SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and Responses December 15, 2011

A-1 Final Staff Report with Appendices for Revised Proposed Amendments t o Rule 4352 

## APPENDIX A

Summary of Significant Comments and Responses For Revised Proposed Amendments to Rule 4352

December 15, 2011SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and Responses December 15, 2011

A-2 Final Staff Report with Appendices for Revised Proposed Amendments t o Rule 4352 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and Responses December 15, 2011

A-3 Final Staff Report with Appendices for Revised Proposed Amendments t o Rule 4352 SUMMARY OF SIGNIFICANT COMMENTS FOR RULE 4352 (SOLID FUEL FIRED BOILERS, STEAM GENERATORS AND PR OCESS HEATERS)

FOR THE PUBLIC HEARING

EPA REGION IX STAFF COMMENTS

No comments were received from EPA.

ARB STAFF COMMENTS

No comments were received from ARB.

STAKEHOLDER COMMENTS

No comments were received from stakeholders.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and Responses December 15, 2011

A-4 Final Staff Report with Appendices for Revised Proposed Amendments t o Rule 4352 SUMMARY OF SIGNIFICANT COMMENTS FOR THE

FINAL DRAFT STAFF REPORT FOR RULE 4352 (SOLID FUEL FIRED BOILERS, STEAM GENERATORS AND PRO CESS HEATERS) DATED NOVEMBER 15, 2011

EPA REGION IX STAFF COMMENTS

1. COMMENT: The District should define the terms in the six-ten ths equation, used for the first time on page seven of the staff report.

RESPONSE : The terms of the six-tenths equation have been de fined in Section IV.D. of the staff report.

2. COMMENT: The District should explain why it uses a 10-year l ife and a 10% interest rate to determine the annualized capital costs for retrofit equipment.

RESPONSE : Refer to Section IV.D. of the staff report for th is discussion.

3. COMMENT: The District should consider including PM 2.5 and SOx emission limits in the SIP in response to the 2006 PM 2.5 NAAQS.

RESPONSE : District staff will explore setting limits on PM 2.5 and its precursors, including SOx, when creating the next attainment pl an.

ARB STAFF COMMENTS

No comment letter has been received from ARB.

STAKEHOLDER COMMENTS

No comments have been received from stakeholders.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and Responses December 15, 2011

A-5 Final Staff Report with Appendices for Revised Proposed Amendments t o Rule 4352 SUMMARY OF SIGNIFICANT COMMENTS FOR THE

DRAFT STAFF REPORT FOR RULE 4352 (SOLID FUEL FIRED BOILERS, STEAM GENERATORS AND PRO CESS HEATERS) DATED OCTOBER 18, 2011

EPA REGION IX STAFF COMMENTS

1. COMMENT : The District should provide an analysis of how t he requirements in the rule fulfill the Clean Air Act (CAA) requirements f or Reasonably Available Control Technology (RACT) regarding technical and economic feasibility. The analysis should consider currently available options for NOx controls and their associated

costs.

RESPONSE: District staff have addresses this comment; further information regarding the technical and economic feasibility of additional NOx control technology has been added to the staff report. Ple ase see Section IV in the staff report for this discussion.

2. COMMENT : The definition of "shutdown" should be revised t o eliminate "solid"

from the first sentence of the definition. Additio nally, the District should provide further information to support the inclusion of zer o steam flow as the end of a

shutdown. Additional information should include th e temperature of the boiler when steam flow reaches zero and average amount of time between the start of a

shutdown and when zero steam flow is reached.

RESPONSE: The definition of Shutdown has been modified to rem ove the language referring to “zero steam flow” and “solid fuel”. Another definition, Hot Standby, will be added to address a concern that wa s called to our attention by

stakeholders. When maintenance is needed a boiler begins the Shutdown process. The boiler that may not actually reach ambient temp erature before the maintenance is complete and is able to be fired back up. Under the existing definitions, a boiler qualifies for the startup exemption from the rule l imit only if it begins startup from a shutdown condition, but a boiler that does not reac h ambient temperature has not actually reached a shutdown condition. In that cas e, the rule definitions would force facilities to wait additional hours, such as overni ght, to reach ambient temperature. Even if they could burn auxiliary fuel without bein g in Startup, they would immediately be subject to the emission limits (whic h apply during startup and shutdown) even though the exhaust gas temperature i s far too low still for SNCR to be effective. By including the hot standby provisi on, it provides a way to transition from shutdown to startup without cooling to an ambi ent temperature as that can vary dramatically on external conditions.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and Responses December 15, 2011

A-6 Final Staff Report with Appendices for Revised Proposed Amendments t o Rule 4352 3. COMMENT : Our final action on the previous version of this rule identified concerns with Section 5.4 (see 75 FR 60626, October 1, 2010) and we understand that this provision has never been used by any sources. The District should remove Section 5.4 or revise it to clarify that any alternate RACT limits must go through the SIP rulemaking process.

RESPONSE: District staff verified that since the provision in Section 5.4 is not being utilized by stakeholders, it has been removed from rule language.

