REQUEST FOR PUBLIC COMMENTS ON DRAFT AIR PERMITS REGULATING THE EMISSIONS OF AIR POLLUTANTS (Docket No. 20-CA-PA-06) 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 DRAFT PERMITS presently under review for the following affected facilities subject to greenhouse gas (GHG) emission reductions: A. Independent Power Producers (IPPs) (1) Amendment of Covered Source Permit (CSP) No. 0087-02-C Application for Significant Modification No. 0087-09 AES Hawaii, LLC (AES) 203 MW Coal-Fired Cogeneration Plant Located At: 91-086 Kaomi Loop, Kapolei, Oahu (2) Amendment of Covered Source Permit (CSP) No. 0243-01-C Application for Significant Modification No. 0243-07 Hamakua Energy, LLC (Hamakua Energy) Hamakua Energy Plant (HEP) 65 MW Cogeneration Facility Located At: 45-300 Lehua Street, Honokaa, Hawaii (3) Amendment of Covered Source Permit (CSP) No. 0214-01-C Application for Significant Modification No. 0214-10 Kalaeloa Partners, L.P. (KPLP) Kalaeloa Cogeneration Plant (KCP) 223.5 MW Kalaeloa Cogeneration Plant Located At: 91-111 Kalaeloa Boulevard, Kapolei, Oahu B. Hawaiian Electric Companies (1) Amendment of Covered Source Permit (CSP) No. 0548-01-C Application for Significant Modification No. 0548-09 Hawaiian Electric Company, Inc. (HECO) Campbell Industrial Park (CIP) Generating Station Located At: 91-196 Hanua Street, Kapolei, Oahu (2) Amendment of Covered Source Permit (CSP) No. 0240-01-C Application for Significant Modification No. 0240-08 Hawaiian Electric Company, Inc. (HECO) Kahe Generating Station Located At: 92-200 Farrington Highway, Waianae, Oahu (3) Amendment of Covered Source Permit (CSP) No. 0238-01-C Application for Significant Modification No. 0238-05 Hawaiian Electric Company, Inc. (HECO) Honolulu Generating Station Located At: 170 Ala Moana Boulevard, Honolulu, Oahu (4) Amendment of Covered Source Permit (CSP) No. 0239-01-C Application for Significant Modification No. 0239-06 Hawaiian Electric Company, Inc. (HECO) Waiau Generating Station Located At: 475 Kamehameha Highway, Pearl City, Oahu (5) Amendment of Covered Source Permit (CSP) No. 0234-01-C Application for Significant Modification No. 0234-05 Hawaii Electric Light Company, Inc. (HELCO) Kanoelehua-Hill Generating Station Located At: 54 Halekauila Street, Hilo, Hawaii (6) Amendment of Covered Source Permit (CSP) No. 0007-01-C Application for Significant Modification No. 0007-07 (0007-01-C) Application for Significant Modification No. 0070-04 (0070-01-C) Hawaii Electric Light Company, Inc. (HELCO) Keahole Generating Station Located At: 73-4249 Pukiawe Street, Kailua Kona, Hawaii (7) Amendment of Covered Source Permit (CSP) No. 0235-01-C Application for Significant Modification No. 0235-04 Hawaii Electric Light Company, Inc. (HELCO) Puna Generating Station Located At: Puna Mill Road, Keaau, Hawaii (8) Amendment of Covered Source Permit (CSP) No. 0232-01-C Application for Significant Modification No. 0232-06 Maui Electric Company, Ltd. (MECO) Kahului Generating Station Located At: 200 Hobron Avenue, Kahului, Maui (9) Amendment of Covered Source Permit (CSP) No. 0067-01-C Application for Significant Modification No. 0067-14 (0067-01-C) Application for Significant Modification No. 0067-15 (0067-02-C) Maui Electric Company, Ltd. (MECO) Maalaea Generating Station Located At: Maalaea Generating Station, Maalaea, Maui (10) Amendment of Covered Source Permit (CSP) No. 0031-04-C Application for Significant Modification No. 0031-08 Maui Electric Company, Ltd. (MECO) Palaau Generating Station Located At: 32 Ulili Street, Kaunakakai, Molokai The DRAFT PERMITS are described as follows: The permit amendments incorporate GHG emission caps in accordance with HAR Chapter 11-60.1, Subchapter 11, to limit GHG emissions from affected facilities. Affected facilities are permitted covered sources with potential carbon dioxide equivalent (CO2e) emissions (biogenic plus nonbiogenic) equal to or greater than 100,000 short tons per year. Pursuant to HAR Chapter 11-60.1, Subchapter 11, the amendments incorporate provisions for partnering between thirteen (13) electric plants to combine emissions for flexibility in achieving the GHG