UNITED STATES ENVIRONMENTAL PROTECTION AGENCY AIR, PESTICIDES & TOXICS MANAGEMENT DIVISION 61 Forsyth St., S. W. Atlanta, Georgia 30303 Fax Number: 404/ 562 9095 Electronic Transmission MEMORANDUM DATE: October 18, 1999 SUBJ: Initial EPA Comments on SCE& G's Williams Station FROM: Scott Miller, Environmental Engineer Operating Source Section, ARTB TO: Mr. Matt Wike South Carolina Department of Health and Environmental Control cc: Mr. Robert Brown, Permit Manager South Carolina Department of Health and Environmental Control Below are initial comments from EPA Region 4 on the above referenced source. Our comments are divided into two categories: 1) Significant Comments and 2) General Comments. Significant comments are defined as those comments that would trigger an objection under 40 CFR Part 70. Given that we have several significant comments on this permit, which was originally submitted as a draft/ proposed permit, EPA no longer considers the permit eligible for parallel review. Please contact me at your convenience in order that we may seek to resolve these issues prior to your submittal of a proposed permit for this source. You may reach me at ( 404) 562 9120. Thank you for your attention to this matter.

Significant Comments 1. The periodic monitoring for particulate matter from the electric utility boilers in permit condition 6. B. 1 on page 24 is inadequate. The only monitoring is an annual stack test. This monitoring is not frequent enough since the sources can not in good faith certify compliance with the particulate matter standard for all times during the year. EPA understands that the utility companies desire to have the same monitoring requirements in their title V permits in South Carolina as they do in North Carolina. It should be noted that although the North Carolina electric utility permits were initially issued with this annual test requirement, these same North Carolina permits have been rescinded, and EPA has informed North Carolina that the monitoring requirements must be changed. EPA maintains that once a year monitoring is not adequate, and EPA does not plan on approving this level of monitoring in any state in Region 4. One approach that the State may want to consider is the use of continuous opacity monitoring data to show compliance with the particulate emission standard. The condition given below is one acceptable way for the State to implement periodic monitoring at the utilities to show compliance with the relevant particulate emission rate:

" Pursuant to Regulation 401 KAR 50: 035, Section 7( 1)( c), to meet the periodic monitoring requirement for particulate, the permittee shall use a continuous opacity monitor ( COM). Excluding the startup, shutdown, and once per hour exemption periods, if any six minute average opacity value exceeds the opacity standard, the permittee shall, as appropriate, initiate an inspection of the control equipment and/ or the COM system and make the necessary repairs. If five ( 5) percent or greater of COM data ( excluding startup, shutdown, and malfunction periods, data averaged over six minute period) recorded in a calendar quarter show excursions above the opacity standard, the permittee shall perform a stack test in the following calendar quarter to demonstrate compliance with the particulate standard while operating at representative conditions. The permittee shall submit a compliance test protocol as required by condition Section G( a)( 20) of this permit before conducting the test. The Division may waive this testing requirement upon a demonstration that the cause( s) of the excursions has been corrected, or may require stack tests at any time pursuant to Regulation 401 KAR 50: 045, Performance tests."

The Region's comments on this approach are attached to this letter.

Another similar approach accepted by the Region for facilities that do not generally operate near the allowable particulate emission rate is as follows:

E6. The particulate emissions from this fuel burning installation shall not exceed 0.105 pounds per million Btu of heat input as specified in Paragraph 1200 3 6. 02( 1) of the Tennessee Air Pollution Control Regulations ( TAPCR).

Compliance Method: Monitoring of this fuelburning source for compliance with the applicable particulate emissions limitations shall be conducted by stack testing in accordance with 40 CFR60, Appendix A, Method 17. This testing shall be performed on a biennial basis and a particulate source test report shall be filed with the Technical Secretary within 60 days after completion of the testing. The source test shall be conducted in accordance with specifications for source sampling given in Chapter 1200 3 12 of the Tennessee Air Pollution Control Regulations. The continuous in stack opacity monitor( s) shall be fully operational prior to and during this compliance testing. The opacity data generated during this compliance testing shall be incorporated into the test report.

Ten ( 10) days prior to conducting the source test, the permittee shall provide notice of such test of the Technical Secretary to afford him the opportunity to have an observer present.

Should atmospheric sulfates ever become an issue, the Division will reassess the applicability of the test procedure as it relates to this issue. This is per the October 25, 1977 letter to Dr. Peter A. Krenkel, P. E.

Compliance with condition E8 of the permit shall be used as an indicator to determine whether compliance with this condition should be confirmed with a Method 17 test. Within sixty ( 60) days of an exceedance of the de minimis criteria specified in condition E8, the facility will conduct a Method 17 test.

TAPCR 1200 3 9. 02( 11)( e) 1.( iii)

E8. The visible emissions from each stack of this fuel burning installation shall not exceed twenty ( 20) percent opacity except for one  six ( 6) minute period per one ( 1) hour of not more than forty ( 40) percent opacity as specified in Paragraph 1200 3 5. 01( 1) of the Tennessee Air Pollution Control Regulations.

Compliance Method: Consistent with the provisions of Paragraph 1200 3 5. 03( 5) of the Regulations, compliance with the applicable visible emissions standards shall be determined from data generated by the opacity monitoring system, provided the quality assurance and operational availability requirements set forth in this permit are met.

