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 J aegel; 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.comDecember 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

– Cogener ation 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 Imp act 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 inp ut 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 burner s 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

- 8350AAQIR

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” c olumn, 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 h eat 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 alrea dy 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 incorpor ated 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. Pleas e 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