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July 27, 1987 Ambient Air Issue from New Jersey Department of Environmental Protection (DEP) 7.7
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ERRORS. TO OBTAIN A LEGAL COPY OF THE ORIGINAL DOCUMENT, AS IT
CURRENTLY EXISTS, THE READER SHOULD CONTACT THE OFFICE THAT ORIGINATED
THE CORRESPONDENCE OR PROVIDED THE RESPONSE.
7.7
MEMORANDUM
FROM: G.T. Helms, Chief
TO: William S. Baker, Chief In response to your request, have reviewed your position with respect to a determination of ambient air applicability in the vicinity of the proposed EF Kenilworth, Inc. (EFKI) cogeneration unit in Union County, New Jersey. As we understand it, EFKI will build and operate the plant on property leased (long-term lease) from Schering Corporation. As we see it the EFKI operator will be completely separate from the Schering operation and except for the land owned and operated by a different Company. The fact that EFKI has entered into a contract to supply electricity/steam to Schering is not really relevant to the ambient air issue. We agree with your position that all property outside of the property leased and controlled by EFKI would be considered ambient air. The word "controlled" is emphasized since nothing is said in either your memorandums or New Jersey's letter to Region II about what, if any, fence or other physical barrier would be installed to prevent public access to the EFKI leased property. If such physical barrier is not erected, then all land including the leased site would have to be considered as ambient air. If you have any questions, please contact Sharon Reinders, at 629-5255.
cc: D. Tyler
DATE: Jun 19, 1987 SUBJECT: Ambient Air Issue from New Jersey Department of Environmental Protection
FROM: William S. Baker, Chief
TO: G.T. Helms, Chief Attached is a copy of a letter directed to us by the State of New Jersey's Department of Environmental Protection. It requests an EPA determination on what constitutes "ambient air" for a particular air permit application. Kevin Doering explained this issue to Dean Wilson of the Modeling Clearinghouse on June 2 and provided him with our preliminary determination. We believe that, because the cogeneration facility could operate independently and will provide power to other sources outside of the Schering Corporation, property outside of its property line should be reviewed for ambient impact. We would appreciate your review and concurrence or comment. We would like to be able to respond to Dr. Berkowitz within two weeks if possible. Thank you for your help. Attachment
JORGE H. BERKOWITZ, Ph.D.
Conrad Simon, Director Dear Mr. Simon: We are reviewing an air pollution control permit application for the proposed Kenilworth, Inc. (EFKI) cogeneration system at the Schering corporation facility in Kenilworth, Union County. Schering has entered into an agreement with EFKI to have EFKI supply the electrical energy and process steam for Schering's manufacturing plant through a cogeneration system to be constructed on property leased by EFKI from Schering (see attached). The leased property is within the property line of Schering's Kenilworth facility. The cogeneration system is to be built, owned and operated by EFKI. We request EPA's interpretation of "ambient air" (40 CFR 50.1(e)) with regard to the portion of the Schering property that is not leased to EFKI. In our air quality modeling analyses of the emissions from the EFKI facility, should we consider the property line to be the boundary of the leased property or the boundary of the Schering plant? Please have EPA's determination forwarded in writing to William O'Sullivan (609-984-6721) at your earliest convenience. The resolution of this issue will remove a major question in the review of this application. Thank you.
JHB/TJ/df
c. H. Wortreich
EBASCO SERVICES INCORPORATED
The following discussion presents an approach to the air quality evaluation of a proposed cogeneration facility (the "Facility") to be built, owned and operated in Kenilworth, New Jersey by EF Kenilworth, Inc. ("EFKI"), a wholly owned subsidiary of Energy Factors, Incorporated ("EFI"), a California corporation engaged in the business of developing, owning and operating electric and thermal energy production facilities throughout the United States. The Facility is to be constructed on a site (the "Site") which has been leased by EFKI from Schering Corporation ("Schering"), a wholly-owned subsidiary of Schering-Plough Corporation ("Schering-Plough") for a term of fourteen years (plus two renewal terms of ten years each) pursuant to a Site Lease between Schering and EFKI dated as of December 10, 1985. EFKI has entered into a Turnkey Construction Contract with Ebasco Constructors Inc., dated as of July 29, 1986, for the construction of the Facility, which is projected to be completed on or prior to June 1988.
The Facility will produce electrical energy and process steam. EFKI has
entered into a power purchase agreement (the "PPA") with Jersey Central
Power and Light Company ("JCP&L") dated as of May 20, 1986, for the sale by
EFKI of electrical energy from the Facility to JCP&L, which energy would be
wheeled from the Site to JCP&L by Public Service Electric & Gas Company
("PSE&G"). EFKI has also entered into an Energy Services Agreement (the
"ESA") with Schering dated as of December 10, 1985, pursuant to which EFKI
will supply Schering with Schering's electrical energy and process steam
requirements at its pharmaceutical manufacturing plant located adjacent to
the Facility Site.
A. General
- The Facility has a nameplate rating of 29,500 kW while extracting a minimum flow of 17,000 lb/hr of steam. |