BEFORE
THE ILLINOIS
POLLUTION
CONTROL
BOAR&PR
26
s
HOLLAND
ENERGY,
LLC,
)
o’u
gLINO,
)
Petitioner,
)
v.
)
PCBO
)
(CAAPP
Permit
Appeal)
ILLINOIS
ENVIRONMENTAL
)
PROTECTION
AGENCY,
)
)
Respondent.
)
NOTICE
OF
FILING
TO:
Clerk
Illinois
Pollution
Control
Board
100 West
Randolph
Street
Suite
11-500
Chicago,
Illinois
60601
(VIA
HAND
DELIVERY)
(PERSONS
ON ATTACHED
SERVICE
LIST)
PLEASE
TAKE
NOTICE
that I have
today
filed with
the Office
of the
Clerk of
the
Illinois
Pollution
Control
Board
an
original
and
nine copies
each
of an ENTRY
OF
APPEARANCE
OF
JOAN
RITCHEY,
PETITION
FOR REVIEW
and
OPEN WAIVER
OF
STATUTORY
DECISION
DEADLINES,
copies
of which
are
herewith
served
upon
you.
Respectfully
submitted,
HOLLAND
ENERGY,
LLC,
Petitioner,
Dated:
4
/
By:
Joan Ritchey
ICE MILLER
LLP
200
W.
Madison
Street
Suite 3500
Chicago,
IL 60606-34
17
(312) 726-1567
Joan
THIS FILING
SUIIMIfl’ED
ON
RECYCLED PAPER
CERTIFICATE
OF SERVICE
I, Joan Ritchey, the undersigned,
hereby certify that I have served the attached ENTRY
OF APPEARANCE
OF JOAN RITCHEY, PETITION
FOR REVIEW
and OPEN
WAIVER
OF
STATUTORY DECISION DEADLINES
upon:
Clerk of the Board
Illinois
Pollution
Control Board
100 West
Randolph
Street
Suite 11-500
Chicago, Illinois
60601
Division of Legal Counsel
Illinois Environmental Protection Agency
1021
North Grand
Avenue
East
P. 0.
Box 19276
Springfield, IL 62794-9276
by
depositing said documents in the United States Mail, in Chicago, Illinois
this
24
th
day of
April, 2009.
1/2319496. 1
Joan
2
BEFORE
THE ILLINOIS
POLLUTION
CONTROL
BOARD
CLERK’S
OFFICE
HOLLAND
ENERGY;
LLC,
)
APR
2
2009
)
STATE
OF
Petitioner,
)
POIIt
Contro’
Board
v.
)
PCB
DCI
-
)
(CAAPP
Permit
Appeal)
ILLINOIS
ENVIRONMENTAL
)
PROTECTION
AGENCY,
)
)
Respondent.
)
ENTRY
OF APPEARANCE
OF
JOAN
RITCHEY
NOW
COMES
Joan
Ritchey,
of
the law
firm
of ICE
MILLER
LLP,
and
hereby
enters
her
appearance
on
behalf
of
Petitioner,
Holland
Energy,
LLC.
Respectfully
submitted,
HOLLAND
ENERGY,
LLC,
Petitioner,
Dated:
(1I
By:
Joan Ritchey
ICE
MILLER
LLP
200 W.
Madison
Street
Suite
3500
Chicago,
IL
60606-34
17
(312)
726-1567
CERTIFICATE
OF SERVICE
I,
Joan Ritchey,
the undersigned,
hereby
certify that
I have
served
the
attached
ENTRY
OF
APPEARANCE
OF JOAN
RITCHEY
upon:
Clerk
of the Board
Illinois Pollution
Control
Board
100 West
Randolph
Street
Suite
11-500
Chicago,
Illinois
60601
Division
of Legal
Counsel
Illinois
Environmental
Protection
Agency
1021
North
Grand
Avenue
East
P.O. Box
19276
Springfield,
IL 62794-9276
by
depositing
said
documents
in
the United
States Mail,
in Chicago,
Illinois
this
24
th
day of
April,
2009.
1/2319533.1
Joan
2
BEFORE
THE ILLINOIS
POLLUTION
CONTROL
BOARD
-
CLEF?
