TSD-vAdd



# Proposed Technical Addendum to Final BART Determina tions

for Affected BART-eligible Sources

in the State of New Jersey

Technical Support Document

State of New Jersey Department of Environmental Pro tection

Division of Air Quality

Bureau of Air Permits

401 E. State Street, 2 nd 

### floor, P.O. Box 27 Trenton, NJ 08625-0027



# July 25, 20112



### 1.0 ADDENDUM TO BEST AVAILABLE RETROFIT TECHNOLOGY (BAR T)

DETERMINATIONS

1.1 Introduction

To fulfill its obligation to complete its review of facilities subject to BART, 1 

### the New Jersey Department of Environmental Protection (NJDEP) subm itted its BART determinations to the United States Environmental Protection Agency (USEP A) Region 2 on March 2, 2011. 2 

### These facilities included: 1) PSEG Hudson Generating Stat ion, 2) Chevron Products, 3) Amerada Hess Port Reading Refinery, 4) ConocoPhillips Bayway Ref inery, and 5) Sunoco Eagle Point.

When asked by USEPA Headquarters to confirm its inv entory of BART-eligible coal-fired electric generating units (EGUs) in the Region, as part of an analysis to determine if the Transport Rule is better than BART, USEPA Region 2 subsequently identified three EGUs listed that were in operation as early as 1962, but were n ot included in NJDEP's BART determination. These EGUs are: 1) Vineland Municipal Electric Util ity (VMEU) - Howard M. Down, Unit 10, and 2) BL England Generating Station, Units 1 and 2

.

The Mid-Atlantic/Northeast Visibility Union (MANE-V U) formed a BART workgroup consisting of member states, including New Jersey, to assist with the BART requirements of the Regional Haze rule including the identification of potentially BART-eligible sources and the emission units that comprise them. The final MANE- VU list of applicable BART-eligible sources developed by NESCAUM 3 

### was the result of an iterative process spanning se veral years. At that time, these sources were anticipated to per manently shutdown as a result of enforceable agreements that were negotiated concurrent with the regional BART process. These enforceable agreements remain, and include options to control o r repower.

NJDEP has consequently determined that these facili ties should be included in this addendum to the Final BART Technical Support Document to provid e a complete picture on the status and commitments to reduce visibility-impairing emission s from these facilities through shutdown, controls, repower, or fuel switch consistent with B ART.

1.2 BART-Eligibility

To be BART-eligible a facility must belong to one o f 26 specific source categories with existing stationary emission units (or pieces of equipment) which meet specific criteria for start-up dates, and potential emissions of any visibility impairing pollutants greater than 250 tons per year including NO

x 

### , SO 2 

### , and PM 10



### . 4 

### These two facilities are classified under the sou rce category of

1 http://www.state.nj.us/dep/baqp/2008%20Regional%20H aze/Regional%20Haze%20SIP%20Final2009.pdf

2 http://www.state.nj.us/dep/baqp/sip/BART%202011_1.p df

3 NESCAUM. Five-Factor Analysis of BART-eligible Sou rces Survey of Options for Conducting BART Determinations. Boston, MA; June 2007.

4 64 Fed . Reg . 35737; July 1, 19993



### “Fossil-fuel fired steam electric plants of more th an 250 million British thermal units per hour heat input.” Upon reviewing the “in operation” date s and current potential emissions from the applicable equipment still in existence at each nam ed facility, NJDEP determined that Vineland MEU and BL England are BART-eligible sources. See Table 1A below.

Table 1A List of Additional BART-eligible Sources i n New Jersey

Cumulative visibility impairing pollutants from BART applicable equipment 1

Potential to Emit (PTE) in tons per year (tpy) 

### Source category/ Facility
NO

x 

### SO 2 

### PM 10 

### BART-eligible

source (PTE > 250 tpy) 

### Power plants:

Vineland MEU

Howard M. Down 442 1,718 131 Yes

RC Cape May BL England 10,629 40,370 4,410 Yes

Notes:

1 

### equipment put in place August 7, 1962 through Augus t 7, 1977.

1.2.1 Identification of BART-eligible Sources

NJDEP followed the step-by-step process for determi ning BART-eligibility provided in Appendix Y to Part 51, Section II. 5 

### The steps in identifying BART-eligible sources ar e:

Step 1: list existing equipment at each of these el ectric generating power plants; Step 2: verify the start-up dates of the equipment and check if within the 1962-1977 time window; and Step 3: compare the cumulative potential emissions (PTE) from qualified equipment identified in Steps 1 and 2 to the 250 tons per year (tpy) cutoff for any single visibility impairing pollutant.

Tables 2A and 3A display the information gathered f rom the steps above for 1) Vineland MEU, and 2) BL England, respectively.