Consistent with the provisions of Rule 1200 3 20. 06 of the Tennessee Air Pollution Control Regulations, no notice of violation shall be automatically issued for periods of visible emissions from this fuel burning installation that are in excess of the applicable visible emission standard so long as the total amount of time that the fuel burning installation is exceeding the applicable visible emission standard ( excluding periods of permitted startup, permitted shutdown, or malfunction and periods when the fuel burning installation is not operating) is not in excess of two ( 2) percent of the total amount of time in a calendar quarter. This exemption is applicable provided that good operational and maintenance practices are utilized for both the fuel burning equipment and the associated air pollution control equipment, the required ninety five ( 95) percent operational availability of the opacity monitoring system is maintained, and that no more than one exceedance of greater than twenty four ( 24) hours duration occurs per calendar year.

Written responses to the quarterly reports of excess emissions shall constitute prima facie evidence of compliance with the applicable visible emission standard. For purposes of annual certification of compliance with the applicable visible emissions condition, the acceptance, by the Division, of the quarterly reports of excess emissions shall be the basis of said certification.

TAPCR 1200 3 20. 06 2. In Table 6.1 Monitoring and Reporting, the facility is required to make one annual visible emissions inspection to demonstrate compliance with 20% and 40% opacity regulations for emission unit 03 ( the coal handling system). The Region believes that more frequent periodic monitoring is necessary to determine the compliance status of the coal handling system with applicable opacity standards. One acceptable approach to periodic monitoring for the facility in determining compliance with the opacity standard:

" The facility shall do a qualitative emissions evaluation on a daily basis for those emission sources controlled by a control device ( i. e. baghouse). Should the observer see visible emissions, the emissions observer must perform an EPA Method 9 reading and log the results of such a reading. For emission units that are uncontrolled, the facility will conduct an annual EPA Method 9 reading to determine compliance with the applicable opacity standard."

General 1. Permit condition 6. B. 12 on page 26 should be updated to clarify that the continuous opacity monitoring system data is being used to satisfy the opacity periodic monitoring requirement under title V of the Clean Air Act to demonstrate compliance with the applicable opacity limit of 40%. The title V permit should be clear on this point since the language in permit condition 6. B. 12 may give one the mistaken belief that compliance with the 40% opacity standard will be determined based on an annual Method 9 test. One way to effect such a clarification would be to add the following language to permit condition 6. B. 12:

" The data generated by the COMS is the periodic monitoring method chosen to assure compliance with the 40% opacity standard."

2. Permit condition 6. B. 4 on page 24 should be updated to clarify that the quarterly continuous emissions monitoring report for sulfur dioxide is to be based on the CEMS data except when the CEMS data is not available. When the CEMS data is not available, fuel sampling analysis would serve as an acceptable substitute during CEMS unavailability.

3. Please note that the allowance allocation to the Williams Station units has been changed in a 1998 reallocation ( see Federal register, Vol. 63, No. 187, page 51706). Although the footnote indicated in Section 2 of the proposed permit refers to the possibility of a 1998 reallocation, we recommend that you take the opportunity of this reopening of the Phase II permit to make the amendment to the allocated allowances.

4. EPA records indicate that unit " WIL1" at the Williams Station is a Group 1, Phase II tangentially fired boiler. Therefore, the NOx emission limitation applicable to this unit is 0.40lb/ mmBtu under 40 CFR 76.7( a)( 1) rather than " 40 CFR 76.5( a)( 2)" as indicated under condition 2 of the Phase II permit for the Williams station. Please correct the regulatory citation.

5. The Btu weighted annual emission rate and the Btu weighted annual average emission rate indicated on the Phase II NOx Averaging plan submitted by South Carolina Electric and Gas Company should be rounded to the nearest one hundredth.


[Federal Register Volume 83, Number 211 (Wednesday, October 31, 2018)]
[Notices]
[Page 54740]
[FR Doc No: 2018-23749]

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DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

[Docket No. ER19-170-000]

Supplemental Notice That Initial Market-Based Rate Filing
Includes Request for Blanket Section 204 Authorization: Gateway Energy
Storage, LLC

    This is a supplemental notice in the above-referenced proceeding of
Gateway Energy Storage, LLC's application for market-based rate
authority, with an accompanying rate tariff, noting that such
application includes a request for blanket authorization, under 18 CFR
part 34, of future issuances of securities and assumptions of
liability.
    Any person desiring to intervene or to protest should file with the
Federal Energy Regulatory Commission, 888 First Street NE, Washington,
DC 20426, in accordance with Rules 211 and 214 of the Commission's
Rules of Practice and Procedure (18 CFR 385.211 and 385.214). Anyone
filing a motion to intervene or protest must serve a copy of that
document on the Applicant.
    Notice is hereby given that the deadline for filing protests with
regard to the applicant's request for blanket authorization, under 18
CFR part 34, of future issuances of securities and assumptions of
liability, is November 14, 2018.
    The Commission encourages electronic submission of protests and
interventions in lieu of paper, using the FERC Online links at http://www.ferc.gov. To facilitate electronic service, persons with internet
access who will eFile a document and/or be listed as a contact for an
intervenor must create and validate an eRegistration account using the
eRegistration link. Select the eFiling link to log on and submit the
intervention or protests.
    Persons unable to file electronically should submit an original and
5 copies of the intervention or protest to the Federal Energy
Regulatory Commission, 888 First Street NE, Washington, DC 20426.
    The filings in the above-referenced proceeding are accessible in
the Commission's eLibrary system by clicking on the appropriate link in
the above list. They are also available for electronic review in the
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For assistance with any FERC Online service, please email
[email protected] or call<PHONE_NUMBER> (toll free). For TTY,
call<PHONE_NUMBER>.

    Dated: October 25, 2018.
Nathaniel J. Davis, Sr.,
Deputy Secretary.
[FR Doc. 2018-23749 Filed 10-30-18; 8:45 am]
 BILLING CODE 6717-01-P