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PA01€'v UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 1 1 CONGRESS STREET, SUITE 1100
BOSTON , MASSACHUSETTS 02114- 2023

June 26 , 2009



### Jeff Underhil
Air Resources Division 

### New Hampshire Department of Environmental Services 29 Hazen Drive , PO Box 95


### Concord , NH 03302- 0095

Dear Mr. Underhil:



### Previously, EP A received two preliminary drafts 

### of New Hampshire s Regional Haze State Implementation Plan (SIP). EP A provided DES 

### written comments on these drafts 

### in letters dated July 10 , 2008 and October 24 , 2008.



### Subsequently, we received New Hampshire 

### s proposed Regional Haze SIP We have 

### reviewed the proposal and you 

### wil the Agency s comments in the Enclosure.



### If you have any questions on these comments, please contact Anne 

### McWiliams of my

staff at 617- 918- 1697.

nce 

### ly, _..



### nne Arnold , Manager 

### Air Quality Planning Unit

Enclosure

Toll Free -1. 888. 372. 7341 Internet Address (URL) - http://www. epa. gov/region1

Recycled/Recyclable - Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)

### Enclosure EPA Comments on New Hampshire 

### May 2009 Proposed Regional Haze SIP



### General BART Comments

1 New Hampshire indicates it used the CALGRID model for assessing the visibility improvement expected from the installation of Best Available Retrofit Technology (BART) controls for its two BART sources , Merrimack station and Newington Station. 

### The CALGRID modeling results indicated that the installation of a scrubber at Merrimack would only result in a visibility improvement of 0. 1 deciview (dv) and 

### switching to lower sulfur fuel at Newington would result in negligible visibility 

### improvement. The reader is directed to Attachment X for additional discussion on this analysis. However 

### , Attachment X does not provide any information regarding the 

### performance or appropriateness of the CALGRID model for this type of application , the 

### Attachment only discusses the use of CALGRID for ozone modeling purposes.

The MANE- 

### VU modeling results indicate that both BART sources are among the top 167 stacks impacting a MANE- VU Class I area. Therefore 

### , it does not seem to make sense 

### that controllng S02 emissions by more than 90% at Merrimack would lead to a visibility improvement of only 0. 

### 1 dv and that 50% control of S02 at Newington would result in 

### negligible visibility improvement. Please include an explanation of how the CALGRID
and MANE- 

### VU modeling relate to each other , especially in respect to pre-control visibility impacts.



### Furthermore 

### , New Hampshire may want to consider using CALPUFF to assess visibility 

### impacts of potential BART controls. As noted in the BART Guidelines (40 CFR Part 51 Appendix Y Section (IV)(D)(5)):

U se CALPUFF 

### , or other appropriate dispersion model to determine the visibility improvement expected at a Class I area from the potential BART control technology applied to the source.



### 2. Implementation of the selected BART control strategies for each of the three 

### pollutants (S02, NOx , and PM2.5) at both 

### BART facilities must be federally enforceable. 

### The Regional Haze SIP must clearly indicate how this is being accomplished in each case. Specifically, the relevant rules or permits should be included 

### as part of New Hampshire 

### s Regional Haze SIP revision or the SIP revision should cite specific rules or permits conditions that are already federally enforceable.

### BART Determination for PSNH - Newin2ton Station

3. For S02, New Hampshire determined that the BART level 

## ofS0 control for PSNH 

### Newington Station unit NT1 is to switch from 2% sulfur content by weight residual oil to

1 % 

### sulfur content by weight residual oil.



### PSNH Newington Station unit NTI is a tangentially- 

### fired steam generating unit. The Title V permit indicates that NTI can burn crude oil or No. 6 fuel oil at no more than 2% 

### sulfur content by weight , No. 

### 2 fuel oil at no more than 0.4% sulfur content by weight , or

natural gas. Based on recent data submitted to EP A' 