1.2.2 Vineland Municipal Electric Utility – Howard M. Down (PI#75507) – Vineland, Cumberland County

The VMEU currently has four pieces of equipment, on e No. 6 fuel oil-fired boiler (E10), ancillary equipment (E12 and E13) and an emergency generator (E22), that fall within the applicable BART time frame. The cumulative permitt ed PTE from these qualified units exceed

the BART threshold for NO

x 

### and SO 2 

### emissions (442 and 1718, respectively), and theref ore this facility is a BART-eligible source. See Table 2A b elow.

5 http://edocket.access.gpo.gov/cfr_2008/julqtr/pdf/4 0cfr51AppY.pdf4



### Unit 10 (E10) is a 357 MMBtu//hr boiler that curren tly combusts No.6 fuel oil. Coal operation ceased in 2010, as a result of State and federal en forcement agreements. The bottom ash handling system (E12) and the fly ash handling syst em (E13) are support systems to E10 with the potential to emit particulate emissions only. The bottom ash and the fly ash handling systems have blower filters, and the PTE totals for these q ualified units are below de minimis 6 

### levels for

PM 10 

### . The distillate fuel oil-fired emergency generato r (E22), rated at 2.3 MMBtu/hr, has not operated in more than ten years as reported to NJDE P in its electronic emission statements. The facility is also required to maintain a record of e mergency use.

The NJDEP Administrative Consent Order (NEA070001) required elimination of coal operation of E10 after December 31, 2010 (permit activity BOP 090003 – effective). Moreover, the federal Consent Decree (Civil Action No. 1:11-cv-1826-RMB-J S) requires VMEU to add on selective non-catalytic reduction (SNCR) for NO

x 

### control by September 1, 2012, or cease operating E 10 by September 1, 2012. VMEU decided to permanently cease operation of E10.

VMEU submitted a deactivation request to Pennsylvan ia-New Jersey-Maryland (PJM) Interconnection on June 6, 2011, and also submitted a written certification to USEPA Region 2 and NJDEP on July 1, 2011. No later than July 30, 2011, VMEU is required to request a modification to the Title V operating permit to del ete E10. When this boiler permanently shuts down, the cumulative permitted PTE for NO

x 

### and SO 2 

### emissions from the remaining qualified

units do not exceed the BART threshold this source. This facility will no longer be considered BART-eligible. NJDEP anticipates E10 permanently s hutting down by September 1, 2012. See Attachments 1, 2, 3, and 4.

Table 2A List of Equipment, Start-up Date, Potentia l Emissions, and Eligibility Determination – Vineland Municipal Electrical Utility

VMEU Howard M. Down (PI#75507) Identify emission units Verify dates If yes, compar e PTE to 250 tpy cutoff Potential to Emit (PTE) in tons per year (tpy) Equip.

NJID Equipment Description Start-up

Date 8/7/62 –

8/7/77

NO

x 

### SO 2 

### PM 10 

### BART eligible

E10 Unit 10 boiler 1969 Yes 438 1,718 131 Yes 1



### E11 Unit 11 turbine 2010 No –– –– –– No

E12 Bottom ash Handling 1969 Yes N/A N/A D 2 

### No 2



### E13 Fly ash handling 1969 Yes N/A N/A D 2 

### No 2



### E14 Bottom ash silo 1952 No –– –– –– No
E22 Em. generator 1969 Yes 3.5 0.18 0.33 Yes 1



### Visibility Impairing Pollutants NO

x 

### SO 2 

### PM 10 

### PTE Totals (tpy): 442 1718 131 > 250

Notes:

6 http://www.state.nj.us/dep/aqm/Sub8.pdf5

1 

### equipment with applicable emissions to be considere d cumulatively in determining the facility’s BART eligibility

2 

### De minimis (D) – potential to emit below de minimis level (less than 0.05 pounds per hour)

1.2.3 BL England – RC Cape May (PI#73242) – Beesley s Point, Cape May County

BL England currently has five pieces of equipment, or sources, and one emission unit that includes the fuel handling equipment, which fall wi thin the BART time frame with cumulative permitted PTE above the 250 tpy applicability thres holds for NO

x 

### , SO 2 

### , and PM 10 

### (10,629, 40,370 and 4,410, respectively). Therefore, this f acility is a BART-eligible source. See Section 1.52 for details regarding existing controls and BA RT determinations.

BL England is subject to an Administrative Consent Order (ACO) issued by NJDEP and agreed to by Atlantic City Electric Company on January 24, 2006. RC Cape May, current owner/operator, assumed the obligations of the ACO in subsequent amendments with a revised timeline to either repower or meet the NO

x 

### , SO 2 

### , and PM performance standards of the ACO. The amended ACO primarily affects Units 1 and 2.

Unit 1 (E1) is a coal-fired boiler, limited to ozon e season operation, that must meet performance

standards for NO

x 

### , SO 2 

### and PM by no later than December 15, 2013, as set forth in the ACO Amendment dated January 13, 2010. 7 

### See Table 9A for a summary of requirements set fo rth in the ACO Amendment. RC Cape May has indicated that there is some uncertainty regarding the commencement date of operation for this boiler. NJ DEP has included it at this time presuming that the “in operation” date occurred after August 7, 1962. If during the public comment period, the date of operation is determined to be outside t he BART time frame based on new documentation, NJDEP will update its determination before finalizing its BART submittal to USEPA Region 2. Whether this unit is BART-qualifie d or not, the enforceable agreements ensure that this unit will meet BART requirements.

