Commonwealth of Pennsylvania 

Department of Environmental Protection 

April 1, 2013 

Subject: Addendum to application review memo for the Repowering Project 

Sunbury Generation LP 

Shamokin Dam Borough, Snyder County 

Plan Approval Application 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 proposed plan approval was submitted to Sunbuty Generation LP for the 

repowering of their facility located in Shamokin Dam Borough, Snyder County for the construction and 

operation of natural gas turbines. Please see the application review memo dated September 7, 2012 for 

the technical infmmation pe1taining 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 in The Daily Item, a paper of general circulation in Snyder County, for 

three days (9/23, 9/24 and 9/25). During the comment period that followed the Pennsylvania Bulletin, 

EPA and the newspaper notices, the Depmiment received comments from EPA Region III, Sunbury 

Generation, the Clean Air Council and numerous citizens on the proposed plan app1'oval55-00001E. 

The comments from each of the pa1iies will be addressed below. The summaries of the comments are 

not necessarily intended to be a complete description of each comment, but rather to provide the context 

for the Depa1iment's response. For a detailed item by item response to the comments ori the proposed 

plan approval please see the Department's comment and response documents in file 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 by the Depmtment, 

please see the April1, 2013, letter regarding the Department's response to EPA comments. 

In order to provide a more detailed STEP 1 analysis for PSD applicability, the Depmiment has included 

all of the increase for each of the proposed sources separately in the table on page 2 of this 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. The project at hand consists of constructing tlu·ee combined cycle gas 
2 

turbines (CCGTs) and associated heat recovery steam generators (HRSGs) equipped with natural gas 

fired duct burners, one natural gas fired auxiliary boiler to assist with start-up and shut down of the 

CCGTs and a natural gas fired heater to maintain the natural gas temperature at its desired temperature 

prior to combustion in the CCGTs. The following table lists the potential emissions from each of the 

sources that make up the project. Please note that the potential emissions for each of the CCGT include 

the operation of the 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 per year. 

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 of the equipment, the 

hours of operation limitation requested and the proposed fuel characteristics. 

In order to clarify the details behind the 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 whether these 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 in 40 CFR Palt 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 month period) of operation for the sources proposed for each of the 

turbine options in order to remain below the significance threshold for GHGs. 

Per EPA's request, the NSPS Subpatt TTTT requirements, Standards ofPerf01mance for Greenhouse 

Gas Emissions for New Stationary Sources: Electric Utility Generating Units, have been removed from 

the plan approval. As of the date of this memo, Subpalt TTTT is only a proposed rule and is not yet an 

applicable requirement. As a result the Department has revised the proposed plan approval to remove all 

citations of the NSPS Subpati TTTT. 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 combustion turbines (P 181, P 182, and P 183) which were named CCGT# 1, CCGT#2 

and CCGT#3 in the proposed plan approval have been revised to show that each of the turbines also 

include an associated heat recovety steam generator and associated natural gas fired duct burners. 

Another concern Sunbmy Generation presented in its 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 in the plan approval application were performed assuming a sulfur content of 1.0 grain per 100 

cubic feet of gas. The calculations were done so this way since that is the pipeline specification for the 

most likely source of gas; the TRANS CO line. However, after discussions with Sunbury they have 

agreed that the use of pipeline quality natural gas will not be an issue. Therefore, the requirement to fire 

pipeline quality natural gas will remain an applicable requirement and established as BAT. 

Sunbury also noted in their comments on the proposed plan approval that the NSPS requirements of 40 

CFR Part 60 Subpatt TTTT were not yet final and that it was premature for the Department to include 

them in the plan approval. As discussed in the EPA comments section, all Subpart TTTT requirements 

have been removed 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 notification requirements are included 

in Section C, Site Level Requirements, since they are applicable to all sources being tested. Testing 

Requirements in the source level of the plan approval will list what air contaminants must be stack 

tested. The Depattment may revise the frequency of the revised testing based upon the results of the 

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 NOx budget trading program be 

removed from the plan approval. The NOx budget program has been replaced by the federal CAIR 

program and incorporated in the Depattment's regulations under 25 Pa. Code Chapter 145. All 

applicable CAlR requirements have been included in the plan approval and the NOx Budget 

requirements have been removed. 

Sunbmy proposed that the Depattment remove the specific equipment designations for each of the 

sources to be constmcted under the plan approval. Additionally, they have requested that differences in 

the emission rates of the different turbine options be removed from the plan approval. The Depattment 

requires that the equipment designations are included in the plan approval. Specifically because 

depending on the option chosen, there are different hours of operation requirements, due to the potential 

emissions from each of the 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 that the Department remove multiple shmt tetm emission limitations for the 

sources. Multiple short term limitations for CO and NOx have be retained and established as BAT 

requirements in the plan approval because the CEMS units on the CCGT's will be monitoring these 

emissions and do so both on a ppm and pounds per hour basis to verify emissions limitations. Shott tetm 

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 Generation had initially commented on a number of the requirements in the proposed plan 

approval that related to start-up and shut down conditions for the turbines. However, since the time of 

the submittal of their comments on the proposed plan approval and conversations with the potential 

vendors of the turbines, Sunbuty has withdrawn their comments on these requirements. All conditions 

that related to start -up and shut down events for the turbines will remain unchanged. 
4 

Sunbmy also commented on the Depaliment's use of a "blanket" condition which they state effectively 

incorporates potions of the federal NSPS requirements in their entirety. The Department has identified 

the applicable requirements of 40 CFR Part 60 Subpali Db and KKKK and streamlined them where 

applicable. The condition referenced by Sunbury Generation states that the unit is subject to the 

Subparts Db and KKKK of the NSPS. 

