----- Forwarded by Omer Shalev/R9/USEPA/US on 09/26/2012 02:12 PM -----

From: <rob@redwoodrob.com>

To: R9AirPermits@EPA

Date: 09/26/2012 11:09 AM

Subject: Sierra Pacific Industries- Docket no. EPA-R09-OAR-2012-0634

Sierra Pacific Industries- Anderson Division

Anderson, CA

Docket no. EPA-R09-OAR-2012-0634

Hi,

I am preparing to comment on the above referenced permit. I wish to contact the applicant but could not

find a contact person in the record. Could you direct me to a contact person. Can you extend the comment

period? This is the first such facility that I will comment on and it appears that there is more information

on the docket than I could possibly review and comment about in the time allotted. Also there appears to

be several applications, which would be the one considered?

Thank you

Rob Simpson

Executive Director

Helping Hand Tools (2HT)

Fw: Sierra Pacific Industries- Docket no. EPA-R09-OAR-2012-0634

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09/26/2012 02:13 PM

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file://C:\Documents and Settings\oshalev\Local Settings\Temp\notesBAAA25\~web5155.... 10/29/2012
Rob Simpson comments on; 

PROPOSED PREVENTION OF SIGNIFICANT DETERIORATION 

PERMIT SPI - Anderson

For the forgoing reasons I request a public Hearing and extension of the public comment period. 

The record is too extensive to review in the allotted time period. The following clear errors are 

evident in the administrative record for this proceeding; 

The Modification fails to consider 

A No or reduced project alternative. The facility apparently requires 7 of the 23 megawatts 

electricity that it can generate. No state authority has, or is, required to make a determination of 

if this electricity, in this location, is beneficial to the system. The project will interfere with the 

development of superior solar and wind alternatives which would have created more jobs and a 

cleaner environment than this project. Clearly appropriately sized equipment 7/23 of the size of 

this one would result in reduced emissions. 

Since it is gas and wood burning proposal; the fuel mix should be considered in BACT analysis. 

The BACT analysis fails to consider a different fuel mix. Increased gas use can raise the 

temperature and reduce emissions through more complete ignition. While the below discussion 

deals with GHG it should hold true for each pollutant. 

In addition, EPA has observed that the application of methods, systems, or techniques to increase 

energy efficiency is a key GHG- -

-emitting technologies, including energy 

efficiency measures, represents an opportunity for GHG reductions in these BACT reviews. EPA 

has encouraged permitting authorities to use the discretion available under the PSD program to 

include the most energy efficient options in BACT analyses for both GHG and other regulated 

are co-firing biomass with a primary fuel, the permitting record should provide a reasoned 

justification for basing BACT for greenhouse gases on a specific proportional allocation of 

ee, In re: Northern Michigan University Ripley Heating Plant. PSD Appeal No. 08-02, 

Slip. Op at 18-23, 28 (EAB 2009) (remanding a permit for a co-fired electric generating facility 

where record did not contain justification for establishing BACT limits based on specific 

-fire 

or combine biomass fuels with another primary fuel type, the list of BACT options should 

include the option of utilizing both types of primary fuels in different combinations. If the 

applicant proposes a specific proportional allocation or fuel mix (i.e., <5 percent biomass, >95 

percent fossil fuel) and believes other allocations should be eliminated from consideration in the 

BACT analysis for GHGs, the permit application should provide an explanation as to why the 

particular allocation desired by the applicant is necessary to achieve a fundamental business 

objective of the project. If the permit applicant is unable to demonstrate that a different allocation 

of primary fuels would fundamentally redefine the proposed source, the options at Step 1 should 
include varying allocations of the two primary fuels if the proportional allocation of fuels has the 

potential to affect the amount of GHGs emitted from the facility or the net atmospheric GHG 

http://www.epa.gov/nsr/ghgdocs/bioenergyguidance.pdf

A solar component should be considered in in the BACT analysis. A solar component would 

reduce all emissions by preheating the system or augmenting the electrical output. Solar energy 

is an inherently lower emitting, add on control technology. 

The BACT analysis fails to adequately consider energy efficiency options. There should be no 

need for cooling towers and their associated emissions to dissipate heat. The heat should be used 

in the existing Kiln or in a new Kiln or pre heater to warm the material before it enters the full 

temperature Kiln. The Permit should consider the existing Kiln as permitted equipment in 

context of this modification and the Kiln should be required to undertake a BACT analysis. The 

insulation, operation and even color of the Kiln will have an effect on its efficiency in reducing 

use of the associated emissions units. 

A new cogeneration unit equipped with a stoker boiler is being proposed in order to burn 

additional clean cellulosic biomass fuel. Fuel will be generated on site from the lumber 

operations and delivered from other fuel sources to produce roughly 250,000 pounds per hour of 

steam. This steam be used to dry lumber in existing kilns for the lumber operation, as well as 

feed a turbine that will drive a generator to produce electricity for use on site or for sale to the 

electrical grid. A closed-loop two-cell cooling tower will be used to dispose of waste heat from 

the steam turbine. 4 

EPA notes that energy efficiency is an option for inclusion in the set of control 

options in the BACT analysis at Step 1 for all facilities. EPA agrees that this should become 

standard practice for all facilities, and notes that the Bioenergy BACT Guidance does not intend 

to remove energy efficiency as a control option for bioenergy facilities. 

http://www.epa.gov/nsr/documents/RTC_6-30_final_comb.pdf

The permit should identify the existing equipment and require its retirement. The administrative 

record demonstrates that the permit should at least require that the existing emissions units do 

not operate concurrently with the new units. The EPA has no authority to modify the underlying 

State permit. 

