## Commonwealth ofPennsylvania Department ofEnvironmental Protection April 1, 2013

Subject: Addendum to application review memo for the Repowering Project Sunbury Generation LP Shamokin DamBorough, Snyder County 

### PlanApprovalApplication 55-0000JE
To: Muhammad Q. Zaman 

# H&J:' Environmental Program Manager Air Quality Program Through: Keith Allison 

# '1(AFrom: Chief, Facilities Permitting Section Air Quality Program Joseph L. PiktelCJlf Facilities Pe1mitting Section Air Quality Program & David Shimmel, P.EJU Chief, New Source Review ection Air Quality Program

On September 7, 2012, a proposedplan approval was submitted to Sunbuty Generation LP for the repowering oftheir facility located in Shamokin Dam Borough, Snyder County for the construction and operation ofnatural gas turbines. Please see the applicationreviewmemo dated September 7, 2012 for the technical infmmationpe1taining to the proposed plan approval. The Department published an intent to issue plan approval notice in the Pennsylvania Bulletin on September 8, 2012 and Sunbury Generation published the required notice inThe Daily Item, a paper ofgeneral circulation in Snyder County, for three days (9/23, 9/24 and 9/25). During the comment period that followed the PennsylvaniaBulletin, EPA and the newspaper notices, the Depmiment received comments from EPA Region III, Sunbury Generation, the Clean Air Council and numerous citizens onthe proposed plan app1'oval55-00001E. The comments from each ofthe pa1iies will be addressed below. The summaries ofthe comments are not necessarily intended to be a complete description ofeach comment, but ratherto provide the context for the Depa1iment's response. For a detailed itemby item response to the comments ori the proposed plan approval please see the Department's comment and response documents infile TVOP 55-00001.
EPA comments on the proposed plan approval were received via e-mail. The following is fmther explanation regarding the comments submitted by EPA. EPA's comments were more administrative in nature. For a detailed item-by-item response to the comments as they were received bythe Depmtment, please see the April1, 2013, letter regarding the Department's response to EPA comments.
Inorder to provide a more detailed STEP 1 analysis for PSD applicability, the Depmiment has included all ofthe increase for each ofthe proposed sources separately in the table on page 2 ofthis memo. In the application review memo for this project dated July 2, 2012, the STEP 1 calculation was not broken down on a source by source basis. Theproject at hand consists ofconstructing tlu·ee combined cycle gas2 turbines (CCGTs) and associated heat recovery steam generators (HRSGs) equipped withnatural gas fired duct burners, one natural gas fired auxiliary boiler to assist with start-up and shut down ofthe CCGTs and a natural gas fired heater to maintainthe natural gas temperature at its desired temperature priorto combustion in the CCGTs. The following table lists the potential emissions from each ofthe sources thatmake up the project. Please note that the potential emissions for each ofthe CCGT include the operation ofthe natural gas fired duct burners for their maximum operation time of 1,000 hours per year. Values listed in the table below are in tons peryear.
Source 