reductions. Three (3) affected facilities are independent power producers (IPPs) owned and operated by AES, Hamakua Energy, and KPLP. The remaining ten (10) affected facilities are from the Hawaiian Electric Companies that include HECO, HELCO, and MECO. The partnering facilities propose a total combined GHG emission baseline for establishing the facility-wide GHG emissions cap of 7,584,991 metric tons (8,361,022 short tons) per year. Partnering facilities used 2010 as the baseline year, except for the KCP cogeneration plant which used 2009 for its baseline year because 2010 was deemed unrepresentative due to an overhaul of its steam turbine generator. Emissions from HECO’s Shipman Generating Station which closed at the end of 2015 were included in the baseline emissions. The total combined GHG emissions cap proposed for the partnering facilities for calendar year 2020 and beyond is 6,371,392 metric tons (7,023,257 short tons) of CO2e emissions per calendar year which is a 16% reduction from the proposed total combined GHG emission baseline level. For calendar year 2019, cap adjustments are necessary to compensate for the continuing unavailability of renewable energy from Puna Geothermal Venture (PGV) and delays to new renewable energy projects for reasons outside of the control of the partnering facilities. The cap adjustments will temporarily increase the total combined GHG emissions cap proposed for the partnering facilities to 6,539,587 metric tons (7,208,661 short tons) for a 13.78% reduction from the proposed total combined GHG emission baseline level. Alternate operating scenarios are added to the permits for continuing with the cap adjustments by adding one twelfth (1/12) of the 2019 annual adjustments for every month that PGV generation is delayed into and beyond calendar year 2020. The 2019 annual CO2e adjustments for each individual facility on the island of Hawaii only are 97,524 short tons for Hamakua Energy, LLC, 17,132 short tons for Kanoelehua-Hill Generating Station, 31,213 short tons for Keahole Generating Station, and 39,535 short tons for Puna Generating Station. The total combined CO2e adjustment for these facilities is 185,404 short tons. For delays in PGV generation into and beyond calendar year 2020, monthly adjustments for each individual facility on the island of Hawaii are 8,127 short tons for Hamakua Energy, LLC, 1,428 short tons for Kanoelehua-Hill Generating Station, 2,601 short tons for Keahole Generating Station, and 3,295 short tons for Puna Generating Station for a total monthly CO2e adjustment of 15,450 short tons. These alternate operating scenarios apply to each individual cap for partnering facilities on the island of Hawaii and the total combined emissions cap for all partnering facilities until PGV restores net generation of electricity to levels that that preceded it’s shutdown due to the volcanic activity that was determined to be 26,883 MWh. Once net generation of 26,883 MWh per month from the PGV facility is reached, the alternate operating scenarios no longer apply and no further adjustments will be made to the CO2e emissions caps, thereafter. For calendar year 2020 and beyond, AES further reduced its individual GHG emissions cap by 16% below its individual GHG emission baseline level. Emissions from the AES cap adjustments were distributed evenly among partnering facilities on the island of Oahu, excluding the AES plant and the HECO Honolulu Generating Station. The three (3) IPP permits and CSP No. 0548-01-C for HECO’s CIP Generating Station will specify individual and total combine GHG emission caps established for the partnering facilities. Any GHG emission cap revision will require each of these facilities (AES, Hamakua Energy, KPLP, and HECO’s CIP Generating Station) to submit a significant permit modification for the change. The permits for the remaining partnering facilities operated by HECO, HELCO, and MECO will not specify individual and total combined GHG emission caps, but instead reference GHG emission caps included in CSP No. 0548-01-C for HECO’s CIP Generating Station. Designating CSP No. 0548-01-C as the main permit will reduce the