Document mqM8QMkoBNa7JMo04m48oYj3g

' x' whiwib1 ,**t~**m**i -****" **' = **!** -yr.-v.- ^ jt.. INTERNAL CORRESPONDENCE------------------------------------------------------------------------------------------- EMICALS AND PLASTICS P. O. BOX 8361, SOUTH CHARLESTON, WEST VIRGINIA 25303 N*m*> ><on tion y to Mr. V. F. Viliam Date May 9, 1978 Originating Dept. EP Efig I flECT IIIQ Mr. J. C. Brannen Mr. T. J. Covin Mr. V. D. Dutcher /Mr-.. J. -F.- / flCts(lKo) Mr. S. J. Fillppone Mr. J. C. Hovious Mr. W. E. James Mr. R. W. Malone/D. L. Demuth Mr. J. D. Martin Mr. R. E. O'Bryan Mr. J. E. Pierce % Mr. R. if. Stodghi11 Mr. P. M. Thomasson Mr. W. R. van der Hoeven Subject Oil Conversion Permits rece:v _ j 1 2 h7d jp - Dear Mr. Vi 1lani: The following comments are-^offered relative to your April 18, 1978, memorandum on oil conversion permits. Conversions to fuel oil for combustion sources are approved via the construction permit application route. The three locations for which it was suggested permits be initiated are in the Prevention of Significant Deterioration (PSD) areas, thus subject to PSD regulations. The proposed PSD regulations state [52:21(h)(2)]: "Approval to construct shall become invalid if construction is not commenced within 18 months after receipt of such approval or if construction is discontinued for a period of 18 months or more. The Administrator may extend such time upon a showing that an extension is justified". Whether early Increment approval to insure mid-80's operational continuity is an acceptable justification Is questionable. I briefly discussed it with EPA's Region VI. They had "kicked this around" earlier and do not feel permit extensions would be granted. Boiler No. 30 at Taft was included in the 1977 application for a permit to fire 0.7% sulfur containing fuels in various combustion facilities. Approval was granted. However, it is doubtful that the permit would be valid in the mid-eighties. Further the magnitude of. the modifications indicates:it would fall under the New Source Performance Standard for boilers applicable at the time reconstruction was initiated. ucc 050221