November
1,
1999
4APT­
ARB
Howard
L.
Rhodes,
Director
Air
Resources
Management
Division
Florida
Department
of
Environmental
Management
Mail
Station
5500
2600
Blair
Stone
Road
Tallahassee,
Florida
32399­
2400
SUBJ:
EPA's
Review
of
Proposed
Title
V
Permit
No.
0170004­
004­
AV
Florida
Power
Corporation
Crystal
River
Plant
Dear
Mr.
Rhodes:

The
purpose
of
this
letter
is
to
notify
the
Florida
Department
of
Environmental
Protection
(
FDEP)
that
the
U.
S.
Environmental
Protection
Agency
(
EPA)
formally
objects
to
the
issuance
of
the
above
referenced
proposed
title
V
operating
permit
for
the
Florida
Power
Corporation
(
FPC)
Crystal
River
Plant
in
Citrus
County,
Florida,
which
was
received
by
EPA,
via
e­
mail
notification
and
FDEP's
web
site,
on
September
17,
1999.
This
letter
also
provides
our
general
comments
on
the
proposed
permit.

Based
on
EPA's
review
of
the
proposed
permit
and
the
supporting
information
received
for
this
facility,
EPA
objects,
under
the
authority
of
Section
505(
b)
of
the
Clean
Air
Act
("
the
Act")
and
40
C.
F.
R.
§
70.8(
c)
(
see
also
Florida
Regulation
62­
213.450),
to
the
issuance
of
the
proposed
title
V
permit
for
this
facility.
The
basis
for
EPA's
objection
is
that
the
permit
does
not
assure
compliance
with
all
applicable
requirements
as
required
by
40
C.
F.
R.
§
70.1(
b)
and
40
C.
F.
R.
§
70.6(
a)(
1).
Specifically,
the
permit
does
not
contain
terms
or
conditions
assuring
compliance
with
Prevention
of
Significant
Deterioration
requirements
applicable
to
this
facility
under
the
Clean
Air
Act,
the
Florida
State
Implementation
Plan,
and
40
C.
F.
R.
part
70.
In
addition,
the
permit
does
not
fully
meet
the
periodic
monitoring
requirements
of
40
C.
F.
R.
§
70.6(
a)(
3)(
i),
and
the
permit
does
not
assure
compliance
with
the
requirements
of
40
C.
F.
R.
§
70.6(
a)(
1).
Pursuant
to
40
C.
F.
R.
§
70.8(
c),
this
letter
and
its
enclosure
contain
a
detailed
explanation
of
the
objection
issues
and
the
changes
necessary
to
make
the
permit
consistent
with
the
requirements
of
40
C.
F.
R.
part
70
and
assure
compliance
with
applicable
requirements
of
the
Clean
Air
Act.
The
enclosure
also
contains
general
comments
applicable
to
the
permit.

Section
70.8(
c)
requires
EPA
to
object
to
the
issuance
of
a
proposed
permit
in
writing
within
45
days
of
receipt
of
the
proposed
permit
(
and
all
necessary
supporting
information)
if
EPA
determines
that
the
permit
is
not
in
compliance
with
the
applicable
requirements
under
the
Act
or
the
requirements
of
40
C.
F.
R.
Part
70.
Section
70.8(
c)(
4)
of
the
title
V
regulations
and
Section
505(
c)
of
the
Act
further
provide
that
if
the
State
fails
to
revise
and
resubmit
a
proposed
permit
within
90
days
to
satisfy
the
objection,
the
authority
to
issue
or
deny
the
permit
passes
to
EPA,
and
EPA
will
act
accordingly.
Because
the
objection
issues
must
be
fully
addressed
within
the
90
days,
we
suggest
that
the
revised
permit
be
submitted
in
advance
in
order
that
any
outstanding
issues
may
be
resolved
prior
to
the
expiration
of
the
90­
day
period.

If
you
have
any
questions
or
wish
to
discuss
this
further,
please
contact
Mr.
Gregg
Worley,
Chief,
Operating
Source
Section
at
(
404)
562­
9141.
Should
your
staff
need
additional
information,
they
may
contact
Ms.
Kelly
Fortin,
Environmental
Engineer,
at
(
404)
562­
9117
or
Ms.
Lynda
Crum,
Associate
Regional
Counsel,
at
(
404)
562­
9524.

Sincerely,

Original
Signed
by:
James
S.
Kutzman
for
Winston
A.
Smith
Director
Air,
Pesticides
&
Toxics
Management
Division
Enclosure
cc:
Joseph
H.
Richardson,
President
&
CEO,
FPC
W.
Jeffery
Pardue,
Director
Env.
Services,
FPC
Clair
Fancy,
P.
E.,
FDEP
A.
A.
Linero,
FDEP