### s Clean Air Market DIvision , it 

### appears that changing the enforceable sulfur- in- 

### fuellimit from 2% sulfur No. 6 oil to 1 

### sulfur No. 

### 6 oil wil provide minimal reductions in S02 emissions since 

### average S02 emission rates are near the levels emitted while burning 1 % 

### sulfur No. 

### 6 oil. (See Table 1 below which contains 2007 data for PSNH Newington Station. ) Thus 

### , other fuel 

### switching options should also be explored. These options include: (1) the use of natural

gas 

### , (2) the use of 0. 3% sulfur No. 

### 6 oil as recommended by the MANE- VU BART 

### workgroup or (3) the use of No. 2 fuel oil at no more than 0. 3% sulfur content by weight.



### Currently, the only consideration of natural gas as a primary fuel source shown in the 

### proposal is the statement , "



### In recent years 

### , there have been sudden and dramatic swings 

### in the price of natural gas relative to fuel oil as supply/demand have shifted. The future 

### price and availability of natural gas are diffcult to discern.

Recent data from the Energy Information Admmistration , however 

### , indicates the Average 

### Cost of Natural Gas and Residual Oil are projected to remain comparable. (See Figure 1 

### Historic and Projected Power generation Fuel Costs - NationaL" ) Therefore , EP A 

### recommends that greater consideration be given to the use of natural gas as the primary fuel at Newington station , with No. 

### 2 fuel oil and/or No. 

### 6 fuel oil being used as the secondary fuel 

### , with a constraint on the number of gallons burned per year.

, however 

### , it is not possible to utilize natural gas as the primary fuel type for this unit 

### then New Hampshire should explain why 1 % 

### sulfur No. 

### 6 oil was determined to be

BART 

### , rather than the MAN- VU BART workgroup recommended sulfur fuel oil limit

of 0. 

### 3% sulfur content by weight. This limit is currently required of facilities in Connecticut pursuant to Connecticut's Section 22a- 17 4- 19a regulation.



### Additionally, New Hampshire should explain why 0. 5% sulfur fuel oil is not BART as

well. The proposal 

### indicates that the cost effectiveness of using 1 % versus 0. 

### 5% fuel oil

is the same at $1900/ton. This argues 

### for 

### the implementation of 0. 5% sulfur fuel oil.

Also 

### , other facilities in New England are currently limited to 0. 5% for No. 

### 6 fuel oil. 

### (See the Title V permit for Salem Harbor Unit #4.



### In table 1 below is a listing of all of the electric generating steam units in New England 

### that were operational in 2007 and which use residual oil as their primary fuel. As
illustrated in the table 

### , most of the units have current S02 emissions rates well below the emission rate proposed as BART for PSNH Newington Station.

### 4. For NOx 

### , New Hampshire has determined that BART is met for Newington Unit

through use of the current suite of NO x controls; low NOx burners 

### , an overfire air
system 

### , and water injection. Ne Hampshire indicates that the current emission limits are a daily average of 0. 

### 35 Ib/MMBtu when burning oil and 0.25lb/MMBtu when burning a combination of oil and gas. The MANE- VU 

### BART workgroup, however
recommended a level of NO x control for non- 

### CAIR EGUs of 0. 1 - 0. 

### 25Ib/MMBtu depending on boiler and fuel type. Therefore , New Hampshire should analyze if a more 

### stringent emission limit is appropriate for this unit.

In New England 

### , there is a least one oil- 

### fired electric generating steam unit with selective 

### catalytic reduction installed (Unit #1 at Canal Electric in Sandwich , MA) and at least
three oil- 

### fired electric generating steam vnits with selective non-catalytic reduction 

### installed (Units #1 and #2 at Norwalk Harbor Station in Norwalk , CT and Unit #3 at


### Middletown Station in Middletown , CT).



### 5. For PM 

### 5, the proposal indicates that the currently installed electro-static precipitator 

### (ESP) is sufficient for BART 

### , yet only cites a 42% control effciency. According to the BART analysis 

### , a rebuilt ESP can achieve collection effciencies of more than 99%.
Therefore 

### , the BART determination should include an analysis of the feasibility of an 

### upgraded or rebuilt ESP for this unit. Furthermore , the MANE- VU BART workgroup
recommendation for non- 

### CAIR EGUs is a PM emission rate of 0. 02 - 0. 

### 04Ib/MMBtu. New Hampshire should provide greater detail as to why the state considers its current
limit ofO. 

### 22lb/MMBtu as suffcient for BART.



### BART Determination for PSNH - 

### Merrimack Station

6. For S02, New Hampshire has determined that BART is the installation of flue gas desulfurization (FGD) controls and has issued a temporary permit to the facility which is


