Lrivironmental Engineer

Air Permits Office (Air3)

bnvronmental Protection Agency Region 1X

75 Hawthorne Street

San Francisco, CA 94105

Subject: Rio Bravo Poso and Jasmin PSD Permit Modifications

Dear Mr. Shalev:

Below are the answers to the three (3) questions you asked regarding the submittal of the above

referenced PSD Permit Modilica ions:

I. Provide future and actual emissions data.

There is 110 ‘WOrst case” fuel or combination of fuels from an air emissions standpoint. in the

case of oxides of nitrogen (N0c) when a “set point” slightly below the permitted concentration

limit is reached, additional ammonia injection (for the Thermal De NOx reaction) is

automatically triggered. Thus, the NOx concentrations resulting from fur each fuel/blend areequaL Likewise with S02, the set point automatically injects more limestone, so that equal S02 pollutant levels are achieved for each fuel/blend.

1 he baghouse controls the Particulate Matter (PM) emissions which are comprised primarily of ash from the fuel and gypsum (calcium sulfate), the product of the reaction of limestone wiil

502. Biomass typically has an ash concentration between that of petroleum coke and coal, and a

sulfur content well bekw that of petroleum coke or coal (which means less limestone is needed

and hence less solid CaSO 4is brrned-than with petroleum coke or coal) which will result in

equal or lower PM emissions.

The extended combustion zone residence time in a circulating fluidized bed combustor results in

minimization of carbon monoxide (CX)) and hydrocarbons, independent of fuel/blend. Thereibre.

the levels will be equivalent.

in summary, the addition of bio.mass fuel will result in equal or lower amounts of all criteria

pollutant emissions. In a]] cases, criteria pollutant fttture emissions minus actual emissions equals

zero or less than zero. Use zero for all criteria pollutant “future actuals minus actual” values.

(See attached tahM.
..

-

OibflIMBTU

O2 -_...—______ 0003* 1bLMF4B__..... _PL___ :.0241b/ML

0 0.000*lbjMMBtu 0.046*1b/MMBtu •0.046__

LYQc__ .._ o.ooo*iitwati *1MM 1b/MMBtu_

* From source test at Rio Bravo Rocklln /a 25MW biomass-fired CE Lurgi circulating fluidized bed

boiler

**From source test at Rio Bravo Paso / a 33MW coal/petroleum coke-fired CE Lurgi circulating

fluidized bed boiler

Note For PM0,the Rio Bravo Rocldin plant has an Electrostatic Precipitator, which does not

control partic.ulates as well as a baghouse, like Rio Bravo Poso and Jasmin have. Since biomass

has substantially less ash than either coal or petroleum coke, and also less sulfur which means

less solid CaSO 4formed-that must be controlled) than either coal or cake, the resulting future

PMw emissions from adding biomass to the Rio Bravo Poso and Jasmin plants minus actual

emissions will be zero or less than zero

2. Specify what type of hiornass is intended to be burned at each thcility.

Rio Bravo Paso and Jasmin will burn a combination of urban, agricultural, contniction and

forest wood material, typical of that currently comnbusted at the Rio Bravo Fresno and Rio Bravo

Rocklin biomass-fired power plants. The fuel will consist of wood residue from the h,rest

products industry (saw mills), aithard prunings, almond, walnut and pistachio shells. frj pits,

vineyard pmunings, grape stems and pumice, alfalfa, beanstraw, corn, oats and wheat (vegetable

crop hiomnass residues). No painted, oiled or stained ficis will he burned.

Rio Bravo Poso and Rio Bravo Jasmin will ensure that only clean biomass will be combusted at

the facility. In accordance with the draft Authority to Construct Permit from the APC D, the

plant will be limited to the following materials in the hiomass:

Biomuss introduced into the coinhuTtor shalt not contain more than 2% by weight non-biornass

muiericil pIastics, metal, painted and preservative-treated wood, roofing mtueriai, fIber glass,

etc.). IDLtrici Rule 4)02/
hiornass procurement agreements

Excluded Materials The hioinoss shall not contain any free ash, soil, or cinder, and shall

he free of foreign material, including, hut not limited to, sand, stone, metal, glass, rubber, plastics, pre.sure treated or lead basedpainted wood, chemicals and any hazardous or toxic

substances as defined under (J’cdifbrnia orfèderal law.

3. How do the sources intend to comply with the 836,520 pounds per day on 30—day rolling

average limits? How do the facilities currently ShoW compliance with the 34,855 pounds

per hour limits?

(‘urrently Rio Bravo Poso and Rio Bravo Jasmin demonstrate compliance with their daily and monthly the! limits by use of a weigh belt built into their fuel conveying systems. These weigh belts will continue to be used with bionwss fuel once the permit modifications are approved. Flie weigh belts are calibrated on a semiannua1 basis.

To accommodate the biomass fuel Rio Bravo Poso and Rio Bravo Jasm.in seek a condition with

language similar to the language EPA approved earlier this year for the Mt Poso Cogeneration.

Company (attached); see Condition IXG, page 9 of PSD Permit Number Si 86-09.

Following the format of the Mt Poso permit language, Rio Bravo Poso and Rio Bravo Jasmin

wish to have the following language modification to their Condition IX-H, page 7 ofthe PSI)

permits: The sum ofthe combined cocil and coke throughput and 1⁄4 times the throughput of

hiomassfd into the coinhustor shall no: exceed 34,855 pounds per hour on a di basis, The jiAel

shall he compthed ofa blend ofpetralewn coke and hiornas-, up to 100% by weight.

Ifthe boiler is fired on 100% hiomass, thefidel throughput shall not exceed 34.855 tons per hour

on a thy basis.

Lastly, Rio Bravo Poso arid Rio Bravo Jasmin formally request RPA approval to conduct a six

month (‘l80-day experimental ‘trial burn” using biomass as fue’ while EPA is reviewing our

request for PSI) permit modification. Rio Bravo Poso and Rio Bravo Jasmin intend to

commence the hiomass tiial buni on or around November 1, 2010. Records of all fuels burned

Will be kept. Emissions data will also be compiled and tbrwarded to your ollice on a monthly

basis for your review unless otherwise directed. It is understood the maxinuxn length ofthis test

is 180 days, with the intent to utilize this period to test burn the biomass fuel on a continuous

basis. Testing will be performed by blending biornass fuel in various combinations With

currenty permitted ftels. including coal and/or petroleum coke, utilizing fly,.existing
experimental biomass trial burn for the Mt Poso Cogeneration Compa

y 

y 

permit modification application was being reviews. EPA determined that the blomass trial burn

was justified since the rest program would be temporary and would have no significant impact on

air quality. As such EPA considered the allowance ofthe test burn to be administrative in

nature and not subject to public review requirements. EPA therefore amended the permit as

requested and stated “this amendment to the permit shall take effect immediately. if you have

any questions, please ask Laura (972-3534) about this experimental trial burn approval process.

Rio Bravo Poso and Rio Bravo Jasmin believe this information satisfies your questions.

Please refer any firnher questions you have regarding this request during your review to Dr. Ted

Guth at (619) 987-1111. Thank you in advance for your expedited response to the Bravo Pos&s

and Jasmin’s requests for approval to conduct the 180-day biomass trial burns.

Bill Rossiter

Vice President

Title V Responsible Official

cc: Maggie lstrada, Constellation Energy

Ted Guth, Rio Bravo

Facility tiles