Emailed by EPA’s Gerallyn Duke to DEP’s Muhammad Zaman and Thomas Calhoun on August 28, 2013. Duke was reviewing the proposed West Campus Steam Plant plan approval, prepared by Calhoun, dated July 25, 2013.
“NSR Applicability Determination
1. This project is aggregated, for NSR purposes, with a previously approved boiler re-tubing project at the East Campus Steam Plant. However, the boiler re-tubing project was for a very different purpose than this plan approval, thus aggregation does not appear to be warranted.
If the boiler replacement project is not aggregated with the boiler re-tubing project, the emissions from the re-tubing project must be included in Step 2 (netting) for the project at hand. In netting, the PTE minus BAE from the boiler re-tubing project must be used; there is no consideration for Could Have Accommodated. For NOx and CO2e, the PTE minus BAE are 116 tpy and 72,426 tpy respectively. The NOx Step 2 calculation is a negative 19.9 tpy, representing no net increase. However, for CO2e, the Step 2 calculation totals 121818 tpy, which triggers PSD. See attachment 1.
2. The review memo on page 3 states replacement provisions of 40 CFR §52.21 and PA rules apply. However, the “replacement” boilers are not identical to the old boilers; they are considered new units for NSR purposes…”