Unit 2 (E2) is a coal-fired boiler that must meet p erformance standards for SO 2 

### and PM by no later than May 1, 2010, and NO

x 

### performance standards by May 1, 2012, as set forth in the ACO Amendment dated January 13, 2010. 8 

### See Table 10A for a summary of requirements set f orth in

the ACO Amendment.

Unit 3 boiler (E3) is permitted to burn No. 6 fuel oil, and primarily operates during the ozone season as a high electric demand day (HEDD) unit. 9



### The coal fuel handling systems (E9 – 20), as applic able, emit particulate emissions only and support the coal-fired units (E1 and E2). The conv eying systems are covered and the fugitive emissions are controlled with wet suppression. The cooling tower (E21) also emits particulates only and supports Unit 3 (E3). One other BART-qual ified equipment includes an emergency fire water pump. See Table 3A below.

7 http://www.epa.gov/compliance/resources/cases/civil /caa/psegfs.pdf

8 Ibid.

9 http://www.state.nj.us/dep/aqm/Sub19.pdf6



### Table 3A List of Equipment, Start-up Date, Potentia l Emissions, and Eligibility Determination – BL England Generating Station

BL England Generating Station (PI#73242) Identify emission units Verify dates If yes, compar e PTE to 250 tpy cutoff Potential to Emit (PTE) in tons per year (tpy) Equip.

NJID Equipment Description Start-up

Date 8/7/62 –

8/7/77

NO

x 

### SO 2 

### PM 10 

### BART eligible

E1 Unit 1 boiler 1962 Yes 4,080 2 

### 31457 3 

### 1,198 Yes 1



### E2 Unit 2 boiler 1964 Yes 5,022 4 

### 1,015 952 5 

### Yes 1



### E3 Unit 3 boiler 1974 Yes 1,506 7,897 2,215 Yes 1



### E4 Diesel electric generator EG1

E5 Diesel electric generator EG2

E6 Diesel electric generator EG3

E7 Diesel electric generator EG4 1961 No –– –– –– No

E8 Em. fire water diesel engine 1968 Yes 21.6 1.49 1.53 Yes 1



### E9 –

20 1968 Yes Yes 1



### E11 1989

E17 &

E18 Coal fuel handling

1995 No N/A N/A 6.1 6



### No

E21 Cooling tower 1974 Yes N/A N/A 127.5 Yes 1



### Visibility Impairing Pollutants NO

x 

### SO 2 

### PM 10 

### PTE Totals (tpy): 10,629 40,370 4,410 > 250

Notes:

1 

### equipment with applicable emissions to be considere d cumulatively in determining the facility’s BART eligibility

2 

### until December 14, 2013; on and after December 15, 2013 NO

x 

### (total) shall be 626.3 tons per year (85% reduction)

3 

### until December 14, 2013; on and after December 15, 2013 SO 2 

### (total) shall be 854.1 tons per year (97% reduction)

4 

### until April 30, 2012; on and after May 1, 2012 NO

x 

### (total) shall be 770.9 tons per year (85% reduction)

5 

### to be established from stack test results after SCR installation

6 

### annual emission limit for E9 – E20 (combined, Unit 7)7



### 1.3 Subject to BART

Based on the cumulative assessment of all BART-elig ible sources in the MANE-VU region, all member states with BART-eligible facilities contrib ute to visibility impairment at Class I areas. 10



### Therefore, as a member state of MANE-VU, the State of New Jersey adhered to the MANE-VU Board decision that any source that meets the BART eligibility requirements is subject to BART

review. 11



### 1.4 Evaluation of BART Analyses

For each qualified emission unit at an eligible fac ility, BART must be established for pollutants reasonably anticipated to impair visibility. NJDEP developed tables summarizing each facility’s current compliance requirements, including enforcea ble consent decree requirements, and recent rule development to help determine the best control options, establish emission limits, and set compliance deadlines for the BART-qualified emissio n units. 12



### 1.5 Fossil fuel-fire steam Electric Power Plant s of more than 250 Million British Thermal Units (BTU) per Hour Heat Input

Power plants are one of 26 specific source categori es identified as being applicable to the BART requirement. The BART requirement applies to quali fied emission units located at Fossil fuelfire steam Electric Power Plants of more than 250 M illion British thermal units (BTU) per hour heat input that generate electricity for sale. App endix Y Guidelines for BART require coal-fired electric generating units (EGUs) greater than 200 M W located at greater than 750 MW power plants meet 0.15 lb/MMBtu emission limit for SO 2 

### ; and for any size oil-fired units, the sulfur fuel content must be limited to 1 percent or less b y weight. The BART guidelines also set yearround use of SCR or SNCR as the presumptive BART fo r NO

x 

### for EGUs currently using these controls. For oil and gas-fired EGUs current combu stion controls should be part of the BART

determination.

