24-hour average PM2.5 design 

concentrations were predicted to be greater than the applicable SILs. As a result, additional 

modeling was required to assess compliance with the applicable NAAQS and PSD 

increments. Details of that additional modeling effort are provided below. Table 7 is a 

summary of the maximum predicted concentrations; these concentrations, after combining 

with representative background concentrations indicate compliance with all applicable 

CAAQS. 

Cumulative Modeling Analysis 

As noted above, the 1-hour and annual average NO2 and 24-hour average PM2.5 design 

concentrations predicted by the normal operation modeling simulations were in greater that 

the applicable SILs. As a result, additional analysis is required to assess the potential for 

compliance with the applicable NAAQS and PSD increments. 

For comparison to the NAAQS, competing emission units are included in the modeling 

analysis and a representative background concentration is added. To this end, Shasta County 

Air Quality Management District (SCAQMD) and Tehama County Air Pollution Control 

District (TCAPCD) were contacted and asked to provide a competing source inventory. The 

inventories were restricted to permitted sources of NO2 and PM2.5 that were within 
Mr. Gerardo Rios 

SPI-Anderson Biomass-Fired Cogeneration Project 

May 30, 2012 

Page 4 

50 kilometers (km) plus the distance from SPI’s Anderson facility to the most distant 

receptor predicted to exceed the applicable SIL. The most distant receptor predicted to 

exceed an NO2 SIL2 was approximately 5.4 km from the facility, so the competing source 

NO2 emission inventory included industrial sources located 55.4 km or less from the facility. 

The most distant receptor predicted to exceed the 24-hour average PM2.5 SIL was 

approximately 1.0 km from the facility, so the competing source NO2 emission inventory 

included industrial sources located 51.0 km or less from the facility. The competing source 

emission inventories are provided in Table 8 (NOX) and Table 9 (PM2.5). 

Screening analyses were developed using the same modeling methodology applied to the 

project to determine which, if any, of the competing sources were predicted to have a 

significant impact (i.e., an impact greater than the applicable SIL) at one or more of the 

receptors the project was predicted to have a significant impact. The results of these 

screening analyses are provided in Table 10 through Table 14. Sources predicted to have a 

significant impact were included in the cumulative modeling analyses with the facility. No 

effort was made to eliminate receptors located on site at the competing source, resulting in a 

conservative analysis. 

An existing dust collection system associated with rail car loading at SPI’s Anderson facility, 

consisting of a cyclone and a baghouse, was included in the cumulative PM2.5 modeling. The 

fan drawing air through the system has a maximum flow rate of 66,000 actual cubic feet per 

minute (acfm), which was combined with manufacturer-provided grain loading of 

0.005 grains per dry standard cubic foot (gr/dscf) to calculate a maximum short-term 

emission rate of 2.82 pounds per hour (lb/hr), and, assuming continuous operation (8,760 

hours per year), a maximum annual emission rate of 12.3 tons per year (tpy).3

 Emission 

release parameters used to represent the dust collection system in the modeling simulations 

were as follows: release height above grade – 37 ft (11.3 m), effective release diameter – 

6.02 ft (1.83 m), exhaust velocity – 38.7 ft/s (11.8 m/s), and exhaust temperature – 68 °F 

(293 K). The POINTHOR option available in the current version of AERMOD was used to 

reflect the horizontal orientation of the exhaust exit from the control system. 

Results of the cumulative modeling analyses based on normal operation are summarized in 

Table 15. When design concentrations are combined with representative background 

concentrations, the predicted total concentrations indicate compliance with all applicable 

NAAQS. Analyses of short-term concentrations were not restricted to the time periods during 

which the proposed project was predicted to exceed the SILs, adding further conservatism to 

the results. No concentration isopleth figures were developed for the cumulative analyses. To 

facilitate post-processing of model results, is restricted to only receptors at which the 

proposed project was predicted to exceed the SIL. 

 

2

 When more than one averaging period SIL is exceeded for a given pollutant, the maximum distance to a 

receptor that exceeds any of the SILs determines the competing source inventory area for all averaging period 

SILs associated with that pollutant. 

3

 The flow was corrected from an assumed ambient temperature of 70 °F to standard conditions, but no 

correction was made for moisture in the air. 
Mr. Gerardo Rios 

SPI-Anderson Biomass-Fired Cogeneration Project 

May 30, 2012 

Page 5 

The cumulative modeling process described above was repeated for the cogeneration unit 

startup scenario. Results of the cumulative modeling analyses based on modeled startup 

conditions are presented in Table 16. As for the project-only modeling analyses, only shortterm averaging periods associated with relevant ambient standards were considered. When 

design concentrations reflecting startup conditions are combined with representative 

background concentrations, the predicted total concentrations indicate compliance with all 

applicable NAAQS. 

Pollutants predicted to exceed the SILs must assess compliance with the PSD increments as 

well as the NAAQS. In theory, compliance with PSD increments would be determined using 

competing source inventories that included only increment-consuming sources. In practice, 

however, because developing such an inventory requires considerable time and effort, the 

inventory developed for the NAAQS compliance analysis is used for a PSD increment 

screening analysis.4

 This screening analysis is essentially a comparison of the cumulative 

modeling analysis results developed for the NAAQS compliance analysis and the PSD 

increments, without the addition of background concentrations. 

In this case, evaluations of compliance with the annual average NO2 and 24-hour average 

PM2.5 PSD increments are required. USEPA has not promulgated a PSD increment for 1-hour 

average NO2. The PSD increment for annual average NO2 is 25 μg/m3; as shown in Table 8, 

the maximum NO2 concentration predicted by the cumulative modeling simulation is 

1.75 μg/m3, which indicated compliance with the PSD increment. Because this project is the 

first in the area to exceed the SIL established for 24-hour average PM2.5, it represents the 

only increment-consuming emission units in the area. As a result, the results of the projectonly analysis can be used to assess compliance with the PSD increment, which, for 24-hour 

average, is 9 μg/m3

. As shown in Table 4, the maximum predicted 24-hour average PM2.5

concentration associated with normal operation is 2.23 μg/m3, and the maximum predicted 

concentration associated with startup and shutdown is 3.36 μg/m3; both indicate compliance 

with the PSD increment. 