OFpICE
HOLLAND
ENERGY,
LLC,
)
APR
2
21309
Petitioner,
)
STATE
Op
uuNog
)
tf
q
POIIUtjQfl
Controi
8oc1
v.
)
PCB
-
)
(CAAPP
Permit
Appeal)
ILLINOIS
ENVIRONMENTAL
)
PROTECTION
AGENCY,
)
)
Respondent.
)
OPEN
WAIVER
OF
STATUTORY
DECISION
DEADLINES
Petitioner,
Holland
Energy,
LLC
(“Holland
Energy”),
pursuant
to Ill.
Admin.
Code
101
.308(c)(1),
hereby
notifies
the
Illinois
Pollution
Control
Board
(the “Board”)
and
the Illinois
Environmental
Protection
Agency
that
it waives
the
Board’s
statutory
decision
deadline
completely
and unequivocally
until
it elects
to
reinstate
the
120-day
decision
period
by
filing
with
the Board
a
notice
to
reinstate.
Respectfully
submitted,
HOLLAND
ENERGY,
LLC,
Petitioner,
Dated:
4
e’’
0
By:
Joan Ritchey
ICE
MILLER
LLP
200
W.
Madison
Street
Suite
3500
Chicago,
IL
60606-34
17
(312)
726-1567
Joan
CERTIFICATE
OF
SERVICE
I, Joan
Ritchey,
the undersigned,
hereby
certify
that I have
served this
OPEN
WAIVER
OF
STATUTORY
DECISION
DEADLINES
upon:
Clerk
of
the Board
Illinois
Pollution
Control Board
100
West
Randolph
Street
Suite 11-500
Chicago,
Illinois
60601
Division
of Legal
Counsel
Illinois
Environmental
Protection
Agency
1021
North
Grand Avenue
East
P.
0.
Box
19276
Springfield,
IL 62794-9276
by
depositing
said
document
in the United
States
Mail, in
Chicago,
Illinois
this
24
th
day of
April,
2009.
1/2319783.1
Joan
2
BEFORE THE
ILLINOIS
POLLUTION
CONTROL
BOAIEcvE
CL
OFFICE
HOLLAND
ENERGY, LLC,
)
APR
2
4
2009
Petitioner,
)
STATE
OF
ILUNOIS
)
A
tj
Pollution
Control
Board
v.
)
PCB
L1-
)“
)
(CAAPP
Permit
Appeal)
ILLINOIS
ENVIRONMENTAL
)
PROTECTION
AGENCY,
)
)
Respondent.
)
PETITION
FOR
REVIEW
NOW
COMES
Petitioner,
Holland
Energy,
LLC
(“Holland
Energy”)
by and
through
its
attorneys,
ICE
MILLER
LLP,
pursuant
to Section
40.2
of the
Illinois
Environmental
Protection
Act,
415
ILCS
5/40.2
(the
“Act”),
and
35
Ill.
Admin.
Code
§
105,
Subpart
C, and
petitions
the
Illinois
Pollution
Control
Board
(the
“Board”)
for
review
of the
Clean
Air
Act
Permit
Program
(“CAAPP”) permit
granted
to
Holland
Energy
on March
20,
2009,
by
the
Illinois
Environmental
Protection
Agency
(“Illinois
EPA”),
pursuant
to
Section
39.5
of
the Act.
In
support
thereof
and in
compliance
with
35
Iii.
Admin.
Code
§
105.304,
Holland
Energy
states
as follows:
1.
This
Petition
is
being
filed
within
35
days
after
Illinois
EPA’s
final
permit
action,
which
took
place
on
March
20,
2009,
so
this
Petition
is
timely
filed.
35
Ill.
Admin.
Code
§
105.302(e).
2.
Holland
Energy
owns
and
operates
a
power
plant
located
at
Rural
Route
2,
270-A,
Beecher
City,
Shelby
County,
Illinois.
This
CAAPP
source
operates
two
natural
gas-fired
combustion turbines/heat
recovery
steam
generators
with
duct
burners
to
generate
electrical
power,
with
other
ancillary
operations.
(The
subject
CAAPP
source
is referred
to
herein
as
the
“Facility”.)
