Comment letter on SPI Anderson proposed permit NO . SAC 12-01

Robyn DiFalco to: R9AirPermits 01/10/2014 12:31 PM

Cc: "Stemen, Mark", "Julia Murphy"

From: "Robyn DiFalco" <robynd@becprotects.org>

To: R9AirPermits@EPA,

Cc: "Stemen, Mark" <MStemen@csuchico.edu>, "Julia Murphy" < j uliam@becnet.org>January 10, 2014Shaheerah Kelly

U.S. Environmental Protection Agency, Region 9 (AIR

‐ 3)

75 Hawthorne Street

San Francisco, CA 94105

‐ 3901

RE: Public Comment on proposed permit NO. SAC 12

‐ 01

To ensure the health of residents in Northern California, the Butte

Environmental Council (BEC) requests that language be included in

proposed permit NO. SAC 12

‐ 01 to limit feedstock at the Sierra

‐ Pacific

Industries Anderson Facility incinerator to clean cellulosic biomass.

SPI may intend to burn only the timber waste of its own industry.

However, the financial incentive to accept urban wood waste from

other counties is compelling. This is particularly true for the Bay Area,

which has a “zero

‐ waste” policy within its own borders that does not

extend to poorer Northern California counties. BEC has addressed the

result of this practice at Pacific Oroville Power Industries Covanta

facility in Oroville, CA.

High levels of dioxin were found in samples taken from waste ash piles

originating from the POPI facility. These elevated levels of dioxin were

found in the waste ash and in soil samples taken within a two

‐ mile

radius of the POPI facility even when fuel stocks were found to have as

low as 3% contamination of non

‐ wood materials.

Biomass facilities are only required to test for criteria pollutants.

Although Butte County Air Quality Management District (BCAQMD) did

monitor POPI’s burn piles, the percentage of “other materials” in the

piles was not found to exceed allowable levels. The facility voluntarily

conducted a stack test for toxics in 2009 that also showed toxic

emissions within allowable levels. Nevertheless, several ash tests, and

even soil tests proximal to the facility, showed elevated levels of dioxins

that exceeded state standards, endangering human and environmental

health.

Dioxin from incinerators is carried in the smoke plume to depose onsoil, where it can remain for decades. Dioxin from soil bioaccumulates

in the fat of food and game animals. Residents in the Anderson area

are raising food animals and are therefore at higher risk of exposure to

dioxin pollution. The Anderson area is similar to the area surrounding

the Oroville POPI plant, which showed in a recent survey (Gary Bess

Consultants, 2013) that 12% of survey respondents raised animals for

consumption.

The practice of paying orchardists and farmers to take waste ash for use

as an agricultural soil amendment necessitates that burn stock is

restricted to clean cellulosic biomass. Our experience trying to hold

Covanta accountable for remediating their toxic legacy from burning

other materials has taught us: prevention is the most cost

‐ effective way

to address contamination. We respectfully submit these comments, and

are happy to provide any additional information or input that may be

helpful.

Robyn DiFalco, Executive Director

Butte Environmental Council



## Robyn DiFalco

Executive Director, Butte Environmental Council

116 W. 2nd St, Ste 3, Chico, CA 95928

530-891-6424

www

. becnet

. org

A n organization succeeds not because it is large or long establishe d

, but because there are people who live it

, sleep it

, dream it

, and build

f

uture plans for i t

.



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This Email message contained an attachment named

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which may be a computer program. This attached

computer program could

contain a computer virus which could cause harm to

EPA's computers,

network, and data. The attachment has been deleted.

This was done to limit the distribution of computer

viruses introduced

into the EPA network. EPA is deleting all computer

program attachments

sent from the Internet into the agency via Email.

If the message sender is known and the attachment was

legitimate, you

should contact the sender and request that they

rename the file name

extension and resend the Email with the renamed

attachment. Afterreceiving the revised Email, c ontaining the rename d

attachment, you can

rename the file extension to its correct name.

For further information, please contact the EPA Call

Center at

(866) 411-4EPA (4372). The TDD number is (866)

489-4900.

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SPI Anderson Comment Letter by BEC 1-9-2014.pd f Anderson Comment 1-9-2014.pdJanuary 9, 2014

Shaheerah Kelly

U.S. Environmental Protection Agency, Region 9 (AIR

- 3)

75 Hawthorne Street

San Francisco, CA 94105

- 3901

RE: Public Comment on proposed permit NO. SAC 12

- 01

To ensure the health of residents in N orthern California, the Butte Environmental Council (BEC)

requests that language be included in proposed permit NO. SAC 12

- 01 to limit feedstock at

the Sierra

- Pacific Industries Anderson Facility incinerator to clean cellulosic biomass.

SPI may intend to burn only the timber waste of its own industry. However, the financial

incentive to accept urban wood waste from other counties is compelling. This is particularly

true for the Bay Area, which has a “zero

- waste” policy within its own borders that does not

extend to poorer Northern California counties. BEC has addressed the result of this practice

at Pacific Oroville Power Industrie s Covanta facility in Oroville , CA

.

H igh levels of dioxin were found in samples taken from waste ash piles originating from the

POPI facility. These elevated levels of dioxin were found in the waste ash and in soil samples

taken within a t wo

- mile radius of the POPI facility even when fuel stocks were found to have

as low as 3% contamination of non

- wood materials.

Biomass facilities are only required to test for criteria pollutants. Although Butte County Air

Quality Management District ( BCAQMD ) did monitor POPI’s burn piles, the percentage of

“other materials” in the piles was not found to exceed allowable levels . The facility

voluntarily conducted a stack test for toxics in 2009 that also showed toxic emissions within

allowable levels. Nevertheless, several ash tests, and even so il tests proximal to the facility,

showed elevated levels of dioxins that exceeded state standards, endangering human and

environmental health.

Dioxin from incinerators is carried in the smoke plume to depose on soil, where it can remain

for decades. Diox in from soil bioaccumulat es in the fat of food and game animals. Residents

in the Anderson area are raising food animals and are therefore at higher risk of exposure to

dioxin pollution

. T he Anderson area is similar to the area surrounding the Oroville POPI

plant, which showed in a rec ent survey (Gary Bess Consultants, 2013) that 12% of survey

respondents raised animals for consumption.

The practice of paying orchardists and farmers to take waste ash for use as an agricultural

soil amendment necessitates that burn stock is restricted to clean cellulosic biomass. Our

experience trying to hold Covanta accountable for remediating their toxic legacy from

burning other materials has taught us : prevention is the most cost

- effective way to address

contamination. We respectfully submit these com ments, and are happy to provide any

additional information or input that may be helpful.

Robyn DiFalco, Executive Director

Butte Environmental Council