1.5.1 Power Plants

New Jersey adopted a rule at N.J.A.C. 7:27-27 to co ntrol mercury emissions from specific sources including coal-fired boilers. 13 

### Compliance with the mercury standard for coal-fir ed boilers was contingent upon the installation and op eration of air pollution control systems to

meet the NO

x 

### , SO 2 

### , and PM standards shown in Table 4A below by Decem ber 15, 2012. Note

10 NESCAUM. Five-Factor Analysis of BART-eligible Sou rces Survey of Options for Conducting BART Determinations. Boston, MA; June 2007.

11 Ibid.

12 http://edocket.access.gpo.gov/cfr_2008/julqtr/pdf/4 0cfr51AppY.pdf

13 http://www.state.nj.us/dep/aqm/Sub27.pdf8



### that the maximum allowable SO 2 

### and PM emission rates for any size coal-fired boil er are 0.150 lb/MMBtu based on 30-day rolling average and 0.030 lb/MMBtu based on 3-hour average.

.

Table 4A N.J.A.C. 7:27-27.7(b) – Maximum Allowable NO

x 

### , SO 2 

### and PM Emission Rates for Coal-fired boilers (Operative on and after December 15, 2012)

Pollutant Emission Limit

(lb/MMBtu) Boiler Type

0.100 Dry bottom NO

x



### 0.130 Wet bottom

SO 2 

### 0.150

PM 0.030*

*also found under N.J.A.C 7:27-4.2(c)



### More recently, NJDEP amended N.J.A.C. 7:27-4 Contro l and Prohibition of Particles from Combustion of Fuel on March 20, 2009, to restrict p article emissions from any coal-fired boiler with particle control that is constructed, installe d or reconstructed as of May 19, 2009, to no greater than greater than 0.0150 lbs/MMBtu.

NJDEP’s NO

x 

### rules for boilers serving EGUs were also revised o n March 20, 2009. Unless subject to more stringent permit limits or otherwis e specified in an enforceable agreement, the rules require more stringent NO

x 

### limits for boilers serving EGUs based on output an d measured in pounds per megawatt-hour (lbs/MW-hr) beginning M ay 1, 2015. See Table 5A below.

Table 5A N.J.A.C. 7:27-19.4 Table 3 – Maximum Allow able NO

x 

### Emission Rates for Boilers Serving Electric Generating Units (Operative on and after May 1, 2015)

Fuel Type lbs/MWhr

Coal 1.50

Heavier than No. 2 fuel oil 2.00 No. 2 and lighter fuel oil 1.00 Gas only 1.00

Also on March 20, 2009, New Jersey adopted an amend ment to its Sulfur in Solid Fuels rule at N.J.A.C. 7:27-10.2(h) which specifies that on and a fter December 15, 2012, the owner or operator of any source that combusts solid fuel sha ll cause it to emit SO 2 

### at a 24-hour emission rate no greater than 0.250 lbs/MMBTU gross heat inp ut for every calendar day, and at a 30- calendar-day rolling average emission rate no great er than 0.150 lbs/MMBTU gross heat input. 14



### The coal-fired boilers addressed in this document a re permitted to combust No.6 fuel oil. In 2010, NJDEP amended N.J.A.C. 7:27-9, Sulfur in Fuel s, to lower the maximum sulfur content

14 http://www.state.nj.us/dep/aqm/Sub10.pdf9



### standard of all grades of fuel oil in most Zones. V MEU and BL England are located in Zone 1. 15



### See Table 6A below.

Table 6A N.J.A.C. 7:27-9 – Sulfur in Fuels

Maximum Allowable Sulfur Content Standards – for Zo ne 1 only from Tables 1A and 1B

Through 06/30/2014 Effective 07/01/2014 -

06/30/2016 Effective 07/01/2016 Fuel grade % by wt ppm % by wt ppm % by wt ppm
No. 2 0.3 3,000 0.05 500 0.015 15
No. 6 2.0 20,000 0.5 5,000 0.5 5000

1.5.2 Vineland Municipal Electric Utility (PI#75507 ) BART Analysis

Based on the current Title V permit, Unit 10 is a 3 57 MMBtu/hr boiler that was "in operation" in May, 1970. The NJDEP’s mercury rule allows facilit ies to shut down any coal-fired boiler in lieu of meeting the mercury standard. VMEU entered into an enforceable agreement with NJDEP to shut down Unit 10 by December 15, 2012. V MEU also agreed in the State’s ACO to cease burning coal after December 31, 2010. See At tachment 1.