The Facility is
classified
as
a
“major
source”
for purposes
of
Title
V of the
Federal
Clean
Air
Act and Section
39.5 of the
Act.
3.
On
January 11,
2008,
Holland Energy
submitted a
renewal
application
for its
CAAPP permit. At
that time,
Holland
Energy
was
owned
by
TPF
General
Holdings
LLC.
4.
On
or
about
October
15, 2008, the
Illinois EPA sent to
public notice a
proposed
CAAPP
permit for the
Facility. The
public notice period
ended on November
14, 2008 and
no
public
comments
or
comments from
“affected states” were
received. Illinois
EPA provided
a
copy
of the proppsed permit
to
the United
States Environmental
Protection Agency
(“U.S.
EPA”)
on January
30, 2009;
Illinois
EPA received
no
written objection
from
U.S.
EPA.
5.
Hoosier Energy
and Wabash
Valley Power
became
the owners
of Holland Energy
on
or
about
January
7,
2009.
Holland Energy
therefore
has
standing to file this
Petition.
6.
Holland
Energy has
initiated
a
dialogue with
Illinois EPA about
the
issues
raised
in
this Petition
(see the
April
20, 2009 letter
attached hereto
as Exhibit
“A”), and is
filing this
appeal to
protect
its
appeal
rights
in
the
event
Illinois EPA
and Holland
Energy do
not resolve
the issues
raised
herein.
Holland Energy
is filing contemporaneously
herewith
an Open
Waiver
Of
Statutory
Decision Deadlines
so that the
parties may continue
to attempt
to resolve the issues
raised
by
Holland
Energy
without the
involvement of the Board.
7.
The
specific
issues raised by
the Petition are:
(a)
The
28 issues identified
in Exhibit “A”
hereto, which are
incorporated as if
set forth
herein;
(b)
Section 3.2,
Compliance with Applicable
Requirements:
Section
3.2.1 of
the Facility’s
prior
permit
contained requirements
for each
cold cleaning degreaser
at the Facility
as
required by
35
Ill.
Admin.
Code
215.182,
but these requirements
are
not included in the
2
renewal
permit.
The
cold
cleaning
degreasers
remain
at
the Facility
and the Facility
does utilize
VOC-containing
solvents
in
them,
so that
the
requirements
found
in 35 Iii.
Admin. Code
215.182
should
be added
to the
renewal
permit.
8.
To the
extent they
are not
explained
in Exhibit
“A”, Holland
Energy’s
justification
as to why Illinois EPA’s
decisions
on these issues
are in error
fall into four
categories:
(a)
The facts
and citations
stated in the
permit are incorrect;
(b)
The
permit conditions
are not
clear and
clarification
is required;
(c)
The permit
mistakenly
includes
requirements
that,
per the
regulations
themselves,
are
not applicable
to this Facility.
Holland
Energy points
out that
this
is a combined cycle
facility,
not
a simple
cycle
peaking facility,
and
that the
Facility
is not located in
a “major
metropolitan
area.”
(d)
Certain insignificant
activities
are incorrectly
designated as
significant
activities.
9.
In accordance
with the Board’s decision
in AmerenEnergy
Generating
Company,
Edwards Power
Station
v. Illinois
EPA, PCB
No. 06-67 (CAAPP
Permit
Appeal
-- Air),
February
16, 2006, Holland
Energy understands
that
its renewal
permit
is stayed with the
filing
of
this Petition and that
Holland
Energy
should continue
to comply with
its prior
permit
at this
time.
WHEREFORE,
Holland
Energy,
LLC
petitions
the
Illinois
Pollution
Control
Board
to
review
the
Illinois
EPA’s action
to issue its CAAPP
permit
in this fashion.
