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tit <br /> �.' SAN JOAQUIN COUIN-nAIR POLLUTION CONTROL Dl5'1'RIt_"P <br /> 1601 E. HA7.EITON AVE, STOCIMN, CA 95105 <br /> COMMENTS ON PROPOSED CONDITIONS FOR FALCON ENERGY <br /> a. This represents a partial control measure since the dryer may not be <br /> operated at all times. APCD may require additional additional controls afire <br /> ,. ; revieing the application for Authority to Construct.. <br /> ;,`•, i, <br /> r b. Continuous monitoring for dioxin is not practical from a technical stand. <br /> point. Monitoring for SO2 is not necessary as long as the sulfur content of <br /> the i.ncommi.ng fuel is known. <br /> c. The term "dust count" is not appropriate. If it is intended to mean <br /> source testing to measure particulate matter emissions, a monthly requirement <br /> is not practical. A more suitable alternative would be to use a less freque t <br /> source testing schedule combinead. with continuous measuring of the incormning <br /> ! <br /> oil. or fuel properties. <br /> Reword to say A source test to measure the PMl.O emissions according to the <br /> '! methods approved by the APCD shall be conducted on an annual. basis or as <br /> frequently as required by the APUD." <br /> ; d. A more feasible alternative would be to monitor the incomming material ard <br /> the equipment performance r.-haract.eristics. <br /> e. It is difficult to directly measure fugitive particulate matter emission. . <br /> Reasonably accurate est.i.ma.tion methods are available to calculate such <br /> emissions. PM10 emissions from the stack can be measure on an annual. basis. <br /> See item c above. <br /> f. Reword to say "Col lc!cted particulate matter from the cyclones or baghous s <br /> shall. be tested for hazardous materials. If the rn.ateri.al is found to be <br /> hazardous as defined by the applicable reguLations, it shall be disposed of ki <br /> a manner- prescribed by law." <br /> g. Reword to say "Water spray nozzles as required by APCD shall be inp lace <br /> and operational prior to acceptance of biomass material." <br /> h. Ok. <br /> Further- evaluation is needed to verify- if this is trrchnologically <br /> j;i feasible. <br /> k. ok. <br /> 1. Add "Each storage tank shall be equipped with a pressure/vacuum valve se <br /> to within 10% of its working pressure. <br /> Ok. <br /> n. Ok. <br /> �Y. <br />