Commonwealth of Massachusetts 

Executive Office of Energy & Environmental Affairs 

Department of Environmental Protection 

One Winter Street Boston, MA 02108 " 617-292-5500 

DEVAL L PATRICK RICHARD K. SULLIVAN JR . 

Governor Secretary 

TIMOTHY P MURRAY KENNETH L. KIMMELL 

Lieutenant Governor Commissioner 

Proposed Revision to Massachusetts Regional Haze State 

Implementation Plan 

February 17, 2012 

This information is available in alternate format . Call Michelle Waters-Ekanem, Diversity Director, at 617-292-6761 . TDD# 1-866-639-7622 or 1-617-674-6868 

MassDEP Website: www.mass.gov/dep 

Printed on Recycled Paper 
Executive Summary 

On December 30, 2011, the Massachusetts Department of Environmental Protection (MassDEP) 

submitted a Regional Haze State Implementation Plan (SIP) to the U.S . Environmental 

Protection Agency (EPA) for approval . The SIP is available on MassDEP's website at 

www.mass. og v/dep/air/ariorities/sip .htm#haze. As explained in the Executive Summary of that 

SIP, MassDEP had originally proposed to meet certain SIP requirements regarding electric 

generating units (EGUs) by relying on emissions reductions in Massachusetts proposed in EPA's 

draft Transport Rule. However, EPA did not include Massachusetts in its final Transport Rule 

("Cross-State Air Pollution Rule," 76 FR 48208, August 8, 2011), which necessitated a revision 

to the SIP. MassDEP now is proposing this SIP revision to amend the December 30, 2011 SIP to 

address Best Available Retrofit Technology (BART) requirements for EGUs by adding Section 

8 .10: Alternative to BART and Section 8 .11 : BART for PM1o Emissions, and to revise the 

Targeted EGUStrategy in Section 10.5 : Additional Reasonable Strategies . These revisions 

include : 

Best Available Retrofit Technology - EPA's Regional Haze Rule requires the control of 

emissions from certain stationary sources placed into operation between 1962 and 1977 through 

the implementation of Best Available Retrofit Technology (BART) or an alternative to BART 

that achieves greater emission reductions. As described in Section 8 of the December 30, 2011 

SIP, MassDEP identified 5 electric generating unit (EGU) facilities, 1 municipal waste 

combustor, and 1 industrial boiler as BART-eligible facilities whose 2002 emissions (the 

baseline year for this SIP) contributed significantly to visibility impairment . MassDEP 

originally proposed to rely on EPA's draft Transport Rule as an Alternative to BART for EGUs, 

but could not finalize its proposal because Massachusetts was not included in EPA's final CrossState Air Pollution Rule . MassDEP now proposes a different Alternative to BART for EGUs 

that includes the following measures : 

1 . Existing regulation 310 CMR 7 .29, Emissions Standards for Power Plants, which 

establishes NO,, and SOZ emissions rates (as well as mercury emission rates and carbon 

dioxide caps) for certain EGUs. 

2. The retirement of Somerset Power. 

3 . Permit restrictions for Brayton Point, Salem Harbor, and Mt. Tom Station that limit/retire 

SOZ and/or NO, emissions. 

4. Existing regulation 310 CMR 7.19, Reasonably Available Control Technology (RA CT) 

for Sources of Oxides ofNitrogen NO,, which establishes NO, emission rates for various 

sources, including EGUs. 

5 . MassDEP's proposed amendments to its low sulfur fuel oil regulation, which would 

require EGUs that burn residual oil to limit the sulfur content to 0.5% by weight 

beginning July 1, 2014. 

This Proposed Revision to the Massachusetts Regional Haze SIP also addresses BART for PMIO . 

