19020 33rd Avenue W, Suite 310, Lynnwood, WA 98036-4748 

Tel: +1 425.412.1800 Fax: +1 425.412.1840 

www.environcorp.com 

July 1, 2010 

Project No. 29-23586A 

Mr. Gerardo Rios 

U.S. Environmental Protection Agency, Region 9 

75 Hawthorne Street 

San Francisco, California 94105 

Subject: Response to Incompleteness Determination and Information Request 

Sierra Pacific Industries Biomass-Fired Cogeneration Project 

Anderson, California 

Dear Mr. Rios:

The U.S. Environmental Protection Agency, Region 9 (USEPA) office issued a letter on 

May 11, 2010 indicating that the Prevention of Significant Deterioration (PSD) permit 

application submitted on March 26, 2010 in support of the biomass-fired cogeneration 

project proposed by Sierra Pacific Industries, Inc. (SPI) for their Anderson facility is 

incomplete, and that additional information is needed to determine that the application is 

complete. This letter is intended to address the issues raised in the letter, and to provide 

the information that will render the application complete. Responses are organized in the 

same order as that of the enclosure to your letter, and the information requests are 

summarized as an italicized introduction to the response. 

Emissions Data:

Provide particulate matter (PM) emission rate data. 

PM not captured by the electrostatic precipitator (ESP) that will be used to control PM 

emissions from the cogeneration unit is expected to be comprised entirely of particulate 

matter less than 10 microns (PM10). Thus, the PM and PM10 emission rates are expected 

to be equivalent for the cogeneration unit. Similarly, because PM emissions from the 

cooling tower are expected to be exclusively condensed aerosols, it was assumed that all 

PM from the cooling tower will be PM2.5. Thus, PM, PM10, and PM2.5 emission rates for 

the cooling tower are expected to be equivalent. 

The expected PM/PM10 emission increase for the proposed project is 37.3 tpy, which is 

greater than the PM significant emission rate (SER) of 25 tpy. Therefore, the project is 

subject to PSD review for both PM and PM10 emissions. Because, as discussed above, 

PM and PM10 emissions are equivalent, the PM10 BACT analysis provided in the 

submitted PSD permit application is also the BACT analysis for PM emissions. 

Provide greenhouse gas (GHG) emission rate data. 

USEPA’s GHG Tailoring Rule was finalized on May 13, 2010, and becomes effective on 

January 2, 2011. If USEPA has not issued a PSD permit before the tailoring rule 
becomes effective, SPI understands that a GHG emissions inventory of the proposed 

emission units may be required on or after January 2, 2011. Following determination of 

the actual requirement date, SPI will provide a GHG emissions inventory prior to January 

2, 2011. However, because a GHG emissions inventory is not currently required, we 

believe that the permit application should be considered complete without a submitted 

GHG emission inventory. 

Best Available Control Technology (BACT) Analysis

Provide BACT analyses for PM and particulate matter less than 2.5 microns (PM2.5) 

The permit application assumes that all PM emissions from the cogeneration unit and the 

cooling tower are PM2.5; therefore, the PM, PM10, and PM2.5 emission rates are 

equivalent. The PM10 section of the BACT analysis provided with the PSD permit 

application was intended to cover all particulate matter emissions, including PM, PM10, 

and PM2.5. The technologies described in the provided BACT analysis apply to PM and 

PM2.5, as well as to PM10, and BACT proposal for PM10 (0.02 lb/MMBtu, achieved using 

an electrostatic precipitator) applies to both PM and PM2.5. 

Provide a GHG BACT analysis 

SPI understands that, because the project is already subject to PSD review, and will have 

the potential to emit more than 75,000 metric tons per year of GHG on a CO2e basis, a 

GHG BACT analysis will be required if a PSD permit has not been issued by January 2, 

2011. Currently, there is no guidance available for preparing a BACT analysis for GHG 

emissions. When it becomes clear that a permit will not be issued before January 2, 

2011, SPI will provide USEPA with the appropriate GHG BACT analysis prior to that 

date. However, because a GHG BACT analysis is not currently required, we believe that 

the lack of such an analysis should not prevent the permit application from being deemed 

complete. Furthermore, should it become necessary to develop a GHG BACT analysis, 

we are confident that the state-of-the-art boiler design proposed by SPI will reflect BACT 

for GHG emissions from a biomass-fired, stoker-type boiler. 

