DEP Air Quality Review Documents – June 25, 2013
[Monday Morning Pipeline News is discontinued for the time being, to free time for ongoing coverage of emerging information]
I went to Williamsport yesterday to review the PA Department of Environmental Protection’s Air Quality Program files on Penn State’s planned update to the East Campus Steam Plant and conversion of the West Campus Steam Plant from coal-fired to natural gas-fired.
There were four folders – three were about an inch thick, and the fourth was thinner – probably more than 1,000 pages in all, dating back to a meeting on March 25, 2011 between Penn State engineering and environmental compliance staff and DEP air quality staff. I copied about 120 pages – Dave Stone scanned them and I posted them here and also in the Right-to-Know timeline.
Nothing in the files undermined the consistent community position that the most reliable, cheapest and cleanest energy supply is energy that isn’t used at all: conservation, followed by carefully targeted renewables.
- Ian Salada – Manager, PSU Engineering Services
- Rhett McLaren – Environmental Compliance Specialist, PSU Engineering Services
- Heather McHale – Consultant, Coterie Environmental LLC
- Mohammad Zaman – Environmental Program Manager, Air Quality Program, DEP
- Thomas Calhoun – DEP-AQ North Central Regional Office
- Keith Allison – DEP, Chief of DEP-AQ Facilities Permitting Section
- David M. Shimmel, Chief of DEP-AQ New Source Review Section
(Check US-EPA for definitions)
- BAT – Best Available Technology (sometimes BACT – Best Available Control Technology)
- MACT – Maximum Achievable Control Technology
- ICI – Industrial/Commercial/Institutional designation
- NSR – New Source Review
- HAP – Hazardous Air Pollutants
- GHG – Greenhouse Gas
- PSD – Prevention of Significant Deterioration
- CT/HRSG – Combustion Turbine/Heat Recovery Steam Generator
- TVOP – Title V Operating Permit
- Major Source Status
- Area Source Status
Documents Copied/Referenced Documents Not Copied
- 3.25.11 – Report of Meeting between DEP staff Mohammad Zaman, Thomas Calhoun and [DMS? = David M. Shimmel, Chief of DEP-AQ New Source Review Section] and PSU staff and consultants, including Rhett McLaren, Ian Salada and Heather McHale. Zaman addressed Penn State’s plans for MACT compliance, intent to seek “area source status for HAP to compliy with the area MACT standards for ICI boilers” along with the potential for a “physical change” at a PSU plant to trigger the requirement for “New Source Review evaluation.” (2 pages)
- 10.6.11 – Combustion Turbine/Heat Recovery Steam Generator Compliance – Results of an internal investigation into a failure to install an air pollution control device in the CT/HRSG system. Letter from Rhett McLaren to Stephen Schulte at DEP. Note: Date-stamped “Received” by Air Quality division about 11 months later, on 9.4.12. (3 pages)
- 6.6.12 – Source Test Review of East Campus Steam Plant at PSU, letter from David R. Baker of DEP to Thomas Calhoun of DEP (8 pages)
- 6.18.12 – Original “Plan Approval Application” for East Campus Steam Plant Boiler Tube Replacement Project, prepared by Heather McHale of Coterie Environmental and submitted to DEP.
- 8.27.12 – DEP “Technical Deficiency Letter” – Comments on ECSP Boiler Tube Replacement Project – Zaman to Salada
- 8.29.12 – Semiannual Report for East Campus Steam Plant, Title VI Operating Permit, letter from Rhett McLaren to Mohammad Zaman; chart of Fiscal 2011/2012 Fuel Consumption and Boiler Operating Hours. (2 pages)
- 9.6.12 – Certification by Morgan Beacker, DEP Air Quality Specialist, that PSU submitted semiannual report of supporting calculations to verify compliance with NOx emissions 7.1.11 through 6.30.12. (1 page)
- 9.26.12 – PSU Response to 8.27.12 DEP “Technical Deficiency Letter” – Salada to Zaman (5 pages) plus two attachments: Spreadsheet of steam generated, in pounds, for ECSP and WCSP monthly July 2003 to June 2012 (3 pages, large format) and September 2012 – First Revision – “Plan Approval Application” for East Campus Steam Plant Boiler Tube Replacement Project, Section 3 – Regulatory Review only (8 pages)
- 10.1.12 – Original “Plan Approval Application” for West Campus Steam Plant Improvement Project, prepared by Heather McHale of Coterie Environmental and submitted to DEP.