However, MassDEP has determined that no additional controls are warranted for primary PM1o 

because controls have been added to all but one of the facilities, and the additional cost of further 

control is not justified since there would be no significant visibility improvement. 
Targeted EGU strategy - Massachusetts is a member of the Mid-Atlantic Northeast Visibility 

Union (MANE-VU), comprised of Mid-Atlantic and Northeast states, tribes, and federal 

agencies, and participated in a regional planning process led by MANE-VU to develop strategies 

for reducing regional haze. MANE-VU identified 167 EGU stacks at power plants in the 

MANE-VU region and adjacent Mid-West and Southeast regions of the U.S . whose sulfur 

dioxide (SOZ) emissions significantly impaired visibility at one or more MANE-VU Class I areas 

(national parks, forests and wilderness areas) . The "167 Stacks" included stacks at 5 

Massachusetts power plants . Massachusetts, along with other MANE-VU states, agreed to 

reduce SOZ emissions from the power plant stacks by 90 percent from 2002 levels by 2018, or to 

pursue equivalent alternative measures. MassDEP originally proposed to rely on EPA's draft 

Transport Rule to meet the Targeted EGU strategy, but could not finalize its proposal because 

Massachusetts was not included in EPA's final Cross-State Air Pollution Rule . 

MassDEP now proposes a revised Targeted EGU Strategy. Taking into account 310 CMR 7 .29 

SOZ emission rates, permit restrictions and retirements, and MassDEP's proposed low-sulfur oil 

regulation, described above, MassDEP conservatively projects SOz emissions in 2018 would 

represent at least a 67% reduction in SOZ emissions compared to 2002 emissions. However, 

taking into account the addition of EPA's recently finalized Mercury and Air Toxics Standards 

(MATS) rule', including the SOz compliance option and incentives for low utilization of oil-fired 

units, MassDEP believes there is a likelihood that SOZ emissions in 2018 will be up to 87% 

lower than 2002 emissions. Therefore, MassDEP believes that existing regulatory programs will 

lead to SOZ emission reductions that fulfill the MANE-VU Targeted EGU Strategy for 

Massachusetts. MassDEP will review emissions and individual facility MATS compliance 

strategies in a mid-course planning review in 2013, and if emissions reductions are not projected 

to be close to 90%, MassDEP will assess whether other equivalent SOZ reduction strategies may 

be necessary. 

MassDEP is soliciting public comment on this Proposed Revision to the Massachusetts Regional 

Haze SIP (the public hearing notice is available at www.rnass . rov/dep/public/publiche .htm). 

After public hearing and comment, MassDEP must make any necessary changes and submit a 

final Regional Haze SIP Revision to EPA by June 20122 to meet the requirements for addressing 

regional haze contained in Section 169A of the Clean Air Act and in EPA's Regional Haze Rule 

at 40 CFR 51 .308(b) . 

' www.,-Ypo .gov/fdsys/pkg/I'R-2012-02-16/pdf/2012-806 .pdf 

Z Submittal of the final Regional Haze SIP to EPA by this date is necessary so EPA can finalize action on the SIP by 

July 13, 2012, as required by a proposed federal Consent Decree (available at 

www.eLia-aov/visibi litv/pdfs/201 11 109conseritdecree.pdf) . 

2 
Contents 

8.10. Alternative To BART 

8.11. BART for PMIO Emissions 

10.5. Additional Reasonable Strategies 

Targeted EGU Strategy 

Appendices (Note to reviewers: lettering is continued from the Appendices in the December 

30, 2011 Regional Haze SIP. Appendices prior to DD are available at 

www.mass. =o~ v/dep/air/priorities/llazeapps.htm). 

DD: 310 CMR 7.29, Emissions Standards for Power Plants 

EE : Mt. Tom Station - Amended Emission Control Plan Final Approval; MassDEP, May 2009. 

FF: Salem Harbor - Amended Emission Control Plan Draft Approval; MassDEP, February 

2012 

GG: Brayton Point - Amended Emission Control Plan Draft Approval; MassDEP, February 

2012 

HH: Somerset Power - Letter Revoking Permits; MassDEP, June 2011 . 

II : Proposed Amendments to 310 CMR 7.00 : Definitions and 310 CMR 7.05 : Fuels All 

Districts; MassDEP, February 2012 
8.10. Alternative to BART 

EPA's Regional Haze Rule at 40 CFR 51 .308(e)(3) gives states the authority to implement an 

alternative measure that achieves greater reasonable progress towards improving visibility at 

Class I areas than source-specific Best Available Retrofit Technology (BART). A state can 

establish a BART benchmark (i .e ., emissions reductions that would result from the application of 

source-specific BART), and then can compare the emissions reductions achieved from the 

alternative measure with the emissions reductions that would be achieved from the BART 

benchmark. If the reductions from the alternative measure are greater than the BART 

benchmark, the state can assume that the alternative measure results in greater reasonable 

progress than BART. 

