From: Fellner, Christian

Sent: Tuesday, September 10, 2013 12:12 PM

To: Forney, Katy; Svendsgaard, Dave

Cc: Hofmeister, Art

Subject: RE: Latest Revised PD/SOB and Draft Permit for TECO

Katy,

That is a good point I wasn’t thinking about. If the duct burners are over 250 MMBtu/h and they sell over 1/3 of 

the potential electric output then the HRSG would trigger applicability (with either Da or TTTT) as they are 

currently drafted. If the duct burners are less than 250 MMBtu/h, then they would not trigger applicability since 

they would not meet the general criteria. 

Thanks, 

---------------------------------------------------------------

Christian Fellner

Energy Strategies Group

Sector Policies and Programs Division

Office of Air Quality Planning and Standards

United States Environmental Protection Agency

919.541.4003 (phone)

919.541.5450 (fax)

From: Forney, Katy 

Sent: Tuesday, September 10, 2013 12:00 PM

To: Fellner, Christian; Svendsgaard, Dave

Cc: Hofmeister, Art

Subject: RE: Latest Revised PD/SOB and Draft Permit for TECO

Ok Thanks.

BTW, Art and I looked at the definition of EGU in the TTTT rule and it says Steam Turbine or Combustion 

Turbine producing more than 25 MW, etc... so why wouldn’t the addition of a steam turbine (which has 

no direct emissions) be triggering the rule? I am just trying to understand the rule applicability language 

so we can speak to it correctly in the Preliminary Determination. I don’t know why the EGU definition 

has “steam turbine” as a possible trigger anyway, since it doesn’t have emissions. Is that trying to get a 

the steam produced from a coal fired boiler? 

Dave – we decided staying completely silent just invites comments from the public/enviros, so we 

wanted to at least address why this project wasn’t subject. 

Thanks

Katy

From: Fellner, Christian 

Sent: Tuesday, September 10, 2013 11:53 AM

To: Forney, Katy; Svendsgaard, Dave
Cc: Hofmeister, Art

Subject: RE: Latest Revised PD/SOB and Draft Permit for TECO

Katy,

Sorry, the EGU GHG reproposal will propose that the GHG standards be put directly in KKKK and Da so applicability 

will be based on the KKKK language. We are also co-proposing to go with a combined TTTT subpart, but would 

make sure applicability is consistent with how it would be done with separate subparts.

Thanks,

---------------------------------------------------------------

Christian Fellner

Energy Strategies Group

Sector Policies and Programs Division

Office of Air Quality Planning and Standards

United States Environmental Protection Agency

919.541.4003 (phone)

919.541.5450 (fax)

From: Forney, Katy 

Sent: Monday, September 09, 2013 2:00 PM

To: Fellner, Christian; Svendsgaard, Dave

Cc: Hofmeister, Art

Subject: RE: Latest Revised PD/SOB and Draft Permit for TECO

Ok thanks Christian. BTW, it’s the TTTT NSPS that we were concerned about so I am not sure how the 

KKKK interacts with that. 

I just wanted to make sure that having the duct burning in the HRSG didn’t trigger something in the 

proposed TTTT reg. 

From: Fellner, Christian 

Sent: Monday, September 09, 2013 1:22 PM

To: Svendsgaard, Dave

Cc: Forney, Katy

Subject: RE: Latest Revised PD/SOB and Draft Permit for TECO

Dave,

The way subpart KKKK proposed criteria pollutant amendments would work is that applicability would be based on 

the combustion turbine and not the HRSG – adding a HRSG would not trigger applicability with the proposed GHG 

NSPS.

The current reading of applicability would also not trigger applicability with KKKK as a new facility (it is not an 

entirely new facility) so the facility will not be impacted by the GHG proposal. Under the current language they 

might be considered reconstructed if the HRSG is over the 50% cost threshold, but since we are not proposing a 

GHG standard for reconstructed facilities that would only matter for criteria pollutants.

Hope this helps, 
---------------------------------------------------------------

Christian Fellner

Energy Strategies Group

Sector Policies and Programs Division

Office of Air Quality Planning and Standards

United States Environmental Protection Agency

919.541.4003 (phone)

919.541.5450 (fax)

From: Svendsgaard, Dave 

Sent: Monday, September 09, 2013 11:56 AM

To: Fellner, Christian

Cc: Forney, Katy

Subject: FW: Latest Revised PD/SOB and Draft Permit for TECO

Christian,

Just left you a message. Isn’t it correct that adding a HSRG does not trigger the New Source NSPS (as 

proposed)? Please reply to all, since I will be leaving for the day shortly.

Dave

From: Forney, Katy 

Sent: Monday, September 09, 2013 11:51 AM

To: Svendsgaard, Dave

Cc: Ceron, Heather; Hofmeister, Art

Subject: RE: Latest Revised PD/SOB and Draft Permit for TECO

Hey Dave, I glanced at your comments. Art is evidently out sick today. 

I didn’t realize that adding just a HRSG would not trigger the new NSPS. Is that true even with the duct 

burners? We can revise that section to indicate that the project wouldn’t be subject under the current 

proposed NSPS. I was hesitant to admit to the NSPS reproposal in a PD, but if you think that is better to 

say, we can add.

I will have to wait until Art gets back (hopefully tomorrow) to fully address your cost comments since he 

is more aware of the cost information that is in the application. 

Thanks,

Katy

From: Svendsgaard, Dave 

Sent: Monday, September 09, 2013 10:31 AM

To: Forney, Katy

Cc: Ceron, Heather; Hofmeister, Art

Subject: RE: Latest Revised PD/SOB and Draft Permit for TECO
Comments on this.

From: Forney, Katy 

Sent: Monday, August 26, 2013 4:57 PM

To: Rao, Raj; Svendsgaard, Dave; Vetter, Cheryl

Cc: Ceron, Heather; Hofmeister, Art

Subject: FW: Latest Revised PD/SOB and Draft Permit for TECO

Hi GHG Permitting Folks,

Here is the draft permit and preliminary determination for our next GHG PSD permit. TECO – Polk

Power. It is for the addition of Combined Cycle technology to an existing Simple Cycle power plant. We 

would like comments back by COB September 9th (2 weeks) if at all possible. We plan to go to public 

comment that week. 

Note, we have 1 placeholder condition (IX.B.2) for how to apportion the MW generated by the Steam 

Turbine back to each combustion turbines so that the lb/MWh emission limits can apply on an individual 

emission unit basis. We are waiting to hear from the company on how they plan to do this (heat input, 

MW generated, etc....)

If you have any questions contact myself or Art Hofmeister (404-562-9115) who wrote the permit. Note, 

I will be out of the office from Aug. 30 – Sept. 6. 

Thanks,

Katy 

p.s. I will be sending you the Shady Hills draft permit and preliminary determination tomorrow 

From: Hofmeister, Art 

Sent: Monday, August 26, 2013 4:34 PM

To: Forney, Katy

Subject: Latest Revised PD/SOB and Draft Permit for TECO

Here you go!

Art Hofmeister

Environmental Engineer

Air Permits Section

EPA Region 4

(404) 562-9115