Air Quality Impact Analysis

Provide a full impact analysis to demonstrate compliance with the Federal 1-hour 

average ambient standard for nitrogen dioxide (NO2). 

The maximum model-predicted ambient 1-hour NO2 concentration calculated using the 

AERMOD dispersion model was 14.0 micrograms per meter cubed (μg/m3

). Because the 

maximum model-predicted value is likely in excess of a potential future promulgated 

SIL, USEPA has requested a cumulative analysis to assess compliance with the Federal 

1-hour NO2 ambient air quality standard. A PSD increment for 1-hour NO2 has been 

neither proposed nor promulgated. 

ENVIRON contacted John Waldrop of the Shasta County Air Quality Management 

District (SCAQMD), Joe Sunday of the Tehama County Air Pollution Control District 
(TCAPCD), and Brian Wilson of the North Coast Unified Air Quality Management 

District (which includes Trinity County) to request emission rates and release parameters 

for industrial sources of NOX within 50 kilometers (km) of SPI’s Anderson facility. 

SCAQMD and TCAPCD provided this information, which is summarized in the attached 

Table 1, and it was determined that none of the NOX-emitting industrial sources located 

in Trinity County were within 50 km of SPI’s Anderson facility. 

An air dispersion modeling simulation, using the methodology described in Section 4 of 

the PSD permit application submitted on March 26, 2010, was conducted to screen the 

industrial sources of NOX within 50 km of SPI’s Anderson facility. Because USEPA has 

not promulgated a significant impact level (SIL) for the Federal 1-hour NO2 standard, we 

proposed to use a value that is approximately 4 percent of the standard (i.e., 8 μg/m3

) as 

an informal SIL. Sources determined to have model-calculated facility-wide NOX

concentrations equal or exceed the informal SIL at a receptor where NOX emissions 

attributable to the proposed project also exceed the informal SIL were included in the 

cumulative analysis to assess compliance with the Federal 1-hour NO2 standard. The 

maximum facility-wide, model-predicted NO2 concentrations (making the conservative 

assumption that 100 percent of NOX is converted to NO2) for each source are presented in 

the attached Table 2. 

The cumulative impact air dispersion modeling simulation, again using the methodology 

described in Section 4 of the submitted PSD permit application, was developed to include 

the proposed cogeneration unit and industrial sources of NOX within 50 km that have a 

significant impact at receptors where the proposed project is also predicted to have a 

significant impact. It should be noted that the cumulative impact modeling analysis was 

conducted in a conservative manner in which all significant receptors were included 

together in the modeling simulations over the entire 5-year simulation period. A more 

resource-intensive, less-conservative analysis would have individual modeling 

simulations for each hour-and-receptor combination that the project was predicted to 

exceed the informal SIL. The less-conservative approach would ensure that only the 

meteorological conditions that caused the model to predict that the proposed project 

would exceed the informal SIL at that receptor were influencing competing industrial 

sources of NOX. 

The maximum model-predicted 1-hour NO2 concentration from the cumulative analysis 

was 59.9 μg/m3

, and the five-year average of the 98th percentile of the annual distribution 

of the daily maximum 1-hour average NO2 concentrations is 24.1 μg/m3. Combining the 

98th percentile concentration with the representative background concentration used in 

the submitted PSD permit application (80.9 μg/m3

) results in a total concentration of 

105 μg/m3, which is less than the ambient standard (188 μg/m3), indicating that the 

proposed project would neither cause nor contribute to an exceedance of the Federal 1-

hour average NO2 ambient standard. 

