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
19,
1999
SUBJ:
Initial
EPA
Comments
on
SCE&
G's
Hagood
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
a
significant
comment
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
Permit
condition
6.
B.
4
does
not
include
the
monitoring
requirements
necessary
for
the
facility
to
show
compliance
with
the
40
CFR
60,
Subpart
GG
nitrogen
and
sulfur
content
of
natural
gas
fired
in
Unit
01.
40
CFR
60,
Subpart
GG
requires
daily
analysis
to
determine
the
nitrogen
and
sulfur
content
of
natural
gas
being
fired
unless
a
custom
fuel
monitoring
plan
has
been
approved.
An
EPA
policy
guidance
document
entitled
"
Authority
for
Approval
of
Custom
Fuel
Monitoring
Schedules
Under
NSPS
Subpart
GG"
allows
the
facility
to
reduce
the
frequency
and
type
of
monitoring
for
showing
compliance
with
the
sulfur
and
nitrogen
content
if
certain
criteria
are
met.
It
is
unclear
if
the
criteria
detailed
in
this
document
have
been
met
so
as
to
justify
approval
of
a
custom
fuel
monitoring
plan
for
the
natural
gas
combusted
in
the
turbine.
If
such
is
the
case,
the
Department
should
list
the
specific
criteria
that
have
been
met
and
what
the
current
monitoring
is
for
showing
compliance
with
these
two
40
CFR
60,
Subpart
GG
requirements.
The
Region
has
faxed
a
copy
of
this
guidance
document
to
the
Department.
Please
update
permit
condition
6.
B.
4
to
reflect
the
specific
monitoring
requirements
in
effect
for
both
nitrogen
and
sulfur
content
of
the
natural
gas
burned.
In
the
event
that
the
facility
has
not
received
approval
of
a
customized
fuel
monitoring
plan,
daily
monitoring
for
the
sulfur
and
nitrogen
content
of
natural
gas
is
required
to
be
included
in
permit
condition
6.
B.
pursuant
to
40
CFR
60.333
and
60.334.

General
Comments
Please
note
that
the
retired
unit
exemption
prepared
by
EPA
and
included
in
the
Acid
Rain
permit
for
the
Hagood
Station
expires
December
31,
1999.
If
the
units
under
this
exemption
wish
to
continue
to
be
exempt
it
will
be
necessary
for
SC
DHEC
to
renew
the
retired
unit
exemption
for
these
units.
Please
refer
to
the
"
Phase
II
Acid
Rain
Permit
Writers
Guide,"
Section
6,
for
recommended
language
to
be
included
in
such
an
exemption.
In
addition
we
recommend
that
language
be
added
to
condition
4,
"
Permit
Application,"
that
indicates
that
the
Retired
Unit
Exemption
forms
that
are
attached
to
the
permit
are
incorporated
into
the
permit
and
constitute
enforceable
parts
to
the
permit.