- 10.16.12 – Rhett McLaren of PSU Letter to Centre County Commissioners regarding Plan Approval Application for WCSP submitted to DEP.
- 10.26.12 – Centre County Planning Director Bob Jacobs Letter to Rhett McLaren acknowledging receipt of notification regarding WCSP plan.
- December 2012 – First Revision “Plan Approval Application” for West Campus Steam Plant Improvement Project (45 pages)
- 12.12.12 – Letter from Zaman at DEP to Salada at PSU, notifying PSU that DEP has sufficient application materials for West Campus Steam Plant project to begin technical review.
- 12.18.12 – Email from Amy Frantz to multiple recipients within PSU, attaching “rolling 12-month” data for steam services coal consumption, natural gas consumption, and fuel oil consumption and for energy consumption at University Park. (5 pages)
- 1.7.13 – DEP Approval of East Campus Steam Plant Boiler Tube Replacement Project, from Keith Allison, Chief of DEP-AQ Facilities Permitting Section through David M. Shimmel, Chief of DEP-AQ New Source Review Section, to Muhammad Zaman, DEP-AQ Environmental Program Manager. Includes analysis of PSD/NSR (Prevention of Significant Deterioration/New Source Review) applicability, pages 1 – 6 only. (6 pages)
- 1.15.13 – West Campus Steam Plant Inspection Report by Joseph Basil of DEP
1.19.13 – PA Bulletin published notice about the ECSP Boiler Tube Replacement Project approval, starting 30 day public comment period, now expired.
- 1.23.13 – East Campus Steam Plant Inspection Report by Joseph Basil of DEP
- 1.24.13 – Email from Rhett McLaren to Muhammad Zaman, Thomas Calhoun and Keith Allison, regarding 11.16.12 telephone conference and subsequent conversations regarding construction timeline. At the time, McLaren was anticipating April 2013 DEP approval. (1 page)
- 2.2.13 – PA Bulletin published notice announcing DEP receipt the WCSP application and the start of technical review. It was not an approval announcement. As far as I can tell, the project is still under review and the public comment period has not begun.
- 2.21.13 – DEP “Technical Deficiency Letter” – Comments on WCSP Improvement Project – Zaman to Salada. (6 pages)
- 3.15.13 – PSU Response to 2.21.13 DEP “Technical Deficiency Letter” – Salada to Zaman, attaching – March 2013 – Second Revision – “Plan Approval Application” for West Campus Steam Plant Improvement Project
- 4.5.13 – Telephone conference between DEP, PSU and Coterie Engineering to expedite PSU’s response to identified deficiencies.
- 4.11.13 – DEP “Technical Deficiency Letter” – Comments on WCSP Improvement Project, documenting contents of 4.5.13 phone conversation. Zaman to Salada. Much of this letter is about Penn State’s ongoing failure to address compliance with New Source Review regulations. (4 pages)
- 5.1.13 – PSU Response to 4.11.13 DEP “Technical Deficiency Letter” – Salada to Zaman, attaching May 2013 – Third Revision – “Plan Approval Application for West Campus Steam Plant Improvement Project”
- 5.22.13 – Rhett McLaren of PSU Letter to Mohammad Zaman of DEP regarding PSU plans to comply with 40 CFR Subpart DDDDD in the coal to natural gas conversion, detailed tables reporting HAP.
- 6.10.13 – Review Memo for Renewal State Only Operating Permit Application (TVOP 14-00003), from Benjamin Hankins, DEP-AQ Facilities Permitting Section, through Keith Allison, DEP-AQ Chief, Facilities Permitting Section, to Muhammad Zaman, DEP-AQ Environmental Program Manager, reviewing emissions data and regulatory issues, and recommending TVOP renewal (12 pages)
- 6.10.13 – Notice of Intent to Issue TVOP 14-00003, starting 30-day public comment/request for public hearing clock. PSU required to provide public notice in the CDT within 10 days, for three consecutive days. I don’t know if they did that or not. Online archive of CDT Legal Notices only goes back to June 19.
As of June 24, there was no further West Campus Steam Plant documentation in the DEP file after the May 22 letter from Salada to Zaman.
Analysis post to follow…