Provide an explanation of why USEPA should not require a revised Class I PSD 

increment analysis. 

The PSD permit application submitted in May 2007 for SPI’s previously proposed new 

biomass-fired cogeneration unit at the Anderson, California facility included analyses of 

criteria pollutant concentrations and air quality-related values (AQRVs) in nearby Class I 
areas using the FLAG modeling guidance and model versions that were current at that 

time. As indicated in the current PSD permit application, which includes an emission 

unit with approximately 25 percent more capacity than that previously proposed, the 

Federal land managers (FLMs) have indicated their lack of interest in reviewing a revised 

AQRV analysis based on the results of the “Q/D” analysis provided in the current permit 

application and the AQRV analysis provided in the previous permit application. 

We understand that EPA does not typically use the results of a Q/D analysis to guide the 

necessity to predict criteria pollutant concentrations in Class I areas for assessing 

compliance with the applicable PSD increments; however, we propose the relatively 

small increase in NOX, SO2, and PM10 emissions compared to the 2007 application 

submittal will not result in a significant change from previous Class I modeling results for 

the following reasons: 

• The maximum CALPUFF-predicted concentrations in the 2007 

application were less than 20 percent of EPA’s proposed Class I 

significant impact levels; and 

• SPI would need to increase emissions by 500 percent from the 2007 

application emission rates for CALPUFF-predicted concentrations to 

come near the applicable Class I significant impact levels. 

SPI is proposing to increase emissions by only 25 percent from the previous Class I 

modeling analysis, which will result in CALPUFF-predicted concentrations much less 

than the Class I SILs. 

Additional Impacts Analysis

Provide a site-specific discussion of nearby soils and vegetation. 

As indicated in Section 4.8.3 of the PSD permit application submitted on March 26, 

2010, based on the potential to only slightly increase the nitrogen and sulfur deposition to 

soil and vegetation, the proposed project in not expected to impact nearby agriculture or 

forestry operations. Additionally, there are no refuges or preserves in the area containing 

sensitive soils or vegetation that could potentially be impacted by air emissions from the 

proposed project. 

The biological review conducted by ENPLAN in 2007, and updated in 2010, identifies 

one federally listed plants species (slender Orcutt grass) in the area. This species has 

been designated as “threatened,” and critical habitat for the species exists in the area. 

According to the US Department of Interior’s Bureau of Land Management, the habitat 

for this species is vernal pools, grasslands, blue-oak and oak-juniper woodlands, and 

Jeffery pine forests, at elevations from 300 to 3,600 feet. Some of the area surrounding 

the facility could be considered forest land, rangeland, or wetlands where the species 

could be present, the majority of the surrounding area is developed for either residential, 

commercial, or agricultural use, where the presence of this species is highly unlikely. 

The primary potential impact on soils from air pollutants is through acidification from 

deposition of nitrogen- or sulfur-containing compounds. According to the US 
Department of Agriculture Natural Resources Conservation Service’s Web Soil Survey 

(http://websoilsurvey.nrcs.usda.gov/), soils in the area are various types of loam with pH 

ratings between 5.3 and 6.5. As indicated in Section 4.8.3 of the permit application, the 

potential nitrogen and sulfur deposition fluxes attributable to the proposed project are 

quite small (approximately 10 pounds per acre per year), and are unlikely to alter or 

influence the pH of soils in the area. 

General Requirements

Provide a PSD permit application submittal statement signed by an appropriate 

representative. 

Please find attached a letter, signed by the manager of SPI’s Anderson facility, certifying 

the PSD permit application submitted on March 26, 2010. 

Provide further location, design, and layout descriptions as well as a detailed 

construction schedule for the proposed project. 

Please find attached a site plan showing the locations of the structures associated with 

proposed project, and elevation drawings of a boiler similar to that proposed. Final 

location and design drawings are not yet available. 

Please also find attached a preliminary construction schedule. Because the permit 

issuance date is unknown at this point, the events and task durations occur relative to that 

date rather than on specific dates in the future. 