3
Respectfully submitted,
HOLLAND
ENERGY,
LLC,
Petitioner,
Dated:
ii/Z
By:
Joan()Utchey
Joan
Ritchey
ICE MILLER LLP
200
W. Madison
Street
Suite
3500
Chicago,
IL 60606-34 17
(312)
726-1567
CERTIFICATE
OF SERVICE
I, Joan
Ritchey,
the undersigned,
hereby certify that I have
served this PETITION
FOR
REVIEW upon:
Clerk of the
Board
Illinois
Pollution
Control
Board
100
West Randolph
Street
Suite
11-500
Chicago, Illinois
60601
Division of
Legal Counsel
Illinois Environmental
Protection
Agency
1021 North
Grand Avenue East
P.O.Box 19276
Springfield,
IL 62794-9276
by
depositing
said document
in the United States
Mail, in Chicago,
Illinois this
24
th
day of
April,
2009.
Joan
itchey
1/2319540.1
4
HoHrndEn
ergy
OWNED
BY Hoosier
Enurgy
&
Wabash
Valley
Power
Your
Tcuchswo
£nergy
Couprratrv
Sent
via
email
Illinois
Environmental
Protection
Agency
Permits
Section
Bureau
of
Air
1021
North
Grand
Avenue
East
P.O.
Box
19276
Springfield,
Illinois
62794-9276
Attn:
Michael
Reed,
CAAP
Unit
Manager
April
20,
2009
RE:
HOLLAND
ENERGY,
LLC
Comments
regarding
Title
V
permit
renewal
issues
March
20,
2009
Dear
Mr.
Reed:
We
are
please
to
have
the
opportunity
to
provide
you
with
the
following
list
of
questions/concerns
regarding
the above
referenced
permit.
We
appreciate
your
offer
to open
a
dialogue
to discuss
these
important
issues
and
look
forward
to
working
with
you.
We
realize
that
time
is
limited
to
resolve
these
issu.es
prior
to
the
April
24th
deadline
to
file
an
appeal
and
wish
to
make
every
effort
to
avoid
that
avenue.
As
such
we
will
make
every
effort
to
be
available
to discuss
the
attached
list
of
concerns
with
IEPA
staff.
I
may
be
reached
at
the
following:
(317)481-2838
Office
(317)439-2932
Cell
j_klaas@wvpa.com
email
Again,
thank
you
for your
time
and
consideration
regarding
our
concerns.
Sincerely,
Jarod
Klaas,
P.E.
Manager,
Enviromnental
Affairs
Wabash
Valley
Power
Association
CC:
Hoosier
Energy,
Michalene
Reilly,
Darrell
Bayless,
Chris
Norris
Holland
Energy,
LLC,
Barry
Hatfield
Enclosure:
Attachment
I
EXHIBIT NA”
Attachment
1
Comments
Regarding
Holland
Energy,
LLC
Title
V
Permit
Issues
March
20, 2009
1.
Section
1.1, Source
Identification:
The.
source
contact
should
be Mr.
Jarod
Klaas,
317-481-
2838.
2. Section
1.2,
Owner/Parent
Company:
The
address
for
Holland
Energy,
LLC
should
be
changed
to
722 North
High
School
Road,
Indianapolis,
Indiana
46214.
3.
Section
1.3,
Operator:
The
operator
should
be
changed
to North
American
Energy
Services
NAES
Corporation
(same
address
as
listed
in
the
permit)
and
the
contact
should
be Mr.
Barry
Hatfield,
618-487-9140.
4.
Section
3.1.3,
Identification
of
Insignificant
Activities
and
Section
4.0,
Significant
Emission
Units
at
this
Source:
This section
states
that
there
are no
insignificant
activities
pursuant
to 35
IAC
201
.210(a)(16);
however,
there
is
an
emergency
generator
and
a
fire
pump
at the
source
that
meet
this dqfinition.
These
units
are now
listed
in
Section
4.0
and it
should
be
noted
that
the
description
of
the emergency
generator
in
Section
4.0 is
incorrect.
The
diesel
backup
generator
is
a
750.
horsepower
unit (the
permit
has it
listed
as 235
hp).
By
definition,
these
units
are
insignificant
activities
and
should
therefore
be
included
in
Section
3.0,
not 4.0.
As described
in
a separate
comment
below,
we believe•
that the
fire
pump
is
subject
to
the MACT
standard,
but pursuant
to the
illinois
regulations,
this unit
should
still
be considered
insignificant.
5.
