## EPA / SPI Anderson Meeting EPA Region 9, 75 Hawthorne Street, San Francisco 94105

Conference Room 1714

2:30 PM

– 3:30 PM

August 6, 2013

AGENDA

1. Introductions

2. Discuss voluntary inclusion of GHGs in the PSD permit

3. Power Contract

4. Re

- notice of Permit

5. Timelines

6. Next Steps

## DRAFT

1 Additional Information EPA Will Need from Sierra Pacific Industries

- Anderson Division to
Proceed with a voluntary GHG PSD Permit

E MISSION E STIMATES

1. In addition to the information provided in Table 2

- 1 in the Sierra Pacific Industries’s (SPI) June

2011 Best Available Control Technology (BACT) analysis for greenhouse gas (GHG)

emissions :

a. GHG emission estimates and calculations (and assumptions used in these calculations) for each of the new and modified emission units (e.g., biomass boiler, emergency eng ine

, circuit breakers,etc ) for (1) maximum worst case annual emission estimates of GHG pollutants (i.e., CO 2 e, CO 2 , N 2 O, CH 4 , SF 6 ,et c) expected from the emission units in tons per year (tpy); Revised and expanded Table 2

- 1

b. Emission estimates of GHG pollutants expected during startup periods , shutdown periods,

and normal operation expected from the emission units in tpy ; and Added explanatory text

c. Emission e stimates of GHG pollutants for existing equipment at the facility in tpy

. Added

Table 2

- 2

GHG BACT A NALYSIS

1. A n assessment of the use of stoker and fluidized bed boiler in the design of the cogeneration unit for minimizing GHG emissions. For your information, EPA’s combined heat and power (CHP) website has information on biomass conversion techno logies, and includes information on stoker and fluidized bed boilers that may be useful. 1 Added explanatory text

2. A GHG assessment of a ny new circuit breakers that potentially emit SF 6 in the GHG BACT analysis. Added explanatory text; e xisting circuit breakers will remain and be used by proposed cogeneration unit

, therefore, no evaluation is needed

3. A GHG assessment of t he proposed natural gas

- fired 256 horsepower emergency engine. Added

section 8

4. An assessment that considers GHG BACT determinations made for other biomass boiler units.

We are aware of the following projects in Table 1 that have been evaluated and issued final permits with GHG emission and operational limits. Obtained and reviewed permit materials for

all faci lities in table below, added text briefly summarizing findings

1 See the section titled “ Biomass CHP Catalog of Technologies ” at http://www.epa.gov/chp/technologies.html

.

## DRAFT

2 Table 1: Recent Permit Decisions containing GHG Determinations Facility State Permit Issuance Date

Montville Power LLC CT 4/6/2010 Beaver Wood Energy Fair Haven LLC VT 2/10/2012

North Springfield Sustainable Energy Project VT 4/19/2013 WE Energies (Rothschild facility) WI 3/28/2011 Abengoa Bioenergy Biomass of Kansas LLC KS 9/16/2011 (Effective date)

5. An evaluation of the technical feasibility of using carbon adsorption in Section 4. Section 3.2 identifies carbon adsorption as a potential control technology for minimizing methan e emissions. Added clarifying text

6. An evaluation of the technical basis th at explains why thermal oxidation is not technical feasible

for the boiler. S ection 4.2, under Thermal Destruction, eliminates thermal oxidation as technically infeasible for control of methane from the boiler because “it is not clear that use of such sys tem would result in a net reduction in methane.” Added clarifying text

7. An evaluation of the technical basis that explains why non

- selective catalytic reduction (NSCR) is not feasible for the boiler. Section 4.3, u nder Non

- Selective Catalytic Reduction Systems, eliminates NSCR as technically infeasible for control of nitrous oxide from the boiler because “significant differences exist between the exhaust from adipic and nitric acid operations and that

of a biomass

- f ired boiler, it is not clear that the technology could be transferred effectively.” It would be helpful if SPI would explain these d ifferences

. Removed text to jibe with

determination that NSCR w as not technically feasible, also added clarifying text

8. E mission calculations (and assumptions used) for the estimates of “percent reduction in emitted

GHGs on a CO 2 e basis” in section 5 of the analysis. This is currently not provided in the analysis. Added references and reduction calculations

9. C ost calculations ( and assumptions used) for the estimates of “percent reduction in emitted

GHGs on a CO 2 e basis” in section 6 of the analysis. This is currently not provided in the analysis. Biomass F uel Use

– no cost calculation needed; CCS

– referenced cost calculation from NETL document; Catalytic Destruction

– calculated cost threshold from calculated potential reduction and value of CO 2 e reduction; Removal of SNCR System

– unacceptable from environmental standpoint, so no cost calculation needed; Proper Combustion/Energy Efficiency

– no cost calculation needed

10. A proposed annual CO 2 e emission limit in tpy for the proposed project. Proposed GHG BACT limit (annual tpy) provided

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