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
CP&
L's
H.
B.
Robinson
Power
Plant
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
29
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rescinded,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."

3.
Condition
2
indicates
the
NOx
limit
for
H.
B.
Robinson/
Darlington
unit
1.
The
third
paragraph
of
this
section
notes
that
"
if
the
unit
fails
to
meet
the
annual
average
alternative
contemporaneous
emission
limitation
of
0.5
lb/
mmBtu
and/
or
has
an
annual
heat
input
greater/
less
than
10,065,000
mmBtu,
then
excess
emissions
will
be
assessed
in
accordance
with
40
CFR
77.6."
This
condition
should
be
corrected
to
indicate
"
greater
than,"
rather
than
"
greater/
less
than".

4.
The
Btu­
weighted
annual
emission
rate
indicated
in
the
left­
hand
box
on
page
one
of
the
Phase
II
NOx
Averaging
Plan
for
Carolina
Power
and
Light
should
be
corrected.
The
corrected
value
should
be
0.43
lb/
mmBtu
rather
than
0.44
lb/
mmBtu.
This
correction
was
made
on
the
Carolina
Power
and
Light
Phase
II
Averaging
Plans
and
incorporated
into
the
Phase
II
permit
for
the
other
facilities
in
the
plan.
(
Please
see
comments
submitted
on
January
9,
1999
to
John
Hiers
and
Matthew
Wike,
of
SC
DHEC
from
Jenny
Jachim,
EPA
Region
4).

General
1.
Permit
condition
6.
B.
5
on
page
30
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.
7
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.
5:

"
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
30
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.