Conditions
5.3.2,
7.1.3(b)(i),
7.2.3(b),
7.3.3(b)
and
7.4.3(b):
These
conditions
reference
35
IAC
212.123,
Visible
Emission
Limitations. Condition
5.3.2
cites
this regulation
as being
applicable
source-wide.
Therefore,
it is
redundant
to
repeat
the
rule requirements
throughout
Section
7
of the
permit.
We
request
that Conditions
7.1.3(b)(i),
7.2.3(b),
7.3.3(b)
and
7.4.3(b)
be
removed
from
the permit.
6.
Condition
5.10.2:
Annual
Emissions
Report
- This condition
now
requires
the
HAP
emissions
to
be
reported.
Additionally,
since
IEPA
is
classifying
the
emergency
generator
and
the fire
pump
as significant
emission
units,
then
the
two
should
also
be
included
on
the
report.
Since
the requirement
is
effective
as of
March
20,
2009
and HAPs
or
information
pertaining
to
the generator
and fire
pump
were
not
tracked
during
the
2008
calendar
year,
we do
not believe
that we
would
need
to
include
them
on
the
Annual
Emissions
Report;
however,
we would
like
additional
guidance
from
IEPA
on this
matter.
7.
Condition
7.1.3(i)(ii)(.C):
This condition
erroneously
references
35
IAC
2
17.708(g).
The
correct
reference
is 35 IAC
217.708(f).
8.
Condition
7.1.3(k),
Malfunction
and
Breakdown
Provisions:
We
request
that the
text
from
the
former
permit
Condition
7.1.3(h)(i)
be
reinstated
for
clarity.
Specifically,
we
would
like to
reinstate
the
language
clarifying
that
under
a
malfunction
or
breakdown
scenario,
the
permittee
shall
begin
shutdown
of
the
CT/HRSG
system
within
90
minutes,
unless
the
malfunction
is
expected
to be
repaired
in
120
minutes
or
such
shutdown
could
threaten
the
stability
of the
regional
electrical
power
system.
.. Condition
7.1.4(d) This
condition
states
that
the
turbines
are
not
subject
to
35
IAC
217.141
because
they
are
not
fuel
combustion
units;
however,
the
citation
is
for
Existing
Emission
Sources
in Major
Metropolitan
Areas
and
the
facility
is
not
located
in the
Chicago
or
St. Louis
metropolitan
areas
and
therefore,
would
not
be
subject
to. this
rule
because
of its
location
and
request
that this
condition
be
removed.
10.
Condition 7.1.6(c),
Emission
Limitations:
This
condition
now
includes
an
annual
emission
limit
for the
combustion
turbines
and
the
auxiliary
boiler
combined
and
states
“the
permit
conservatively provides
for
overlapping
operation
of
the
auxiliary
boiler
for
as
many
as
1,000
hours
per
year at
full
load
while
both
of the
CTs
are operating.”
We
do
not
understand
why
the IEPA
is
effectively limiting
the
auxiliary
boiler
to
1,000
hours
per
year
and
request
that
this statement
be
removed.
11.
Condition
7.1.9(f),
Recordkeeping
Requirements: This
condition
requires
recordkeeping
of the
ratio
of water
to
fuel
being
fired
in
the
affected
turbine/HRSG
system.
This
requirement
would
only
apply
to
units
that
utilize
a
water
injection
system.
Since
the
CT/HRSG
systems
are not
equipped with
water
injection systems,
this
requirement does
not
apply
and
should
be
removed
from
the
permit.
12. Section
7.2
Diesel
Engines:
This
section
assumes
that
both
the
backup
generator and the
fire
pump
are subject
to the
MACT
standard
found
at
40 CFR
63,
Subpart
ZZZZ:
NESHAP
for
Stationary
Reciprocating
Internal
Combustion
Engines
(RICE).
Note
that
the
two
potentially
subject
units
are
a diesel
mobile
emergency
generator
with
a rating
of
750
hp and
a
stationary
diesel
fire
pump
with
a rating
of
235
hp.
Since
the
emergency
generator
is
a mobile
unit, it
would
not
be subject
to
Subpart
ZZZZ
since
this
rule
only
applies
to
stationary
sources.