### included in Attachment EE of the submittal. EP A previously reviewed a draft of this 

### permit and submitted comments to the DES in a letter dated March 3 

### 2009. We have reviewed the version of the permit included in the proposal and note that all of our previous comments have been adequately addressed.

7. For NOx 

### , New Hampshire has determined the year round use of selective catalytic 

### reduction (SCR) is considered BART for Unit MK2. This determination seems reasonable. New Hampshire 

### , however 

### , states that its current federally enforceable limit
for this unit is 0. 

### 86Ib/MMBtu , while the MANE- 

### VU recommended level of BART
control for non- 

### CAIR EGUs is 0. 

### 1 - 0.25 Ib/MMBtu , depending on the boiler and fuel 

### type. A review of the data in the CAMD database indicates that MK2 is achieving an
emission rate well below 0. 

### 86 Ib/MMBtu. Fore ample 

### , the highest monthly average

emission rate in 2008 was 0. 30' lb/ 

### MMBtu. Therefore , New Hampshire should impose a 

### more stringent emission limit for this unit.

### 8. For PM 

### 5, New Hampshire has determined that the use of two currently installed



### ESPs is consIdered BART for Unit MK2. This seems reasonable. The proposal,


### however , indicates that the current air permit imposes a 0.227 1b/MMBtu limit , while the

MANE- 

### VU recommended level of BART control for non- CAIR EGUs is 0. 02-


### Ib/MMBtu. Therefore , New Hampshire should analyze if a more stringent emission limit is appropriate for this unit.



### Other Comments

9. We recommend the 5 

### paragraph on page 6 be revised as follows:



### About half of the worst visibility days in the New Hampshire Class I Areas occur in the summer when meteorological conditions are more conducive to the 

### formation of sulfate from S02 and to the oxidations of organic aerosols. IE
addition , ',.'inter and summcr transport patterns are different 

### , possibly leading to 

### different contributions from upwind source regions. As a result The remaining

worst visibility days are divided nearly equally among spring, winter and fall. 

### addition, winter and summer transport patterns are different, possibly leading to 

### different contributions from upwind source regions

10. In Section 6. 

### , the Beyond-on- 

### the way (BOTW) emISSIOns scenario 

### is described as 

### accounting for controls from potential regulations that may be necessary to meet attainment and other air quality goals , mainly for ozone. 

### " Based on the list of measures

provided on page 123 

### , it is unclear how New Hampshire expects to reduce area source emissions by 4 303 tons per year 

### , as depicted in Table 6. 

### 3 2018 BOTW Emissions 

### Inventory Summary for New Hampshire.

11. The MANE- VU " 

### Ask" includes a low sulfur fuel oil strategy. With regard to this

strategy, on page 141 

### of New Hampshire s proposal 

### , the state indicates that it plans to
revise its Env- A 1604 regulation and a draft of the revised rule is provided in Attac1mlent 

### FF. niese revised 

### provisions wil need to be adopted and submitted to EP A as a SIP 

### revision so they may become a federally enforceable part of New Hampshire s Regional Haze SIP. The proposal currently indicates that New Hampshire commits to revising this 

### rule " at the earliest practicable date. " New Hampshire 

### should include a schedule for adoption of the revised regulation.

In addition 

### , the discussion of the low sulfur fuel oil strategy in Section 10. 3 (page 98) 

### of the proposal notes a concern for potential supply disruptions for residual fuels in 

### northern states. This discussion also states , "



### MANE- VU has identified several 

### mechanisms that could be implemented to address disruptions , including seasonal

averaging and emergency waivers. 

