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Chang, Andy

From: Jones, Rhea

Sent: Wednesday, January 13, 2016 7:21 AM

To: Chang, Andy

Cc: Mathias, Scott

Subject: FW: SO2 air dispersion modeling: H.A. Wagner (Maryland)

Attachments: 2014 01 16 Draft COMAR 26.11.39 - SO2.pdf; 2014 02 12 MDE SO2 Modeling 

Presentation.pdf

Looking at this now, but Andy, please forward to R3. Thanks! 

From: Joshua Berman [mailto:josh.berman@sierraclub.org] 

Sent: Tuesday, January 12, 2016 8:36 PM 

To: Mathias, Scott <Mathias.Scott@epa.gov> 

Cc: Jones, Rhea <Jones.Rhea@epa.gov>; Zachary Fabish <zachary.fabish@sierraclub.org> 

Subject: Re: SO2 air dispersion modeling: H.A. Wagner (Maryland) 

Dear Ms. Jones and Mr. Mathias: 

 

As a follow-up to the time series modeling that I provided last week, I wanted to briefly address a couple of points in Maryland’s November 

20, 2015 SO2 designation submission. 

 

First, contrary to the State’s suggestion, the ambient monitor data collected during a two-month period in 2013 if anything supports a 

nonattainment designation—not an attainment designation—for the area around the Wagner and Brandon Shores facilities. Notably, this is 

the only reported ambient monitor data that was collected in any proximity to the Wagner and Brandon Shores facilities. Given its limited 

two-month duration, the occurrence of a maximum 1-hour SO2 concentration of 101.7 ppb at the monitor closest to those plants during that 

time, and the fact that the monitoring was conducted during the summer months even though Wagner Unit 2 has been operating at far higher 

capacity factors in winter than summer months in recent years (and Unit 3’s operations show no seasonal bias), even a basic extrapolation the 

monitored results produces a 99th percentile 1-hour maximum far in excess of the 75 ppb standard. 

 

Second, in Attachment 6, the State indicates that on January 15, 2016 it will “identif[y] federally enforceable emissions limits or permit 

conditions that may be needed to support the attainment designation.” Unless those limitations have been fully reviewed and vetted by EPA 

to ensure they adequately maintain the SO2 NAAQS and are already embodied in federally enforceable permits or regulations, EPA cannot 

rely on the State’s unenforceable promise of potential future action as a basis for declining to propose a nonattainment designation at this 

time. I also wanted to draw your attention to SO2 modeling that MDE previously completed for these plants and modeling-informed SO2 

emission limits that MDE previously shared with stakeholders in early 2014. I have attached MDE's presentation to stakeholders from 

February 2014 in which MDE summarizes the results of its modeling (as well as Sierra Club's prior modeling) and explains the unit-specific 

emission rates necessary to ensure compliance with the 1-hour SO2 NAAQS. Shortly before that stakeholder meeting, MDE released to 

stakeholders a draft SO2 regulation (attached) that includes modeling-informed unit- or plant-specific emission rates. EPA should review 

with special care any newly proposed emission limitations that differ meaningfully from those identified by Maryland as requisite to maintain 

the NAAQS in 2014. 

 

Finally, the State indicates that it will be submitting “further emissions and modeling analyses and information” in “early 2016.” To date, 

EPA has not posted any additional submissions on its State Designations webpage. If EPA has or receives any additional submissions from 

Maryland, I would appreciate if you could post those on the website and/or provide a copy to me. 
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Thank you, 

Josh 

On Tue, Jan 5, 2016 at 10:47 AM, Mathias, Scott <Mathias.Scott@epa.gov> wrote: 

Mr. Berman,

On behalf of Ms. Jones, I’m acknowledging that we have received your email and its attachments pertaining 

to the power plants located in the Baltimore area.

Scott Mathias | Associate Director, Air Quality Policy Division | U.S. EPA, RTP, NC 27711 | 919.541.5310

From: Joshua Berman [mailto:josh.berman@sierraclub.org] 

Sent: Monday, January 04, 2016 4:19 PM 

To: Mathias, Scott <Mathias.Scott@epa.gov>; Jones, Rhea <Jones.Rhea@epa.gov> 

Cc: Fernandez, Cristina <Fernandez.Cristina@epa.gov>; Esher, Diana <Esher.Diana@epa.gov>; George Aburn -MDE- 

<george.aburn@maryland.gov>; Zachary Fabish <zachary.fabish@sierraclub.org> 

Subject: SO2 air dispersion modeling: H.A. Wagner (Maryland)

 

Ms. Jones and Mr. Mathias: 

 

Per the attached cover letter, please find enclosed time series and steady-state sulfur dioxide air dispersion 

modeling for the H.A. Wagner, C.P. Crane, and Brandon Shores power plants located in the Baltimore area in 

Maryland. This modeling was previously provided as an attachment to a June 18, 2015 letter to the Maryland 

Department of the Environment, and is provided here again as an attachment along with the original June 18th 

letter. CDs with the input and output files are being sent via FedEx and copied to the other recipients on this 

email. 

 

If you have any questions, please let me know. 

 

Thank you, 

Josh 
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-- 

Joshua Berman 

Staff Attorney 

Sierra Club Environmental Law Program 

50 F St. NW, 8th Floor 

Washington, DC 20001 

Tel: (202) 650-6062

Fax: (202) 547-6009

-- 

Joshua Berman 

Staff Attorney 

Sierra Club Environmental Law Program 

50 F St. NW, 8th Floor 

Washington, DC 20001 

Tel: (202) 650-6062 

Fax: (202) 547-6009