MassDEP proposes an alternative to BART that covers all of the BART-eligible electric 

generating units (EGUs) plus all additional coal- and oil-fired EGUs subject to MassDEP's 

regulation 310 CMR 7.29, Emissions Standards for Power Plants . This includes the BARTeligible EGUs (Brayton Point Units 1-4, Canal Station Units 1-2, Mystic Unit 7, Salem Harbor 

Unit 4, and Cleary Flood Units 8-9), plus additional units subject to 310 CMR 7.29, which 

include Salem Harbor Units 1-3, Mt. Tom Station Unit l, and Somerset Power Unit 8. 

MassDEP's proposed alternative to BART includes the following measures : 

1 . Existing regulation 310 CMR 7.29, Emissions Standards for Power Plants, which 

establishes NOX and SOZ emissions rates (as well as mercury emission rates and carbon 

dioxide caps) for certain EGUs. 

2 . The retirement of Somerset Power. 

3 . Permit restrictions for Brayton Point, Salem Harbor, and Mt. Tom Station that limit/retire 

SOZ and/or NOx emissions. 

4 . Existing regulation 310 CMR 7.19, Reasonably Available Control Technology (RACT) 

for Sources of Oxides of Nitrogen NO,, which establishes NOX emission rates for various 

sources, including EGUs. 

5 . MassDEP's proposed amendments to its low sulfur fuel oil regulation, which would 

require EGUs that burn residual oil to limit the sulfur content to 0 .5% by weight 

beginning July 1, 2014. 

As demonstrated below, MassDEP's alternative to BART will achieve greater emission 

reductions of SOZ and NOX than would be achieved through the installation and operation of 

BART alone. The following sections establish a BART benchmark, provide estimated emission 

reductions that will be achieved by the alternative to BART measures listed above, and show that 

reductions from these alternative measures exceed reductions from the application of BART 

alone . 

BART benchmark 

Massachusetts has used a most-stringent-case BART as the BART benchmark, based on EPA's 

Guideline for BART Determinations and the MANE-VU Workgroup recommended emissions 
limits for SOZ and NO,,, which take into consideration the currently available cost-effective SOZ 

and NO. control technologies for EGUs. 

EPA's Guideline for BART Determinations (40 CFR 51, Appendix Y) establishes presumptive 

SOZ emission limits for 750 megawatt (MW) and larger power plants . Four facilities (Brayton, 

Canal, Mystic, and Salem Harbor) are greater than 750 MW, while Cleary Flood is below 750 

MW. Seven of the BART-eligible units are primarily oil-fired, while Brayton Point Units 1, 2, 

and 3 are primarily coal-fired . 

For each oil-fired EGU at a 750 MW or larger power plant, regardless of size, EPA recommends 

that, for SOZ control purposes, states evaluate limiting the sulfur content of the fuel oil burned to 

1 percent or less by weight . For NO, control purposes at power plants with a generating capacity 

in excess of 750 MW currently using SNCR or SCR for part of the year, EPA suggests that use 

of such controls year round is BART. 

For each uncontrolled coal-fired EGU greater than 200 MW at a 750 MW or larger power plant, 

EPA recommends SOZ control levels of either 95% or 0 .15 lbs/MMBtu . For NO,, EPA 

recommends using selective non-catalytic reduction (SNCR) or selective catalytic reduction 

(SCR) year round. For coal-fired EGUs operating without post-combustion NO,{ controls, EPA 

provides presumptive NO, emission rates differentiated by boiler design and type of coal burned . 

