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PD.Box81077Bakersfield,CA93380 Operating Services661792-3048661792-2812FaxDeliveryAddress:11258PortervilleHwy.Bakersfield,Ca93308 July 22, 2011 Ms. Deborah Jordan 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

asix (6) month (180-day) temporary biomass fuel testing program.This amendment wasissued on12/17/2010 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 onMarch
8, 2011. The purpose
of the biomass fuel testing program wasto 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, upto 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 orSO 2 emission levels compared

to burning 100% coal. While these results were not unexpected,

it wasstill 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 assoonas 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 canaccommodate 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
oralmond shells.Ms. Jordan EPA, Region IX July 22, 2011

2 •Some back-end slagging

in the superheater section of the boiler occurs, likely due to the potassium content of the biomass. •A slight decrease

in the amount of ash is generated from blending biomass fuel with coal. •When purchasing only small amounts
of biomass fuel, prices areclose to 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 programonan uninterrupted basis. The current 180-day testing program

is set to expire on September

4, 2011. Rio Bravo Jasmin herein formally requests

aI 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 onMarch
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 canin 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 youfor yourcontinued support and guidance. Sincerely, Maynard Adams Plant Manager, Rio Bravo Jasmin Cc: Omer Shalev—EPA Kris Rickards-SJVAPCD Bakersfield