_____________________________________________ 

] 

Newington Energy, LLC ] FINAL RACT ORDER

Newington Power Facility ] ARD-04-001 

200 Shattuck Way, Newington, NH ] June 20, 2007 

_____________________________________________ ] 

A. Introduction

This NOx RACT Order is issued by the New Hampshire Department of Environmental Services, Air 

Resources Division, to Newington Energy, LLC pursuant to RSA 125-C. 

B. Parties

1. The New Hampshire Department of Environmental Services, Air Resources Division ("DES"), is a 

duly constituted administrative agency of the State of New Hampshire having its principal offices at 

29 Hazen Drive, Concord, NH 03302-0095, telephone number (603) 271-1370. 

2. Newington Energy, LLC (NEL) is a Delaware Limited Liability Corporation, having a mailing 

address of 15 Agawam Avenue, West Springfield, MA. 

C. Statements of Fact and Law

1. NEL operates the Newington Power Facility located at 200 Shattuck Way in Newington, NH. 

2. NEL is a 525 megawatt combined cycle electric generation facility, which is fully permitted to 

operate as such by DES. 

3. On December 4, 2001, NEL was issued a Temporary Air Permit for One Natural Gas-Fired Auxiliary 

Boiler, Eight Natural Gas-Fired Fuel Gas Heaters, One Diesel-Fired Emergency Generator, and One 

Diesel-Fired Firewater Pump, State Permit No. TP-B-0483. 

4. Effective May 20, 1994, DES adopted PART Env-A 1211 NITROGEN OXIDES (NOx). Effective 

October 31, 2002, DES revised and adopted Env-A 1211. 

5. In compliance with Condition V.B of Temporary Permit No. TP-B-0483, a NOx Reasonably 

Available Control Technology Plan (“NOx RACT Plan”) was required for the eight fuel gas heaters, 

rated at 2.0 MMBtu/hr each. NEL, through its consultant TRC Environmental Corporation, filed a 

“NOx RACT Plan for Fuel Gas Heaters,” dated April 23, 2002. The NOx RACT Plan was filed in 

compliance with the requirements of Env-A 1211.14, Emission Standards and Control Options for 

Miscellaneous Stationary Sources.

6. On September 9, 2002, DES issued RACT Order # ARD-02-003 to NEL for the eight fuel gas 

heaters. The RACT Order required NEL to install and operate low NOx burners and comply with 

NOx emission limits of 12 ppm and 0.018 lb/MMBtu for each of the eight fuel gas heaters. 

7. On September 9, 2002, DES submitted to United States Environmental Protection Agency (USEPA) 

NOx RACT Order # ARD-02-003 as a revision to the New Hampshire State Implementation plan 
Newington Energy, LLC June 20, 2007 

ARD-04-001 Page 2 of 3 

(SIP). 

8. NEL’s current NOx emitting sources include two combustion turbines and their associated heat 

recovery steam generators with duct burners, an auxiliary boiler, a firewater pump, an emergency 

generator, and eight fuel gas heaters. 

9. On July 26, 2004, NEL, through its consultant Earth Tech Corporation, submitted a revised NOx 

RACT Plan for new fuel gas heaters. The revised plan proposes replacing the eight fuel gas heaters 

(rated at 2.0 MMBtu/hr each) with six fuel gas heaters, rated at 2.4 MMBtu/hr each. This reduces the 

total heat input rate of the fuel gas heaters from 16 MMBtu/hr to 14.4 MMBtu/hr. The vendor NOx 

emission guarantee on the Low NOx burners is 9.9 ppm at 3% O2. NEL estimates that the emission 

factor will be approximately 0.0120 lb NOx/MMBtu or 0.0289 lb NOx/hr for each fuel gas heater. 

This equates to a potential reduction of 0.51 tons NOx per year when compared to NOx emissions 

from the current fuel gas heaters. 

10. NEL analyzed alternative methods for lowering NOx emissions including the following: 1) the use of 

low sulfur distillate fuel oil; 2) NOx emission reduction credits (ERCs) or discrete emission 

reductions (DERs); and low NOx burners. The use of low sulfur distillate fuel oil would increase the 

NOx emissions by approximately a factor of eight over the use of the vendor supplied NOx emissions 

for natural gas firing; therefore, NEL did not choose this option. As the NOx emissions from all eight 

burners are 0.76 tons per year, NEL dismissed the use of DERs or ERCs because of the high 

administrative costs of a low quantity of credits. NEL chose to use low NOx burners to meet the 

NOx RACT requirements. 

11. NEL also reviewed the US EPA RACT/Best Available Control Technology/Lowest Achievable 

Emission Rate (BACT/LAER) Information System clearinghouse to search for other for natural gasfired combustion devices with low NOx emissions. NEL searched the database for comparably sized 

units (up to ten times larger in heat input) that were installed since the original RACT Order was 

issued on September 9, 2002. No permits of comparably-sized units were found with lower NOx 

emissions. 

12. When DES submits RACT Order # ARD-04-001 to EPA as a SIP revision, the new RACT Order will 

supersede the NOx RACT Order ARD-02-003 and DES will request for the withdrawl of the 

September 9, 2002 submittal. 

D. Order

Based upon the above findings and determinations, DES hereby orders NEL as follows: 

1. Install and operate low NOx burners on each of the six new fuel gas heaters. 

2. Comply with a NOx emission concentration of 9.9 ppm @3%O2 and a 0.012 lb/MMBtu emission rate 

for each of the six new fuel gas heaters. 

3. Perform annual efficiency tests to determine the combustion efficiency (percent), the NOx emission 

concentration (ppmvd), CO concentration (ppmvd), oxygen levels (percent), and carbon dioxide 

levels (percent). 
Newington Energy, LLC June 20, 2007 

ARD-04-001 Page 3 of 3 

4. Maintain records of the combined monthly fuel consumption of the six fuel gas heaters. 

5. Maintain records of the hours of operation, based on the fuel flow data, when any of the six fuel gas 

heaters are operating. 

6. Comply with the record keeping and reporting requirements of the New Hampshire Code of 

Administrative Rules, Chapter Env-A 900. 

Please address any correspondence and communication in reference to this Order to the following: 

Ms. Padmaja Baru 

NHDES, Air Resources Division 

Stationary Source Management Bureau 

29 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

(603) 271-2630 

____________________________________ 

Robert R. Scott, Director 

Department of Environmental Services 

Air Resources Division 

cc: Timothy Drew, PIP Office 

David Conroy, US EPA 

 Alan Douglass, CED 

Town Selectmen, Newington 

RRS/pb