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OAR Box 1778 

Prepped by Ollie Stewart 

Document Number: 

41) ll-B-16 

Docket Number: 

A-90-06 

Printed 10/28/2008 9:50:53 AM Sheet 41 of 276 
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i PSOV 

UNITED STATES ENVIRONMENTAL PR 

\\\\S 

SUBJECT: 

FROM: 

TO: 

\WASHINGTON, D.C. 20460 

JUL 2 8 1933 

II-B-16 

OFFICE OF 

AIR. NOISE AND RADIATION 

idgeport Harbor Coal Conversion 

Director 

Stationary Source Compliance Division 

Office of Air Quality Planning and Standards 

Harley Laing, Director 

Air Management Division, Region I 

This is in response to your June 8, 1983 request for an 

applicability determination concerning the conversion to coal 

of Bridgeport Harbor Unit #3. Your opinion is that the conversion should not be subject to either PSD or NSPS requirements 

because you feel the boiler was originally designed to burn 

coal, and as such is exempt under §60.14(e)(4) from NSPS coverage 

and under §52.21(b)(2)(iii)(e)(1) from PSD coverage. You 

asked for our concurrence in this opinion. 

United Illuminating Company (UI) wants to burn coal in 

its 400 MW capacity Bridgeport Harbor Unit #3 (it currently 

burns oil) and requests your determination that such a conversion 

is exempt from NSPS and PSD applicability. UI contends that 

the unit was originally designed to accommodate coal, and has 

supplied copies of the original proposal, contract and designs 

to support this position. Even though a decision was made in 

1967, during the latter stages of construction, to use oil as 

the primary fuel, no coal-firing equipment was deleted from 

the contract and all equipment contracted for was installed. 

Additionally, coal handling facilities, pulverizers, ash and 

slag handling equipment and all other systems and equipment 

required for pulverized coal firing of the unit were installed. 

Since coal was never burned in the unit, changes are now 

necessary to enable its use. Such changes include modifications 

to tubing within the boiler, the addition of flame scanners, burners, 

ignitors and relays, and piping and wiring to allow for bottom 

ash removal. In addition, the pulverizers must be made 

functional. These changes to the steam generating unit are 

estimated to cost approximately 5 million dollars. 
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The NSPS for electric utility steam generating units, 

40 CFR 60, Subpart Da, provides an exemption from coverage 

for conversion from oil to coal. See §60.40a(d): 

Any changes to an existing steam generating 

unit originally designed to fire gaseous or 

liquid fossil fuels to accommodate the use 

of any other fuel (fossil or nonfossil) shall 

not bring that unit under the applicability 

of this subpart. 

A less inclusive provision exempts coal conversions from 

Subpart D NSPS applicability if the existing facility was designed 

to accommodate coal before August 18, 1971. See §60.14(e)(4), 

which exempts from the modification provisions: 

Use of an alternative fuel or raw material if, 

prior to the date any standard under this part 

becomes applicable to that source type, the 

existing facility was designed to accommodate 

that alternative use. A facility shall be 

considered to be designed to accommodate 

an alternative fuel or raw material if that use 

could be accomplished under the facility's 

construction specifications as amended prior to 

the change. 

Bridgeport Harbor Unit #3 is exempt from Subpart Da coverage 

because of the provision at §60.40a(d). My staff has examined 

the conversion as related to Subpart D applicability, and discussed 

it with EPA's Emission Standards and Engineering Division (ESED). 

The construction specifications for unit #3 outlined in your 

memorandum clearly indicate that the unit was designed to 

accommodate coal prior to the Subpart D applicability date, 

even though coal was never burned. Also, the approximately 5 

million dollars which UI must spend on the affected facility, the 

steam generating unit, to enable it to actually burn coal, is 

minimal compared to the costs of a coal conversion, and represents 

only minor adjustments to equipment already in place. For these 

reasons, both SSCD and ESED concur with your conclusion that Unit 

#3 is exempt from coverage under Subpart D as well as Subpart Da. 

The question of PSD applicability is more difficult because 

it is necessary to determine if the entire plant, rather than 

simply the boiler, was capable of accommodating coal before the 

January 6, 1975 applicability date. In a telephone conversation 

on July 19, 1983 between Robert Myers of my staff and John Courcier 
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of your office, John related to Bob the extent to which UI has 

incorporated coal capability at their Bridgeport Harbor Station. 

Apparently UI has already put in place, prior to January 6, 1975, 

all of the coal handling and support facilities necessary for 

the combustion of coal. This equipment continues to be available and 

only requires some minor adjustment in order to accommodate coal 

at Unit #3. Therefore, it is the opinion of this office that 

UI's Bridgeport Harbor Station was capable of accommodating the 

alternative fuel prior to January 6, 1975, and is exempt 

from the PSD permitting requirements pursuant to §52.21(b)(2) 

(iii)(e)(1). 

This response has received the concurrence of both OAQPS 

and the Office of General Counsel. Please contact Robert 

Myers at FTS 382-2875 if you have additional concerns. 