burden of modifying all Hawaiian Electric Companies’ permits should an emissions cap be revised. Only CSP No. 0548-01-C would require modification as the emission caps will not be incorporated separately into each facility’s permit. Individual and total combined GHG emission caps were established in each facility’s GHG emission reduction plan. Each facility may exceed its individual cap as long as the total combined GHG emissions cap is met. Biogenic carbon dioxide emissions are excluded in determining compliance with the CO2e emissions caps. A. Independent Power Producers (IPPs) (1) The significant modification of CSP No. 0087-02-C will grant conditional approval to incorporate an individual CO2e emissions cap of 1,534,598 metric tons (1,691,605 short tons) for calendar year 2019 and 1,281,442 metric tons (1,412,548 short tons) for calendar year 2020 and beyond that applies specifically to the AES cogeneration plant. The conditional approval includes temporarily increasing the total combined CO2e emissions cap proposed in partnering with the other affected facilities to 6,539,587 metric tons (7,208,661 short tons) for calendar year 2019 and an alternate operating scenario that adds one twelfth (1/12) of the 2019 annual adjustments to the 2020 and beyond GHG emissions cap for every month that PGV’s restoration is delayed into and beyond calendar year 2020. A total combined CO2e emissions cap of 6,371,392 metric tons (7,023,257 short tons) is specified for calendar year 2020 and beyond. The alternate operating scenarios will no longer apply once a net generation of 26,883 MWh per month from PGV is reached. (2) The significant modification of CSP No. 0243-01-C will grant conditional approval to temporarily increase individual CO2e emissions cap to 227,906 metric tons (251,223 short tons) for calendar year 2019 and an alternate operating scenario that adds one twelfth (1/12) of the 2019 annual adjustments to the 2020 and beyond GHG emission cap for every month that PGV’s restoration is delayed into and beyond calendar year 2020. For 2020 and beyond, an individual CO2e emissions cap of 139,433 metric tons (153,699 short tons) is specified for the Hamakua Energy cogeneration plant. The conditional approval includes temporarily increasing the total combined CO2e emission cap proposed in partnering with the other affected facilities to 6,539,587 metric tons (7,208,661 short tons) for calendar year 2019 and alternate operating scenario that adds one twelfth (1/12) of the 2019 annual adjustments to the 2020 and beyond GHG emissions cap for every month that PGV’s restoration is delayed into and beyond calendar year 2020. A total combined CO2e emissions cap of 6,371,392 metric tons (7,023,257 short tons is specified for calendar year 2020 and beyond. The alternate operating scenarios will no longer apply once a net generation of 26,883 MWh per month from PGV is reached. (3) The significant modification of CSP No. 0214-01-C will grant conditional approval to incorporate an individual CO2e emissions cap of 993,198 metric tons (1,094,813 short tons) for calendar year 2019 and 1,056,486 metric tons (1,164,577 short tons) for calendar year 2020 and beyond that applies specifically to the KPLP cogeneration plant. The conditional approval includes temporarily increasing the total combined CO2e emissions cap proposed in partnering with the other affected facilities to 6,539,587 metric tons (7,208,661 short tons) for calendar year 2019 and an alternate operating scenario that adds one twelfth (1/12) of the 2019 annual adjustments to the 2020 and beyond GHG emissions cap for every month that PGV’s restoration is delayed into beyond calendar year 2020. A total combined CO2e emission cap of 6,371,392 metric tons (7,023,257 short tons) is specified for calendar year 2020 and beyond. The alternate operating scenarios will no longer apply once a net generation of 26,883 MWh per month from PGV is reached. B. Hawaiian Electric Companies (1) The significant modification of CSP No. 0548-01-C will grant conditional approval to incorporate an individual CO2e emissions cap of 48,752 metric tons (53,740 short