Class I Area PM2.5 Analysis 

The March 2010 permit application as well as the July 1, 2010 letter sent in response to an 

incompleteness determination and information request, explains that scaling the Class I area 

modeling developed for the PSD permit application submitted in May 2007 for SPI’s 

previous proposed biomass-fired cogeneration project indicated that none of the Class I area 

SILs were likely to be exceeded. At the time, EPA had not promulgated SILs for PM2.5, and 

the PM10 surrogacy policy was still in effect. Now that the PM2.5 SILs have been adopted, 

EPA has asked SPI to assess the need for a PSD increment compliance demonstration by 

comparing PM2.5 concentrations attributable to the proposed project to the applicable SILs. 

Although PM2.5 was not included in the May 2007 PSD permit application analysis, PM2.5

concentrations were developed using the original CALPUFF results, and the post-processing 

 

4

 The emission inventory used to evaluate compliance with the NAAQS contains all permitted sources, those 

that consume increment, as well as those that do not. Because it includes non-increment consuming emissions, 

use of this inventory to evaluate compliance with a PSD increment is considered a conservative approach. 
Mr. Gerardo Rios 

SPI-Anderson Biomass-Fired Cogeneration Project 

May 30, 2012 

Page 6 

programs POSTUTILS and CALPOST. Reflecting current guidance from EPA,5 the coarse 

PM, sulfate, and nitrate fractions were removed from the post-processing originally used to 

develop PM10 concentrations to obtain PM2.5 concentrations. As described in the March 2010 

permit application, the results were scaled by a factor of 1.25 to reflect the 25 percent greater 

heat input capacity of the currently proposed cogeneration unit, as compared to the unit 

proposed in the May 2007 permit application. The maximum three-year by-receptor average 

concentrations in the most-impacted Class I area (the Yolla Bolly – Middle Eel Wilderness 

Area) were 0.0118 μg/m3

 on a 24-hour average basis, and 0.000602 μg/m3 on an annual 

average basis. Both are less than the applicable PM2.5 Class I SILs (0.07 μg/m3 on a 24-hour 

average basis, and 0.06 μg/m3 on an annual average basis), which indicates that the proposed 

project will not significantly impact nearby Class I areas. 

Conclusions 

The new biomass-fired cogeneration unit proposed by SPI for installation and operation at 

their existing facility in Anderson, California was re-evaluated for compliance with ambient 

standards and PSD increments following finalization of the project design. At EPA’s request, 

compliance during startup and shutdown and PM2.5 impacts in nearby Class I areas were also 

evaluated. The results of the analyses indicated that, under normal operation, as well as 

during startup and shutdown periods, the proposed biomass-fired cogeneration unit does not 

have the potential to cause or contribute to violations of ambient standards or PSD 

increments. 

We believe that the information provided in this letter addresses the information requested by 

Region 9, and should be considered to amend the submitted PSD permit application. Please 

let me know if Region 9 requires any additional information to finalize the draft permit. 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 

Cleveland Holladay, USEPA Region 9 

Ross Bell, Shasta County Air Pollution Control District 

Shane Young, Sierra Pacific Industries 

Dave Brown, Sierra Pacific Industries 

 

5

 The e-mail message from Stanley Krivo of EPA Region 4 to Bart Brashers of ENVIRON confirming this 

approach to obtaining PM2.5 concentrations from CALPUFF for regulatory application is attached. 
Table 1 

Point Source Release Parameters 

Source 

Height

(ft) 

Diameter

(ft) 

Exit Velocity

(ft/s) 

Temperature 

(°F) 

Proposed Cogeneration Unit1 85 8.5 61.1 350 

Cooling Tower (Each of 3 Cells) 41.6 32.8 23.9 73 

Emergency Backup Feedwater Pump Engine 6.58 0.333 209 1,151 

1 For the startup scenario, the exit velocity was reduced to 36.7 ft/s and the exhaust temperature was 

reduced to 250 °F. 

Table 2 

Modeled Normal Operation Emission Rates 

Pollutant 

Averaging 

Period Units 

Proposed 

Cogeneration 

Unit1

Cooling 

Tower 

(All 3 Cells 

Combined) 

Emergency 

Backup 

Feedwater 

Pump Engine2

NOX

Hourly Avg. lb/hr 70.2 -- 0.782 

Annual tpy 242 -- 0.0391 

CO Hourly Avg. lb/hr 108 -- 6.11 

8-Hour Avg. lb/hr 108 -- 0.764 

PM/PM10/PM2.5

Daily Avg. lb/hr 8.93 0.272 0.000899 

Annual tpy 37.3 1.19 0.00108 

SO2

Hourly Avg. lb/hr 2.34 -- 0.00127 

3-Hour Avg. lb/hr 2.34 -- 0.000423 

Daily Avg. lb/hr 2.23 -- 0.0000529 

Annual tpy 9.32 -- 0.0000635 

1 Based on the following maximum firing rates: 467.9 MMBtu/hr hourly average, 446.7 MMBtu/hr daily 

average, and 425.4 MMBtu/hr annual average. 

2 Based on maintenance and testing operation no more than 1 hour per day and 100 hours per year. 
Table 3 

Normal Operation Project-Only Modeling Results 

Pollutant 

Averaging 

Period 

Design 

Concentration1 SIL1,2

Over 

SIL? 

Monitoring 

De 

Minimis1,3

Over De

Minimis?