Edward E. Reich 

cc: Jack Farmer 

Walt Stevenson 

Earl Salo 

Dave Rochlin 

Mike Trutna 

Peter Wyckoff 
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•' > " UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

DA-5E: June 8, 1983 

SUBJECT 

FROM 

PSD Applicability for Bridgeport Harbor Coal Conversion 

Harley F. Laing, Director \\\ ^ 

Air Management Division Region I 

TO Edward E. Reich, Director 

Division of Stationary Source Enforcement 

Issue 

Region I requests your concurrence in our determination that 

the Bridgeport Harbor Unit #3 is not subject to either PSD or 

NSPS requirements. It is our belief that the boiler was originally designed to burn coal and the changes that are being undertaken at UI's Bridgeport Harbor station do not constitute a major 

modification as defined under PSD and NSPS, and therefore, should 

be exempt from these reviews. 

Background 

The United Illuminating Company (UI) has filed an application with 

the Connecticut Department of Environmental Protection (CT DEP) to 

burn coal in Unit #3 (BHS 3) at UI's Bridgeport Hatbor Station. 

The CT DEP issued UI an operating permit for BHS 3, and has since 

requested that Region I determine whether or not the coal conversion 

at BHS 3 (which was originally designed to burn coal) should be 

considered a modification and therefore subject to the PSD and/or 

the NSPS regulations (40 CFR Part 60, Subparts D and Da). 

UI contends that BHS 3 was originally designed to accommodate coal. 

In fact, they have supplied the CT DEP with copies of the original 

proposal, contract, and designs which indicate that coal was indeed 

intended to be the primary fuel. During the latter stages of the 

construction in 1967-1968, a decision was made to use oil as the 

primary fuel and coal as a secondary fuel. However, no coal 

firing equipment was deleted from the contract and all coal firing 

equipment contracted for was installed. In addition, all of the 

other systems and equipment required for pulverized coal firing of 

the unit, including coal handling facilities, pulverizers and ash 

and slag handling equipment, were similarly specified by UI and 

installed by UI's contractor. 

At a state investigative hearing on the coal conversion, certain 

additional facts were revealed. Although UI showed that the boiler 

was originally designed and built to burn either coal or oil, 

significant heat exchange surface alterations were made to allow 

for continuous, long-term oil burning. Coal has never been burned 

in the BHS 3. Some modifications to BHS 3 are now necessary in 

order to allow for continuous, reliable coal burning at partial 

EPA F«m 13204 (R.v. 3-76) 
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load or oil at full load, including modifications to tubing within 

the boiler, as well as to some of the auxiliary equipment. Other 

changes to the unit include the addition of flame scanners, burners 

and ignitors, and additional relays. Certain piping and wiring to 

allow the bottom ash removal system, certain coal handling equipment 

and the pulverizers to be functional is also necessary. Additional 

equipment modification would have been necessary in 1968 to burn 

coal, but because oil was to be used as fuel, such modifications 

were never fully completed. Although the state hearing officer 

concluded that extensive "physical changes and additions" to the 

BHS 3 totalling some $35 million constitute a modification to a 

stationary source, the CT DEP did not require UI to obtain a modified source permit for BHS 3. The state did, however require Ul 

to obtain an operating permit to convert to coal. 

Rationale 

NSPS (Subpart D): 40CFR 60.14(e)(4) exempts a change to a facility 

(in this case, a boiler) from consideration as a modification if the 

emissions increase from such change results from use of an alternative fuel, provided the use of the alternative fuel could be accommodate under the facility's construction specifications as amended 

prior to the change. UI's designs for BHS 3, as well as their 

contract, specified all equipment necessary for burning coal as the 

primary fuel. 

All major equipment was installed. It is Region I's opinion that 

the alterations to the boiler necessary to burn coal presently result from the 1968 alterations to the boiler that were made to 

enable the boiler to burn oil, and as such do not constitute a 

modification. 

NSPS (Subpart Da): 40 CFR 60.40a(d) exempts an oil burning unit from 

the provisions of Subpart Da if such unit is modified to burn coal. 

PSD: 40 CFR 52.21(b)(2)(iii)(e)(1) exempts a change to a source (in 

this case, the generating station) from consideration as a major 

modification if such change results from the use of an alternative 

fuel, provided the source could accommodate the alternative fuel 

prior to January 6, 1975. BHS 3 was built before this date and was 

designed to burn coal, and is therefore exempt from PSD. If your 

office concurs with Region I's determination, please advise 

us by June 24, 1983. If your office does not concur, please forward 

your determination by July 8, 1983. 

Since several parties are anxiously awaiting this determination we 

would appreciate your response by the dates indicated above. 

If you should have any questions, or should need additional information, please contact John Courcier (FTS 223-5137) of my staff. 

cc: Rich Biondi, DSSE 

Marcus McCraven, UI 

Leonard Bruckman, CT DEP , 

Mike Trutna, QAQPS