We believe that the information provided in this letter addresses the issues raised by 

USEPA, and should be considered to amend the submitted PSD permit application. As 

requested in your letter, a list of Federal, State, and local entities that may require EPA to 

provide notice is also attached. If you or your staff has any additional questions or need 

additional information, please do not hesitate to contact me at 425.412.1804. 

Sincerely yours, 

ENVIRON INTERNATIONAL, INC. 

Eric Albright 

Senior Manager 

Enclosures 

cc: Omer Shalev, USEPA, Region 9 

Shane Young, Sierra Pacific Industries 

Dave Brown, Sierra Pacific Industries 

Cedric Twight, Sierra Pacific Industries 
Tables
Table 1. NOX-Emitting Industrial Sources Within 50 km of SPI’s Anderson Facility 

Source Unit 

UTMx 

(m) 

UTMy 

(m) 

NOX

Emission

Rate 

(lb/hr) 

Stack 

Height

(ft) 

Stack 

Temp. 

(F) 

Flow 

Rate 

(acfm) 

Stack 

Dia. 

(in) 

Kiara Co Gen Project (proposed) 1 556901 4480286 19.2 77 374 81,542 84 

1 561184 4475287 50.7 170 260 154,808 90 

Wheelabrator Shasta Co-Gen 2 561184 4475287 50.7 170 260 154,808 90 

3 561184 4475287 50.7 170 260 154,808 90 

Wheelabrator Lassen Gas Turbine 1 561987 4476151 92.0 70 350 386,648 108"x118"

1 548845 4484294 10.0 45 400 304,310 102 

2 548845 4484294 12.1 45 400 304,310 102 

3 548845 4484294 12.1 45 400 304,310 102 

4a 548841 4484222 8.9 110 331 377,575 90 

4b 548841 4484222 8.9 110 331 377,575 90 

City of Redding Power Plant 

5 548731 4484141 4.2 100 575 447,038 112 

Ag Products Asphalt 1 549536 4484029 8.0 40 140 89,436 120 

North State Asphalt 1 548075 4483242 9.17 50 140 89,436 120 

JF Shea Smith Road Asphalt 1 554477 4484456 25.0 80 120 86,453 120 

Aramark Industries 1 552296 4492776 0.7 60 200 6,000 12 

Knauf Insulation 1 551587 4501005 16.5 199 100 411,077 264 

Sierra Pacific Industries, Shasta 1 552344 4502712 10.0 60 475 24,127 42 

Lake 2 552344 4502712 6.54 60 300 22,515 42 

Lehigh Cement 1 557225 4509534 248 175 285 180,316 84 

JF Shea Fawndale Asphalt 1 558579 4509638 11.0 50 140 89,436 96 

Pactiv Corporation 1 567278 4444393 0.315 52 1,000 32,876 48 

North Valley Crematory 1 564652 4447377 0.0945 15 1,300 2,513 24 

1 569475 4442292 1.19 8 1,300 400 6 

2 569475 4442292 1.91 8 1,300 500 6 

3 569475 4442292 1.57 8 1,300 400 6 

Lassen Forest Products 

4 569475 4442292 1.19 8 1,300 400 6 

PG & E Gerber Compressor Station 1 567119 4434882 7.34 58 943 80,000 108 

Cottonwood Creek Sand & Gravel 1 557822 4469048 0.694 8 1,300 600 6 

Chuck Wolf Sand And Gravel 1 555714 4460172 1.74 8 1,300 600 6 

Bens Truck & Equipment Inc 1 570761 4451508 1.05 8 1,300 4,600 12 

1 568731 4441574 0.18 5 120 896 48 

Sierra Pacific Industries, Red Bluff 

2 568731 4441574 0.18 5 120 896 48 
Source Unit 

UTMx 

(m) 

UTMy 

(m) 

NOX

Emission

Rate 

(lb/hr) 

Stack 

Height

(ft) 

Stack 

Temp. 