Subsequently VMEU entered into an enforceable agree ment with the USEPA on March 10, 2011, to install SNCR on Unit 10, or deactivate no later than September 1, 2012. See Attachment 2. VMEU decided to permanently shut dow n the operation of Unit 10 and on June 6, 2011, requested that PJM retire this unit from s ervice. See Attachment 3. On July 1, 2011, USEPA Region 2 and NJDEP received a written certifi cation of its decision. By July 30, 2011, VMEU is required to submit a request to remove Unit 10 from its Title V operating permit effective September1, 2012. See Attachments 3 and 4. Note that PJM has requested additional information from the facility, and as of July 22, 2 011, the facility has yet to submit the permit modification request to NJDEP. The requirements of the ACO and CD are summarized in Table

7A below.

Table 7A Summary of 2011 Consent Decree (CD) 16 

### and 2007 Administrative Consent Order (ACO) 17 

### for Unit 10 – Vineland Municipal Electrical Utilit y (PI#75507)

Equip.

NJID Pollutant Control strategy Emission limit Compliance

date

Interim: E10 NO

x 

### LNB & OFA Annual tonnage Effective

15 http://www.state.nj.us/dep/aqm/Sub9.pdf

16 Consent Decree; Civil Action No. 1:11-cv-01826 (RMB -JS); filed 05/02/11, p8

17 01/24/2006 Administrative Consent Order, p2 (NEA07 0001)10



### Equip.

NJID Pollutant Control strategy Emission limit Compliance

date cap (438 tpy);

0.28 lb/MMBtu 30-day avg. BOP100003

Final: Install SNCR, or permanently cease operation of Unit 10 September 1,

2012

Interim: Cease burning coal –– Effective

BOP100003 SO 2



### Use low sulfur No. 6 fuel oil –

0.7% by wt. Annual tonnage cap (1,718 tpy);

392.3 lb/hr Effective

BOP080001

NJDEP has determined that once shut down, VMEU no l onger qualifies as a BART-eligible source. Receipt of the modification request to del ete Unit 10 from the Title V operating permit is required no later than July 30, 2011.

1.5.3 BL England Generating Station (PI#12202) BART Analysis

BL England Generating Station is a 449 MW electric utility steam generating plant with three boilers serving electric generating units (EGUs) th at are subject to BART review. E1 and E2 are coal-fired and subject to controls and enforceable emission limits due to an Administrative Consent Order (ACO) and supplemental Amendments. E 3 combusts No.6 fuel oil.

Unit 1 is limited to blended coal including bitumin ous and low sulfur coal and supplemented with up to 8% tire derived fuel (TDF), or No. 6 fue l oil. The unit’s coal authorization plan was extended by the ACO until December 14, 2013, when i t is required to meet more stringent short

term SO 2 

### standards as part of the agreement. OFA, SNCR, an d ESP provide continuous air pollution control of NO

x 

### , SO 2 

### and PM emissions. SCR and scrubber will be instal led by December 15, 2013. Operation of SNCR after install ation of the SCR is optional.

Unit 2 is limited to blended coal including bitumin ous and low sulfur coal and supplemented with up to 8% tire derived fuel (TDF), or No. 6 fue l oil. NO

x 

### , SO 2 

### and PM emissions from this boiler are continuously controlled with OFA, SNCR, wet FGD scrubber, and ESP. SCR will be installed by May 1, 2012. Operation of SNCR after installation of the SCR is optional.

Unit 3 boiler combusts No. 6 fuel oil and is permit ted to use No. 2 fuel oil for start-up. NO

