1 Attachment 

Cleve:

I’m working on a response to your request for a Class II Area plume blight analysis using VISCREEN. 

The soils and vegetation information provided in the March 2010 PSD permit application was based on the 

deposition modeling developed in support of the 2007 permit application. The additional soils and vegetation 

discussion provided in the July 1, 2010 letter (“Response to Incompleteness Determination and Information 

Request”) was based on the same modeling results and a biological review conducted in 2007 and updated in 

2010.

Thanks, and please let me know if you need any additional information.

Eric

Eric Albright, PE | Senior Manager

RE: SPI-Anderson Cogeneration Project-Class II Additional Impacts Analysis 

Eric Albright 

to: 

Cleveland Holladay 

07/16/2012 05:18 PM 

Cc: 

Dave Brown, George Emmerson, Omer Shalev, Shane Young, Shirley Rivera 

Hide Details 

From: Eric Albright <ealbright@environcorp.com> Sort List... 

To: Cleveland Holladay/R9/USEPA/US@EPA 

Cc: Dave Brown <DBrown@spi-ind.com>, George Emmerson <GEMMERSON@spiind.com>, Omer Shalev/R9/USEPA/US@EPA, Shane Young <SYoung@spi-ind.com>, 

Shirley Rivera/R9/USEPA/US@EPA 

image002.jpg

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ENVIRON International Corporation

19020 33rd Avenue W, Suite 310 | Lynnwood, WA 98036

T: +1 425 412 1804 | F: +1 425 412 1840 | M: +1 206 909 0591

ealbright@environcorp.com

From: Cleveland Holladay [mailto:Holladay.Cleveland@epamail.epa.gov] 

Sent: Friday, July 06, 2012 2:09 PM 

To: Eric Albright; Kyle Heitkamp 

Cc: Dave Brown; George Emmerson; Omer Shalev; Shane Young; Shirley Rivera 

Subject: Re: SPI-Anderson Cogeneration Project-Class II Additional Impacts Analysis

 

Eric, Kyle,

As part of preparing the Fact Sheet and Ambient Air Quality Impact Report for SPI-Anderson 

(SPIA), EPA is requesting the following information, which is lacking, pertaining to the Class II 

additional impacts analysis, especially to visibility impairment. The Class II visibility analysis is 

independent of the Class I visibility Air Quality Related Values (AQRV) analysis. The PSD 

application (March 2010) is not responsive to the intent of 40 CFR Part 52.21(o).

Therefore, identify Class II federal and state areas (e.g., potentially sensitive 

parks, forests, monuments, and recreational areas) within 50 km of SPIA. Discuss 

the potential visual impacts of the SPIA project on these areas. Consider 

information presented in the EPA 1992 workbook -

“Workbook for Plume Visual Impact Screening and Analysis (Revised)”, EPA, EPA–

454/R–92–023, 

1992.

Then based upon your evaluation, conduct a VISCREEN Level 1 analysis for any identified areas, 

and if necessary, a Level 2 analysis if the Level 1 impacts are exceeded. If there is a valid 

reason not to conduct an analysis, SPIA/Environ should provide that narrative.

In addition, for the soils and vegetation analysis, provide the time frame the soils 

information was based (e.g., 2010, 2006, other recent review?) on.

If you have questions, call me at the number below or Shirley Rivera at 415-972-3966.

Thanks,

Cleve Holladay

415-947-4140

U.S. EPA, Region 9, AIR-07

75 Hawthorne Street

San Francisco, CA 94105

-----Eric Albright <ealbright@environcorp.com> wrote: -----

To: Omer Shalev/R9/USEPA/US@EPA, Cleveland Holladay/R9/USEPA/US@EPA 

From: Eric Albright <ealbright@environcorp.com> 

Date: 06/29/2012 02:55PM 

Cc: Dave Brown <DBrown@spi-ind.com>, George Emmerson 

<GEMMERSON@spi-ind.com>, Shane Young <SYoung@spi-ind.com> 

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Subject: SPI-Anderson Cogeneration Project

Omer & Cleveland: 

 

As I mentioned previously, I’m going to be out of the office from July 2 until July 16. In my absence, 

Kyle Heitkamp (425.412.1803) may be able to help you if you have any questions or need additional 

information while I am away. I will check e-mail as often as possible, but I don’t know in advance 

what my connectivity will be; I will almost certainly not be receiving voice mails. 

 

If possible, it would be helpful if you could send brief e-mails notifying SPI when internal milestones 

have been reached (e.g., modeling review is complete, draft permit has been finalized for internal 

review, internal review is complete, etc.). Assuming it is possible for you to send such 

communications, please copy everyone on the distribution list for this message. This will help SPI to 

forecast future activities related to this project, which is, as you know, “shovel ready,” and critical to 

the ongoing viability of the Anderson facility. 

 

Thanks, and please do not hesitate to contact me or Kyle if we can provide anything to help get the 

draft permit out for public comment. 

 

Eric 

 

Eric Albright, PE | Senior Manager

ENVIRON International Corporation

19020 33rd Avenue W, Suite 310 | Lynnwood, WA 98036

T: +1 425 412 1804 | F: +1 425 412 1840 | M: +1 206 909 0591

ealbright@environcorp.com

 

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