### RE: Request for BACT/Permit information Jim Swaney t o : Shaheerah Kelly 03/02/2010 09:00 AM History: This message has been replied to. Shaheerah, We haven't issued a Permit to Operate for this unit, as it hasn't demonstrated compliancy at this time with this limit. Let me know if you have any other questions. Jim Swaney, P.E. Permit Services Manager Valley Air District (559) 230-6000 (559) 230-6061 fax www . valleyair . org

From: Kelly.Shaheerah@epamail.epa.gov [ mailto:Kelly.Shaheerah@epamail.epa.gov] Sent: Monday, February 22, 2010 4:52 A M To: Jim Swaney Subject: RE: Request for BACT / Permit information Hi, Jim. Thanks so much for the information you sent previously. I have an additional request regarding an entry in the SJVAPCD BACT guidelines for external combustion at http :// www . valleyair . org / busind / pto / bact / bactchidx . htm . Can you let me know whether the unit listed below is currently achieving the NOx limit associated with it, and can you also send me the current ATC for this unit. I am working on a PSD permit that contains a small heater and I am gathering data on other comparable units. This should be the last bit of information I need from SJVAPCD for the PSD permit. Please let me know if you have any questions. Source: Occidental of Elk Hills BACT Determination: NOx= 12 ppmvd Fuel: Natural gas with LPG backup or propane-fired Unit rating: Less than or equal to 20 mmbtu/hr Control: Low NOx burner system Permit #: ATC #: S-2234-178-0, Project # S-1063316Date of Determination: not given Thanks.

************************************ Shaheerah Kelly Air Division (AIR-3) U S EPA Region 9 75 Hawthorne Street San Francisco, CA 94105 Phone: 415-947-4156 Fax: 415-947-3579 email: kelly.shaheerah@epa.gov

From: "Jim Swaney" <Jim.Swaney@valleyair.org> To: Shaheerah Kelly/R9/USEPA/US@EPA Date: 12/02/2009 06:07 PM Subject: RE: Request for BACT/Permit information

Shaheerah, Here is the information you are looking for. Insituform - the equipment did not pass their source test (tested 7/1/02), and they replaced it with 3 smaller boilers that were permit exempt. Also, BACT Guideline 1.1.1 has been rescinded, as it has not been updated since the passage of District Rule 4320. Kaiser Foundation Hospital - all units are in operation and have passed their source tests. Copies of the Permits to Operate are attached. Note that BACT Guideline 1.1.5 has also been rescinded, as it has not been updated since the passage of District Rule 4320. Dynamis - the equipment was never installed. Instead they installed a 10.0 MMBtu/hr dryer under the same BACT guideline at 0.011 lb NOx/MMBtu, which has passed it's source tests. Copy of this permit is also attached. Please note that while this unit has the same permit number, that is due to transfer of ownership of part of the facility and then back - it was originally approved as C-4071-10-0. Central Valley Meat Co - the application was denied, and they have not re-applied. Let me know if you have any other questions. Jim Swaney, P.E. Permit Services Manager Valley Air District(559) 230-6000 (559) 230-6061 fax www . valleyair . org

From: Dave Warner Sent: Wednesday, December 02, 2009 10:02 A M To: Kelly.Shaheerah@epamail.epa.gov; Jim Swaney Subject: Re: Request for BACT / Permit information 

### Jim, p lease help Kelly. Thanks, Dave On Dec 2, 2009, at 8:54 AM, " Kelly . Shaheerah @ epamail . epa . gov " < Kelly . Shaheerah @ epamail . epa . gov > wrote: Hi, Dave. I'm seeking information on whether the units listed below are currently achieving the NOx limits that are associated with them. I obtained this information from the SJVUAPCD BACT guidelines for external combustion at http :// www . valleyair . org / busind / pto / bact / bactchidx . htm . Also, I would like to obtain the current ATCs for these units. Can you let me know how I may do so? Your assistance on this is greatly appreciated. Thanks. Insituform Technologies NOx= 20.0 ppmvd @ 3% O2 (0.024 lb/MMBtu/hr) Propane-fired boiler, 8.4 mmbtu/hr Low NOx burner system, ATC #: C-3524-3-0, Project #: C-1001106 Date of Determination: 11/22/2000 Kaiser Foundation Hospital, NOx= 15.0 ppmvd @ 3% O2 Boilers, 12.5 MMBtu/hr for 3 boilers & 7.0 MMBtu/hr for 2 boilers Ultra-low NOx burner system for the primary fuel ATC # N-7192-3-0 though '-7-0; Project N-1052075 Date of Determination: 12/15/2005 Dynamis-Sangar Power and FeedNOx= 0.15 lb NOx/MMBtu Auxiliary Burner Dryer for Hydromulch (TM) Manufacturing System, 14.7 mmbtu/hr Low NOx burner ATC #: C-445-10-0, Project #: C-990515 Date of Determination: 3/14/2000 Central Valley Meat Co NOx= natural gas fired with LPG as a backup fuel; 9.0 ppmvd @ 3% O2 (0.011 lb-NOx/MMBtu) Blood Meal Processing Ring Dryer Burner, 3.0 MMBtu/hr Ultra low NOx burner system ATC # C-2282-6-0 Date of Determination: 10/19/2006

************************************ Shaheerah Kelly Air Division (AIR-3) U S EPA Region 9 75 Hawthorne Street San Francisco, CA 94105 Phone: 415-947-4156 Fax: 415-947-3579 email: kelly . shaheerah @ epa . gov [ attachment " Microsoft Word - N - 7192 - 7 - 0 - PTO - FINAL . doc . pdf " deleted by Shaheerah Kelly / R 9 / USEPA / US ] [ attachment " Microsoft Word - N - 7192 - 3 - 1 - PTO - FINAL . doc . pdf " deleted by Shaheerah Kelly / R 9 / USEPA / US ] [ attachment " Microsoft Word - N - 7192 - 4 - 1 - PTO - FINAL . doc . pdf " deleted by Shaheerah Kelly / R 9 / USEPA / US ] [ attachment " Microsoft Word - N - 7192 - 5 - 1 - PTO - FINAL . doc . pdf " deleted by Shaheerah Kelly / R 9 / USEPA / US ] [ attachment " Microsoft Word - N - 7192 - 6 - 0 - PTO - FINAL . doc . pdf " deleted by Shaheerah Kelly / R 9 / USEPA / US ] [ attachment " Microsoft Word - C - 445 - 10 - 0 - PTO - FINAL . doc . pdf " deleted by Shaheerah Kelly / R 9 / USEPA / US ]