x 

### and PM emissions from this boiler are continuously cont rolled with SNCR and a mechanical cyclone, respectively.11



### The coal fuel handling systems (E9, E10, E12, E13, E14, E15, E16, E19, and E20) are support systems to the coal-fired boilers (E1 and E2). The unloading, processing, and transferring systems are covered, and fugitive particulate emiss ions are controlled with surfactant-based wet suppression as required by the Title V permit. The cooling tower (E21) supports Unit 3 boiler (E3) and has the potential to emit particulate emis sions only. The natural draft cooling tower (E21) circulates treated sea water in a closed loop system and is equipped with high efficiency drift eliminators, which is BART for cooling towers . These pieces of equipment, E9 – 20, as applicable, and E21, are either de minimis or have BART control. See Table 8A for a summary of current compliance requirements.Table 8A Summary of Current Title V Permit Conditions for BART Qualified Equipment (BOP100003) – BL England (PI#73242)NOxSO2PM10Heat InputAllowableemissionlimitAllowableemissionlimitAllowableemissionlimitEquip.NJIDEquipmentDescription(MMBtu/hr)FueltypeExistingControl(lb/hr)ExistingControl(lb/hr)ExistingControl(lb/hr)Notes1. E1 U1 boiler(129 MW)1300 Coalw/ upto 8%TDF*or#6FOSNCR&OFA780For coal:0.60lb/MMBtucalendarday avg.(5/1-9/30)0.60lb/MMBtu30-dayrollingavg.(10/1-4/30)For oil:0.43lb/MMBtucalendarday avg.(5/1-9/30);0.43lb/MMBtu30-dayrollingavg.(10/1-4/30)Lowsulfurcoal plan1.9%monthly;1.7% 12-month;Lowsulfurfuel oil1% by wt7,182 ESP273.59PM, 130Coalreauthorization planin place until Unit 1is shutdown or by12/14/2013,whichever is soonerSubject to N.J.A.C.7:27-9.2 lowersulfur #6FO (0.5%)effective 07/01/1413NOxSO2PM10Heat InputAllowableemissionlimitAllowableemissionlimitAllowableemissionlimitEquip.NJIDEquipmentDescription(MMBtu/hr)FueltypeExistingControl(lb/hr)ExistingControl(lb/hr)ExistingControl(lb/hr)NotesSee note. 0.110lb/MMBtu30-dayroll avg.&0.150lb/MMBtu24-hr avg.(effective12/15/13)See note. 0.150lb/MMBtu(30-dayroll. avg.);0.250lb/MMBtu24-hr avg.(effective12/15/13)See note. PM, 0.030lb/MMBtu3-hr avg.(effective12/15/13)ACO: repower**by 12/15/11, ormeet NOx, SO2andPM performancestandards by12/15/2013182. E2 U2 boiler(160 MW)1600 Coalw/ upto 8%TDF*and/or#6 FOSNCR&OFA960For coal:0.60lb/MMBtucalendarday avg.(5/1-9/30)0.60lb/MMBtu30-dayrollingavg.(10/1-4/30)For oil:0.43lb/MMBtucalendarFGD wetscrubber&sorbentinjection;Lowsulfurfuel oil1% by wt1,3360.150lb/MMBtu(30-dayroll. avg.);0.250lb/MMBtu24-hr avg.(effective05/01/10)ESP(updatedto meetACOstandard);ESP neednot beenergizedduringPM, 0.030lb/MMBtu3-hr avg.(effective05/01/10)ACO: repower**by 12/15/11, ormeet NOxperformancestandards by05/01/201219Subject to N.J.A.C.7:27-9.2 lowersulfur #6FO (0.5%)effective 07/01/1418Administrative Consent Order Amendment, certified01/13/2010, p6; and 01/24/2006 Administrative Consent Order19Ibid.14NOxSO2PM10Heat InputAllowableemissionlimitAllowableemissionlimitAllowableemissionlimitEquip.NJIDEquipmentDescription(MMBtu/hr)FueltypeExistingControl(lb/hr)ExistingControl(lb/hr)ExistingControl(lb/hr)Notesday avg.(5/1 -9/30)0.43lb/MMBtu30-dayrollingavg.(10/1-4/30)OFA &installSCR by05/01/120.110lb/MMBtu30-dayroll avg.&0.150lb/MMBtu24-hr avg.(effective12/15/12)No.6 oiloperation3. E3 U3 boiler(160 MW)1720 #6FOFOforS/USNCR(yearround)3440.2lb/MMBtuLowsulfurfuel oil1% by wt1803 Cyclone 505PM, 172Subject to N.J.A.C.7:27-9.2 lowersulfur #6FO (0.5%)effective 07/01/144. E8 U6 emergencyfire waterpump engine1.12 diesel None 4.94 0.3% Sby wt0.43 None 0.35 Subject to N.J.A.C.7:27-9.2 lowersulfur #2FO(0.05%) effective07/01/14 and(0.015%) effective07/01/16;typically operatesless than two hours15NOxSO2PM10Heat InputAllowableemissionlimitAllowableemissionlimitAllowableemissionlimitEquip.NJIDEquipmentDescription(MMBtu/hr)FueltypeExistingControl(lb/hr)ExistingControl(lb/hr)ExistingControl(lb/hr)Notesper year5. E90.21E100.21E120.062E13D***E14DE15DE16DE19DE20U7 Coal andtire-derivedfuel handlingN/A N/A N/A N/A Alloperationscovered;All wetspray dustsuppressorused forfugitivedustexceptE15, E19and E20D6. E21 U8 Unit 3Cooling towerN/A N/A N/A N/A High eff.drifteliminator29.1Note:a new SCR and scrubber, as well as an ESP upgrade,will be required to meet ACO Performance Standardson U1* tire derived fuel (TDF)** “Repower” means the replacement of an existingcoal-fired boiler with a new heat source (e.g. natural gas or distillate oil), or new coal-combustion technology (e.g. circulating fluidizedbed boilers or integrated gasification combined-cycle (IGCC”) technology as defined in01/24/2006 Administrative Consent Order.*** De minimis (D) – potential to emit below de minimis level (less than 0.05 pounds per hour)16



