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OAR Box 1787 

Prepped by Ollie Stewart 

Document Number: 

72) ll-C-30 

Docket Number: 

A-90-37 

Printed 11/4/200810:22:19 AM Sheet 72 of 147 
•f'u: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

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n < -JO 

NOV 0 6 1987 

Mr. John M. Daniel, Jr., P. E. 

Asst. Executive Director, Operations 

Virginia State Air Pollution Control Board 

Room 301, Ninth Street Office Building 

P. 0. Box 10089 

Richmond, VA 23240 

Dear Mr. Daniel: 

SA^-S-'S-- .:.' 

w«y 

L — -J 

Thank 

Chesterf 

make the 

nk you for submitting tho proposed permit for VEPCO's 

iold project. We have reviewed the material and wish to 

following comments part of the official record. 

1. The proposed limitation of 102.4 ppmv tTOx, as defined 

in the VSAPC3 August 6, 1987 memorandum, is equivalent to the 

USPS Subpart GG limitation and is substantially less stringent 

than BACT limitations for other much smaller facilities in this 

source category. In tho absence of an acceptable technical and 

economic justification, a valid 3ACT determination for this type 

'and size of source requires steam injection with selective . 

catalytic reduction (SRC) for NOx control. This level of 

control should reduce MOx c-aissioncj to 25 ppmv or less at 

15% 02. 

LAER requires either an oxidising catalyst for unburned 

hydrocarbon (i.e. VOC) control or a design standard which will 

achieve a VOC emission limitation no groater than 0.006 lbs/MBtu. 

Economics or cost of control is not an appropriate factor for 

determining LAER. Both VEPCO*s April 5, 1987 letter to the 

VSAPCB and the VSAPCB's August 6, 19G7 BACT/LAER analysis 

discuss an appropriate LAER emission rate (.006 Ibs/MBtu). 

Hov/ever, the proposed permit reflects GE'G guarantee (0.022 

lbs/HBtu) and provides for an adjustment after an initial source 

test. Thia is unacceptable as LAER. From VEPCO*s April 15, 1987 

letter and from information received from the California Air 

Resources Board, 3ACT/LAER for the 49.3 IV.1 Union Oil facility in 

California is defined as follows: 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

NOx - 25 ppmv at 15% 00 

VOC - 0.006 lbs/MMBtu 

Because the approximately 1100 MW (547.5 ea) facility, as 

proposed, is 22 times larger in rated capacity than the Union 

Oil facility, it appears the economies of scale would mean a 

substantial reduction in incremental pollution control costs 

(i.e. $/ton of pollutant removed). 

2. In Part 1, Condition 5 of tho proposed permit, the 

emission limitation for NOx is specified in lbs/hr yet these 

units are not consistent with those specified in the performance 

test. How arc ppmv limits converted to lbs/hr? This must be 

clarified and clearly specified in the permit. 

3. In Part 1, Condition 13 of the proposed permit, it is 

unclear how the data obtained pursuant to this condition will bo 

used to determine compliance with the NOx emission limitation 

which is specified in lbs/hr. Is it to be used to determine 

compliance with some other condition? Or is it to be used to 

determine a "factor" that will be used to calculate compliance? 

The use of this data should be clearly specified in the permit. 

cc 4. The permit should cloarly define the appropriate sou] 

test methods for determining compliance with each emission 

limitation specified in Part 1, Condition 5. 

5. A condition should be added which cloarly states that 

this facility is subject to all NSPS Subpart GG requirements in 

addition to the 3ACT/LAER emission limitations. 

6. It appears that the VSAPCD has performed a quite 

comprehensive modeling analysis which conforms to EPA's modeling 

policies and procedures. However, although the VSAPCB appears 

to have very thoroughly evaluated tha possible operating 

configurations in order to arrive at a worst case emission 

scenario, there is no indication that the omission rates modeled 

arc the same as the emission limitations contained in the 

proposed permit. In fact, a cursory review of the modeled SO-> 

and NOx rates appears to indicate that the modeled emission rate 

is lower than the allowable rate contained in the proposed permit 

Please clarify this point for us before a final permit is issued. 

CONCURRENCES 

SYMBOL k 

SURNAME k 

DATE k 

EPA Form 1320-1 (12-70) OFFICIAL FILE COPY 

•U.S . GPO : 1986-159-31 9 
'' I;*.""! ZV*,TM**" ' 

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•A' UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

7. There is no indication that VEPCO has obtained the 

required VOC offsets for the proposed now source Vie understand 

that the "accommodative" SIP's growth allowance is virtually 

depleted and are concerned that adequate emission offsets are 

not being obtained for this source. Please address this issue 

before the final permit is issued. 

Again, thank you for providing an opportunity for EPA to 

comment on the proposed permit. If you or your staff have any 

questions regarding our comments, please contact Hr. Sernie Turlinski 

at (215) 597-3939 or Ms. Eileen Glen at (215) 597-9379. 

Sincerely, 

Thomas J. Maslany, Director 

Air Management Division 

bcc: Jim Topsale 

Al Cimorelli 

Steve Copeland 

cc: Mr. A. W. Madder, Manager 

Air Quality, VEPCO 

CONCURRENCES 

SYMBOL k 

SURNAME k 

OATE k 

EPA Form 1320-1 (12-70) OFFICIAL FILE COPY 

• i l C R W • 1 Qo