## co NOx PM/PM!O/PM2.5 SOx 

## voc H2S04 GHGs
CCGT#l 114.5 60.73 59.56 20.37 16.83 ·. 15.61 983,462 CCGT#2 114.5 60.73 59.56 20.37 16.83 15.61 983,462 CCGT#3 114.5 60.73 59.56 20.37 16.83 15.61 983,462 Aux 15.70 7.60 1.60 0.60 1.10 0.05 25,093 Boiler Heater 2.30 5.30 0.47 0.17 0.34 0.01 7,346
Totals 361.5 195.1 180.75 61.88 51.76 46.89 2,982,825
The potential emissions were calculated using emission factors from the vendors ofthe equipment, the hours ofoperation limitation requested and the proposed fuel characteristics.
In order to clarify the details behindthe netting calculation, the Department is clarifying that Units 1, 2, 3 and 4 (the coal fired utility boilers) are the.only sources being counted as contemporaneous decreases. The diesel combustion turbines are not accounted for in the netting analysis as Sunbury has not yet determined whetherthese sources will remain once the facility transitions to natural gas.
The GHG emission calculations for the project were made utilizing the methods and emission factors provided in40 CFRPalt 98. C02e emission calculations were made for the sources using EPA developed emission factor data for C02, methane and N20. Sunbuty Generation calculated a maximum hours per year (12 consecutive monthperiod) ofoperation for the sources proposed for each ofthe turbine options in order to remain belowthe significance threshold for GHGs.
Per EPA's request, the NSPS SubpattTTTTrequirements, Standards ofPerf01mance for Greenhouse Gas Emissions forNew Stationary Sources: Electric Utility Generating Units, have been removed from the plan approval. As ofthe date ofthis memo, SubpaltTTTT is only a proposedrule and is notyet an applicable requirement. As a result the Department has revised the proposed plan approval to remove all citations ofthe NSPS SubpatiTTTT. The Department will incorporate any applicable requirements of Subpati TTTT when the rule becomes final. Sunbury Generation submitted comments by letter dated October 16, 2012. The reference names for the Source IDs for the combustionturbines (P 181, P 182, and P 183) whichwere named CCGT#1, CCGT#2 and CCGT#3 in the proposed plan approval have been revised to showthat each ofthe turbines also include an associated heatrecovety steam generator and associated natural gas fired duct burners.
Another concern Sunbmy Generationpresented inits comments was that the proposed plan approval listed the fuel as pipeline quality natural gas. Pipeline quality natural gas is defined by the federal

### 3 regulation as gas that contains a sulfur content ofless than 0.6 grains per 100 cubic feet. Calculations made inthe plan approval application were performed assuming a sulfur content of 1.0 grain per 100 cubic feet ofgas. The calculations were done so this way since that is the pipeline specification for the most likely source ofgas; the TRANSCO line. However, after discussions with Sunbury they have agreed that the use ofpipeline quality natural gas will not be an issue. Therefore, the requirement to fire pipeline quality natural gas will remain an applicablerequirement and established as BAT. Sunbury also noted in their comments onthe proposed plan approval that the NSPS requirements of40 CFRPart 60 SubpattTTTT were not yet final and that it was premature for the Department to include them in the plan approval. As discussed inthe EPA comments section, all Subpart TTTT requirements have beenremoved from the proposed plan approval at this time. Sunbury also commented on the testing requirements for the CCGTs and Aux. boiler. All general testing requirements such as 25 Pa. Code Chapter 139 regulations and the notificationrequirements are included in Section C, Site Level Requirements, since they are applicable to all sources being tested. Testing Requirements inthe source level ofthe plan approval will list what air contaminants must be stack tested. The Depattment mayrevise the frequency ofthe revised testing baseduponthe results ofthe tests, but at this time testing for air contaminants that are not monitored by CEMS must be tested every two years. Sunbmy further requested that any regulations that applied to the NOxbudget tradingprogram be removed from the plan approval. TheNOx budget program has been replaced bythe federal CAIR program and incorporated in the Depattment's regulations under 25 Pa. Code Chapter 145. All applicable CAlRrequirements have been included in the plan approval and the NOx Budget requirements have beenremoved. Sunbmyproposed that the Depattmentremove the specific equipment designations for each ofthe
sources to be constmcted under the plan approval. Additionally, they have requested that differences in the emissionrates ofthe different turbine options beremoved from the plan approval. The Depattment requires that the equipment designations are included in the plan approval. Specifically because depending onthe option chosen, there are different hours ofoperationrequirements, due to the potential emissions from each ofthe options. Futihermore, Sunbmy needs to notify the Department which option is selected in order to verify that the turbines, boiler and heater can meet the requirements established in the plan approval. Sunbmy has requested thatthe Department remove multiple shmttetm emission limitations for the sources. Multiple short term limitations for CO andNOxhave be retained and established as BAT requirements in the plan approval because the CEMS units onthe CCGT's will be monitoring these emissions and do so both on a ppm and pounds per hour basis to verify emissions limitations. Shotttetm emission limits for all other air contaminants are established on a lbs/MMBTU basis rather than a lbs/hr

· basis in order to ensure the units are operated efficiently.

Sunbmy Generationhad initially commented on a number ofthe requirements inthe proposed plan approval that related to start-up and shut down conditions for the turbines. However, since the time of the submittal oftheir comments onthe proposed plan approval and conversations with the potential vendors ofthe turbines, Sunbuty has withdrawntheir comments onthese requirements. All conditions that related to start-up and shut down events for the turbines will remain unchanged.

