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Kelly, Shaheerah

From: Rose Flame [mysecretfires@gmail.com]

Sent: Friday, January 10, 2014 2:54 PM

To: R9AirPermits

Cc: Kelly, Shaheerah; Jordan, Deborah; hswriter@frontiernet.net; Marily Woodhouse

Subject: Official Public Comments - Permit No. SAC 12-01/Modification of Permit #94-VP-18b

Deborah Jordan, Region 9, EPA Air Director

Shaheerah Kelly, Project Administrator/Engineer 

EPA Region 9

75 Hawthorne St.

San Francisco, CA 94105-3901

R9airpermits@epa.gov

RE: Permit No. SAC 12-01/Modification of Permit #94-VP-18b

Dear Shaheerah Kelly, 

Please include the following email in the Response to Comments Document you are preparing: 

http://yosemite.epa.gov/oa/eab_web_docket.nsf/Filings%20By%20Appeal%20Number/2303451E3FD9594B85

257B5500684B63/$File/EAB%20Celeste%20Omer%20email...30.pdf

I noticed that the links have been changed. 

Could you please include the f “Post Final Decision Material Not Included in the Administrative Record” and 

my original questions in, as well?

I would also appreciate any other RTC documents from this time period that are related to BACT be included. 

Regarding BACT, I have some ideas I would like your office to consider: 

1.6.4 Controls

Currently, the four most common control devices used to reduce PM emissions from wood-fired boilers are 

mechanical collectors, wet scrubbers, electrostatic precipitators (ESPs), and fabric filters. Theuse of multitube 

cyclone (or multiclone) mechanical collectors provides particulate control for many wood-fired boilers. Often, 

two multiclones are used in series, allowing the first collector to remove thebulk of the dust and the second to 

remove smaller particles. The efficiency of this arrangement varies from 25 to 65 percent. The most widely 

used wet scrubbers for wood-fired boilers are venturi scrubbers.

With gas-side pressure drops exceeding 15 inches of water, particulate collection efficiencies of 85 percent or 

greater have been reported for venturi scrubbers operating on wood-fired boilers.

ESPs are employed when collection efficiencies above 90 percent are required. When applied towood-fired 

boilers, ESPs are often used downstream of mechanical collector precleaners which remove larger-sized 

particles. Collection efficiencies of 90 to 99 percent for PM have been observed for ESPs operating on woodfired boilers.
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A variation of the ESP is the electrostatic gravel bed filter. In this device, PM in flue gases is removed by 

impaction with gravel media inside a packed bed; collection is augmented by an electrically charged grid within 

the bed. Particulate collection efficiencies are typically over 80 percent.

Fabric filters (i. e., baghouses) have had limited applications to wood-fired boilers. The principal drawback to 

fabric filtration, as perceived by potential users, is a fire danger arising from the collectionof combustible 

carbonaceous fly ash. Steps can be taken to reduce this hazard, including the installationof a mechanical 

collector upstream of the fabric filter to remove large burning particles of fly ash (i. e.,"sparklers"). Despite 

complications, fabric filters are generally preferred for boilers firing salt-laden wood. This fuel produces fine 

particulates with a high salt content having a quenching effect, thereby reducing fire hazards. Particle collection 

efficiencies are typically 80% or higher.

For stoker and FBC boilers, overfire air ports may be used to lower NOx emissions by staging the combustion 

process. In those areas of the U. S. where NOxemissions must be reduced to their lowest levels, the application 

of selective noncatalytic reduction (SNCR) to residue wood-fired boilers has beenaccomplished; the application 

of selective catalytic reduction (SCR) is being contemplated. Both systems are post combustion NOx reduction 

techniques in which ammonia (or urea) is injected into the flue gas to selectively reduce NOxto nitrogen and 

water. In one application of SNCR to an industrial wood-fired boiler, NOx reduction efficiencies varied 

between 35 and 75 percent as the ammonia-to-NOx ratio increased from 0.4 to 3.2.

Please consider BACT more carefully in your analysis of this project.

Please include all public comments. 

Thank you, 

Celeste Draisner, citizen activist 

Citizens For Clean Air 

530-223-0197 
Attached Copy of March 6, 2013 Email by EAB Petitioner Celeste Draisner

from: Shalev, Omer <Shalev.Omer@epa.gov> 

to: Rose Flame <mysecretfires@gmail.com>

cc: "Rios, Gerardo" <Rios.Gerardo@epa.gov>

date: Wed, Mar 6, 2013 at 5:25 PM

subject: USEPA Region 9- Response to Comments Submitted by Ms. Celeste Draisner for PSD Permit

SAC 12-01

: Important mainly because of the words in the message

Dear Ms. Draisner:

I am responding to your email sent to Omer Shalev and received on Friday, February 22, 2013,

inquiring about comments you submitted regarding the U.S. Environmental Protection Agency’s

Prevention of Significant Deterioration (PSD) permit (PSD permit # SAC 12-01). The PSD permit

applies to the approval to construct and operate a new stoker boiler capable of generating 31 MW of

gross electrical output from the combustion of biomass and natural gas, and related auxiliary equipment

(Project), at Sierra Pacific Industries’ Anderson, California facility. Thank you for your interest in this

PSD permit action and for your efforts in preparing a submittal.

We could not find your submittal among the comments received at either of the two locations specified

in the public notice for our proposed permit. Our September 12, 2012 public notice stated that all

written comments and requests on EPA’s proposed action “must be sent or delivered in writing to Omer

Shalev” either by email to R9airpermits@epa.gov or by U.S. mail at the EPA’s offices at 75 Hawthorne

Street in San Francisco. The AAQIR/Fact Sheet that you reference in your comments also states on

page 46 that all written comments and requests on the EPA’s proposed action “must be sent or delivered

in writing to Omer Shalev” either by email to R9airpermits@epa.gov or by U.S. mail at the EPA’s

offices at 75 Hawthorne Street in San Francisco.

When EPA staff could not find your submittal, they checked individual email accounts and found your

comments in Omer Shalev’s individual email account. This account was not the correct address for

submitting email comments regarding the EPA’s PSD permit for the Project; therefore, your comments

were not identified or recognized as formal comments and were not included in the Responses to Public

Comments document for the Project. 

Nevertheless, the EPA would like to acknowledge your interest in the PSD permit for SPI-Anderson.

We are therefore providing the following responses to your questions in the attachment to this email.

To a large extent, we believe that your comments were addressed by the EPA’s Ambient Air Quality

Impacts Report (AAQIR) or were similar to comments the EPA received from other commenters. We

hope that you will find these responses helpful in addressing your concerns regarding the Project. We

will be including your comments and our responses in the online docket for this action under the

heading of “Post Final Decision Material Not Included in the Administrative Record.” This material is

accessible through a link on our website, www.epa.gov/region09/air/permit/r9-permitsissued.html#psd, or at www.regulations.gov (Docket ID # EPA-R09-OAR-2012-0634).