### Unit 1 Boiler (E1):

Unit 1 is a 1300 MM/Btu Babcock and Wilcox, cyclone -fired, wet bottom boiler with a rating of 129 MW. According to the ACO amendment, Unit 1 mu st repower by December 15, 2011, or meet performance standards by December 15, 2013 as shown in Table 9A. If Unit 1 does not meet the emission rates by December 15, 2013, Unit 1 may not restart unless RC Cape May obtains a permit modification which incorporates ad vances in the art of air pollution control according to N.J.A.C. 7:27-22.35. If RC Cape May d ecides to repower, it must incorporate advances in the art of air pollution control which may result in more stringent emission limits. Before repowering, or installing new controls, RC C ape May will optimize the existing NO

x 

### control to minimize NO

x 

### emissions in the interim.

Table 9A Summary of 2010 Amendment to 2006 Administ rative Consent Order 20 

### for Unit 1 – BL England (PI#73242)

Equip.

NJID Pollutant Control strategy Emission limit Compliance

date

Interim:

SNCR & OFA 4,080.7 tpy

0.60 lb/MMBtu calendar day avg. (5/1 -9/30)

0.60 lb/MMBtu 30-day rolling avg. (10/1-4/30) Effective until

12/14/13

BOP100003

Final: NO

x



### Install SCR* (use of SNCR is

optional after installation and operation of SCR) & OFA 626.3 tpy

0.110*

lb/MMBtu 30-day rolling

avg. 0.150 lb/MMBtu 24-hr avg. Effective from

12/15/13

BOP100003

Interim:

Reauthorized low sulfur coal plan 31,457 tpy 7,182 lbs/hr and 1852 ppmvd Effective until

12/14/13

BOP100003

Final: E1

SO 2



### Install scrubber. 854.1 tpy

0.150

lbs/MMBtu Effective from

12/15/13

BOP100003

20 Administrative Consent Order Amendment, certified 0 1/13/2010, p6; and 01/24/2006 Administrative Consen t Order, p3717



### Equip.

NJID Pollutant Control strategy Emission limit Compliance

date 30-day rolling

avg. 0.250

lbs/MMBtu 24-hr avg.

Interim: ESP 569.4 tpy

0.150

lbs/MMBtu Effective until

12/14/13

BOP100003

Final: PM

ESP update 170.8 tpy

0.030

lbs/MMBtu 3-hr avg. Effective from

12/15/13

BOP100003

Other Repower by 12/15/11, or meet NO

x 

### , SO 2 

### and PM performance

standards by 12/15/2013
Note: a new SCR and scrubber, as well as an ESP up grade, will be required to meet ACO Performance

Standards on U1



### Unit 2 Boiler (E2):

Unit 2 is a 1600 MM/Btu Babcock and Wilcox, cyclone -fired, wet bottom boiler with a rating of 160 MW. According to the ACO amendment, Unit 2 mu st repower by December 15, 2011, or meet performance standards for SO 2 

### and PM by no later than May 1, 2010 (completed), a nd NO

x 

### performance standards by May 1, 2012. Before insta lling and operating the new SCR, RC Cape May will optimize the existing NO

x 

### control to minimize NO

x 

### emissions in the interim. See

Table 10A.

Table 10A Summary of 2010 Amendment to 2006 Adminis trative Consent Order 21 

### for Unit 2 – BL England (PI#73242)

Equip.

NJID Pollutant Control strategy Emission limit Compliance

date

Interim: E2 NO

x 

### SNCR& OFA 5,022.4 tpy

0.60 lb/MMBtu calendar day avg. (5/1 -9/30) Effective until

04/30/12

BOP100003

21 Administrative Consent Order Amendment, certified 0 1/13/2010, p6; and 01/24/2006 Administrative Consen t
Order18



### Equip.

NJID Pollutant Control strategy Emission limit Compliance

date

0.60 lb/MMBtu 30-day rolling avg. (10/1-4/30)

Final: Install SCR* (use of SNCR is optional after installation and operation of SNCR) & OFA 770.9 tpy

0.110 lb/MMBtu 30-day rolling

avg. 0.150

lbs/MMBtu 24-hr avg. Effective from

05/01/12

BOP100003

Final: SO 2 

### FGD wet scrubber & sorbent

injection 1051.2 tpy

0.150

lbs/MMBtu 30-day rolling

avg. 0.250

lbs/MMBtu 24-hr avg Effective

05/01/10

BOP080001

Final: PM ESP update 210.2 tpy

0.030

lbs/MMBtu 3-hr avg. Effective

05/01/10

BOP080001

Other Repower by 12/15/11, or meet NO

x 

### performance standards by

05/01/12

Unit 3 Boiler (E3):

Unit 3 is a 1720 MMBtu/hr Combustion Engineering, o il-fired, tangential boiler with a rating of 160 MW. This unit typically operates as a HEDD uni t during hot summer days. Table 11A below shows the hours of operation reported to NJDE P in its electronic emission statements. The declining use of No. 6 fuel oil is a general tr end in the power industry.