tons) for calendar year 2019 and 112,041 metric tons (123,504 short tons) for calendar year 2020 and beyond that applies specifically to the HECO CIP Generating Station. The conditional approval includes temporarily increasing the total combined CO2e emissions cap proposed in partnering with the other affected facilities to 6,539,587 metric tons (7,208,661 short tons) for calendar year 2019 and an alternate operating scenario that adds one twelfth (1/12) of the 2019 annual adjustments to the 2020 and beyond GHG emissions cap for every month that PGV’s restoration is delayed into and beyond calendar year 2020. A total combined CO2e emission cap of 6,371,392 metric tons (7,023,257 short tons) is specified for calendar year 2020 and beyond. The alternate operating scenarios will no longer apply once a net generation of 26,883 MWh per month from PGV is reached. (2) The significant modification of CSP No. 0238-01-C will grant conditional approval to incorporate an individual CO2e emissions cap 0 metric tons (0 short tons) per calendar year that applies specifically to the HECO Honolulu Generating Station. The conditional approval includes temporarily increasing the total combined CO2e emissions cap proposed in partnering with the other affected facilities to 6,539,587 metric tons (7,208,661 short tons) for calendar year 2019 and an alternate operating scenario that adds one twelfth (1/12) of the 2019 annual adjustments to the 2020 and beyond GHG emissions cap for every month that PGV’s restoration is delayed into and beyond calendar year 2020. A total combined CO2e emission cap of 6,371,392 metric tons (7,023,257 short tons) is specified for calendar year 2020 and beyond. The alternate operating scenarios will no longer apply once a net generation of 26,883 MWh per month from PGV is reached. (3) The significant modification of CSP No. 0240-01-C will grant conditional approval to incorporate an individual CO2e emissions cap 1,935,707 metric tons (2,133,752 short tons) for calendar year 2019 and 1,998,996 metric tons (2,203,516 short tons) for calendar year 2020 and beyond that applies specifically to the HECO Kahe Generating Station. The conditional approval includes temporarily increasing the total combined CO2e emissions cap proposed in partnering with the other affected facilities to 6,539,587 metric tons (7,208,661 short tons) for calendar year 2019 and an alternate operating scenario that adds one twelfth (1/12) of the 2019 annual adjustments to the 2020 and beyond GHG emissions cap for every month that PGV’s restoration is delayed into and beyond calendar year 2020. A total combined CO2e emission cap of 6,371,392 metric tons (7,023,257 short tons) is specified for calendar year 2020 and beyond. The alternate operating scenarios will no longer apply once a net generation of 26,883 MWh per month from PGV is reached. (4) The significant modification of CSP No. 0239-01-C will grant conditional approval to incorporate an individual CO2e emissions cap of 733,265 metric tons (808,286 short tons) for calendar year 2019 and 796,554 metric tons (878,050 short tons) for calendar year 2020 and beyond that applies specifically to the HECO Waiau Generating Station. The conditional approval includes temporarily increasing the total combined CO2e emissions cap proposed in partnering with the other affected facilities to 6,539,587 metric tons (7,208,661 short tons) for calendar year 2019 and an alternate operating scenario that adds one twelfth (1/12) of the 2019 annual adjustments to the 2020 and beyond GHG emissions cap for every month that PGV’s restoration is delayed beyond into and beyond calendar year 2020 to a total combined CO2e emission cap of 6,371,392 metric tons (7,023,257 short tons) in partnering with all other affected facilities. The alternate operating scenarios will no longer apply once a net generation of 26,883 MWh per month from PGV is reached. (5) The significant modification of CSP No. 0234-01-C will grant conditional approval to temporarily increase the individual CO2e emissions cap to 171,991 metric tons (189,588 short tons) for calendar year 2019 and an alternate operating