40
CFR
63.6675
defines
Stationary
RICE
as “any
reciprocating
internal
combustion
engine
which
uses
reciprocating motion
to
convert
heat
energy
into
mechanical
work
and
which
is not
mobile.
Stationary RICE
differ
from
mobile
RICE
in
that
a stationary
RICE
is
not a
non-road
engine
as defined
at
40 CFR
1068.30,
and
is
not
used
to propel
a
motor
vehicle
or
a vehicle
used
solely
for
competition.”
40
CFR
1068.30
defines
a
nonroad
engine
as
“By
itself
or in
or on
a piece
of
equipment,
it
is
portable
or
transportable,
meaning
designed
to
be and
capable
of being
carried
or
moved
from
one
location
to
another.
Indicia
of transportability
include, but are
not
limited
to,
wheels,
skids,
carrying
handles,
dolly,
trailer,
or
platform.”
With
respect
to
the
diesel
fire
pump,
we
believe
that this
unit
is
subject
to the
regulation,
but
given
that
it
is
less
than
500
hp,
we
do
not
believe
that
there
are
any
administrative
or
operating
requirements.
13.
Conditions
7.2.6
— 7.2.12:
The
diesel
fire
pump
and
emergency
generator
are,
by
definition,
insignificant
activities.
We
do not
believe
that
all
of the
testing,
monitoring,
recordkeeping,
reporting,
and
compliance
procedure
requirements
are
warranted.
We
requested
that
Conditions
7.2.6
and
7.2.12
be
removed
from
the
permit.
14.
Condition
7.3.6(a)(iii).
The
requirements
of
7.3.6(a)
could
not be found
in
the PSD
Permit
No.
99100022
and therefore,
this
paragraph
should
be
removed.
15. Condition
7.4.3 b: This
section proposes
to impose
a
30%
opacity
factor for
the
cooling
tower. It
specifically
cites 35
IAC
2 12.123
for the authorization
for
this
requirement.
However,
the opacity
created
by a
wet
cooling
tower is
primarily
moister
in the
form of
water vapor
(sometimes
referred
incorrectly
to as “steam”)
and
a small
fraction
of drift.
Section
212.124
which
is
titled
“Exceptions”
has
paragraph b
that states:
“Sections
212.122
and
212.123
of
this Subpart
shall
not apply
to
emissions
of
water or water
vaporfrom
an emission
unit.”
As
such,
the
opacity
limits
proposed
to
be imposed
citing 212.123
are
clearly
excluded
from
regulation
by
212.124(b).
We request
that this
condition
be deleted.
16.
Condition
7.4.c:
To the extent
that
this
paragraph
relies
on
a visible plume
of water
vapor or water
droplets
emitted
from
the
cooling
tower, we
believe
that the
requirement
is invalid.
It is,
as clearly
stated, only
applicable
to
“particulate
matter”
not
water
vapor
or droplets,
as excluded
above.
We
request
that this
condition
be removed.
17.
Condition
7.4.5
a: Please
delete
“opacity
observations”
from
this
paragraph.
As
noted above,
opacity
limits
are
not
applicable
to regulation
by 212.122
and
212.123 if
the opacity
is caused by
emissions
of
water or
water vapor.
18.
Condition
7.4.7 a.
Testing
Requirement:
This section
should
be deleted
in its entirety.
The
requirements
refer to
opacity reading
(“Method
9”) which
we
have shown
not
to be
applicable
to
cooling
towers.
The one noted
exception
is
Section
7.4.7
a.
ii. which,
for some
reason, addresses
“diesel engine
(s)”, not
the
cooling
tower.
As such,
it
too should
be
deleted.
19.
Condition
7.4.12
a: We request
that
the
references
to Conditions
7.4.3 (b)
and (c) be
deleted
as
these
conditions
refer
to
opacity and
not to particulate.
Imposing
opacity on
wet plumes
is clearly
prohibited
by
Section
212.124,
as noted
above.
20.
Condition
7.4.12
b: Should
be
deleted
in
its
entirety. This
condition
imposes
AP-42 emission
factors
on the
facility
for use to
determine
compliance
with
particulate
emission
limits
from the
cooling
tower.
