UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
 

REGION IX
 

75 Hawthorne Street
 

San Francisco, CA 94105-3901 

JUL 12 2011 

Mr. Brenner Munger 

Manager, Environmental Depatiment 

Hawaiian Electric Company, Inc. 

PO Box 2750 

Honolulu, Hawaii 96840-0001 

Dear Mr. Munger: 

We are responding to two letters dated October 27,2010, from Mr. Stephen Ward of your Department. 

Each letter transmitted a report by Trinity Consultants, who evaluated the feasibility of emissions 

controls at the Kanoelehua-Hill Power Plant and at the Kahului Generating Station. 

Please reply within 45 days to our requests for further information in the enclosed EPA Review ofBART 

and RP Analyses. Our office has reviewed the reports, and found that the evaluation of control options 

and alternatives is incomplete. We are primarily interested in a feasibility assessment of switching to 

lower sulfur residual fuel oil. We disagree with the contention in the two reports that this option is not 

technically feasible due to the residual fuel oil's higher viscosity and lack of availability. 

The reports were in response to EPA's determination that emissions from four power plants cause or 

contribute to haze at Hawaii's two national parks. These facilities are Kanoelehua-Hill, Puna and 

Shipman power plants on the Big Island, and the Kahului generating station on Maui. The analysis for 

Kanoelehua Hill also will provide a basis for determining whether emissions reductions are feasible at 

the nearby Puna and Shipman plants. 

Please note that we are interested in another facility owned by HECO for the purpose of reducing 

regional haze in the national parks. Hawaii's Department of Health, on behalf of EPA, sent a letter 

dated June 15,2011 to Mr. Michael Ribao requesting information on emissions from the Maalaea 

Generating Station on Maui. EPA plans to use this information to determine whether emissions from 

Maalaea cause or contribute to visibility impairment at Haleakala or Volcanoes National Parks. If the 

emissions significantly affect visibility in either one of the parks, we may conduct, or request that HECO 

conduct, a reasonable progress analysis to determine whether emissions controls on this source are 

required. 

EPA's determination that four facilities are subject to controls under the Regional Haze Rule was 

communicated to the HELCO and MECO plant managers on April 30, 2010 and May 24, 2010, 

respectively. For your convenience, we have enclosed copies of both letters. We understand that these 

letters were forwarded to HECO, where Mr. Ward was designated as the point of contact. As a result, 

we are redirecting our correspondence to HECO, and sending copies of this letter to the plant managers 

as well as Mr. Ward. 

Printed 011 Rene/ed Paper 
EPA Region 9 is developing a Federal Implementation Plan for a Regional Haze Program in Hawaii. 

The national goal of the program is to improve visibility in federally mandated national parks and 

wilderness areas as required by the Regional Haze Rule (40 CFR 51.308) under Section 169A of the 

Clean Air Act. EPA has previously determined that emissions from four power plants are degrading 

visibility at Hawaii Volcanoes National Park and/or Haleakala National Park. 

Please contact me at 415-947-8715 if you have any questions or concerns, or have your staff contact 

Tom Webb at 415-947-4139. 

Sincerely, 

ebora ordan 

Director, Air Division 

Enclosures 

Cc:	 Mr. Norman Verbanic, HELCO 

Mr. Michael P. Ribao, MECO 

Mr. Stephen Ward, HECO