NO2

4 1-Hour 26.3 7.5 Yes -- -- 

Annual 1.35 1 Yes 14 No 

CO 

1-Hour 122 2,000 No -- -- 

8-Hour 36.0 500 No 575 No 

PM10 24-Hour 2.23 5 No 10 No 

PM2.5

5 24-Hour 1.84 1.2 Yes -- -- 

Annual 0.272 0.3 No -- -- 

SO2

1-Hour 1.15 7.8 No -- -- 

3-Hour 0.952 25 No -- --

24-Hour 0.527 5 No 13 No 

Annual 0.0689 1 No -- --

1 Concentrations are in micrograms per cubic meter (μg/m3) 

2 SIL = Significant Impact Level. Taken from USEPA’s New Source Review Workshop Manual (October, 

1990), Table C-4, except the 24-hour and annual average PM2.5 SILs, which are from 40 CFR 

52.21(k)(2), and the 1-hour average NO2 interim SIL as described in the memorandum “Guidance 

Concerning the Implementation of the 1-hour NO2 NAAQS for the Prevention of Significant 

Deterioration Program,” issued by Stephen Page, Director of EPA’s Office of Air Quality Planning 

and Standards. 

3 Monitoring de Minimis concentrations from 40 CFR 52.21(i)(8)(i). 

4 Based on guidance in the “Additional Clarification Regarding Application of Appendix W Modeling 

Guidance for the 1-hour NO2 National Ambient Air Quality Standard” memorandum issued on 

March 1, 2011 by Tyler Fox, Leader of the Air Quality Modeling Group at EPA’s Office of Air 

Quality Planning and Standards, the one-hour average NO2 concentrations were assumed to be 

80 percent of the NOX concentrations calculated by the model. Annual average NO2

concentrations were assumed to be 75 percent of the NOX concentrations calculated by the 

model, based on guidance in Section 6.2.3 of the USEPA’s Guideline on Air Quality Models 

(codified as Appendix W to 40 CFR Part 51). Also, based on guidance in the March 1, 2011 

memorandum issued by Tyler Fox, the 1-hour average NO2 design concentration is the maximum 

1-hour average concentration averaged across the five modeled years at each receptor. 

5 Based on guidance in the “Modeling Procedures for Demonstrating Compliance with PM2.5 NAAQS” 

memorandum issued on March 23, 2010 by Stephen Page, Director of the EPA’s Office of Air 

Quality Planning and Standards, the 24-hour average design concentration for comparison to the 

SILs is the maximum 24-hour average concentration averaged at each receptor across the five 

modeled years. 

 
Table 4 

Normal Operation CAAQS Compliance Assessment 

Pollutant 

Averaging 

Period 

Maximum 

Predicted1 Background2

 Total3 CAAQS 

Over 

CAAQS?

NO2

4 1-Hour 27.8 77.1 105 339 No 

Annual 1.35 33.1 34.5 57 No 

CO 

1-Hour 122 2,976 3,098 23,000 No 

8-Hour 36.0 2,404 2,440 10,000 No 

PM10

24-Hour 2.23 42.0 44.2 50 No 

Annual 0.344 16.1 16.4 20 No

PM2.5

5

 Annual 0.344 5.30 5.64 12 No 

SO2

1-Hour 1.15 13.1 14.3 655 No 

24-Hour 0.527 2.62 3.15 105 No

1 Concentrations are in micrograms per cubic meter (μg/m3) 

2 Background concentrations are the maximum monitored concentrations (with exceptional event data 

removed, where applicable) from the following stations and years: 

 NO2 & CO: Chico – Manzanita Ave; maximum concentrations 2011 

 PM10: Anderson – North Street; 2011 

 PM2.5: Redding – Health Department Roof; 2011 

 SO2: Sacramento – Avalon Drive; 2011 

 Monitoring data are from EPA’s AirData website (http://www.epa.gov/aqspubl1/annual_summary.html) 

3 Total = Maximum Predicted + Background 

4 NO2 was assumed to be 100 percent of the emitted NOX. 

5 All PM10 was assumed to be PM2.5
Table 5 

Modeled Startup and Shutdown Emission Rates 

Pollutant 

Averaging 

Period Units 

Proposed 

Cogeneration 

Unit1

Cooling 

Tower 

(All 3 Cells 

Combined) 

Emergency 

Backup 

Feedwater 

Pump Engine2

NOX Hourly Avg. lb/hr 70.2 -- -- 

CO Hourly Avg. lb/hr 108 -- -- 

8-Hour Avg. lb/hr 108 -- -- 

PM/PM10/PM2.5 Daily Avg. lb/hr 8.93 0.272 -- 

SO2

Hourly Avg. lb/hr 2.34 -- -- 

3-Hour Avg. lb/hr 2.34 -- -- 

Daily Avg. lb/hr 2.23 -- -- 

1 Mass emission rates are not expected to exceed those associated with normal operation, except CO. A 

worst-case emission rate of four times the mass emission rate expected during normal operations 

was assumed for startup and shutdown. 

2. The emergency backup feedwater pump engine would not be operated for maintenance or testing 

when the cogeneration unit was being started or shutdown. 
Table 6 

Startup and Shutdown Project-Only Modeling Results 

Pollutant 

Averaging 

Period 

Design 

Concentration1 SIL1,2

Over 

SIL? 

Monitoring 

De 

Minimis1,3

Over De

Minimis?

NO2

4

 1-Hour 38.6 7.5 Yes -- -- 

CO 

1-Hour 307 2,000 No -- -- 

8-Hour 212 500 No 575 No 

PM10 24-Hour 3.36 5 No 10 No 

PM2.5

5

 24-Hour 3.11 1.2 Yes -- -- 

SO2

1-Hour 1.67 7.8 No -- -- 

3-Hour 1.55 25 No -- --

24-Hour 0.837 5 No 13 No 

1 Concentrations are in micrograms per cubic meter (μg/m3) 

2 SIL = Significant Impact Level. Taken from USEPA’s New Source Review Workshop Manual (October, 

1990), Table C-4, except the 24-hour and annual average PM2.5 SILs, which are from 40 CFR 

52.21(k)(2), and the 1-hour average NO2 interim SIL as described in the memorandum “Guidance 

Concerning the Implementation of the 1-hour NO2 NAAQS for the Prevention of Significant 

Deterioration Program,” issued by Stephen Page, Director of EPA’s Office of Air Quality Planning 

and Standards. 

