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OAR Box 1778 

Prepped by Ollie Stewart 

Document Number: 

40) II-B-15 

Docket Number: 

A-90-06 

Printed 10/28/2008 9:50:53 AM Sheet 40 of 276 
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II-B-15 

NOTE: A signed copy of this item was not available. 
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UNITED STATES ENVIRONMENTAL PROTI 

2.13 

JAN 2 8 1982 

MEMORANDUM 

SUBJECT: Painesville Municipal Power Boiler Derat 

FROM: 

TO: 

Director 

Division of Stationary Source Enforcement\ 

Sandra S. Gardebring, Director 

Enforcement Division, Region V i^Kesss 

This is in response to your December 11, 1981 request for an 

applicability determination, and the follow-up material which we 

received January 5, 1982. Your request involves the Painesville 

Municipal Power Plant boiler No. 5, which is subject to NSPS, 

Subpart D. 

The City of Painesville wishes to avoid meeting the 

1.2 lb/mm Btu standard for SO2

 by derating the boiler so that ! 

its capacity is less than the 250 mm Btu/hour minimum required by ' 

Subpart D. Painesville proposes to do this by inserting a plate , 

in the feeder to the pulverizer which will restrict the maximum '. 

coal feed capability. Once set, the upper limit on the coal \ 

feeder gate adjusters would be welded in place to make the derate ; 

permanent. ' k v 

Region V feels this does not meet criteria established by ; 

DSSE in its October 7, 1977 derate memorandum. This provided 

that a derate "must be accomplished through a permanent physical 

change to the affected facility which will preclude it from 

operating at a capacity greater than the derated value." The 

Region believes the cost and length of time needed to undo the 

derate are minimal, and that it is physically possible to undo 

the derate without a unit outage. Concurrence is requested from 

DSSE that Painesville*s proposed derate strategy is unacceptable, 

and guidance is requested as to what specific physical changes 

would result in acceptable derates for purposes of avoiding NSPS 

applicability. 

DSSE has discussed this issue with EPA's Office of Air 

Quality Planning and Standards, and we are in agreement with your 

position. What Painesville has proposed would not represent a 

permanent physical derate because it would be relatively easy to 

undo the plate and increase the feed rate to the pulverizer, and 

it could be done without removing the boiler from operation. 

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Although DSSE and OAQPS believe that modifications to the boiler 

itself would be preferable, we will consider other procedures 

involving the coal feed system which would result in a permanent 

physical derate while not causing boiler damage. 

P.ecause of the wide range of possible derate options, an 

inclusive list of acceptable ones can obviously not be given. 

General guidance can, however, be provided. DSSE has previously 

determined, in its February 28, 1978 menorandum, that changing 

system capacity represents an acceptable- derate. This would 

involve a switch to smaller fans with smaller capacity, and the 

use of smaller pipes end pumps to control feed rate. 

Additionally, both TSSE and OAQPS agree that changes involving 

the burner or pulverizer which require a unit outage to be undone 

offer the best guarantee that the derate will be permanent, but 

any proposed derate will be considered. It must provide enough 

detail to allow a judgment as to its permanency, end allow a 

determination as to the resulting maximum capacity. In no case 

must the maximum derated capscity exceed 250 mm Btu per hour heat 

input, averaged over any one hour period. 

The source must submit any proposed derate to your office in 

order to ensure it is acceptable. If you need assistance in 

evaluating a proposal, please feel free to contact us. 

This response has been prepared with the concurrence of 

OAQPS. Should you have any questions, please contact Robert 

Myers of my 6taff at FTS 382-2875. 

hi U (bat 

Edward E. Reich 

cc: Devid Schultz 

John Gaitskill 

Edith Ardiente 

Bob Walsh 

Eerl Salo 

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