Response to Comments, APMC Stockton CoGen Draft PSD permit #SJ 85

- 04 September 1 6 , 2011

EPA received three comments on the Air Products Manufacturing Corporation Stockton Cogeneration facility (Stockton CoGen) PSD permit, #SJ 85

- 04. EPA’s responses are detailed

below:

Commenter #1: Arthur Unger:

Mr. Unger asserted that the proposed PSD permit for the Stockton C oGen plant d id not comply with PSD regulations and recommended that the permit not be issued. Further, h e

c ommented that the Ambient Air Qua lity Impac t Report (AAQIR) associated wit h the Stockton CoGen PSD permit incorrectly allowed project netting in reaching its conclusion.

Response to C

ommenter #

1 :

The commenter then suggests that based on an actual

- to

- potential test, the

Stockton CoGe n plant was subject to PSD permitting for its greenhouse gas (GHG) emissions. The source’s potential emissions are calculated by considering the maximum amount the source can emit, taking into account any feder ally enforceable restrictions.

The basis of th e commenter’s potential GHG emissions calculation is a continuous plant operati ng for 24 hours daily , 7 days a week. That is why the commenter calculated potential GHG emissions to be above the 75,000 tons per year ( TPY ) threshold.
However, t his level of operation i s not consistent with Stockton CoGen facility’s actual operating conditions.

In the AAQIR , EPA showed that the Stockton CoGen modification did not exceed the PSD applicability threshold for criteria pollutants. EPA conducted an actual

- to

proj ected actual test to determine whether the modified sourc e was subject to PSD regulation with respect to its GHG emissions. PSD applies if the net emissions increase

of GHGs from the modifications is equal to or greater than 75,000 TPY on a CO 2 e basis

and greater than zero TPY on a mass basis. The projected actual emissions are the source’s estimate of the emissions increase directly attributable to the modification. As stated in the AAQIR, the facility plans to rely primarily on its natural gas

- fired au xiliary

boiler ; and no more than 250 hours of simultaneous operation of its coal

- fired circulating fluidized bed (CFB) boiler and the auxiliary boiler are contemplated

. The estimated GHG emissions from the natural gas

- fired auxiliary boiler are significa ntly less than the

CFB boiler GHG emissions. Under this operating scenario, the estimated emissions are

much l ower than the 75,000 TPY GHG applicability threshold. Thus, the p roject GHG

emissions do not exceed the PSD applicability threshold.

Although t h e 250 hour operations limit is a federally enforceable condition in the

Stockton CoGen Title V operating permit , an explicit condition is not included in the proposed PSD permit. However, EPA will include a similar condition under Permit Condition IX.F Op erating Limitations in the final PSD permit to clarify this issue

.Commenter #2: Rob Simpson:

Mr. Simpson submitted a comment to EPA on August 30, 2011 , r equest ing a 30

- day

extension to the public commenting period because he allege d ly was not notified of the proposed permit

.

Response to C

ommenter #2:

EPA’s records show that Mr. Simpson was notified on July 5, 2011, via e lectronic mail, of the availability of the Public Notice and related materials of the Stockton CoGen permit. Mr . Simpson used the very same electronic mail address to submit the extension

request. For future notifications, if Mr. Simpson prefer s, EPA can arrange that public

notices be sen t to a physical address via the U.S. Postal Service

.

Additionally, t he pub lic notice clearly stated that the closing date for public comments was August 4, 2011. Since EPA received Mr. Simpson’s request after that date, the comment is not timely, and EPA is denying the request

. However, the re will be

an opportunity for Mr. Sim pson to comment on Stockton CoGen ’s Title V operating permit wh en it is eligible for renewal

.

Commenter #3: Air Products Manufacturing Corporation :

Stockton CoGen submitted the foll o wing administrative corrections:

Throughout the document, change t he owner to “Air Products Manufacturing Corporation” and the facility to “APMC Stockton CoGen:”

In Section IX.B the title is missing the letter “t” at the end of “Equipment;”

Section IX.B is missing the word “SO 2 ” in the last sentence and should re a d “A mi nimum

SO 2 removal efficiency... ; ”

In Section IX.F.1 , first sentence, delete the word “provided;”

In Section IX.F.1.a.ii

, delete the “1” a t the end of “Condition IX.F.1. a. ii .1 ; ” and

In Sect ion X.C the last line of the address was dropped and should include “ Fresno, CA

93726

- 0244.”

Response to C

ommenter #3 :

We agree with the administrative corrections. Therefore, EPA has incorporated the changes in the final PSD permit.