3 Monitoring de Minimis concentrations from 40 CFR 52.21(i)(8)(i). 

4 Based on guidance in the “Additional Clarification Regarding Application of Appendix W Modeling 

Guidance for the 1-hour NO2 National Ambient Air Quality Standard” memorandum issued on 

March 1, 2011 by Tyler Fox, Leader of the Air Quality Modeling Group at EPA’s Office of Air 

Quality Planning and Standards, the one-hour average NO2 concentrations were assumed to be 

80 percent of the NOX concentrations calculated by the model. Annual average NO2

concentrations were assumed to be 75 percent of the NOX concentrations calculated by the 

model, based on guidance in Section 6.2.3 of the USEPA’s Guideline on Air Quality Models 

(codified as Appendix W to 40 CFR Part 51). Also, based on guidance in the March 1, 2011 

memorandum issued by Tyler Fox, the 1-hour average NO2 design concentration is the maximum 

1-hour average concentration averaged across the five modeled years at each receptor. 

5 Based on guidance in the “Modeling Procedures for Demonstrating Compliance with PM2.5 NAAQS” 

memorandum issued on March 23, 2010 by Stephen Page, Director of the EPA’s Office of Air 

Quality Planning and Standards, the 24-hour average design concentration for comparison to the 

SILs is the maximum 24-hour average concentration averaged at each receptor across the five 

modeled years. 

 
Table 7 

Startup and Shutdown CAAQS Compliance Assessment 

Pollutant 

Averaging 

Period 

Maximum 

Predicted1 Background2

 Total3 CAAQS 

Over 

CAAQS?

NO2

4

 1-Hour 40.0 77.1 117 339 No 

CO 

1-Hour 307 2,976 3,283 23,000 No 

8-Hour 212 2,404 2,616 10,000 No 

PM10 24-Hour 3.36 42.0 45.4 50 No 

SO2

1-Hour 1.67 13.1 14.8 655 No 

24-Hour 0.837 2.62 3.46 105 No

1 Concentrations are in micrograms per cubic meter (μg/m3) 

2 Background concentrations are the maximum monitored concentrations (with exceptional event data 

removed, where applicable) from the following stations and years: 

 NO2 & CO: Chico – Manzanita Ave; maximum concentrations 2011 

 PM10: Anderson – North Street; 2011 

 PM2.5: Redding – Health Department Roof; 2011 

 SO2: Sacramento – Avalon Drive; 2011 

 Monitoring data are from EPA’s AirData website (http://www.epa.gov/aqspubl1/annual_summary.html) 

3 Total = Maximum Predicted + Background 

4 NO2 was assumed to be 80 percent of the emitted NOX based on guidance in the “Additional 

Clarification Regarding Application of Appendix W Modeling Guidance for the 1-hour NO2

National Ambient Air Quality Standard” memorandum issued on March 1, 2011 by Tyler Fox, 

Leader of the Air Quality Modeling Group at EPA’s Office of Air Quality Planning and Standards. 

5 All PM10 was assumed to be PM2.5
Table 8 

NOX Competing Industrial Source Emission Inventory 

Point Source Unit UTMx 

(m) 

UTMy 

(m) 

NOX

Emission

Rate 

(lb/hr) 

Stack 

Height

(ft) 

Stack 

Temp. 

(°F) 

Exit 

Velocity

(ft/s) 

Stack 

Diameter

(in) 

Kiara Co Gen Project (under 

constr.) 1 556901 4480286 19.20 77 374 35.4 84 

Wheelabrator Shasta Co-Gen 

1 561184 4475287 50.67 170 260 58.4 90 

2 561184 4475287 50.67 170 260 58.4 90 

3 561184 4475287 50.67 170 260 58.4 90 

Wheelabrator Lassen Gas Turbine 1 561987 4476151 92.00 70 350 72.8 108x118 

City of Redding Power Plant 

1 548845 4484294 10.00 45 400 89.4 102 

2 548845 4484294 12.10 45 400 89.4 102 

3 548845 4484294 12.10 45 400 89.4 102 

4a 548841 4484222 8.90 110 331 142.4 90 

4b 548841 4484222 8.90 110 331 142.4 90 

5 548731 4484141 4.20 100 575 108.9 112 

6 548731 4484141 4.20 100 575 108.9 112 

Ag Products Asphalt 1 549536 4484029 8.00 40 140 19.0 120 

North State Asphalt 1 548075 4483242 9.17 50 140 19.0 120 

JF Shea Smith Road Asphalt 1 554477 4484456 25.00 80 120 18.3 120 

Aramark Industries 1 552296 4492776 0.70 60 200 127.3 12 

Knauf Insulation 1 551587 4501005 16.50 199 100 18.0 264 

Sierra Pacific Industries, Shasta 

Lake 

1 552344 4502712 10.00 60 475 41.8 42 

2 552344 4502712 6.54 60 300 39.0 42 

Lehigh Cement 1 557225 4509534 247.50 175 285 79.0 83.5 

JF Shea Fawndale Asphalt 1 558579 4509638 11.00 50 140 29.7 96 

Pactiv Corporation 1 567278 4444393 0.30 52 1000 43.6 48 

North Valley Crematory 1 564652 4447377 0.10 15 1300 13.3 24 

Lassen Forest Products 

1 569475 4442292 1.20 8 1300 34.0 6 

2 569475 4442292 1.90 8 1300 42.4 6 

3 569475 4442292 1.60 8 1300 34.0 6 

4 569475 4442292 1.20 8 1300 34.0 6 

PG & E Gerber Compressor Station 1 567119 4434882 7.30 58 943 21.0 108 

Cottonwood Creek Sand & Gravel 1 557822 4469048 0.70 8 1300 50.9 6 

Chuck Wolf Sand And Gravel 1 555714 4460172 1.70 8 1300 50.9 6 
Point Source Unit UTMx 

(m) 

UTMy 

(m) 

NOX

Emission

Rate 

(lb/hr) 

Stack 

Height

(ft) 

Stack 

Temp. 

