### 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 wou ld 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 R evised 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 anyw ay, 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, DaveCc: 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 E nvironmental 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: F ellner, 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 applicabi lity 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 a n

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 reconstructe d 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 Pe rmit 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: Svendsga ard, 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, Ra j; 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 co ndition (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 t his (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