Table 11A Reported Operating Time of Unit No. 3 Fir ing No. 6 Fuel Oil

U3, OS1 – Utility boiler firing No. 6 fuel oil

Emission

Year Operating time

(hours) Emission

Year Operating time

(hours)
1999 2,777 2005 1,462
2000 1,854 2006 881
2001 2,045 2007 1,10219 

### U3, OS1 – Utility boiler firing No. 6 fuel oil

Emission

Year Operating time

(hours) Emission

Year Operating time

(hours)
2002 2,039 2008 373
2003 2,452 2009 172

2004 901 2010 159

On May1, 2015, Unit 3 is required to meet an effici ency-based NO

x 

### emission limit of 2.00 lb/MW-hr that is approximately equivalent to the cu rrent input-based emission limit of 0.2 lb/MMBtu in the Title V permit. Additionally, effe ctive 07/01/2014, the sulfur in fuel content of No. 6 fuel oil will decrease, from the permitted 0. 7% by wt, to an allowable 0.5% pursuant to

N.J.A.C. 7:27-9.2.

1.7 Final BART Requirements

Under the Regional Haze rule, States must identify the best system of continuous emission control technology for each eligible source that is subject to BART. After a State has identified the level of control representing BART, it must est ablish an emission limit representing BART and must ensure compliance with that requirement no later than five years after the USEPA Region 2 approves the State Implementation Plan. T he BART requirements must be included as operating permit conditions according to the proced ures established in 40 CFR part 70, and the State regulations promulgated at N.J.A.C. 7:27-22.

With the anticipated shutdown of Unit 10 at VMEU by September 1, 2012, the cumulative PTE from qualified equipment is well below the emission s threshold for BART eligibility, and not subject to further BART review. BL England has two coal units which are subject to an enforcement agreement to install modern air polluti on control by the end of 2012 and 2013; and an oil-fired boiler. RC Cape May, owner/operator o f this power plant, has indicated it is evaluating the conversion of all three electric ste am generating units to natural gas or No. 2 fuel oil. To the extent that RC Cape May decides to con vert one or all of the units, NJDEP anticipates that RC Cape May would submit a specifi c proposal that addresses applicable requirements including BART.

Vineland Municipal Electric Utility : On May 20, 2011, the USEPA entered into a CD with V MEU. As a result of its decision not to install SNCR on Unit 10, VMEU is required to submit a modification to NJDEP by July 30, 2011, requesting the deletion of Unit 10 boiler fro m its Title V operating permit effective September 1, 2012. NJDEP anticipates a timely perm it modification submittal from VMEU to incorporate the effective shutdown date for Unit10 boiler.20



### BL England : BL England currently has three boilers serving elec tric generating units (E1, E2 and E3), a fire pump engine, coal fuel handling systems (E9, E10, E 12, E13, E14, E15, E16, E19, and E20) and a cooling tower that are subject to BART review. T he fuel handling systems support the coalfired boilers (E1 and E2). All of the fuel unloadi ng, processing, and transferring operations are covered, and, with the exception of E15, E19 and E2 0, fugitive particulate emissions are controlled with surfactant-based wet suppression as required by the Title V permit. The cooling tower (E21) supports the Unit 3 boiler (E3) with th e potential to emit particulate emissions only.

According to the Title V permit requirements, the s alt water tower has drift eliminators to control

salt water drift. NJDEP has determined that the ex isting particulate controls are BART for the fuel handling systems and the cooling tower.

On January 13, 2010, the NJDEP entered into an ACO Amendment with RC Cape May. NJDEP

has determined that the NO

x 

### , SO 2 

### , and PM controls, emission limits, averaging times , and compliance dates from the ACO for the process are B ART for E1 & E2. The ACO Amendment requirements for E1 and E2, are already included in the current approved Title V operating permit, BOP100003.

NJDEP has determined that the existing SNCR and mec hanical cyclone air pollution control systems for oxides of nitrogen (NO

x 

### ), and particulate matter (PM), respectively, for E 3, are BART and are included as applicable requirements in the current approved Title V operating permit, BOP100003. Beginning May 1, 2015, Unit 3 i s subject to N.J.A.C. 7:27-19.4 Table 3

that restricts the maximum allowable NO

x 

### emission rate to no greater than 2.00 lbs/MW-hr. In addition, a more stringent sulfur content of 0.5% b y wt. for No. 6 fuel oil is effective on July 1, 2014, pursuant to NJDEP’s sulfur in fuel rule at N. J.A.C.7:27-9.2.21



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