(°F) 

Exit 

Velocity

(ft/s) 

Stack 

Diameter

(in) 

Ben’s Truck & Equipment Inc. 1 570761 4451508 1.10 8 1300 97.6 12 

Sierra Pacific Industries, 

Red Bluff 

1 568731 4441574 0.20 5 120 1.2 48 

2 568731 4441574 0.20 5 120 1.2 48 

Louisiana Pacific Corp. 1 568663 4442113 0.00 4 300 1.3 96 

Siemens Water Technologies 

1 568012 4442557 2.80 78 185 42.5 24 

2 568012 4442557 0.20 20 185 8.0 24 

North State Asphalt Inc. 

1 560013 4469320 2.60 25 150 29.5 72 

2 560013 4469320 6.00 15 120 30.0 12 

3 560013 4469320 5.80 15 60 30.0 8 

Tehama Asphalt Crushing 1 563975 4450548 7.40 8 1300 63.7 12 

Tehama Asphalt Processing 

1 564068 4450561 6.70 25 60 17.7 72 

2 564068 4450561 6.70 25 120 29.5 72 

3 564068 4450561 8.20 25 1300 23.3 4 

California Power Holdings, LLC 1 567167 4444519 9.80 40 1300 53.1 24 

Tehama County Landfill 1 560206 4449619 0.40 28 1600 8.9 60 

SPI Powder Coatings 

1 568311 4442156 0.60 30 150 42.4 12 

2 568311 4442156 0.00 30 150 42.4 12 

3 568311 4442156 0.10 30 150 39.8 24 

4 568311 4442156 0.20 30 150 53.1 48 

5 568311 4442156 0.20 30 150 53.1 24 

6 568311 4442156 0.20 15 150 21.2 12 
Table 9 

PM2.5 Competing Industrial Source Emission Inventory 

Point Source Unit 

UTMx 

(m) 

UTMy 

(m) 

PM2.5

Emission

Rate 

(lb/hr) 

Stack 

Height

(ft) 

Stack 

Temp. 

(°F) 

Exit 

Velocity 

(ft/s) 

Stack 

Diameter

(in) 

Kiara Co Gen Project (under constr.) 1 556994 4480302 9.60 77 373 35.4 84 

Wheelabrator Shasta Co-Gen 

1 561276 4475303 20.00 170 260 58.4 90 

2 561276 4475303 20.00 170 260 58.4 90 

3 561276 4475303 20.00 170 260 58.4 90 

Wheelabrator Lassen Gas Turbine 1 562079 4476168 2.80 70 350 72.8 108x118 

City of Redding Power Plant 

1 548937 4484311 5.66 45 400 89.4 102 

2 548937 4484311 5.66 45 400 89.4 102 

3 548937 4484311 5.66 45 400 89.4 102 

4a 548934 4484239 0.21 110 331 142.4 90 

4b 548934 4484239 0.21 110 331 142.4 90 

5 548824 4484158 2.70 100 575 108.9 112 

6 548824 4484158 2.80 100 575 108.9 112 

Ag Products Asphalt 1 549628 4484046 16.60 40 140 19.0 120 

North State Asphalt 1 548168 4483259 2.59 50 140 19.0 120 

JF Shea Smith Road Asphalt 1 554569 4484472 71.20 80 120 18.3 120 

Aramark Industries 1 552388 4492794 0.21 60 200 127.3 12 

Knauf Insulation 1 551679 4501022 29.07 199 100 18.0 264 

Sierra Pacific Industries, 

Shasta Lake 

1 552436 4502729 1.17 60 475 41.8 42 

2 552436 4502729 0.47 60 300 39.0 42 

Lehigh Cement 1 557317 4509551 17.90 175 285 79.0 84 

JF Shea Fawndale Asphalt 1 558671 4509656 9.60 50 140 29.7 96 

Pactiv Corporation 1 567167 4444519 0.01 52 1000 43.6 48 

North Valley Crematory 1 564652 4447377 0.03 15 1300 13.33333 24 

Lassen Forest Products 5 569475 4442292 0.34 15 60 0.5 120 

PG&E Gerber Compressor Station 1 567119 4434882 0.16 58 949 20.96667 108 

Cottonwood Creek Sand & Gravel 2 557822 4469048 0.15 15 60 0.5 120 

Ben’s Truck & Equipment Inc. 2 570761 4451508 2.03 15 60 0.5 120 

Sierra Pacific Industries, Red Bluff 3 568731 4441574 0.54 5 60 24.93333 36 

Louisiana Pacific Corp. 2 568663 4442113 2.13 65 70 65.98333 48 

Crain Walnut Shelling 1 575235 4439261 0.03 18 60 18.56667 24 

Long & Long Orchards, Inc. 1 574473 4442490 0.30 30 60 18.56667 24 
Point Source Unit 

UTMx 

(m) 

UTMy 

(m) 

PM2.5

Emission

Rate 

(lb/hr) 

Stack 

Height

(ft) 

Stack 

Temp. 

(°F) 

Exit 

Velocity 

(ft/s) 

Stack 

Diameter

(in) 

Siemens Water Technologies 1 567994 4442656 0.60 25 70 40.08333 36 

California Power Holdings, LLC 1 567167 4444519 2.73 40 1300 53.05 24 

Tehama County Landfill 1 560206 4449619 0.12 28 1600 8.916667 60 

SPI Powder Coatings 7 568311 4442156 0.03 15 65 23.58333 36 

 

Volume Source Unit 

UTMx 

(m) 

UTMy 

(m) 

PM2.5

Emission

Rate 

(lb/hr) 

Release

Height

(ft) 

Initial 

Horizontal

Dimension

(ft) 

Initial 

Vertical 

Dimension

(ft) 

Bio Industries, Inc. 1 559651 4448205 0.164 5.0 22.9 4.7 

Foothill Ready Mix 1 568110 4441709 1.084 15.0 22.9 14.0 

Chuck Wolf Sand & Gravel 2 555714 4460172 0.002 4.0 22.9 3.7 

Tehama Asphalt Crushing 2 563975 4450548 0.150 15.0 22.9 14.0 
Table 10 

Maximum Predicted 1-Hour Average NO2 Competing Source Concentrations 

(Normal Operation Scenario) 

Source 

Maximum NO2 Concentration1

(μg/m3) 

Include in Cumulative 

Analysis? 