We
believe
that
this
is
incorrect
for
a
number
of reasons,
including
the following:
a)
According
to
table
13.4-1
reproduced
from AP-42
and
inserted
into
the
permit,
the
Emission
Factor
Rating
for “Induced
Draft”
cooling
tower “Total
Liquid Drift”
is a “D”.
According
to
AP-42 a rating
of D “=Tests
are
based on a
generally unacceptable
method,
but
the
method
may
provide
an
order-of-magnitude
value
for
the
source. “ (AP-
42
Introduction,
Page
9).
b)
AP-42
continues
to elaborate
on
a Emission
Factor Rating
of D: “Below
average.
Factor
is
developed
from
A-,
B-
and/or
C-rated test
data from a
small
number
of
facilities,
and
there
may
be
reason
to
suspect
that these
facilities
do not represent
a random
sample
of
the
industry.
There
also may
be
evidence
of
variability
within
the source population.”
(AP-42
Introduction,
Page
10).
c)
The
above cited
table,
inserted
in
the Title
V
permit, shows
a rather
inaccurate
Emission
Factor
Rating
of
an
“E” for the
PM-b
calculation.
An
E
rating
is
described
by
EPA
in
AP-42
as
“Poor. Factor
is
developed
from
C-and D-ra
ted data,
and there
may
be reason
to
suspect
that the
icilities tested
do not
represent
a random sample
of the
industry. There
also
may be
evidence
of
variability
within
the
source
category
population.
“(AP-42
Introduction,
page
10).
d)
The
EPA
further
indicates:
“Emission
factors
in
AP-42
are neither
EPA-recommended
emission
limits
(e.g.,
best
available
control
technology
or
BAC7
or
lowest
achievable
emission
rate
or
LAER)
nor
standards
(e.g.,
National
Emission
Standards
for
Hazardous
Air
pollutants
or
NESHAP,
or
New
Source
Performance
Standards
orNSPS).
Use
of
these
factors
as
source-specific
permit
limits
and/or
as
emission
regulation
compliance
determinations
is
not
recommended
by
EPA.
Because
emission
factors
essentially
represent
an
average
of
a
range
of
emission
rates,
approximately
haif
ofthe
subject
sources
will
have
emission
rates
greater
than
the
emission
factor
and
the
other
ha
f
will
have
emission
rates
less
than
the
factor.
As
such,
a
permit
limit
using
an
AP-42
emission
factor
would
result
in
half of
the
sources
being
in
noncompliance.”
(Emphasis
added.)
(AP-42
Introduction,
Page
2).
e)
Finally,
it
is
worth
noting
that
Table
13.4-1,
footnote
c
acknowledges
thatthe
PM-b
factor
“...imply
an
effective
TDS
content
of
approximately
12,000
parts
per
million
(ppm)
in
the
circulating
water.”
As
the
TDS
rises
in
cooling
water,
the
assOciated
fine
particulate
would
also
rise,
assuming
all
other
things
were
constant.
As
this
facility
has
a
TDS
limit
of
3,000
ppm
(see
permit
condition
7.4.5
b.),
the
12,000
ppm
value
represents
a
4
fold
inappropriate
stringency
imposed
by
this
method.
21.
Condition
7.4.3(b)
and
(c):
These
conditions
have
been
added
to
the
renewal
permit
and
reference
35
IAC
212.123,
Visible
Emission
Limitations
and 35
IAC
212.301,
Fugitive
Particulate
Matter.
Given
the
nature
of
cooling
tower
operations,
there
would
not
be
any
smoke
or
particulate
matter
resulting
from
the
operation
of
this unit,
and
therefore,
these
conditions
should
be
removed.
22.
Condition
7.4.7(a)(i),
(ii),
and
(vii):
Section
7.4
pertains
to
operation
of
the
cooling
towers
but
there
are
several
references
to
testing
diesel
engines
and
exhaust
in
the
testing
requirements
found
in
Condition
7.4.7.
These
references
should
be
modified
to
reference
cooling
towers
instead
of
engines.
23.
Condition
7.4.9.
Based
on
the
arguments
stated
above,
we
request
that this
section
be
deleted
and
replaced
with
the
text
from section
7.3.9 of
the
prior
permit.