### A seasonal averaging approach w()uld reduce 

### potential supply constraints by allowing the use of higher-sulfur during periods of peak
demand. " The proposal 

### , however 

### , does not further elaborate on whether or not New 

### Hampshire plans to allow seasonal averaging and emergency waivers. If such provisions

are allowed 

### , then there should also be a mechanism to ensure that the use of higher-sulfur

### oil during peak demand times does not correspond with meteorological conditions

leading to the 20% worst visibility days.

### Figure 1.

Historic and Projected Power Generation Fuel Costs - National

Natural Gas Residual Fuel Oil Distillate Fuel Oil 

### 25 -- 

# ----
-------_. _._

---w 

### ~~~ --_.._ 

### -----------_.

__. _.----

= 15 ._. .. 'p 

# ., , '

2004 2005 2006 2007

Year 2008 2009 2010



### Source: Energy InformatIOn Administration (EIA) Offcial Energy Statistics Short- Term 

### Energy Outlook. Release Data: June 09 , 2009 

### (http://tonto. eia. 

### doe. gov/ cfapps/S TEO TableBuilder/index. cfm '

Historical data: Latest data available 

### from EIA databases supporting the 

### following reports: Petroleum Marketing Monthly, DOE/EIA- 0380; Weekly Petroleum Status Report , DOE/EIA- 

### 0208; Natural Gas Monthly, DOE/EIA- 

### 0130; Electric Power Monthly, DOE/EIA- 

### 0226; and Monthly Energy Review , DOE/EIA- 

### 0035. Natural gas

Henry Hub spot price from NGI's Daily Gas Price Index 

### (http://Intellgencepress. com 

### WTI crude oil price from Reuter s News Service ( 

## http://ww. reuters. 

### com

Projections: Generated by simulation of 

### the EIA Regional Short- Term Energy



### Model.- .- -20072007 S022007 S022007 HEATOperatingMASSRATEINPUTPrimary FuelSecondary FuelBARTStateFacilty NameUnit IDHours(TPY)(lbs/mmBtu)(lbs/mmBtu)Boiler TypeTypeTypeEligibleMiddletown828,99.4098030305Dry bottom wall-firedResidual OilNatural GasMontville912.46,179523358Tanqentially-firedResidual OilNatural GasMiddletown069.4272.4182989,410CvcloneResidual OilNatural GasYesNew HavenDiesel OilHarborNHB1634.815.237890;274T ariaentially-firedResidual OilNatural GasYesMontvile423,80,253633758Tanaentially"firedResidual OilYesMiddletown568,142,2571 ,107873T anaentially-firedResidual OilYesBridgeportHarborBHB2802.52,281371551CycloneResidual OilDiesel OilNorwalkHarbor584.222.4293518,125Tanaentially-firedResidual OilNorwalkHarbor184,338,295291675T anaentially-firedResidual OilYesMvstic687.922.4314251958T anaentially-firedResidual OilNatural GasYesSalem Harbor729.164.40.492668060Dry bottom wall-firedResidual OilYesCanal3,463,506.20.498050203Dry bottom wall-firedResidual OilNatural GasYesCanal599,169.545976,807Dry bottom wall-firedResidual OilYesWestSorinafield858.366.6091 ,202764Tanaentially-firedResidual OilNatural GasWvman1 ,439,050.654212,458Dry bottom wall-firedResidual OilYesClearY Flood127.14.481535,436Dry bottom wall-firedResidual OilDiesel OilYesBravton Point018.741.901645,406Dry bottom wall-firedResidual OilNatural GasYesNewinaton503,269.2054303867Tanaentially-firedResidual OilNatural GasWvman977.96,228156729Dry bottom wall-firedResidual OilWvman073.452,313689029T anaentially-firedResidual OilYesWvman421.55,346691Drv bottom wall-firedResidual OilTable 1S02E .dERate flAll ResidI Oil BElectric GBoil. NSource: EP A's Clean Air Markets Acid Rain Database