Kiara Co Gen Project (under const.) 24.2 Yes 

Wheelabrator Shasta Co-Gen 32.8 Yes 

Wheelabrator Lassen Gas Turbine 13.7 Yes 

City of Redding Power Plant 8.15 Yes 

Ag Products Asphalt 3.08 No 

North State Asphalt 3.07 No 

JF Shea Smith Road Asphalt 14.9 Yes 

Aramark Industries 0.323 No 

Knauf Insulation 1.51 No 

Sierra Pacific Industries, Shasta Lake 2.43 No 

Lehigh Cement 7.57 Yes 

JF Shea Fawndale Asphalt 1.41 No 

Pactiv Corporation 0.0662 No 

North Valley Crematory 0.0525 No 

Lassen Forest Products 2.76 No 

PG & E Gerber Compressor Sta. 1.27 No 

Cottonwood Creek Sand & Gravel 2.14 No 

Chuck Wolf Sand And Gravel 2.33 No 

Bens Truck & Equipment Inc 0.578 No 

Sierra Pacific Industries, Red Bluff 0.209 No 

Louisiana Pacific Corp. 0.0159 No 

Siemens Water Technologies 0.874 No 

North State Asphalt Inc. 51.9 Yes 

Tehama Asphalt Crushing 4.73 No 

Tehama Asphalt Processing 14.6 Yes 

California Power Holdings Llc 2.93 No 

Tehama County Landfill 0.119 No 

SPI Powder Coatings 0.518 No 

1

 80 percent of NOX was assumed to be converted to NO2. 
Table 11 

Maximum Predicted Annual Average NO2 Competing Source Concentrations 

(Normal Operation Scenario) 

Source 

Maximum NO2 Concentration1

(μg/m3) 

Include in Cumulative 

Analysis? 

Kiara Co Gen Project (under const.) 0.283 No 

Wheelabrator Shasta Co-Gen 0.0664 No 

Wheelabrator Lassen Gas Turbine 0.0200 No 

City of Redding Power Plant 0.0217 No 

Ag Products Asphalt 0.0121 No 

North State Asphalt 0.00743 No 

JF Shea Smith Road Asphalt 0.0887 No 

Aramark Industries 0.00232 No 

Knauf Insulation 0.0106 No 

Sierra Pacific Industries, Shasta Lake 0.0186 No 

Lehigh Cement 0.0968 No 

JF Shea Fawndale Asphalt 0.00651 No 

Pactiv Corporation 0.000180 No 

North Valley Crematory 0.000120 No 

Lassen Forest Products 0.00408 No 

PG & E Gerber Compressor Sta. 0.00302 No 

Cottonwood Creek Sand & Gravel 0.00575 No 

Chuck Wolf Sand And Gravel 0.00517 No 

Bens Truck & Equipment Inc 0.00125 No 

Sierra Pacific Industries, Red Bluff 0.000240 No 

Louisiana Pacific Corp. 0.0000225 No 

Siemens Water Technologies 0.00200 No 

North State Asphalt Inc. 0.101 No 

Tehama Asphalt Crushing 0.0105 No 

Tehama Asphalt Processing 0.0308 No 

California Power Holdings Llc 0.00680 No 

Tehama County Landfill 0.000353 No 

SPI Powder Coatings 0.000810 No 

1

 75 percent of NOX was assumed to be converted to NO2. 
Table 12 

Maximum Predicted 24-Hour Average PM2.5 Competing Source Concentrations 

(Normal Operation Scenario) 

Source 

Maximum PM2.5 Concentration

(μg/m3) 

Include in Cumulative 

Analysis? 

Kiara Co Gen Project (under const.) 2.08 Yes 

Wheelabrator Shasta Co-Gen 0.685 No 

Wheelabrator Lassen Gas Turbine 0.0209 No 

City of Redding Power Plant 0.181 No 

Ag Products Asphalt 0.650 No 

North State Asphalt 0.0545 No 

JF Shea Smith Road Asphalt 3.12 Yes 

Aramark Industries 0.00974 No 

Knauf Insulation 0.157 No 

Sierra Pacific Industries, Shasta Lake 0.0406 No 

Lehigh Cement 0.0617 No 

JF Shea Fawndale Asphalt 0.102 No 

Pactiv Corporation 0.000250 No 

North Valley Crematory 0.00144 No 

Lassen Forest Products 0.0341 No 

PG & E Gerber Compressor Sta 0.00166 No 

Cottonwood Creek Sand & Gravel 0.0541 No 

Chuck Wolf Sand And Gravel 0.000490 No 

Bens Truck & Equipment Inc 0.272 No 

Sierra Pacific Industries, Red Bluff 0.0294 No 

Louisiana Pacific Corp. 0.0687 No 

Siemens Water Technologies 0 No 

North State Asphalt Inc. 0 No 

Tehama Asphalt Crushing 0.0107 No 

Tehama Asphalt Processing 0 No 

California Power Holdings Llc 0.0845 No 

Tehama County Landfill 0.00339 No 

SPI Powder Coatings 0.00142 No 
Table 13 

Maximum Predicted 1-Hour Average NO2 Competing Source Concentrations 

(Startup & Shutdown Scenario) 

Source 

Maximum NO2 Concentration1

(μg/m3) 

Include in Cumulative 

Analysis? 

Kiara Co Gen Project (under const.) 32.9 Yes 

Wheelabrator Shasta Co-Gen 35.8 Yes 

Wheelabrator Lassen Gas Turbine 31.9 Yes 

City of Redding Power Plant 9.18 Yes 

Ag Products Asphalt 7.53 Yes 

North State Asphalt 5.14 No 

JF Shea Smith Road Asphalt 34.8 Yes 

Aramark Industries 0.462 No 

Knauf Insulation 1.71 No 

Sierra Pacific Industries, Shasta Lake 2.57 No 

Lehigh Cement 7.89 Yes 

JF Shea Fawndale Asphalt 1.46 No 

Pactiv Corporation 0.0737 No 

North Valley Crematory 0.0629 No 

Lassen Forest Products 3.08 No 

PG & E Gerber Compressor Sta 1.48 No 

Cottonwood Creek Sand & Gravel 2.49 No 

Chuck Wolf Sand And Gravel 3.29 No 

Bens Truck & Equipment Inc 0.600 No 

Sierra Pacific Industries, Red Bluff 0.209 No 

Louisiana Pacific Corp. 0.0169 No 

Siemens Water Technologies 0.909 No 

North State Asphalt Inc. 68.0 Yes 

Tehama Asphalt Crushing 5.17 No 

Tehama Asphalt Processing 14.6 Yes 

California Power Holdings Llc 3.07 No 

Tehama County Landfill 0.177 No 

SPI Powder Coatings 0.551 No 

1

 80 percent of NOX was assumed to be converted to NO2. 