24.
Condition
7.4.12
This
condition
establishes
compliance
procedures
for
demonstrating
compliance
with PM
emission
limitations.
For
the
reasons
discussed
above,
we
request
that
this
entire
section
be
deleted.
25.
Attachment
5
and
6
list
Ter’taska
personnel
and
should
be
updated
as
follows:
Attachment
5
•
The
designated
representative
should
be
changed
from
Greg
Kunkle
to
Jarod
Klaas,
722
North
High
School
Road,
Indianapolis,
Indiana
46214
Attachment
6
•
Larry
Carison
should
be
changed
to
Jarod
Klaas,
722 North
High
School
Rd,
•
Indianapolis,
Indiana
46214.
26.
There
are
several
rule
citations
that
have
been
erroneously
referenced
throughout
the
permit
and
should
be
changed as
follows:
a)
Section
7.1.3(b)(ii):
“The
emission
of
smoke
or
other
particulate
matter
from
the
affected
turbine/HRSG
system
shall
not
have
an
opacity
greater
than
20
percent,
pursuant to
40
CFR
60.42a(b)
60.42Da(b),
except
for
one
6-minute
period
per
hour
of
not
more
than
27 percent
opacity,
as
further
allowe4
by
40 CFR
60.’12a(b)
60.42Da(b).”
b)
Section
7.1.3(b)(iii):
“When
the
duct
burner
in
an
affected
CT/HRSG
system
is
fired,
the
Permittee is
hereby
shielded
from
35
IAC212.122
and
35 IAC
212.123
[Condition
7.1.3(b)(i)(A)
and
Condition
5.3.2(b)]
for
the affected
boilers
as
it must
comply
with
40
CFR
60.42a(b) 6O.42a(b)
[Condition
7.1.3(b)(ii)].
c) Section
7.1.3(0(i),
Standard
for
Nitrogen
Oxides:
“Pursuant
to
40 CFR
60.41(a)(d)(1)
60.44Da(d)(1),
no
new
source
owner
or
operator..
.based
on
a
30-day
rolling
average,
except
as
provided
under
40
CFR
60.46a(k)(1) 60.48Da(k).”
d)
Section
7.1.3(f)(ii),
Standard
for
Sulfur
Dioxide:
“Pursuant
to
40
CFR
60.43(a)(b)(2)
60.43Da(b)(2),
no owner
or
operator
shall
cause
to be
discharged...”
e)
Section
7.1.3(f)(iii),
Standard
for Particulate
Matter:
“Pursuant to 40
CFR
60.42(a)(1) 60.42Da(a)(1),
no owner
or
operator
of
an
affected
HRSG
shall
cause
to
be
discharged...”
f)
Section
7.1.3(f)(iv),
Standard
for
Opacity:
“Pursuant.to
40
CFR
60.42(b)
60.42Da(b),
no
owner
or
operator...”
g)
Section
7.1.5(b):
“The
only
fuels
fired
in
the
affected
CT/HRSG
systems
shall
be
natural
gas
as
defined
in
40 CFR
60.41(c)
60.4lDa(c)
[Ti].”
27.
Section
7.1.3(d)(i):
The
equation
used
to
calculate
the
NOx
emission
allowance
for
fuel-
bound
nitrogen,
calculated
from
the
nitrogen
content
of
the
fuel,
is incorrect
for
the
percent
by
weight
in
the
range
of
0.1
to 0.25.
This
equation
should be
changed as follows
to be
consistent
with
60.332(a)(4):
Fuel-bound
nitrogen
F
(percent
by
weight)
(NOx
percent
by
volume)
N
0.015
0
0.015
<NOi
0.04(N)
0.1
<N
0.25
004
O.004+O.0067(N-0.1)
N
>0.25
0.005
28.
Section
7.1.7(b)(ii)(A):
The
equation
used
to
calculate
the
NOx
emission
limitation is
incorrect
and
should
be
changed
as
follows,
pursuant
to
40 CFR
60.335(b)(1):
NO,<
(NOo)(Pr/Po)°
5
el
9
(HoO.OO
633
)(288oK/Ta)
53