### 4 Sunbmy also commented onthe Depaliment's use ofa "blanket" condition which they state effectively incorporates potions ofthe federal NSPS requirements in their entirety. The Departmenthas identified the applicable requirements of40 CFRPart 60 SubpaliDb and KKKK and streamlined them where applicable. The condition referenced by Sunbury Generation states thatthe unit is subject to the Subparts Db and KKKK ofthe NSPS. Sunbmy has objected to the need to conduct source tests for the CCGT's evetytwo years. Inthe proposedplan approval, the Depatimentwrote conditions requiring Sunbmy to continuously monitor the NOx, CO, C02, andammonia (NH3) emissions through the use ofa continuous emissions monitoring system (CEMS). The CEMS will provide a continuous real-time analysis of the emission ofthose air contaminants. With respectto theperformancetesting, the emission of sulfur oxides (S02), sulfuric acid mist, total PM, total PMl0, total PM2.5, and fmmaldehyde will be minimizedthrough the use ofnatural gas as fuel for the CCGTs and duct burners. The Depatimenthas detetmined that performance testing for these air contaminants evety two years is reasonable. The Depalimentmaintains authority to require perfmmance testing to demonstrate compliance with any applicable emission limitation ifan exceedance ofan applicable emission limitation is suspectedby the Depatiment. The Depalimenthas deleted therequirement to test for hexane and C02e.
Clean Air Council (CAC) and a number ofother commenters submitted comments onthe proposed plan approval. All ofthe comments from the general public were made via e-mail and were the exact same fotm letter. The commenters all requested a public hearing on the project. The Depatimenthas previously held public meetings and hem·ings inthe region for facilities constructed inthis area. The Department believes that the responses contained within this letter are sufficient to address the public's concerns, and a public meeting/hem·ing for this platt approval is not warranted. Local interest inthe project is one ofmany things considered when a decision to hold a public hearing is made. The vast majority ofthe commenters requesting a public hearing were from New York State and the greater Philadelphia area. There was not atty significant interest expressed from the local community.
Other comments contained in the form e-mail were not specific to the Sunbury Generation project and were made as a general oppositionto the natural gas activities inthe area.
As noted in CAC's comments, the GHG emissiontotals inthe September 7, 2012 application review memo for the repowering project are inconect. The inconect values in the review memo accounted for the actual emissions from Units l, 2 and 3 at the Sunbmy plant. The table did not include the actual emissions that resulted from unit 4 at the facility. The initial plan approval application submitted was for only the retirement ofUnits l, 2 and 3 and notUnit 4. To correct the table, the emissions from Unit 4 needed to be accounted for in the analysis. Please see the table attached to this review memo for the cotTect GHG emissions from all four units at the Sunbury facility being shut down as a result ofthe project.
CAC also commented that the Depatiment should not issue a plan approval for sources that are undetetmined at this time. Withrespect to the turbines, Sunbmy has proposed three distinct options that were reviewed by the Depatiment and were detetmined to meet BATrequirements, in addition to the applicable NSPS requirements. Sunbury will further be required to notify the Department upon selection ofthe make and model ofthe units in order to verify that they will achieve compliance with all plan approval tenus and conditions.

### 5

CAC also commented that PMlO and P2.5 emission limitations should be separate limitations. In the proposed plan approval the limitation was grouped together. The Depmiment has revised the condition to indicate separate emission limitations for total PM, PMl0 and PM2.5.
After thoroughreview and careful consideration ofthe comments received during the comment period, theplan approval has been revised as indicated inthis addendum to the initial applicationreview memo. I recommend that plan approval 55-0000lE be issued to Sunbuty Generationfor the repowering project. Appropriate conditions including monitoring, record keeping and reporting have beenincluded in plan approval55-00001E.Sunbury Generation LP Actual Pollutant Emissions from Boilers 1A, 1B, 2A, 2B, 3, and 4 (tons)

co NOx TSP **PM~10** SOx voc PM-2.5 GHG H2S04

Feb·oz 27.77 ";6.762 29.79119,<7 **1~!'\.26!'11~~2** ,,.9.724

**~-~ 1~-~-27**  265.646.1< **240.'~()**

Mar·07 2,.,7 '06.,67 26.<;Q907684 116.1296975 26,2.9' 2.79 **116.1~** 225.487.56 201.S8