 
Table 14 

Maximum Predicted 24-Hour Average PM2.5 Competing Source Concentrations 

(Startup & Shutdown Scenario) 

Source 

Maximum PM2.5 Concentration

(μg/m3) 

Include in Cumulative 

Analysis? 

Kiara Co Gen Project (under const.) 3.55 Yes 

Wheelabrator Shasta Co-Gen 0.719 No 

Wheelabrator Lassen Gas Turbine 0.0224 No 

City of Redding Power Plant 0.184 No 

Ag Products Asphalt 0.651 No 

North State Asphalt 0.0915 No 

JF Shea Smith Road Asphalt 3.57 Yes 

Aramark Industries 0.0112 No 

Knauf Insulation 0.160 No 

Sierra Pacific Industries, Shasta Lake 0.0421 No 

Lehigh Cement 0.0629 No 

JF Shea Fawndale Asphalt 0.105 No 

Pactiv Corporation 0.00026 No 

North Valley Crematory 0.00147 No 

Lassen Forest Products 0.0342 No 

PG & E Gerber Compressor Sta 0.00186 No 

Cottonwood Creek Sand & Gravel 0.0636 No 

Chuck Wolf Sand And Gravel 0.000490 No 

Bens Truck & Equipment Inc 0.272 No 

Sierra Pacific Industries, Red Bluff 0.0314 No 

Louisiana Pacific Corp. 0.0687 No 

Siemens Water Technologies 0 No 

North State Asphalt Inc. 0 No 

Tehama Asphalt Crushing 0.0113 No 

Tehama Asphalt Processing 0 No 

California Power Holdings Llc 0.0851 No 

Tehama County Landfill 0.00358 No 

SPI Powder Coatings 0.00152 No 
Table 15 

Normal Operation NAAQS Compliance Cumulative Modeling Results 

Pollutant 

Averaging

Period 

Design 

Concentration1 Background Concentration1,2

Total 

Concentration1,3 NAAQS1,4

Over 

NAAQS?

NO2

5 1-Hour 46.9 62.7 110 188 No 

Annual 1.75 33.1 34.8 100 No 

PM2.5

6

 24-Hour 14.6 15.3 29.9 35 No 

1 Concentrations are in micrograms per cubic meter (μg/m3) 

2 Background concentrations are based on monitored concentrations (with exceptional event data 

removed, where applicable) from the following stations and years: 

 NO2: Chico – Manzanita Ave; 3-year average of the 98th percentile of daily maximum 1-hour average 

concentrations, 2009-2011 

 PM2.5: Redding – Health Department Roof; 3-year average of the 98th percentile of 24-hour average 

concentrations ,2009-2011 

3 Total Concentration = Design Concentration + Background Concentration 

4 NAAQS = National Ambient Air Quality Standards 

5 Based on guidance in the “Additional Clarification Regarding Application of Appendix W Modeling 

Guidance for the 1-hour NO2 National Ambient Air Quality Standard” memorandum issued on 

March 1, 2011 by Tyler Fox, Leader of the Air Quality Modeling Group at EPA’s Office of Air 

Quality Planning and Standards, the one-hour average NO2 concentrations were assumed to be 

80 percent of the NOX concentrations calculated by the model. Also, based on guidance in the 

March 1, 2011 memorandum issued by Tyler Fox, the 1-hour average NO2 design concentration 

is the maximum 1-hour average concentration averaged across the five modeled years at each 

receptor. 

6 Based on guidance in the “Modeling Procedures for Demonstrating Compliance with PM2.5 NAAQS” 

memorandum issued on March 23, 2010 by Stephen Page, Director of the EPA’s Office of Air 

Quality Planning and Standards, the 24-hour average design concentration for comparison to the 

SILs is the maximum 24-hour average concentration averaged at each receptor across the five 

modeled years. 

 
Table 16 

Startup and Shutdown NAAQS Compliance Cumulative Modeling Results 

Pollutant 

Averaging

Period 

Design 

Concentration1 Background Concentration1,2

Total 

Concentration1,3 NAAQS1,4

Over 

NAAQS?

NO2

5

 1-Hour 94.0 62.7 157 188 No 

PM2.5

6

 24-Hour 13.5 15.3 28.8 35 No 

1 Concentrations are in micrograms per cubic meter (μg/m3) 

2 Background concentrations are based on monitored concentrations (with exceptional event data 

removed, where applicable) from the following stations and years: 

 NO2: Chico – Manzanita Ave; 3-year average of the 98th percentile of daily maximum 1-hour average 

concentrations, 2009-2011 

 PM2.5: Redding – Health Department Roof; 3-year average of the 98th percentile of 24-hour average 

concentrations ,2009-2011 

3 Total Concentration = Design Concentration + Background Concentration 

4 NAAQS = National Ambient Air Quality Standards 

5 Based on guidance in the “Additional Clarification Regarding Application of Appendix W Modeling 

Guidance for the 1-hour NO2 National Ambient Air Quality Standard” memorandum issued on 

March 1, 2011 by Tyler Fox, Leader of the Air Quality Modeling Group at EPA’s Office of Air 

Quality Planning and Standards, the one-hour average NO2 concentrations were assumed to be 

80 percent of the NOX concentrations calculated by the model. Also, based on guidance in the 

March 1, 2011 memorandum issued by Tyler Fox, the 1-hour average NO2 design concentration 

is the maximum 1-hour average concentration averaged across the five modeled years at each 

receptor. 