scenario that adds one twelfth (1/12) of the 2019 annual adjustments to the 2020 and beyond GHG emissions cap for every month that PGV’s restoration is delayed into and beyond calendar year 2020. For calendar year 2020 and beyond, an individual CO2e emissions cap of 156,449 metric tons (172,456 short tons) per calendar year is specified for the HELCO Kanoelehua-Hill Generating Station. The conditional approval includes temporarily increasing the total combined CO2e emissions cap proposed in partnering with the other affected facilities to 6,539,587 metric tons (7,208,661 short tons) for calendar year 2019 and an alternate operating scenario that adds one twelfth (1/12) of the 2019 annual adjustments to the 2020 and beyond GHG emission cap for every month that PGV’s restoration is delayed into and beyond calendar year 2020. A total combined CO2e emission cap of 6,371,392 metric tons (7,023,257 short tons) is specified for calendar year 2020 and beyond. The alternate operating scenarios will no longer apply once PGV net generation of 26,883 MWh per month is reached. (6) The significant modification of CSP No. 0007-01-C will grant conditional approval to temporarily increase the individual CO2e emissions cap to 248,043 metric tons (273,421 short tons) for calendar year 2019 and an alternate operating scenario that adds one twelfth (1/12) of the 2019 annual adjustments to the 2020 and beyond GHG emissions cap for every month that PGV’s restoration is delayed into and beyond calendar year 2020. For calendar year 2020 and beyond, an individual CO2e emissions cap of 219,727 metric tons (242,208 short tons) per calendar year is specified for the HELCO Keahole Generating Station. The conditional approval includes temporarily increasing the total combined CO2e emissions cap proposed in partnering with the other affected facilities to 6,539,587 metric tons (7,208,661 short tons) for calendar year 2019 and an alternate operating scenario that adds one twelfth (1/12) of the 2019 annual adjustments to the 2020 and beyond GHG emissions cap for every month that PGV’s restoration is delayed into and beyond calendar year 2020. A total combined CO2e emission cap of 6,371,392 metric tons (7,023,257 short tons) is specified for calendar year 2020 and beyond. The alternate operating scenarios will no longer apply once a net generation of 26,883 MWh per month from PGV is reached. (7) The significant modification of CSP No. 0235-01-C will grant conditional approval to temporarily increase the individual CO2e emissions cap to 64,666 metric tons (71,282 short tons) for calendar year 2019 and an alternate operating scenario that adds one twelfth (1/12) of the 2019 annual adjustments to the 2020 and beyond GHG emissions cap for every month that PGV’s restoration is delayed into and beyond calendar year 2020. For calendar year 2020 and beyond an individual CO2e emissions cap of 28,800 metric tons (31,747 short tons) per calendar year for the HELCO Puna Generating Station. The conditional approval includes temporarily increasing the total combined CO2e emissions cap proposed in partnering with the other affected facilities to 6,539,587 metric tons (7,208,661 short tons) for calendar year 2019 and an alternate operating scenario that adds one twelfth (1/12) of the 2019 annual adjustments to the 2020 and beyond GHG emissions cap for every month that PGV’s restoration is delayed into and beyond calendar year 2020. A total combined CO2e emission cap of 6,371,392 metric tons (7,023,257 short tons) is specified for calendar year 2020 and beyond. The alternate operating scenarios will no longer apply once a net generation of 26,883 MWh per month from PGV is reached. (8) The significant modification of CSP No. 0232-01-C will grant conditional approval to incorporate an individual CO2e emissions cap of 140,281 metric tons (154,633 short tons) per calendar year that applies specifically to the MECO Kahului Generating Station. The conditional approval includes temporarily increasing the total combined CO2e emissions cap proposed in partnering with the other affected facilities to 6,539,587 metric tons (7,208,661 short