(F) 

Flow 

Rate 

(acfm) 

Stack 

Dia. 

(in) 

Louisiana Pacific Corp. 1 568663 4442113 0.033 4 300 3,800 96 

1 568012 4442557 2.8 78 185 8,016 24 

Siemens Water Technologies 

2 568012 4442557 0.151 20 185 1,500 24 

1 560013 4469320 2.64 25 150 50,000 72 

North State Asphalt Inc. 2 560013 4469320 6.02 15 120 1,413 12 

3 560013 4469320 5.78 15 60 634 8 

Tehama Asphalt Crushing 1 563975 4450548 7.41 8 1,300 3,000 12 

1 564068 4450561 6.69 25 60 30,000 72 

Tehama Asphalt Processing 2 564068 4450561 6.69 25 120 50,000 72 

3 564068 4450561 8.19 25 1,300 120 4 

California Power Holdings, LLC 1 567167 4444519 9.79 40 1,300 10,000 24 

Tehama County Landfill 1 560206 4449619 0.376 28 1,600 10,500 60 

1 568311 4442156 0.6 30 150 2,000 12 

2 568311 4442156 0.0342 30 150 2,000 12 

3 568311 4442156 0.05 30 150 7,500 24 

4 568311 4442156 0.15 30 150 40,000 48 

5 568311 4442156 0.15 30 150 10,000 24 

SPI Powder Coatings 

6 568311 4442156 0.15 15 150 1,000 12 
Table 2. Maximum Predicted NO2 Concentrations for Competing Sources 

Source 

Maximum NO2 Concentration1

(μg/m3) 

Include in Cumulative 

Analysis? 

Kiara Co Gen Project (proposed) 25.41 Yes 

Wheelabrator Shasta Co-Gen 35.71 Yes 

Wheelabrator Lassen Gas Turbine 17.30 Yes 

City of Redding Power Plant 10.30 Yes 

Ag Products Asphalt 4.52 No 

North State Asphalt 3.64 No 

JF Shea Smith Road Asphalt 18.34 Yes 

Aramark Industries 0.40 No 

Knauf Insulation 1.94 No 

Sierra Pacific Industries, Shasta Lake 3.09 No 

Lehigh Cement 9.76 Yes 

JF Shea Fawndale Asphalt 1.80 No 

Pactiv Corporation 0.08 No 

North Valley Crematory 0.06 No 

Lassen Forest Products 3.35 No 

PG & E Gerber Compressor Sta 0.85 No 

Cottonwood Creek Sand & Gravel 2.47 No 

Chuck Wolf Sand And Gravel 2.56 No 

Bens Truck & Equipment Inc 0.72 No 

Sierra Pacific Industries, Red Bluff 0.24 No 

Louisiana Pacific Corp. 0.02 No 

Siemens Water Technologies 1.03 No 

North State Asphalt Inc. 59.87 Yes 

Tehama Asphalt Crushing 5.12 No 

Tehama Asphalt Processing 16.72 Yes 

California Power Holdings Llc 3.50 No 

Tehama County Landfill 0.14 No 

SPI Powder Coatings 0.59 No 

1 100 percent of NOX was assumed to be converted to NO2. 
Attachments
 Sierra Pacific 

Industries 

June 22, 2010 

Gerardo C. Rios, Chief, Permits Office 

United States Environmental Protection Agency 

Region IX 

75 Hawthorne Street 

San Francisco, CA 94105 

Mr. Rios, 

This letter is intended to hereby certify that the information contained in the 

PSD permit application to construct a biomass-fired cogeneration unit 

submitted to USEPA on March 26, 2010 is, to the best of my knowledge, 

accurate and complete. 

Thank you for your efforts at processing this permit in a timely manner. 

