REQUEST FOR PUBLIC COMMENTS
ON DRAFT AIR PERMIT
REGULATING THE EMISSIONS OF AIR POLLUTANTS
(Docket No. 22-CA-PA-07)
Pursuant to Hawaii Revised Statutes (HRS), Chapter 342B-13 and Hawaii Administrative Rules (HAR), Chapter 11-60.1, the Department of Health, State of Hawaii (DOH), is requesting public comments on the following DRAFT PERMIT AMENDMENT presently under review for:
Covered Source Permit (CSP) No. 0548-01-C
Application for Significant Modification No. 0548-10
Hawaiian Electric Company, Inc.
Campbell Industrial Park Generating Station
Located At: 91-196 Hanua Street, Kapolei, Oahu
The DRAFT PERMIT AMENDMENT is described as follows:
This is an application for a significant modification to CSP No. 0548-01-C. The applicant is proposing to modify CSP No. 0548-01-C for the existing CIP1 combustion turbine (CIP1) at the Campbell Industrial Park Generation Station (CIPGS) to allow increased operation of this turbine. Currently, the permit limits CIP1 turbine operation to near minimum load, with higher loads allowed only during periods when no other sources are reasonably available to meet the Oahu electrical grid needs. Instead, the applicant would like the flexibility to operate CIP1 to satisfy peak system demands irrespective of the status of other units. The requested change will allow CIP1 to operate more often at higher and more efficient loads during highest demand periods, which typically occur between 5 pm and 9 pm each day. The purpose is to allow the system to more efficiently adjust to variations in generation from intermittent renewable sources (i.e., wind and solar). As such, the total annual emissions of CIP1 are expected to increase above past average actual levels by significant amounts for several pollutants, which will trigger Prevention of Significant Deterioration (PSD) for those pollutants, while the maximum potential short-term emissions will not increase. CIP1 will continue to serve as a peaking unit with its operation projected to remain considerably below its annual maximum capacity. Accordingly, the applicant is also proposing annual emissions limits for nitrogen oxide (NOX) and carbon monoxide (CO) as part of this permit modification. There are no physical changes needed to the turbine, or any other part of the CIPGS, to accommodate the proposed increased operation and flexibility. The table below shows the annual potential to emit (PTE) as constrained by proposed emission limits versus the annual PTE with no emission limits.
Pollutant Maximum PTE Maximum PTE at 8760 Comments on PTE
(Limited by Proposed hrs/yr at worst load constraints
Emission Limits) scenario
NOx 350.0 1081.0 PTE limited by proposed NOx emission limit
CO 1000.0 1759.4 PTE limited by proposed CO emission limit
VOC 136.8 167.8 Maximum emissions are at
Particulat Matter 288.0 350.4 25% load for VOC and 50%
load for PM, indirectly
limited by the proposed CO
SO2 (at 0.05% wt Sulfur) 157.7 329.6 Maximum emissions are at
CO2e 508,019.7 1,062,04039 peak load, indirectly limited
by proposed NOx emission
This facility is subject to the following federal regulations:
1. 40 Code of Federal Regulations (CFR) Part 52, §52.21 – Prevention of Significant Deterioration
of Air Quality
2. 40 CFR Part 60 – Standards of Performance for New Stationary Sources (NSPS)
Subpart A: General Provisions
Subpart KKKK: Standards of Performance for Stationary Combustion Turbines
The ADMINISTRATIVE RECORD, consisting of the APPLICATION and non-confidential supporting materials from the applicant, the permit review summary, and the DRAFT PERMIT AMENDMENT, is available online at: http://health.hawaii.gov/cab/public-notices/ and for public inspection during regular office hours, Monday through Friday, 7:45 a.m. to 4:15 p.m., at the following location:
State of Hawaii
Clean Air Branch
2827 Waimano Home Road, #130
Pearl City, Hawaii 96782
All comments on the draft permit amendment and any request for a public hearing must be in writing, addressed to the Clean Air Branch at the above address on Oahu and must be postmarked or received by July 23, 2022.
Any person may request a public hearing by submitting a written request that explains the party’s interest and the reasons why a hearing is warranted. The DOH may hold a public hearing if a hearing would aid in DOH’s decision. If a public hearing is warranted, a public notice for the hearing will be published at least thirty days in advance of the hearing.
Interested persons may obtain copies of the administrative record or parts thereof by paying five (5) cents per page copying costs. Please send written requests to the CIean Air Branch listed above or call Mr. Darin Lum at the Clean Air Branch at (808) 586-4200.
Comments on the draft permit amendment should address, but need not be limited to, the permit conditions and the facility’s compliance with federal and state air pollution laws, including: (1) the National and State Ambient Air Quality Standards; and (2) HRS, Chapter 342B and HAR, Chapter 11-60.1.
DOH will make a final decision on the permit after considering all comments and will send notice of the final decision to each person who has submitted comments or requested such notice.
Elizabeth A. Char, M.D.
Director of Health