1 Kelly, Shaheerah

From: Rose Flame [mysecretfires@gmail.com]
Sent: Friday, January 10, 2014 2:54 PM

To: R9AirPermits
Cc: Kelly, Shaheerah; Jordan, Deborah; hswrit er@frontiernet.net; Marily Woodhouse Subject: Official Public Comments - Permit No. SAC 12-01/Modification of Permit #94-VP-18b

Deborah Jordan, Regi on 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 Respon se 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 “Pos t Final Decision Material Not Incl uded 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 BA CT be included.

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

1.6.4 Controls Currently, the four most common cont rol devices used to reduce PM emi ssions from wood-fired boilers are mechanical collectors, wet scrubbers, electrostatic precip itators (ESPs), and fabric filters. Theuse of multitube cyclone (or multiclone) mechanical co llectors provides particulate contro l for many wood-fired boilers. Often, two multiclones are used in series, allowing the first colle ctor to remove thebulk of the dust and the second to remove smaller particles. The efficiency of this arra ngement varies from 25 to 65 percent. The most widely

used wet scrubbers for wood-fire d boilers are venturi scrubbers.

With gas-side pressure drops exceeding 15 inches of wate r, particulate collection effi ciencies of 85 percent or greater have been reported for venturi scrubbers operating on wood-fired boilers.

ESPs are employed when collection e fficiencies above 90 percent are re quired. When applied towood-fired boilers, ESPs are often used downstr eam of mechanical collector preclea ners which remove larger-sized particles. Collection efficiencies of 90 to 99 percent for PM have been observed for ESPs operating on woodfired boilers.2 A variation of the ESP is the electrostatic grav el 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 ch arged grid within the bed. Particulate collection efficiencies are typically over 80 percent.

Fabric filters (i. e., baghouses) have had limited applications to wood-fire d boilers. The principal drawback to fabric filtration, as perceived by poten tial users, is a fire danger aris ing 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 gene rally preferred for boilers firing salt -laden wood. This fuel produces fine particulates with a high salt content having a quenching effect, thereby reduci ng fire hazards. Particle collection efficiencies are typically 80% or higher.

For stoker and FBC boilers, overfire ai r 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 lo west levels, the application of selective noncatalytic reduction (SN CR) to residue wood-fired boilers ha s beenaccomplished; the application of selective catalytic reduction (S CR) is being contemplated. Both sy stems 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 reduc tion 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

530-223-0197Attached 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).