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Addition of Natural Gas Firing Capacity to the Greenwood Unit I Power Plant 4.46EPA Region V and Headquarters agree that a proposed conversion of an oil-fired unit to dual capacity for oil and gas firing would subject the Detroit Edison Greenwood Unit 1 Power Plant to a PSD review for NOx. Because the source did not own, or initiate plans to construct equipment necessary to deliver natural gas, EPA believes the source was not capable of accommodating natural gas prior to January 6, 1975. Second, actual emissions after the change to natural gas are deemed to be the sources' "potential to emit", and under this criteria the source will experience a "significant net emissions increase". A comparison of current allowable to future allowable emissions is irrelevant for PSD applicability purposes. Simple addition of gas to the boiler would not be subject to BACT. More information is necessary to assess the effect of other proposed changes at the plant.
Notebook Entries: 6.30