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3.28
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
230 SOUTH DEARBORN ST.
CHICAGO, ILLINOIS 60604
30 SEP 1987
Mr. Dell Collins
Impell Power Projects
320 Lennon Lane
Walnut Creek, California 94598
Dear Mr. Collins:
This letter is in response to the information and questions in your letters
of June 25, 1987, July 7, 1987, and September 2, 1987, and in response to
your telephone inquiries. You have requested that Region V reconsider its
position on what fuel combustion equipment should be counted toward the 250
million Btu/hr cut off given in the Prevention of Significant Deterioration
(PSD) source category of "fossil fuel-fired steam electric plants of more
than 250 million Btu/hr heat input." You suggest that for the project of
concern the heat input of the gas turbine, which produces electricity
directly, should not be counted towards the 250 million Btu/hr because the
electricity is not generated from steam. You further suggest that your
interpretation is allowed by the PSD Workshop Manual dated October 1980.
In addition, you inquired about whether the higher or lower heating value
should be used for gas turbines which may be significant depending on the
outcome of the first determination.
After consultation with United States Environmental Protection Agency
(USEPA) Headquarters, we have made the following determinations with respect
to your requests.
- The definition of the PSD source category "steam electric plants"
should include the heat input of the gas turbine because the source
category is for a plant. The term "plant" is inclusive of all heat
generating equipment. A more restrictive term than "plant" could have
been used as is the case in another PSD source category, "fossil fuel
boilers totaling more than 250 million Btu/hr heat input." However, a
restrictive definition was not used in this case but the broad word
"plant" was used, and, therefore, it is appropriate to include all heat
generating equipment in determining the applicability for the fossil
fuel-fired steam electric plants.
- The PSD Workshop Manual in Section A.4 states that where a source may
not clearly fall into any one category, the applicant may consult the
definition of the affected facility in an applicable new
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source performance standard (NSPS). As you know, there is no NSPS for
"fossil fuel-fired steam electric plants of more than 250 million
Btu/hr heat input." Although there are NSPS's for certain emission
units within such steam electric plants, it is inappropriate to
conclude that the NSPS definition for affected facility should be
considered the same as the PSD source category for "steam electric
plants."
- With respect to the precedent setting value of another Region's
determination that the gas turbines should not be included in the 250
million Btu/hr heat input, we are not in a position to defend or refute
that position. Our determination is based upon staff support from the
Stationary Source Compliance Division and the Control Programs
Development Division of USEPA Headquarters.
- It is the general approach of the PSD regulations to be comprehensive
in its inclusion of activities or equipment and pollutants in making
regulation applicability determinations, whereas NSPS applicability is
emission-unit and pollutant specific. For example, in determining
applicability for most PSD categories, fugitive emissions are taken
into account as well as emissions from ancillary equipment, neither of
which is regulated by the comparable NSPS. It would be contrary to the
general approach of the PSD program to separate out specific equipment
or activities of a source while making an applicability determination.
- With respect to the heating value used in applicability determinations
involving gas turbines, the higher heating value should be used. (As
you are aware, the higher heating value includes the energy needed to
heat the moisture in the fuel. The data used in setting the gas
turbine NSPS, which was developed by the aircraft industry, introduces
the concept of a lower heating value). Although the lower heating
value is used for NSPS applicability determination, it is more
consistent to use the higher heating value of gas when calculating a
turbine's contribution for a PSD applicability determination for steam
electric plants. The higher heating values of gas and other fuels are
used in evaluating all other types of combustion equipment.
It is, therefore, our determination that the heat input associated with the
gas turbine must be included in the 250 million Btu/hr applicability limit
and that the higher heating value should be used for the turbine.
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If you have need for further clarification, please do not hesitate to
contact me at (312) 353-2211 or Ron Van Mersbergen, at (312) 886-6056.
Sincerely yours,
David Kee, Director
Air and Radiation Division (5AR-26)
cc: Gerald Avery
Air Quality Division
Michigan Department of Natural Resources |