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 Box2750 Honolulu, Hawaii 96840-0001 DearMr. Munger: We are responding to two letters dated October 27,2010, from Mr. Stephen Ward ofyourDepartment. Each letter transmitted a report by Trinity Consultants, who evaluated the feasibility ofemissions controls at the Kanoelehua-Hill Power Plant and at the Kahului Generating Station. Please reply within 45 days to our requests for further information inthe enclosed EPA Review of BART 

### andRP

### Analyses. Our office has reviewed the reports, and found that the evaluation ofcontrol options and alternatives is incomplete. We are primarily interested 

### in a feasibility assessment ofswitching 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 ofavailability. The reports were in response to EPA's determination that emissions from four powerplants cause or contribute to haze at Hawaii's two national parks. These facilities are Kanoelehua-Hill, Puna and Shipmanpowerplants on the BigIsland, 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 Shipmanplants. Please note that we are interested in another facility owned by HECO for the purpose ofreducing regional haze in the national parks. Hawaii's DepartmentofHealth, onbehalfofEPA, sent a letter dated June 15,2011 to Mr. Michael Ribao requesting informationon emissions from the Maalaea Generating Station on Maui. EPA plans to usethis information to determine whether emissionsfrom Maalaea cause or contribute to visibility impairment at Haleakala orVolcanoesNational Parks. Ifthe emissions significantly affect visibility in either one ofthe parks, we may conduct, or request that HECO conduct, a reasonable progress analysis to determine whether emissions controls onthis 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, wehave enclosed copies ofboth letters. We understand that these letters were forwarded to HECO, where Mr. Ward was designated as thepoint ofcontact. As a result, we are redirecting our correspondence to HECO, and sending copies ofthis letter to the plant managers as well as Mr. Ward.

Printed 011 Rene/edPaperEPA Region 9 is developing a Federal Implementation Plan for a Regional Haze Program in Hawaii. The national goal ofthe 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 169Aofthe CleanAirAct. EPAhas previously determined that emissions from four power plants are degrading visibility at Hawaii VolcanoesNational Park and/or HaleakalaNational Park. Please contactme at 415-947-8715 ifyou have any questions or concerns, orhave your staffcontact TomWebb 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