Sincerely, 

Shane Young 

Manager 

 Anderson Sawmill Division z P.O. Box 10939 z Anderson, California 96007 

Phone (530) 378-8350 z FAX (530) 378-8360



Preliminary Cogeneration Unit Construction Schedule Week 1 Week 2 Week 3 Week 4 Week 5 Week 6 Week 7 Week 8 Week 9 Week 10 Week 11 Week 12 Week 13

Week 14Week 15Week 16Week 17Week 18Week 19Week 20Week 21Week 22Week 23Week 24Week 25Week 26

Wet Ash Conveyors Under Furnace X

Ash Screw Conveyors from Multiclone X

Grate Support Steel (Beams & Posts) X

UG Hoppers (set) X

Clinker Chute X

Chutes from Hoppers to WAC Under Furnace X

UG Air Ducting X

UG Dampers X

GRATE Frames, Set & Assemble X

Primary Furnace Lower Combustion Chamber Assemble X

Primary Furnace Lower Combustion Chamber Weld X X

Sight Glass Assemblies (Roof & End Wall) X

FD Combustion Air Fan X

Overfire Wind Boxes and Ducting X X

Furance Access Platforms X X

Fuel Ram Feeder & Hopper Assy X

Fuel Infeed Screw Conveyor X

Fuel Feeder Dribble Chutes X

ID Fan X

Multiple Cone Collector X

Air Heater X

Economizer X

ID Breeching X

Boiler Lower Support Steel X

Boiler Drum Setting X X

Boiler Tubes/Drums Installation XXXXXXXXXXXX

Boiler Housing Casing Installation XXXXXXXXXX

Boiler Upper Support Steel X

Boiler Access Platforms XXXX

Boiler Trim XXXXX

Miscellaneous Boiler XXXXX

Boiler Convection Outlet Duct X

Misc Platforms XXX

Sootblowers X X

Deaerator X

Feedwater Pumps X

Feedwater Piping XXXXX

Refractory Anchors X X

Refractory Furnace XXXXXXX

Refractory Cure: Install Bulkheads pre Gas Firing & Cure X

Refractory Cure: Gas Heaters X

Refractory Cure: Remove required Bulkheads & Insulation X

Water Piping Wet Ash Conveyor X

Water Piping Fuel Feeder Water Jacket X

Water Piping Deluge System Furnace Fuel System X

Hydraulic Power Unit WFB X

Hydraulic Piping WFB X X

Hydraulic Power Unit Furnace X

Hydraulic Pipling Furnace X X

Hydraulic Piping Flush X

Paint X X

Miscellaneous XXXXXXXXXXXX
Federal, State, and Local Entity Contact Information 

State & Local air pollution control agency: 

Shasta County Air Quality Management District 

1855 Placer Street, Suite101 

Redding, California 96001 

Phone: (530) 225-5674 

Fax: (530) 225-5237 

Ross Bell, Manager 

Chief executives of the city & county 

City of Anderson 

1887 Howard St. 

Anderson, CA 96007 

Phone: (530) 378-6626 

Dana Shigley, City Manager 

Shasta County 

1450 Court St., Suite 308B 

Redding, CA 96001-1680 

Phone: (530) 225-5557 

Fax: (530) 225-5189 

David Kehoe, Chairman, Board of Supervisors 

Regional land use planning agency 

Shasta County Department of Resource Management 

Planning Division 

1855 Placer Street, Suite 103 

Redding, California 96001 

Phone: (530) 225-5532 

Fax: (530) 245-6468 

Richard Simon, Planning Division Manager 

Federal land managers 

US Forest Service 

Pacific Southwest Region 

1323 Club Drive 

Vallejo, CA 94592 

Phone: (707) 562-8737 

Fax: (707) 562-9130 

Randy Moore, Regional Forester 
National Park Service 

Air Resources Division 

P.O. Box 25287 

Denver, CO 80225-0287 

Phone: (303) 969-2818 

Fax: (303) 969-2822 

Chris Shaver, Division Chief 

Indian governing body 

Redding Rancheria 

2000 Redding Rancheria Road 

Redding, CA 96001 

Phone: (530) 225-8979 

Fax: (530) 241-1879