June 10, 2021

Mr. Gregory J. Mitchell, General Manager  -  Keystone Station
gmitchell@keyconops.com
Keystone Conemaugh Project, LLC
175 Cornell Road
Blairsville, PA 15717


Re:	Title V Operating Permit 03-000027 Modification Application
      Keystone Conemaugh Project, LLC
      Keystone Generating Station
      Units 1 & 2 & Auxiliary Boilers A & B RACT II Compliance
	Plumcreek Township, Armstrong County
	APS # 1002530, Auth #1349542, PF # 275229

Dear Mr. Mitchell,

The Department of Environmental Protection (DEP) has reviewed the above referenced operating permit significant modification application (Keystone Generating Station TV-03-00027) and has identified the following technical deficiencies.  This information is required pursuant to 25 Pa. Code §127.541.

 The following data should be supplied for all hours during the years 2017 to 2020 in an electronic format, preferably in an excel spreadsheet. This data should be given in hourly increments in a form that it can easily be added to the publicly available CAMD data (sample attached).

          The hourly exhaust temperature at the inlet to the SCR for each unit

          The hourly ammonia injection rate

 Please provide SCR operations and maintenance manual. If you wish to keep certain information confidential, please see the Confidential Business Information (CBI) Procedure, below.

      Confidential Business Information (CBI) Procedure

      Any CBI claims must be addressed at the time of submittal.  Please be aware that DEP has a specific procedure for deciding confidentiality requests from source owners made under Section 13.2 of the Air Pollution Control Act (APCA), 35 P.S. Section 4013.2.  This procedure requires that source owners submit their request in writing to DEP.  The request must specifically designate which items of information the source owner wishes DEP to treat confidentially, along with a reason why those items should be treated in this manner.  The word "confidential" on a page or plan sheet submitted to DEP has no validity by itself.  Each item must be identified, and justification presented per Section 13.2 of the APCA for why it warrants confidential treatment.

             Pursuant to Section 13.2 of the APCA, information can generally qualify for confidential treatment if it is not emission data and if disclosure of the information would divulge production or sales figures or methods, or would divulge a unique process or production, or would otherwise adversely affect competitive position by revealing trade secrets.

             In order to request confidential treatment for information in any document, you must submit a redacted version of the relevant document with the confidential information blacked out (and thus suitable for public disclosure), along with a letter of request containing a table identifying the page and line number of each redaction, along with a justification for each redacted item as to why it should be deemed confidential under the specific criteria allowed under Section 13.2 of the APCA.  Please see the Example Confidential Information Log to use as a guide when submitting your confidentiality justifications.
            
             DEP's final decision on any CBI request will be sent to you in writing, along with a notice of appeal rights in the event the request is denied.  Please be aware that if you do not provide adequate justification for each redacted item such that it meets one of the specific criteria for confidential treatment under Section 13.2 of the APCA, your request may be denied.

Example Confidential Information Log
Page # in Document
Description 
Basis for Confidential Treatment as Identified in the Pennsylvania Air Pollution Control Act, 
35 P.S. § 4013.2
 
 
 
 
 
 
 
 
 
 
      
You must submit a response fully addressing the significant technical deficiencies set forth above within 15 business days of receipt of this letter or the Department may deny the application.

If you believe that any of the stated deficiencies is not significant, instead of submitting a response to that deficiency, you have the option of asking the Department to make a decision based on the information with regard to the subject matter of that deficiency that you have already made available.  If you choose this option with regard to any deficiency, you should explain and justify how your current submission satisfies that deficiency.  Please keep in mind that if you fail to respond, your application may be denied.

Should you have any questions regarding the identified deficiencies, please contact me at hflaherty@pa.gov or David Balog at 814-332-6328 or dbalog@pa.gov, and refer to TV-03-00027 to discuss your concerns or to schedule a meeting.  The meeting must be scheduled within the 15-day period allotted for your reply, unless otherwise extended by the Department.  You may also follow your application through the review process via eFACTS on the Web at:  http//www.ahs2.dep.state.pa.us/eFactsWeb/default.aspx.

Sincerely,

/s/ Hubert Thomas Flaherty

Hubert Thomas Flaherty
Air Quality Engineer
Air Quality Program

cc:  	AQ/Facilities/Permits/03-00027
	New Castle District Office
	Harrisburg