Sunbmy has objected to the need to conduct source tests for the CCGT's evety two years. In the 

proposed plan approval, the Depatiment wrote conditions requiring Sunbmy to continuously 

monitor the NOx, CO, C02, and ammonia (NH3) emissions through the use of a continuous 

emissions monitoring system (CEMS). The CEMS will provide a continuous real-time analysis of 

the emission of those air contaminants. With respect to the performance testing, the emission of 

sulfur oxides (S02), sulfuric acid mist, total PM, total PMl 0, total PM2.5, and fmmaldehyde will 

be minimized through the use of natural gas as fuel for the CCGTs and duct burners. The 

Depatiment has detetmined that performance testing for these air contaminants evety two years is 

reasonable. The Depaliment maintains authority to require perfmmance testing to demonstrate 

compliance with any applicable emission limitation if an exceedance of an applicable emission 

limitation is suspected by the Depatiment. The Depaliment has deleted the requirement to test for 

hexane and C02e. 

Clean Air Council (CAC) and a number of other commenters submitted comments on the proposed plan 

approval. All of the 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 Depatiment has 

previously held public meetings and hem·ings in the region for facilities constructed in this 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 in the 

project is one of many things considered when a decision to hold a public hearing is made. The vast 

majority of the 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 opposition to the natural gas activities in the area. 

As noted in CAC's comments, the GHG emission totals in the 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 of Units l, 2 and 3 and not Unit 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 of the 

project. 

CAC also commented that the Depatiment should not issue a plan approval for sources that are 

undetetmined at this time. With respect to the turbines, Sunbmy has proposed three distinct options that 

were reviewed by the Depatiment and were detetmined to meet BAT requirements, in addition to the 

applicable NSPS requirements. Sunbury will further be required to notify the Department upon selection 

of the make and model of the 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, PMl 0 and PM2.5. 

After thorough review and careful consideration of the comments received during the comment period, 

the plan approval has been revised as indicated in this addendum to the initial application review memo. 

I recommend that plan approval 55-0000lE be issued to Sunbuty Generation for the repowering project. 

Appropriate conditions including monitoring, record keeping and reporting have been included 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 

Feb·oz 27.77 ";6.762 29.79119,<7 1~!'\.26!'11~~2 ,,.9.724 ~-~ 1~-~-27 265.646

Mar·07 2,.,7 '06.,67 26.<;Q907684 116.1296975 26,2.9' 2.79 116.1~ 225.48

Apr-07 26.06 344·64 27.39056742 123 .• 216607 2616.207 3.11 123.32 ~:2,379

Mav~o7 20.2<) 249.6,2 19.009,9789 88.714920,1 1n8.729 2.41 88.71 184.49

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

Jul-07 qo.SS ,94.192 •o.96882528 142.1726fi82 2649.0" •. 69 142.17 285.~9

AU<·07 24.56 ~1 ).518 25. 78~872'2 114.202772~ 2461. 02 2.n 114.20 229.55

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

Oct·07 n.5, ,15.848 24.6121629 105.1966~6 2410.18 2.81 10S.20 21,.~17

Nov·07 2 •..• 0 209.741 24.48372917 106m2~•6 2617.804 2.79 106.zq 218.74

Dec~o7 22.~0 ,09.741 24 .. >50'10'5 107.020,678 2660.169 2.67 107.02 21 '.40

Jan-oS 22..54 300.1§9 24.83981059 107. 788•821 266 •. 817 2.69 1QZ.79 218.87

Feb-o8 28.16 ~4~.287 28.801."406 110.7o76n9 2849.4, '·'·' 1~0.71 262,00

Mar-o8 2 .85 370.35? ~0.61607004 140.186236 3123.604 ~.56 140.1 276,46

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

Mav-o8 22.7,~ 293-992 24.68~8218 111.4~S958 2.336.57' 2.71 111.44 213.40

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

Jul·o8 ,,.14 44~-741 ... ~7109974 1.>2 . '227.Z.1 <.96 1.52.95 '06.525

Aug·o8 34.02 446. 34-1 235215 .157.4006919 .35:23,315 4.07 !57.40 _315,00

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

Oct-o8 25,47. 28Z·54? 1 >-54660036 100.6782727 2507-603 3-03 100.68 214.~22

Nov-o8 25.07 ~12.n7 20.1421QQ1 10~.~746478 2588.016 2.90 10 ·-~7 218.59

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

Jan-09 28.0Q 360.66 29·54147364 135. 78928'-' 3067.94 3-36 135,79 26,,,62

-----· 

Sunbury Generation LP 

Contemporaneous Decreases Associated with Shutdown of Boilers 1A, 1B, 2A, 2B, 3 a

Time Period 

Pollutant 2/2oo7-1/2oo8 I 2/2oo8-1/2oo9 Average 

tons per year 

co 291.82 337.65 314.73 

NOx 3,787.38 4,268-41 4,027.89 

TSP 303.29 329.64 316-47 

PM-10 1,357·56 1,539·53 1,448·54 

SOx 29,963-48 34,258.54 32,111.01 

voc 34.86 40.28 37.57 

PM-2.5 1,357.5585 1,539.5284 1,448.54 

GHG 2, 734.231.51 3,081,460.16 

H2S04 2,294.08 2,622.92 2,458.50