tons) for calendar year 2019 and an alternate operating scenario that adds one twelfth (1/12) of the 2019 annual adjustments to the 2020 and beyond GHG emissions cap for every month that PGV’s restoration is delayed into and beyond calendar year 2020. A total combined CO2e emission cap of 6,371,392 metric tons (7,023,257 short tons) is specified for calendar year 2020 and beyond. The alternate operating scenarios will no longer apply once a net generation of 26,883 MWh per month from PGV is reached. (9) The significant modification of CSP No. 0067-01-C will grant conditional approval to incorporate an individual CO2e emissions cap of 417,182 metric tons (459,864 short tons) per calendar year that applies specifically to the MECO Maalaea Generating Station. The conditional approval includes temporarily increasing the total combined CO2e emissions cap proposed in partnering with the other affected facilities to 6,539,587 metric tons (7,208,661 short tons) for calendar year 2019 and an alternate operating scenario that adds one twelfth (1/12) of the 2019 annual adjustments to the 2020 and beyond GHG emissions cap for every month that PGV’s restoration is delayed into and beyond calendar year 2020. A total combined CO2e emission cap of 6,371,392 metric tons (7,023,257 short tons) is specified for calendar year 2020 and beyond. The alternate operating scenarios will no longer apply once PGV net generation of 26,883 MWh per month is reached. (10) The significant modification of CSP No. 0031-04-C will grant conditional approval to incorporate an individual CO2e emissions cap of 23,999 metric tons (26,454 short tons) per calendar year that applies specifically to the MECO Palaau Generating Station. The conditional approval includes temporarily increasing the total combined CO2e emissions cap proposed in partnering with the other affected facilities to 6,539,587 metric tons (7,208,661 short tons) for calendar year 2019 and an alternate operating scenario that adds one twelfth (1/12) of the 2019 annual adjustments to the 2020 and beyond GHG emissions cap for every month that PGV’s restoration is delayed into and beyond calendar year 2020. A total combined CO2e emission cap of 6,371,392 metric tons (7,023,257 short tons) is specified for calendar year 2020 and beyond. The alternate operating scenarios will no longer apply once a net generation of 26,883 MWh per month from PGV is reached. The ADMINISTRATIVE RECORDS, consisting of the APPLICATIONS, GHG EMISSION REDUCTION PLANS, and non-confidential supporting material from the applicant, the permit review summary, and the DRAFT PERMITS, are available for public inspection during regular office hours, Monday through Friday, 7:45 a.m. to 4:15 p.m., at the following locations: Oahu: State of Hawaii Clean Air Branch 2827 Waimano Home Road, #130 Pearl City, HI 96782 Hawaii: Hilo: Hawaii District Health Office, Department of Health 1582 Kamehameha Avenue, Hilo, Hawaii 96720 Kona: Sanitation Branch, Department of Health 79-1020 Haukapila Street, Room 115, Kona, Hawaii 96750 Maui: Maui District Health Office, Department of Health 54 High Street, Wailuku, Maui 96793 Kauai: Kauai District Health Office, Department of Health 3040 Umi Street, Lihue, Kauai 96766 All comments on the draft permits 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 August 14, 2020. 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 (30) 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 Oahu office of the Clean Air Branch listed above or call Mr. Dale Hamamoto (CSPs for Hamakua Energy and KPLP facilities) or Mr. Michael Madsen (CSPs for AES, HECO, HELCO, and MECO facilities) at the Clean Air Branch office at (808) 586-4200. Electronic copies of the draft permits, permit reviews, and GHG emission reduction plans may be found online at http://health.hawaii.gov/cab/public-notices/. Comments on the draft permits 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 permits after considering all comments and will send notice of the final decision to each person who has submitted comments or requested such notice. Bruce S. Anderson, Ph.D. Director of Health (HTH1287141 7/14/20)