Ms.
Asavari
Alzarez
Manager,
Commercial
Management
Newark
Bay
Cogeneration
Partnership,
L.
P.
414­
462
Avenue
P
Newark,
NJ
07105
Dear
Ms.
Alzarez:

The
U.
S.
Environmental
Protection
Agency
(
EPA)
is
revising
the
determination
contained
in
the
enclosed
letter
sent
to
Mr.
Thomas
J.
Koehler,
General
Manager
of
Newark
Bay
Cogeneration
Partnership
(
NBCP)
on
September
29,
1995.
The
revision
consists
principally
of
changing
conditions
C
and
D
under
the
alternative
opacity
monitoring
requirements
granted
to
NBCP.
These
modifications
are
necessary
because
we
do
not
now
believe
that
two­
minute
readings
are
sufficient.
The
specific
terms
to
be
followed
are
described
below:

An
opacity
monitor
is
not
required
when
only
natural
gas
is
fired
in
the
auxiliary
boilers.
However,
when
firing
kerosene
the
facility
is
still
subject
to
the
opacity
standards
as
provided
in
40
CFR
§
60.43b
(
f).
Since
boiler
operation
is
restricted
by
a
NJDEP
Air
Permit
to
about
3%
of
total
potential
annual
fuel
usage,
40
CFR
§
60.13
(
i)
(
2)
allows
EPA
to
approve
alternative
opacity
monitoring
requirements
for
sources
that
are
"
infrequently
operated".

EPA
will
continue
to
allow
NBCP
to
use
visual
determination
of
opacity
during
the
firing
of
kerosene
in
the
auxiliary
boiler
(
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
NBCP.

B)
At
least
one
certified
smoke
reader
will
be
at
the
facility
when
auxiliary
boiler
operation
is
required.

C)
A
six­
minute
reading
will
be
taken
at
the
beginning
of
every
hour
that
the
auxiliary
boilers
are
operating.
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%.
Night
readings
are
exempt.

D)
A
six­
minute
reading
will
be
taken
during
the
first
six
minutes
of
boiler
start­
up.
If
the
sixminute
reading
exhibits
an
average
of
20%
opacity
or
greater,
then
readings
will
continue
at
sixminute
intervals
until
a
six­
minute
reading
exhibits
an
opacity
average
of
less
than
20%.
Night
readings
are
exempt.

E)
Records
of
certification
of
smoke
readers
and
all
smoke
readings
taken
shall
be
kept
onsite
for
at
least
five
years.
F)
Records
of
the
reasons
for
operating
the
auxiliary
boilers,
the
times
of
operation,
the
types
and
amount
of
fuel
used,
and
fuel
analysis
shall
be
kept
for
at
least
five
years.

G)
All
records
pertinent
to
this
alternative
opacity
monitoring
method
shall
be
kept
onsite
for
a
period
of
five
years,
and
be
available
for
inspection
by
personnel
of
federal,
state,
and
local
pollution
control
agencies.

H)
Should
NBCP
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
deviation
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
