Omer Shalev 

Environmental Engineer 

Air Permits Office (Air-3) 

Environmental Protection Agency, Region 9 

75 Hawthorne St. 

San Francisco, CA 94105 

415-972-3538

Dear Presiding Officer Omer Shalev, 

I am disappointed in EPA Region 9 s decision to not address BACT (Best Available Control 

Technology) seriously. 

1. What specific and actual examples of filtering technology are being provided by EPA Region 9 in 

their fact sheet ? 

SPI-Anderson Fact Sheet AAQIR/ Fact Sheet, available at: http://epa.gov/region9/air/permit/r9-permitsissued.html#pubcomment

2. Are wet electrostatic precipitators (WESP or wet ESP) being considered for use at the proposed 

Anderson manufacturing facility? A WESP operates with saturated air streams (100% relative 

humidity). WESPs are commonly used to remove liquid droplets such as sulfuric acid mist from 

industrial process gas streams. The WESP is also commonly used where the gases are high in moisture 

content, contain combustible particulate, or have particles that are sticky in nature. 

3. The preferred and most modern type of WESP is a downflow tubular design. This design allows the

collected moisture and particulate to form a slurry that helps to keep the collection surfaces clean. Will

Public Comments Regarding Sierra Pacific Industries PSD permit modification (code: Shasta

123) 

Rose Flame

to: 

Omer Shalev 

10/17/2012 06:27 PM 

Cc: 

Heidi Strand, Eric Cassano, Adam Fieseler, Bill Walker, "Ed Smith & Virgina Phelps", 

Angelique Salzmann, Alayna Shulman, Gerardo Rios 

Hide Details

From: Rose Flame <mysecretfires@gmail.com> Sort List... 

To: Omer Shalev/R9/USEPA/US@EPA, 

Cc: Heidi Strand <hswriter@frontiernet.net>, Eric Cassano <ecassano@shastalake.com>, 

Adam Fieseler <afieseler@co.shasta.ca.us>, Bill Walker <bwalker@co.shasta.ca.us>, "Ed 

Smith & Virgina Phelps" <ednva@frontiernet.net>, Angelique Salzmann 

<asalzmann@me.com>, Alayna Shulman <ashulman@redding.com>, Gerardo 

Rios/R9/USEPA/US@EPA 

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the downflow tubular design be utilized here?

4. Plate style and upflow design WESPs are very unreliable and should not be used in applications 

where particulate is sticky in nature. Are the particulates at the proposed Anderson facility of a type that

could be effectively filtered out by a plate style and unflow design? 

5. ESPs continue to be excellent devices for control of many industrial particulate emissions, 

including smoke from electricity-generating utilities (coal and oil fired), salt cake collection from black 

liquor boilers in pulp mills, and catalyst collection from fluidized bed catalytic cracker units in oil 

refineries to name a few. These devices treat gas volumes from several hundred thousand ACFM to 2.5 

million ACFM (1,180 m /s) in the largest coal-fired boiler applications. For a coal-fired boiler the 

collection is usually performed downstream of the air preheater at about 160 C (320 deg.F) which 

provides optimal resistivity of the coal-ash particles. For some difficult applications with low-sulfur fuel

hot-end units have been built operating above 371 C (700 deg.F). 

6. The original parallel plate weighted wire design has evolved as more efficient (and robust) 

discharge electrode designs were developed, today focusing on rigid (pipe-frame) discharge electrodes 

to which many sharpened spikes are attached (barbed wire), maximizing corona production. 

Transformer-rectifier systems apply voltages of 50 100 kV at relatively high current densities. Modern

controls, such as an automation voltage control, minimize electric sparking and prevent arcing (sparks 

are quenched within 1/2 cycle of the TR set), avoiding damage to the components. Automatic platerapping systems and hopper-evacuation systems remove the collected particulate matter while on line, 

theoretically allowing ESPs to stay in operation for years at a time. Which of these BACT methods, 

procedures and determinations have you, as the EPA Region 9 Presiding Officer, considered? 

7. Please provide and describe what tests have been conducted to determine resistivity under the 

previous Sierra Pacific permit and how that would apply to this modified PSD permit. A widely 

taught concept to calculate the collection efficiency is the Deutsch model, which assumes infinite 

remixing of the particles perpendicular to the gas stream. Was the Deutsch model used here, as part of 

your agency s BACT analysis? (Resistivity can be determined as a function of temperature in 

accordance with IEEE Standard 548. This test is conducted in an air environment containing a specified 

moisture concentration. The test is run as a function of ascending or descending temperature or both. 

Data are acquired using an average ash layer electric field of 4 kV/cm. Since relatively low applied 

voltage is used and no sulfuric acid vapor is present in the environment, the values obtained indicate the 

maximum ash resistivity.) 

8. Ideally, BACT considers energy, environmental, and economic impact. How specifically are these 

issues being addressed by EPA Region 9? 

9. BACT can be add-on control equipment or modification of the production processes or methods. 

Were any add-ons to the previous factory, under this permit, looked at? Were any add-ons used? 

10. BACT includes fuel cleaning or treatment and innovative fuel combustion techniques. BACT may 

also be a design, equipment, work practice, or operational standard, if imposition of an emissions 

standard is infeasible. Were any of the above items and conditions considered in your BACT 

determination? 

11. Currently, Shasta County has rated 2nd worst in California for filthy air quality, behind Los 

Angeles. What is EPA Region 9 doing to help solve our air quality problems?

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12. PSD increment is the amount of pollution an area is allowed to increase. PSD increments prevent

the air quality in clean areas from deteriorating to the level set by the NAAQS. The NAAQS is a 

maximum allowable concentration "ceiling." A PSD increment, on the other hand, is the maximum 

allowable increase in concentration that is allowed to occur above a baseline concentration for a 

pollutant. Please explain how the baseline concentration in Shasta County was determined and where 

our ceiling is currently at. What efforts, if any, were considered in regards to PSD increments at the 

proposed Anderson facility? 

13. The baseline concentration is defined for each pollutant and, in general, is the ambient

concentration existing at the time that the first complete PSD permit application affecting the area is 

submitted. Significant deterioration is said to occur when the amount of new pollution would exceed the 

applicable PSD increment. It is important to note, however, that the air quality cannot deteriorate beyond

the concentration allowed by the applicable NAAQS, even if not all of the PSD increment is consumed. 

Will significant deterioration be the case here? How were ambient concentrations determined at this 

proposed facility? 

I hope that these questions will be addressed by EPA Region 9. The health and welfare of real people 

will be affected by the decisions you and your agency make. 

Sincerely, 

Celeste Draisner 

(530)921-0272

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