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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

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= 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.
. 

2007 2007 S02 2007 S02 2007 HEAT

Operating MASS RATE INPUT Primary Fuel Secondary Fuel BART

State Facilty Name Unit ID Hours (TPY) (lbs/mmBtu) (lbs/mmBtu) Boiler Type Type Type Eligible

Middletown 828, 99.4 098 030 305 Dry bottom wall-fired Residual Oil Natural GasMontville 912. 46, 179 523 358 Tanqentially-fired Residual Oil Natural Gas

Middletown 069.4 272.4 182 989,410 Cvclone Residual Oil Natural Gas Yes

New Haven Diesel OilHarbor NHB1 634. 815. 237 890;274 T ariaentially-fired Residual Oil Natural Gas YesMontvile 423, 80, 253 633 758 Tanaentially"fired Residual Oil Yes

Middletown 568, 142, 257 1 , 107 873 T anaentially-fired Residual Oil YesBridgeportHarbor BHB2 802. 52, 281 371 551 Cyclone Residual Oil Diesel OilNorwalkHarbor 584. 222.4 293 518, 125 Tanaentially-fired Residual Oil

Norwalk

Harbor 184, 338, 295 291 675 T anaentially-fired Residual Oil Yes

Mvstic 687. 922.4 314 251 958 T anaentially-fired Residual Oil Natural Gas YesSalem Harbor 729. 164.4 0.492 668 060 Dry bottom wall-fired Residual Oil YesCanal 3,463, 506.2 0.498 050 203 Dry bottom wall-fired Residual Oil Natural Gas YesCanal 599, 169. 545 976,807 Dry bottom wall-fired Residual Oil Yes

West

Sorinafield 858. 366. 609 1 ,202 764 Tanaentially-fired Residual Oil Natural Gas

Wvman 1 ,439, 050. 654 212,458 Dry bottom wall-fired Residual Oil Yes

ClearY Flood 127. 14.4 815 35,436 Dry bottom wall-fired Residual Oil Diesel Oil Yes

Bravton Point 018. 741. 901 645,406 Dry bottom wall-fired Residual Oil Natural Gas Yes

Newinaton 503, 269.2 054 303 867 Tanaentially-fired Residual Oil Natural Gas

Wvman 977. 96, 228 156 729 Dry bottom wall-fired Residual Oil

Wvman 073. 452, 313 689 029 T anaentially-fired Residual Oil YesWvman 421. 55, 346 691 Drv bottom wall-fired Residual Oil

Table 1 S02E . dE Rate fl All Resid I Oil B Electric G Boil . N

Source: EP A's Clean Air Markets Acid Rain Database