1'. O. Box 60(,6 

:\ewark, DE 19714·606tS 

VIA EMAIL AND US MAIL 

September 23,2008 

Mr. Jack Sipple, Environmental Scientist 

Air Quality Management Section 

Delaware Department of Natural Resources 

& Environmental Control 

156 South State Street 

Dover, DE 19901 

A New Generation of Energy 

RE: Conectiv Comments on Delaware's Proposed 

August 15, 2008 Visibility State Implementation Plan 

Dear Mr. Sipple, 

Conectiv Delmarva Generation (Conectiv or the Company) is pleased to provide the 

following comments to the Delaware Department of Natural Resources & Environmental 

Control (DNREC or the Department) regarding the Department's August 15,2008 

proposed State Implementation Plan (SIP) revision to the United States Environmental 

Protection Agency (USEP A) associated with the reduction of visibility impairing 

pollutants. Conectiv is a competitive energy supplier based in Newark, Delaware, with 

electric generating facilities in the mid-Atlantic region. The Company owns and operates 

two electric generating units (Edge Moor Units 4 and 5) in Delaware that may be affected 

by the proposed SIP submittal to the USEP A. 

As you know, Conectiv submitted to the Department a revised Best Available Retrofit 

Technology (BART) Analysis for Edge Moor Units 4 and 5 on July 25,2008. This 

analysis demonstrated that the Company's proposed compliance effort associated with 

implementation of the Department's Multipollutant Regulation (Delaware Regulation No. 

1146, "Electric Generating Unit (EGU) Multi-Pollutant Regulation") would also meet 

BART for the two affected Units at Edge Moor. 
Mr. Jack Sipple 

DNRECAQMS 

September 23,2008 

Page 2 

Delaware's Proposed Visibility State Implementation Plan (DE BART Plan) 

appropriately incorporates the BART options for Edge Moor Units 4 and 5 demonstrated 

in Conectiv's analysis. It is Conectiv's understanding that implementation ofthese 

options at Edge Moor 4 and 5 satisfies the DE BART Plan and federal BART 

requirements. It is Conectiv's further understanding that the DE BART Plan is based on 

modeling of short term (e.g. hourly) emissions rates for Edge Moor 4 and 5 only and that 

the annual emissions numbers discussed in the DE BART Plan were provided for 

comparative purposes, and not used as model inputs. 

As demonstrated by the Department, generating Units subject to Regulation No. 1146 are 

in the process of implementing the controls necessary to meet Regulation No. 1146 

emission requirements for affected pollutants. These controls are consistent with those 

adopted in the DE BART Plan. Conectiv, like the other entities with units subject to 

Regulation No. 1146, are relying on DNREC to ensure that the Regulation No. 1146 

implementation strategies for which air quality construction permits have been agreed to 

and issued by the Department are consistent with the DE BART Plan and federal BART 

requirements. 

Thank you for giving Conectiv this opportunity to comment on Delaware's proposed 

Visibility SIP Revision. Please incorporate these comments into the hearing record for 

this proceeding. 

Please feel free to contact me at (302) 451-5319 should you have any questions regarding 

the above. 

Sincerely, 

}eoJ!L 

Stuart Widom 

Sr. Environmental Consultant