Jenny Filipy P.E.
Environmental Engineer - Air Quality
Washington Dept. of Ecology
Spokane, Washinton
Environmental Review, Inc. has reviewed the Preliminary Determination to grant an permit to operate a boiler; we have the following comments:
1) Page 1 Determinations section second bullet - calling for "all known, available and reasonable methods of emissions controls" seems too general. Please specify that the control devices should operate according to manufacturers specifications or equivalent.
2) Section 3 Compliance Testing - This section only requires submittal of reports describing general operating data upon the request by the Department of Ecology. Please require regular annual submittal of the operating data.
3) Section 3 only requires stack testing at the discretion of the Department of Ecology. Please add a requirement for annual stack testing and submittals of the reports to ensure compliance with the allowable emissions limits.
Thank you, Tom Price-Director, Environmental Review, Inc. P.O. Box 2756, Berkeley, CA. 94702, www.envreview.org
"Filipy, Jenny (ECY)" <This email address is being protected from spambots. You need JavaScript enabled to view it.> wrote:
Good Afternoon Mr. Price,
Please see the attached preliminary Determination for Cott Beverages/Cliffstar LLC.
Thank you.
Jenny Filipy, PE
Environmental Engineer - Air Quality
Washington State Department of Ecology
(509) 329-3407 | This email address is being protected from spambots. You need JavaScript enabled to view it.
From: Filipy, Jenny (ECY)
Sent: Monday, October 09, 2017 9:54 AM
To: 'Thomas Price' <This email address is being protected from spambots. You need JavaScript enabled to view it.>
Cc: Koster, Robert (ECY) <This email address is being protected from spambots. You need JavaScript enabled to view it.>; Robbins, Miriam (ECY) <This email address is being protected from spambots. You need JavaScript enabled to view it.>
Subject: RE: Washington Dept. of Ecology Public Comment Period-Cliffstar Cott Beverages, Walla Walla, Washington, Comments due 10-16-17
Good Morning Mr. Price,
I am currently working on the draft permit for this project and I will share that with you when I have it ready. This project will be a reduction in emissions as the current Natural Gas boiler that Cliffstar is replacing was installed in 1951 with limited control. The new boiler to be installed will have better pollution control and meet 9 ppmv NOx and 30 ppmv CO. This reduction in emissions is why the Notice of Construction application for this project was placed on 15 day web notice and not a 30 day public comment period (WAC 173-400-171).
Miriam will be tracking this request. As I am still working on the document, it will be easiest for me to send it to you.
Thank you.
Jenny Filipy, PE
Environmental Engineer - Air Quality
Washington State Department of Ecology
(509) 329-3407 | This email address is being protected from spambots. You need JavaScript enabled to view it.
From: Thomas Price [mailto:This email address is being protected from spambots. You need JavaScript enabled to view it.]
Sent: Sunday, October 08, 2017 5:02 PM
To: Filipy, Jenny (ECY) <This email address is being protected from spambots. You need JavaScript enabled to view it.>
Cc: Koster, Robert (ECY) <This email address is being protected from spambots. You need JavaScript enabled to view it.>; Robbins, Miriam (ECY) <This email address is being protected from spambots. You need JavaScript enabled to view it.>
Subject: Re: Washington Dept. of Ecology Public Comment Period-Cliffstar Cott Beverages, Walla Walla, Washington, Comments due 10-16-17
Dear Ms. Filipy:
Mr. Koster communicated to me that it may be more efficient for your program to provide technical documents to me (when you have a notice of opportunity to request a public comment period) instead accommodating a request for a public comment period.
So, I'd like to find out if there are currently any additional documents which are available besides the application (which I already received).
For example can you provide: 1) draft permit documents, and 2) draft permit requirements including required startup testing procedures, and ongoing testing requirements? If yes, please send those to me via email.
You suggested that I should contact Ms. Robbins for future document requests, I take it that you meant that for general project documents, not for documents related to the current public notice.
Thank you, Tom Price-Director, Environmental Review, Inc. P.O. Box 2756, Berkeley, CA 94702, www.envreview.org
From: "Filipy, Jenny (ECY)" <This email address is being protected from spambots. You need JavaScript enabled to view it.>
To: Tom Price <This email address is being protected from spambots. You need JavaScript enabled to view it.>
Cc: "Koster, Robert (ECY)" <This email address is being protected from spambots. You need JavaScript enabled to view it.>; "Robbins, Miriam (ECY)" <This email address is being protected from spambots. You need JavaScript enabled to view it.>
Sent: Friday, September 29, 2017 2:16 PM
Subject: RE: Washington Dept. of Ecology Public Comment Period-Cliffstar Cott Beverages, Walla Walla, Washington, Comments due 10-16-17
Good Afternoon Mr. Price,
Please see the attached Notice of Construction Application for Cliffstar LLC, Cott Beverages.
For future document requests, Miriam Robbins is our Public Information Coordinator: (509) 329-3415, This email address is being protected from spambots. You need JavaScript enabled to view it.
Thank you for your interest.
Jenny Filipy, PE
Environmental Engineer - Air Quality
Washington State Department of Ecology
(509) 329-3407 | This email address is being protected from spambots. You need JavaScript enabled to view it.
From: Tom Price [mailto:This email address is being protected from spambots. You need JavaScript enabled to view it.]
Sent: Friday, September 29, 2017 8:43 AM
To: Filipy, Jenny (ECY) <This email address is being protected from spambots. You need JavaScript enabled to view it.>
Cc: Koster, Robert (ECY) <This email address is being protected from spambots. You need JavaScript enabled to view it.>
Subject: Washington Dept. of Ecology Public Comment Period-Cliffstar Cott Beverages, Walla Walla, Washington, Comments due 10-16-17
Jenny Filipy
Dept. of Ecology
State of Washington
Dear Ms Filipy:
Please send me the application materials for this project via email or provide an electronic link to view those.
I'd like to see that if it is available instead of requesting a public comment period at this time.
Thank you, Tom Price-Director, Environmental Review, Inc., PO. Box 2756, Berkeley, CA 94702, www.envreview.org