4. COMMENT : The District should consider including EPA Metho ds 201a and 202 to

test for filterable and condensable PM2.5 emissions in Section 6.4. Inclusion of such testing will help the District gather needed d ata to include adequate emission

limits on future revisions of this rule.

RESPONSE: District staff will explore this option when creati ng the next attainment plan, but will not incorporate additional testing i n rule language at this time.

ARB STAFF COMMENTS

No comment letter has been received from ARB.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and Responses December 15, 2011

A-7 Final Staff Report with Appendices for Revised Proposed Amendments t o Rule 4352 STAKEHOLDER COMMENTS

Covanta Energy (CE) Covanta Stanilaus (CS) Covanta Delano (CD) Rio Bravo Fresno (RBF) Rio Bravo Poso (RBP) Rio Bravo Jasmin (RBJ) Association of Irritated Residents (AIR) Madera Power (MP) Dinuba Energy (DE) Thermal Energy Development Partnership (TEDP)

5. COMMENT : Covanta appreciates the considerations of Distri ct staff to set a reasonable limit. Covanta facilities could potenti ally meet a lower limit on an annual basis but the draft limit for Municipal Solid Waste (MSW) can be reasonably achieved with 24-hour averaging. Covanta facilitie s are fully offset for NOx. (CE, CS)

RESPONSE: Comment noted.

6. COMMENT : The definition for Flame Stabilization is restri ctive when referring specifically to power outrages. (CE) The definitio n should allow facilities to burn clean alternative fuels to stabilize when a potenti al exceedance could occur for another pollutant. The following language could be added to definition to address this concern: “in instances including control of on e or more pollutants, stabilization of the combustion process, process upsets, wet fuel ”. The current definition does not address the start-ups and controlled shut-downs , specifically the minimum temperatures that can be reached with regards to ea ch process. There has to be a minimum temperature of 900 degrees F to start burni ng coal or 1100 degrees F to start burning petroleum coke. This is achieved by burning start-up fuel (natural gas or propane) before coal can be introduced to the bo iler. On a controlled shutdown the boiler would trip at less than 1200 degrees F u nless the start-fuel was in service. This is allowed by our current Title V permit and t he PSD permit. (RBF, RBP, RBJ)

RESPONSE: The definition for Flame Stabilization has been mod ified. Please see

Section 3.0 in the rule and Section IV.B. in the st aff report for more information.

7. COMMENT : Rio Bravo would like to propose the following la nguage to define a unit

shutdown: "A shutdown starts when fuel feed is curt ailed and the unit begins cooling from the unit's normal operating temperature, as sp ecified by the manufacturer, andSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and Responses December 15, 2011

A-8 Final Staff Report with Appendices for Revised Proposed Amendments t o Rule 4352 ends when combustion emissions are essentially zero . The shutdown time period may vary depending on specific boiler technology." (RBF, RBP, RBJ)

RESPONSE: The definition for Shutdown has been modified. Ple ase see Section 3.0 in the rule and Section IV.B. in the staff repo rt for more information.

8. COMMENT : The proposed rule tightens NOx limits without ac hieving actual air quality improvements since the limits are already a chieved in practice. The NOx limits should be lowered to the minimum of the rang e indicated by EPA and to at least, the lowest level found elsewhere. It does n ot matter if there is a significant

cost when the health effects are considered. Nothi ng else takes into account the seriousness of our air quality problem and the cost this problem represents to the economy and to the health of valley residents. (AIR )

RESPONSE: While evaluating EPA’s concerns with RACT, the Dist rict conducted a detailed analysis and did not find any cost effecti ve options lower than those proposed in the amended rule. Further reductions f rom this source category will continue to be evaluated under subsequent attainmen t plans.

9. COMMENT : The proposed limit of 65 ppm corrected to 3% O2 f or NOx from Other Fuels will cost us more in ammonia usage costs to b e able to achieve that limit. (RBP, RBJ)

RESPONSE : District staff evaluated the possible need for i ncreased ammonia usage and determined that it may be needed by some facilities to consistently reach the proposed draft NOx emission limits. District s taff expect the need for increased ammonia usage will be minimal based on CEMS data.

10. COMMENT : Both facilities are clean burning power plants wi th selective noncatalytic reduction (SNCR) NOx control system. Based on historical emissions data, these facilities will be able to meet the NOx and CO emission limits as specified in the draft Rule 4352. However, with th ese proposed limits, the margin for plant upsets which will result in exceeding the se limits is very limited. (MP, DE)

RESPONSE: District staff have reviewed CEMS data for every fa cility and propose a draft NOx limit that not only meets RACT standard s but has a small buffer between the 24-hour average facilities are currentl y meeting and the proposed NOx

emission limit. Breakdown relief may be granted under Rule 1100 for qualifying
process upsets.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and Responses December 15, 2011

A-9 Final Staff Report with Appendices for Revised Proposed Amendments t o Rule 4352 11. COMMENT : Any further reduction of the proposed emission li mits will require major facility retrofits. Significant process reconfigur ation and installation of emission control equipment will be needed to be in complianc e with a more restrictive District Rule 4352. Capital costs associated with these mod ifications are in the range of $10 to $20 million dollars. There will also be los s of revenue due to downtime during installation of this equipment and the addit ional operating cost for the control devices. (MP, DE)

RESPONSE: Staff has estimated the cost of emission controls r equired for more

substantial reductions and concluded that the cost effectiveness goes beyond RACT. Please refer to the Staff Report Section IV. for that information.

