E-M:/ EPA says NO to MDEQ permit on Wyandotte Energy

["Alex J. Sagady & Associates" <ajs@sagady.com>]

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Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>
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EPA Region V says MDEQ air permit for Wyandotte 
Energy not approvable under the Clean Air Act.....


January 4, 1999

Lynn Fiedler, Supervisor
Permit Section
Michigan Department of Environmental Quality
P.O. Box 30260
Lansing, Michigan 48909-7760 
Dear Ms Fiedler:

The purpose of this letter is to inform you of the United
States Environmental Protection Agency's
(USEPA) position regarding the proposed Permit 
to Install for Wyandotte Energy. The USEPA's position
is that the application does not contain sufficient information 
for the permitting authority to make an
adequate determination of Best Available Control Technology 
(BACT) emission limitations. Under 40
CFR 52.21(n), the owner of a proposed source must 
submit all information necessary to perform an
analysis and make determinations.

Further, it is the position of the USEPA that the permit, 
as currently drafted, does not meet the
requirement of Section 165(a)(4) of the Clean Air Act 
(CAA), which requires the source to apply BACT
to meet achievable emission limits. Specifically, based on 
other similar sources and recently submitted
applications, the application of BACT for Nitrogen Oxides 
for this source should allow an emission limit of
no more that 3.5 - 4.5 parts per million at full load. The 
Nitrogen Oxides emission limit currently proposed
allows an emission limit of 9 parts per million at full load. 

Also, the permit application states that the facility 
is expected to run at full load most of the time. At full
load, the permit allows for emissions of Nitrogen Oxides 
of 66 pounds per hour. This equates to annual
emission of approximately 300 tons per year. However, 
the permit allows for total annual emissions of
1390 tons per year at any load condition. No accounting 
or justification is given for this difference.
Likewise, this full-load hourly versus variable-load annual 
analysis follows for the other regulated
pollutants for which BACT applies.

Finally, the permit and permit application do not contain 
an adequate Title IV applicability or compliance
determinations. Although not critical at this point in time, 
the permit also does not address periodic
monitoring requirements that will be necessary under Title V of the CAA.

Based on the issues outlined above, it is the position of 
the USEPA that this permit does not meet the
requirements of the CAA. We would like to continue to work 
with MDEQ to ensure that a permit meeting
the requirements of the CAA and associated rules and regulations 
is issued. If we can answer any
questions regarding these comments, please contact Eaton 
Weiler, Permit Engineer, at (312) 886-6041, or
me at (312) 353-0396.

Sincerely yours,

/s/

Robert Miller, Chief
Permits and Grants Section

Enclosure

cc: Mary Charley
Michigan Department of Environmental Quality

Dave Ferrier
Michigan Department of Environmental Quality


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Alex J. Sagady & Associates        Email:  ajs@sagady.com
Environmental Consulting and Database Systems
PO Box 39  East Lansing, MI  48826-0039  
(517) 332-6971 (voice); (517) 332-8987 (fax)

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