6 Based on guidance in the “Modeling Procedures for Demonstrating Compliance with PM2.5 NAAQS” 

memorandum issued on March 23, 2010 by Stephen Page, Director of the EPA’s Office of Air 

Quality Planning and Standards, the 24-hour average design concentration for comparison to the 

SILs is the maximum 24-hour average concentration averaged at each receptor across the five 

modeled years. 
Figure 1. Updated Site Plan
Figure 2. Normal Operation Project-Only 1-hr Average NO2 Concentrations 

Averaged By-Receptor Over Five Years UTM Northing (meters)
Figure 3. Normal Operation Project-Only Annual Average NO2 Concentrations

553000 554000 555000 556000 557000 558000 559000 560000 561000 562000

UTM Easting (meters)

4476000

4477000

4478000

4479000

4480000

4481000

4482000

4483000

4484000

4485000

U

T

M

Northing (meters)
Figure 4. Normal Operation Project-Only 1-hr Average CO Concentrations

553000 554000 555000 556000 557000 558000 559000 560000 561000 562000

UTM Easting (meters)

4476000

4477000

4478000

4479000

4480000

4481000

4482000

4483000

4484000

4485000

U

T

M

Northing (meters)
Figure 5. Normal Operation Project-Only 8-hr Average CO Concentrations

553000 554000 555000 556000 557000 558000 559000 560000 561000 562000

UTM Easting (meters)

4476000

4477000

4478000

4479000

4480000

4481000

4482000

4483000

4484000

4485000

U

T

M

Northing (meters)
Figure 6. Normal Operation Project-Only 24-hr Average PM2.5 Concentrations 

Averaged By-Receptor Over Five Years 

553000 554000 555000 556000 557000 558000 559000 560000 561000 562000

UTM Easting (meters)

4476000

4477000

4478000

4479000

4480000

4481000

4482000

4483000

4484000

4485000

U

T

M

Northing (meters)
Figure 7. Normal Operation Project-Only Annual Average PM2.5 Concentrations

553000 554000 555000 556000 557000 558000 559000 560000 561000 562000

UTM Easting (meters)

4476000

4477000

4478000

4479000

4480000

4481000

4482000

4483000

4484000

4485000

U

T

M

Northing (meters)
Figure 8a. Annual Emission Rates and Hours of Operation Versus Number of 

Starts Per Year 

0

876

1,752

2,628

3,504

4,380

5,256

6,132

7,008

7,884

8,760

0

50

100

150

200

250

300

350

400

450

500

0 50 100 150 200 250

Hours of Operation Per Year

Pollutant Tons Per Year

Starts Per Year

NOx CO SO2 PM-10 VOC Sulfuric Acid Lead Op. Hrs
Figure 8b. Annual Emission Rates and Hours of Operation Versus Number of 

Starts Per Year (with NOX and CO removed and scales adjusted to more clearly 

show lower emitting pollutants) 

0

876

1,752

2,628

3,504

4,380

5,256

6,132

7,008

7,884

8,760

0.00

5.00

10.00

15.00

20.00

25.00

30.00

35.00

40.00

45.00

0 50 100 150 200 250

Hours of Operation Per Year

Pollutant Tons Per Year

Starts Per Year

SO2 PM-10 VOC Sulfuric Acid Lead Op. Hrs
Figure 9. Startup & Shutdown Project-Only 1-hr Average NO2 Concentrations 

Averaged By-Receptor Over Five Years UTM Northing (meters)
Figure 10. Startup & Shutdown Project-Only 1-hr Average CO Concentrations

553000 554000 555000 556000 557000 558000 559000 560000 561000 562000

UTM Easting (meters)

4476000

4477000

4478000

4479000

4480000

4481000

4482000

4483000

4484000

4485000

U

T

M

Northing (meters)
Figure 11. Startup & Shutdown Project-Only 8-hr Average CO Concentrations

553000 554000 555000 556000 557000 558000 559000 560000 561000 562000

UTM Easting (meters)

4476000

4477000

4478000

4479000

4480000

4481000

4482000

4483000

4484000

4485000

U

T

M

Northing (meters)
Figure 12. Startup & Shutdown Project-Only 24-hr Average PM2.5 Concentrations 

Averaged By-Receptor Over Five Years 

553000 554000 555000 556000 557000 558000 559000 560000 561000 562000

UTM Easting (meters)

4476000

4477000

4478000

4479000

4480000

4481000

4482000

4483000

4484000

4485000

U

T

M

Northing (meters)
E-Mail From Stanley Krivo of USEPA Region 4 Discussing Inclusion of Precursors 

When Predicting PM2.5 Concentrations in Class I Areas Using CALPUFF 

-----Original Message----- 

From: Stanley Krivo [Krivo.Stanley@epamail.epa.gov] 

Received: Wednesday, 11 Apr 2012, 7:34am 

To: Bart Brashers [bbrashers@environcorp.com] 

Subject: Re: Refs or other backup for excluding secondary PM2.5 in a Class I analysis

Bart,

The Stephen Page 23 March 2010 clarification memo provides current guidance on modeling 

compliance with PM2.5 NAAQS. 

[http://www.epa.gov/ttn/scram/Official%20Signed%20Modeling%20Proc%20for%20Demo%20Co

mpli%20w%20PM2.5.pdf] 

Although the memo is written for NAAQS compliance, it should also be applicable for PSD 

increments.

I can not find any explicit reference concerning the limitations of CALPUFF to direct emissions 

accept Appendix A of Appendix W limits CALPUFF regulatory application to the default options. 

Another reference could be the requirement to consult with Regional EPA office on acceptable 

model/modeling procedures. As indicated in our discussion, OAQPS indicated the CALPUFF 

chemistry was not included in the regulatory evaluation of the model so is currently not a 

regulatory application of CALPUFF.

I hope that helps.

...sjk

Stanley J. Krivo 

US Environmental Protection Agency, Air Planning Branch 

Atlanta Federal Center, 61 Forsyth Street, SW 

Atlanta, Georgia 30303 

404/562-9123 (Phone) 404/562-9019(Fax)