Handling and transport emissions. The analysis fails to consider the, perhaps collateral, 

emissions associated with the, primarily diesel powered, collection transport and on site 

handling of biomass. A permit condition should require that all associated equipment operates on 

Methane gas, or biomass power. 

The analysis fails to consider increased kiln emissions and other operational emission increases. 

Kiln and other facility emissions should be considered prior to final circulation of a draft permit. 
The project should be based upon a Comparison to the actual baseline instead of prior permit 

levels. 

The air quality monitoring station, 50 miles from the site fails to represent conditions in the 

projects impact area. The EPA should require one year of local monitoring prior to consideration 

of a permit request. 

EJ The EPA failed to identify the environmental Justice community in the vicinity of the 

proposed project. This should be the first step in an EJ analysis in order for the EPA to conduct 

outreach and identify any stressors. It is inadequate for the EPA to skip this step and simply 

claim no harm to any potential community without notification. The EPA failed to issue a notice 

in Spanish. 

 

Public notice participation The EPA failed to demonstrate that it notified participants in the State 

action(s) about this proposed permit. The EPA failed to demonstrate that it provided Notice to 

the appropriate elected officials. The EPA should reissue a Public Notice to the appropriate 

elected officials and members of the public who have expressed an interest in this project and 

other projects in the area. The public Notice fails to disclose any effect on air quality. A new 

notice should demonstrate the projects effects in relationship to the National Ambient Air 

Quality Standards or at least in gross pollutant weights. The Notice fails to alert the public of a 

reason to participate. 

-consumer wood which would be more appropriately burned with a DLN Burner 

 50,000 BDT of agricultural and urban wood 

DLN Burner 

With two or more DLN burners, the biomass combustion fuel would need to be pulverized and 

burned in suspension using wall-mounted burners. This presents a significant departure from 

designed to limit the amount of fuel-bound nitrogen that is converted to NOx during combustion, 

and are generally suited to boilers that burn wood waste containing a high percentage of resins, 

such as the waste from medium density fiberboard, plywood, or veneer operations. The emission 

rate with DLN burners is projected to be 0.35 lb/MMBtu. 

The permit fails to require appropriate Ash bunker waste disposal. It does little good if the ash is 

collected and then left to blow away into the air or contaminate some other resource. 

EMX, SCR and Urea should be required. 

Consideration of the McNeil facility are entirely speculative. If the project is to be excused from 

the BACT demonstrated at McNeil than additional analysis is required 

Although the McNeil Generating Station has demonstrated a lower NOx emission limit on a 

calendar quarterly basis, it has a short term NOx emission limit of 0.23 lb/MMBtu. Moreover, 
the possible economic incentives of the Class 1 Renewable Energy Credits in New England are 

difficult to quantify and not available to SPI- Anderson. This may allow SCR system to be more 

economically feasible for McNeil Generating Station and other proposed systems in the New 

England area than for SPI- Anderson in California. 

EPA does not anticipate additional significant environmental or energy impacts from employing 

the SNCR or SCR technology. Both systems use ammonia as a reagent: anhydrous ammonia, 

aqueous ammonia, or urea mixed with water (which hydrolyzes in the hot exhaust to form 

ammonia). In the case of aqueous ammonia or urea mixed with water, additional fuel must be 

combusted to evaporate the water associated with the reagent. Moreover, energy is required to 

operate the injectors used by either technology to introduce the reagent into the exhaust. With 

either technology, the exhaust leaving the boiler stack will contain some small quantity of 

ammonia. 

The PSD increment trigger date should have been when the original permit was issued. 

PM2.5 increments become effective under the Federal PSD program is October 20, 2011. The 

SPI- Anderson PSD permit application was determined to be administratively complete by EPA 

on October 4, 2010. However, EPA is requiring each source that receives its PSD permit after 

the trigger date, regardless of when the application was submitted, to provide a demonstration 

that the proposed emissions increase, along with other increment consuming emissions will not 

cause or contribute to a violation of the PM2.5 increments. Also the major source baseline, 

which precedes the trigger date is the date after which actual emissions increases associated with 

construction at any major stationary source consume PSD increment. That date is October 20, 

2010. With this PSD permit, SPI-Anderson would begin construction after this date. In general, 

for PM2.5, the minor source baseline date is the earliest date after the trigger date of a complete 

PSD permit application for a source with a proposed increase in emissions of PM2.5 that is 

significant. No source has triggered the minor source baseline date in the area at issue. Other 

than SPIchanges of PM2.5 from any new or modified major stationary source on which construction 

commenced after October 20, 2010. Therefore, the only source to consume PM2.5 increment in 

the area is SPI- Anderson. The applicant considered only the allowable emissions increase from 

the SPI- Anderson project in the 24-

The analysis must demonstrate the Nitrogen and other pollutant deposition on the adjacent 

Elderberry plants 

SPI has confirmed that construction activities will not occur within 100 feet of the elderberry 

shrubs that are in the Pacific Gas and Electric power line Right of Way. The nearest construction 

activity to the existing elderberry plants will be the erection of the electrical power poles at the 

existing electrical sub-station which are 137 feet away from the nearest elderberry shrub.