12. COMMENT : SCR requires the use of fossil fuel to condition the flue gases to capture the emissions. Aside from the additional c ost of fossil fuel, it will also increase the greenhouse emission from our facility. The catalyst for an SCR control system is susceptible to fouling by ash which is in herently a control issue. Any breakthrough of ash will not affect opacity or visi ble emission but also could result in catalyst fouling resulting in increase of NOx emiss ion. Replacement cost of the catalyst and the required downtime will be addition al burden to our facilities. (MP, DE)

RESPONSE: The cost of additional fuel for a duct burner has b een included in the cost analysis in Section IV of the staff report. A dditional greenhouse gas emissions resulting from any revised proposed amendments to t he rule would be evaluated in the CEQA process but will not be considered at this time since SCR is not required. The fouling by ash concern is specifically for a ho t-side SCR, whereas the cost

effectiveness evaluated in Section X of the staff r eport cold-side SCR. A cold-side SCR would be located downstream of the unit’s bagho use and would, therefore, be shielded from potential ash issues.

13. COMMENT : District staff should take into consideration the impact on open burning when setting the biomass NOx limit since it is anot her major concern for Valley air quality. As facilities permitted to burn biomass, if our operation was shut down due

to costs and time needed to retrofit to meet a lowe r limit, the biomass would then be destined for open burning or would be diverted to l andfills, using up much of their valuable space available. (CD, MP, DE, RBF, RBP, RB J, TEDP)

RESPONSE: District staff recognizes the importance of biomass power generation facilities and the role they play in reducing the o pen burning of agricultural materials. In the Staff Report, District staff has carefully evaluated the feasibility of achieving lower NOx emissions and has proposed rule limits that staff believes areSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and Responses December 15, 2011

A-10 Final Staff Report with Appendices for Revised Proposed Amendments t o Rule 4352 reasonably achievable. Please refer to the Staff R eport Section IV. for additional

information.

14. COMMENT : It is not technologically or economically feasibl e for the plants to be retrofitted with SCR to gain more NOX reductions. The respective plants already achieve NOx levels that represent 60-66% reduction from uncontrolled levels, so the cost effectiveness of adding SCR to reduce NOx is impractical. A one year

minimum variance would have to be obtained to maint ain efficient operating conditions of a retrofitted system without violatio ns. The only type of particulate collection device that works at the temperature nee ded is a “hot side” ESP, which would also need to be purchased in addition to the SCR equipment. Any increase in downtime due to forced unit outages, because of SCR pluggage, could render the plant(s) not economically feasible. The entire bac k half of each facility would have to be completely reworked as part of the retrofit e qualing a total budgetary cost of $15 million per plant. In addition, the facility w ould be off-line for at least twelve months resulting in lost revenue from electricity s ales which pay for the plant operation and maintenance costs. Given the extreme downtime required to retrofit, the loss of revenue needed to pay for plant loans a nd employees, would result in having to lay off all employees, file for bankruptc y and permanently shut down affecting numerous jobs directly and indirectly. (R BF, RBP, RBJ, TEDP)

RESPONSE: District staff have evaluated the cost effectivenes s and determined it is not cost effective to require a retrofit at this time. Please refer to the Staff Report

Section IV. for that information.

15. COMMENT : Combustion modifications typical of the methods u sed to prevent the formation of thermal NOx are already in place, but the effectiveness is naturally limited by the very low operating temperatures in t he bubbling fluidized beds.

Excess O 2 is limited as part of the combustion and temperatu re controls in the bed and aids in restricting thermal and fuel bound NOx formation. Add-on NOx controls are necessary to meet the present and proposed NOx emission limits. SNCR is already installed at the facility, which is common for use in wood- and biomass-fired plants. SCR is not a feasible technology to retrof it to since being upstream of particulate controls in a wood-fired power plant co uld significantly degrade catalytic surfaces in a short period of time due to the prese nce of compounds resulting from wood and biomass combustion. However, Regenerative SCR (RSCR) has been demonstrated at several plants and has found favor in plants qualifying to generate

Connecticut and Massachusetts RECs for sale. RSCR l ocates the SCR downstream of the particulate control device where the catalytic surface can be protected. Assessing the incremental cost effectiv eness of retrofitting RSCR on the facility’s two units, demonstrates that RSCR is not cost effective. To retrofit and install RSCR, the cost effectiveness of controlling from 0.1 lb/MM Btu over the 10-SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and Responses December 15, 2011

A-11 Final Staff Report with Appendices for Revised Proposed Amendments t o Rule 4352 year project life is $80,500/ton and the cost effec tiveness of controlling from 0.09 lb/MM Btu is $161,000/ton. Clearly, RSCR is no t cost effective for installation on our two units. (CD)

RESPONSE: Please see response to Comment 14.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and Responses December 15, 2011

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