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OAR Box 1778 

Prepped by Ollie Stewart 

Document Number: 

72) ll-C-14 

Docket Number: 

A-90-06 

Printed 10/28/2008 9:50:54 AM Sheet 72 of 276 
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JUL I 4 1989 

fXSJAA 

Williaa A. Murray, Esq. 

Utilit y Project Manager 

City V^ter, Light and Power 

Municipal Building 

Springfield, Illinois 62757 

Ret Lakeside Generating Station Unit #7, 

Project 

Clean Coal Technology 

Dear Hr. Murray* 

I aa responding t o your fcay 1, 19 89, lette r to Mr. Don Clay, 

regarding a Clean Coal Technology demonstration project at 

Lakeside Generating Station Unit #7. As repreaented t o us, 

this project will test the abilit y of gas reburning technology 

t o reduce nitrogen oxide emissions and sorbent injection technology 

to reduce sulfur dioxide amissions. In addition, a decrease in 

particulate s and other pollutants say occur. Your lette r 

requests an assurance from the United State s Environmental 

Protection Agency (EPA) not t o enforce Hew Source Performance 

Standards (USPS) and Prevention of Significant Deterioration 

during the project or when the unit is restored to its predeoonstration condition following completion of the project. 

In your lette r you asked whether restoration of Lakeside 

Unit *7 t o its pre-project condition would constitut e a 

"oodification" or "major modification" pursuant to 40 CFR 

H60.1 4 or pursuant to 40 CFR 52.21(b)(2). The information 

submitted is not sufficient to determine whether ther e would 

be a physical or operational change which would increase 

emissions. Therefore, i t is not possibl e for EPA to determine 

with certainty whether there would in fact ba a raodification or 

soajor modification under the NSPS and PSD programs. 

However, assuming this unit wil l ba subject to new source 

requirements, EPA has evaluated the merits of the Lakeside Unit 

#7 project with regard t o applicabilit y of the Agency's 

November 16, 1984, Policy Against "Ko Action" Assurances. As a 

result, EPA believe s a "no action" assurance is appropriate in 

this case because the project appears to be "clearly 
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necessary to serve the public interest;" it ia expected to 

provide "important information for research purposes;" anu there 

is a need "which no other mechanism can address adequately." 

EPA supports this innovative technology demonstration as a means 

of potentially reducing emissions of nitrogen oxides and sulfur 

dioxide. 

Based on the representations made in your May 1, 1939, 

letter, EPA provides an assurance not to enforce against 

civil violations of NSPS and PSD requirements that may apply, 

pursuant to 40 CFR §§60.14 and 52.21(b)(2), as a result of emission 

increases which may occur during and after completion of the 

innovative technology demonstration at Lakeside Unit #7. This 

assurance does not apply to emission increases which result 

from physical or operational changes that are unrelated to the 

conduct of the demonstration project. Whether these changes are 

made before, during or after the project. In addition, we 

have noted that your letter states that it is unknown if the 

changes will be temporary or permanent. This assurance does 

not apply to permanent demonstration projects, that is, projects 

lasting more than five years. Of course, Lakeside Unit #7 uuat 

continue to coiaply with all applicable EPA and State emission 

limits and permit conditions during and after the demonstration. 

EPA is now evaluating if a change is necessary to the USPS ' 

and PSD regulations to accommodate temporary Department of 

Energy Clean Coal Technology Projects and similar EPA-funded 

•projetrtw----.to^i»-tir«^th«t**t^ •!•:••;?•: 

types of projects. Also, EPA and DOE have agreed to a proposed 

Clean Air Act amendment that addresses these projects. 

In the future, when we receive a request for a "no action" 

assurance, we will routinely ask the source for in for nation to 

allow us to determine if it would be appropriate to issue an 

assurance. We have now made a decision as to precisely what 

information we need. We will be sending you a letter asking 

for this information about your project. We will be asking you 

to subiait this information to ensure that we have complete files 

on all the projects. 
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i 

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Please keep EPA's Regional Office i n Chicago notified of 

the status and significan t results of this project. Your 

contact there will be Mr. David Kee a t (312) 353-2212. If this 

technology is successful and eaission reductions are demonstrated, 

the continued use of this technology would be strongly encouraged 

by EPA. 

Sincerely, 

DON R. CLAY FOB 

w> — 

William G. Rosenberg 

Assistant Administrator 

for Air and Radiation 

cct David Kee, Region V 

Terrell Hunt, OECM 

Alan Eckert, OGC 

Brian McLean, OAIAP 

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