Frederick
J.
Neri,
Jr.
Plant
Manager
Calpine
Parlin
Cogeneration
Facility
970
Washington
Road
Parlin,
NJ
08859
Re:
Calpine
Parlin,
Inc.
Request
for
Alternative
NSPS
Subpart
Db
Opacity
Monitoring
Requirement
Dear
Mr.
Neri:

The
U.
S.
Environmental
Protection
Agency
(
EPA)
has
reviewed
your
letter
dated
April
11,
2001,
requesting
an
Alternative
Monitoring
Procedure
with
respect
to
Continuous
Opacity
Monitoring
(
COMS)
requirements
for
its
auxiliary
boilers
that
are
subject
to
NSPS
Subpart
Db.
The
basis
for
your
request
is
that
Calpine
Parlin's
auxiliary
boilers
are
affected
by
the
opacity
standard
provided
in
40
CFR
§
60.43
(
b),
only
when
firing
kerosene,
and
would
not
be
subject
to
the
opacity
monitoring
requirements
when
firing
natural
gas.

EPA
concurs
with
Calpine
Parlin
that
an
opacity
monitor
is
not
required
when
only
natural
gas
is
fired.
However,
when
firing
kerosene
the
facility
is
still
subject
to
the
opacity
standard
as
provided
in
40
CFR
§
60.43
(
b)
(
f).
Since
historical
data
shows
that
boiler
operations
when
burning
kerosene
are
limited,
40
CFR
§
60.13
(
i)
(
2)
allows
EPA
to
approve
alternative
opacity
monitoring
requirements
for
sources
that
are
"
infrequently
operated".

EPA
will
allow
Calpine
Parlin
to
use
visual
determination
of
opacity
during
the
firing
of
kerosene
in
the
auxiliary
boilers
(
40
CFR
§
60,
Appendix
A,
Method
9)
provided
that
it
complies
with
the
following
conditions:

A.
Two
certified
smoke
readers
will
be
on
the
operating
staff
of
Calpine
Parlin,
Inc.

B.
At
least
one
certified
smoke
reader
will
be
present
at
the
facility
when
an
auxiliary
boiler
is
required
to
operate
on
kerosene.

C.
A
six­
minute
reading
will
be
taken
at
the
beginning
of
every
hour
that
an
auxiliary
boiler
is
operating
on
kerosene.
If
the
six­
minute
reading
exhibits
an
average
of
20%
opacity
or
greater,
then
readings
will
continue
at
six­
minute
intervals
until
a
six­
minute
reading
exhibits
an
opacity
average
of
less
than
20%.
Opacity
readings
during
night
time
hours
are
exempt.

D.
A
six­
minute
reading
will
be
taken
during
the
first
six
minutes
of
boiler
start­
up
on
kerosene.
If
the
six­
minute
reading
exhibits
an
average
of
20%
opacity
or
greater,
then
readings
will
continue
at
six­
minute
intervals
until
a
six­
minute
reading
exhibits
an
opacity
average
of
less
than
20%.
Opacity
readings
during
night
time
hours
are
exempt.
E.
Certification
records
of
smoke
readers,
and
all
smoke
readings
taken
shall
be
kept
on­
site
for
at
least
five
years.

F.
Records
of
the
reasons
for
operating
the
auxiliary
boilers
when
firing
kerosene,
the
times
of
operation,
the
amount
of
kerosene
used,
and
fuel
analysis
shall
be
kept
onsite
for
at
least
five
years.

G.
All
records
pertinent
to
this
Alternative
Opacity
Monitoring
Procedure
shall
be
kept
on­
site
for
a
period
of
five
years,
and
be
available
for
inspection
by
personnel
of
Federal,
State,
and
Local
pollution
control
agencies.

H.
Should
Calpine
Parlin,
Inc.
opt
to
use
the
continuous
monitoring
system
required
by
40
CFR
§
60.48b
(
a),
it
shall
provide
EPA
with
notice
60
days
in
advance.

Any
deviations
from
the
above
conditions
would
constitute
a
violation
of
the
NSPS.
If
you
have
any
questions
regarding
this
letter,
please
contact
Marina
Castro
at
212­
637­
3516.

Sincerely,

Kenneth
Eng,
Chief
Air
Compliance
Branch