As part of the regional consultation process, the MANE-VU BART Workgroup established 

recommended BART emission limits for various types of sources (see Appendix R, Five-Factor 

Analysis of BART-Eligible Sources) . Table 15 includes the MANE-VU BART Workgroup 

recommended BART emission limits for non-CAIR EGUs . (The BART-eligible units in 

Massachusetts are considered non-CAIR EGUs because Massachusetts was not subject to the 

CAIR SOZ and NOX annual programs.) The MANE-VU BART workgroup's recommended 

BART emission limits are the same as EPA's recommended limits for SOZ for coal, but are more 

stringent than the EPA recommended limits for SOZ for oil and for NO, Therefore, 

Massachusetts used the MANE-VU recommended emission limits to establish the BART 

benchmark. 

Table 15: MANE-VU BART workgroup recommended BART emission 

limits for SOZ and NO,, for non-CAIR EGUs 

SOZ NO, 

95% control or 0.15 lb/MMBtu o In NO,, SIP call area, 

(coal) and 0.33 Ibs/MMBtu (oil) extend use of controls to 

year-round, and 

o 0 .1 - 0 .25 lbs/MMBtu, 

depending on boiler and fuel type 

Massachusetts' Alternative BART Program for SOZ 

MassDEP's Alternative to BART for SOZ relies on: 
1 . 310 CMR 7.29, Emissions Standards for Power Plants, which establishes SOZ emissions 

standards for certain EGUs. 

2. Permit restrictions for Mt. Tom Station, Brayton Point, and Salem Harbor that disallow 

the use of 310 CMR 7.29 SOZ Early Reduction Credits and federal Acid Rain Allowances 

for compliance with 310 CMR 7.29 . 

3. An annual cap of 300 tons of S02 for Salem Harbor Unit 2, and a shutdown of Units 3 

and 4 beginning June 1, 2014 . 

4. The retirement of Somerset Power in 2010 . 

5. MassDEP's proposed low sulfur fuel oil regulation, which would require EGUs that burn 

residual oil to limit the sulfur content to 0.5% by weight beginning July 1, 2014. 

Each is described below: 

310 CMR 7 .29, Emissions Standards for Power Plants : MassDEP's existing regulation 310 

CMR 7.29 (Appendix DD) establishes a facility-wide rolling 12-month S02 emissions rate of 3 .0 

pounds per megawatt-hour and a monthly average emissions rate of 6.0 pounds per megawatthour. This regulation allows the use of 310 CMR 7.29 S02 Early Reduction Credits (on a 1 ton 

credit to 1 ton excess emission basis) and the use of federal Acid Rain S02 Allowances (on a 3 

ton allowance to 1 ton excess emission basis) for compliance with the 3 .0 pounds per megawatthour emissions rate . 310 CMR 7.29 applies to Brayton Point, Canal Station, Mt. Tom Station, 

Mystic, Salem Harbor, and Somerset Power. 

Mt. Tom Station: On May 15, 2009, MassDEP issued an amended Emission Control Plan Final 

Approval (Appendix EE) for Mt. Tom Station that prohibits the use of 310 CMR 7.29 SOZ Early 

Reduction Credits and federal Acid Rain Allowances for compliance with 310 CMR 7.29. 

Brayton Point: On February 16, 2012, at Brayton Point's request, MassDEP issued an Amended 

Emission Control Plan Draft Approval (Appendix GG) that would prohibit the use of Early 

Reduction Credits and federal Acid Rain Allowances for compliance with 310 CMR 7.29 after 

June 1, 2014. 

Salem Harbor: On February 17, 2012, at Salem Harbor's request, MassDEP proposed an 

Amended Emission Control Plan (ECP) Approval (Appendix FF) that would prohibit the use of 

310 CMR 7.29 S02 Early Reduction Credits and federal Acid Rain Allowances for compliance 

with 310 CMR 7 .29, after June 1, 2014 . The ECP also would establish an annual cap of 300 tons 

of SOZ for Salem Harbor Unit 23 and the shutdown of Units 3 and 4 effective June 1, 2014. 

Somerset Power Retirement: Somerset Power ceased operating in 2010, and on June 22, 2011, at 

Somerset Power's request, MassDEP issued a letter (Appendix HH) that revoked all air 

approvals and permits for the facility and deemed all pending permit applications withdrawn. 

