Director, Air Division (Attn: Air-3)

United States Environmental Protection Agency, Region IX

75 Hawthorne Street

San Francisco, CA 94105-3901

Subject: Temporary Biomass Testing Program

Request for 180-Day Extension

Rio Bravo Jasmin (SJ85-07)

Dear Ms. Jordan:

Rio Bravo Jasmin wishes to express its gratitude for EPA’s amendment to its PSD

permit to allow a six (6) month (180-day) temporary biomass fuel testing program. This

amendment was issued on 12/17/2010 and the testing program commenced as required

in Section IX.J. Special Conditions — Temporary Alternate Fuel Testing Operations of the

PSD Permit within three months of amended permit receipt on March 8, 2011.

The purpose of the biomass fuel testing program was to evaluate the combustion of

various biomass in the fluidized bed boiler with respect to emissions and operations.

During this testing period Rio Bravo Jasmin has conducted biomass fuel blending with

coal, utilizing its existing feed systems. To date, up to 15% by weight of biomass fuel

has been combusted during the testing.

The existing feed systems were designed primarily for coal and petroleum coke

receiving and handling. During the time since commencement of the test burn, the

Continuous Emissions Monitoring System (CEMS) has not detected any changes in

opacity, CO, NOx or SO2emission levels compared to burning 100% coal. While these

results were not unexpected, it was still important that they be confirmed throughout the

testing period. The remaining criteria pollutant emissions, PM and VOC, will be

measured while burning biomass during the annual source test which is scheduled to be

conducted during the week of August 22, 2011. EPA will be provided with these test

results as soon as they are made available to Rio Bravo Jasmin.

Rio Bravo Jasmin has learned a great deal from the biomass fuel testing to date

including:

• The existing fuel system can accommodate biomass fuel without interruption.

This is especially true when the biomass material is small (chipped to 1/2 inch

minus) andlor hard (such as pistachio or almond shells.
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prohibitive. Contracting for a longer term continuous supply alleviates this cost

problem.

While EPA is still in the process of reviewing Rio Bravo Jasmin’s PSD modification

application to permanently allow biomass combustion, Rio Bravo Jasmin wishes to

continue the temporary biomass testing program on an uninterrupted basis. The current

180-day testing program is set to expire on September 4, 2011.

Rio Bravo Jasmin herein formally requests a I 80-day extension to the biomass fuel

testing program, to commence immediately after expiration of the current test program

(beginning on September 5, 2011 and ending on March 3, 2012). This will allow the

plant to continue evaluating different types and increasing amounts of biomass fuel, and

the resulting emissions associated with both. Furthermore having learned that biomass

fuel can in fact be combusted in the fluidized bed boiler, upon receipt of the requested

180-day extension, Rio Bravo Jasmin will sign a long-term contract to procure a large

amount of biomass fuel.

At the end of the first 180-day biomass fuel testing period, a Summary of the Results

Report which will include the analytical data of the testing will be submitted to the EPA.

Rio Bravo Jasmin appreciates your expeditious review and approval of this request.

Once again, thank you for your continued support and guidance.

Sincerely,

Maynard Adams

Plant Manager, Rio Bravo Jasmin

Cc: Omer Shalev — EPA

Kris Rickards - SJVAPCD Bakersfield