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Doug Thompson and Pam Burmich:

 

I certainly appreciate your consideration of Covanta’s and IEP’s
comments on your initial draft GHG regulations issued in August. 
I have two quick comments about the current October review draft:

 

1.  In 95125 (g) (2) “Emissions shall not be based on O2
concentrations” is stated.  I would like you to consider the
attached special study Covanta conducted during our annual
permit-required RATA at Burney Mountain Power biomass facility: 
Avogadro calculated the CO2 concentrations from the O2 CEMS
concentrations using 40CFR60 Appendix A Method 19 and compared it
to their CARB Independent Testing Contractor CO2 reference CEMS; 
the calculated CO2 passed the RATA requirements.  

 

Would you please reconsider the language in 95125 (g) (2) to allow
O2 CEMS if it can pass RATA as in the above special test?

 

2.  In 95103 (c) (2)  “Triennial Schedule” is stated that only
“pure” biomass electric generating facilities may use this
triennial schedule.  Why was the word “pure” used here?  Is an MSW
electric generating facility > 10 MW subject to an annual schedule
as in 95103 (c) (1)? And was this your intent?

 

Thank you for your attention to these details and please contact
me if I can add any additional information or answer any further
questions. 

 

 _______________________________________________________

Jeffrey L. Hahn, PE, BCEE, QEP

Director, Environmental

 

COVANTA

   E N E R G Y

 for a cleaner world

 

 

Covanta Energy Corporation

876 Mt. View Dr, Lafayette, CA   94549

925.284.2006   Fax: 925.284.2284 Cell:  201.723.6447

www.CovantaHolding.com