Apr-07 26.06 344·64 27.39056742 123 .• 216607 2616.207 3.11 123.32

**~:2,379.8** 200.30

**Mav~o7** 20.2<) 249.6,2 19.009,9789 88.714920,1 1n8.729 2.41 88.71 184.497.77 **1~~-12**

Jun-07 **~0.78** 404.338 **,1.15644~5** 145.219742 2842.36, **~.68** 14,1;:.22 2 1,068.<)1 217.62

Jul-07 qo.SS ,94.192 •o.96882528 142.1726fi82 2649.0" •. 69 142.17 **285.~9.94** 202.82

AU<·07 24.56 **~1** ).518 25. **78~872'2 114.202772~**  2461. 02 2.n 114.20 229.551.94 188.47

Se]>-07 16.46 186.4' 14,10585687 6<.704144., 1<;q0.70< 1.96 65.70 14l.Q12.81 117.20

Oct·07 n.5, ,15.848 24.6121629 **105.1966~6** 2410.18 2.81 10S.20 **21,.~17.06** 184.5'

Nov·07 2 •..• 0 209.741 24.48372917 **106m2~•6** 2617.804 2.79 106.zq 218.740 ... 20043

**Dec~o7 22.~0**  ,09.741 24 .. >50'10'5 107.020,678 2660.169 2.67 107.02 21 '.406.82 **20~.67**

Jan-oS 22..54 300.1§9 24.83981059 107. 788•821 266 •. 817 2.69 1QZ.79 218.872.32 203.95

Feb-o8 28.16 **~4~.287** 28.801."406 110.7o76n9 2849.4, '·'·' **1~0.71** 262,002.81 218.16

Mar-o8 2 .85 370.35? **~0.61607004** 140.186236 3123.604

**~.56** 140.1 276,464.84 **2~~.15**

Anr-oS 25.88 qq,.q88 26.684'4"8 **12~.0164027** 2zq9.4o8 •. oo **12~.02** 2412QQ.08 20Q.74

Mav-o8 **22.7,~** 293-992 **24.68~8218**

**111.4~S958** 2.336.57' 2.71 111.44 213.407.2' 1 8.8

Jun-o8 so . .,. ,99.272 29,59587108 139·54"066 2910.8o8 3.61 119.54 282.7<0.65 222.86

Jul·o8 ,,.14 **44~-741** ... **~7109974** 1.>2 . '227.Z.1 <.96 1.52.95 '06.525.40 247.12

Aug·o8 34.02 446. 34-1 235215 .157.4006919 .35:23,315 4.07 !57.40 _315,006.8 269.75

Sep-o8 2 .87 ,66.809 27.01691471 128.'762724 2728.11!') M6 128.76 **26~.9(}2.06** 208.87

Oct-o8 25,47. 28Z·54? 1 >-54660036 100.6782727 2507-603 3-03 100.68

**214.~22.17** 191.99

Nov-o8 25.07 **~12.n7** 20.1421QQ1 **10~.~746478** 2588.016 2.90 10 **·-~7** 218.591.76 108.14

De<X>8 25.02 312.118 25-46683258 115.6871925 2655·992 2.99 115.6 223.7M-55 203-35

Jan-09 28.0Q 360.66 29·54147364 135. 78928'-' 3067.94 3-36 135,79 26,,,62.74 234.89-----·SunburyGenerationLPContemporaneousDecreasesAssociatedwithShutdownofBoilers1A,1B,2A,2B,3and4TimePeriodPollutant2/2oo7-1/2oo8I2/2oo8-1/2oo9Averagetonsperyearco291.82337.65314.73NOx3,787.384,268-414,027.89TSP303.29329.64316-47PM-101,357·561,539·531,448·54SOx29,963-4834,258.5432,111.01voc34.8640.2837.57PM-2.51,357.55851,539.52841,448.54GHG2,734.231.513,081,460.16H2S042,294.082,622.922,458.50