3 Salem Harbor Units 1 and 2 were removed from service as of December 31, 2011, which means that these units 

can no longer generate electricity for the power grid . These units are not restricted from operating for other 

purposes ; therefore, MassDEP must establish permit restrictions in order for emission reductions at these units to be 

counted in the Alternative to BART. 
Low sulfur oil : On February 17, 2012, MassDEP proposed amendments to 310 CMR 7.00 : 

Definitions and 310 CMR 7 .05, Fuels All Districts (Appendix 11) to lower the allowable sulfur 

content of distillate oil and residual oil combusted by stationary sources . For residual oil, 310 

CMR 7.05 currently limits sulfur content to 0.5% to 2 .2%, depending on the area of the state 

(most areas are limited to 1% or lower) . The proposed amendments would establish a 1% limit 

statewide beginning July 1, 2014, but for power plants would establish a 0.5% limit by that date 

(equivalent to 0.56 lbs S02/MMBtu) . The proposed amendments would require all stationary 

sources to meet a 0.5% limit statewide beginning July l, 2018.4 

Analysis of Alternative BART Program for S02 

Table 16 shows the BART benchmark projected SOZ emissions for the BART-eligible units, 

which were calculated by multiplying the MANE-VU BART workgroup recommended BART 

S02 emission rates in lbs/MMBtu (see Table 15 above) by each unit's 2002 heat input in 

MMBtu. The BART benchmark results in a projected emissions reduction of 50,752 tons of SOZ 

from 2002 emissions. 

Table 16: BART Benchmark for S02 

ART Eligible 

Facility nit 

2002 SO2 

Emissions 

(Tons) 

2002 Heat 

Input 

(MMBtu) 

MANE-VU 

Recommended 

S02 BART 

Emission Rate 

(Ibs/MMBtu) 

BART Benchmark 

Projected SOZ 

Emissions (Tons) 

Brayton Point 1 9,254 17,000,579 0.15 1,275 

Brayton Point 2 8,853 15,896,795 0.15 1,192 

Brayton Point 3 19,450 36,339,809 0.15 2,725 

Brayton Point 4 2,037 4,787,978 0.33 790 

Canal Station 1 13,066 27,295,648 0.33 4,504 

Canal Station 2 8,948 19,440,919 0.33 3,208 

Cleary Flood 8 39 92,567 0.33 15 

Cleary Flood 9 68 2,123,819 0.33 350 

Mystic 7 3,727 15,172,657 0.33 2,503 

Salem Harbor 4 2,886 6,137,412 0.33 1,013 

Total 68,328 17,576 

50z Reduction 50,752 

Table 17 shows the Alternative to BART projected SOZ emissions, which were calculated by 

multiplying MassDEP's proposed low-sulfur fuel oil regulation SOZ emission rates in 

lbs/MMBtu by the 2002 heat input in MMBtu, multiplying the 310 CMR 7 .29 SOZ rolling 12- 

4 Except that allowable sulfur content in residual oil would remain at 2.2% in Berkshire County due to a 1974 

legislative exemption. None of the power plants in the Alternative to BART are located in Berkshire County . 

7 
month emissions rate in lbs/MWh by the 2002 megawatt-hours electrical generation, and 

accounting for permit restrictions in effect at Mt. Tom Station and proposed for Brayton Point 

and Salem Harbor, as well as the retirement of Somerset Power. The Alternative to BART 

results in a projected emissions reduction of 54,986 tons from 2002 emissions, which is 4,234 

tons more than the projected emissions reductions from the BART benchmark. 

Table 17: Alternative to BART for SOZ 

acility nit 

2002 SO2 

Emissions 

(Tons) 

2002 Heat 

Input 

(MMbtu) or 

Generation 

(MWh) 

Alternative BART 

Emission Rate 

(Ibs/MMBtu or 

Ibs/MWh) 

Alternative BART 

Projected SOZ 

Emissions (Tons) 

Brayton Point 1 9,254 1,951,839 3.0 2,928 

Brayton Point 2 8,853 1,855,515 3.0 2,783 

Brayton Point 3 19,450 4,294,957 3.0 6,442 

Brayton Point 4 2,037 4,787,978 0.56 1,341 

Canal Station 1 13,066 27,295,648 0.56 7,643 

Canal Station 2 8,948 19,440,919 0.56 5,443 

Cleary Flood 8 39 92,567 0.56 25 

Cleary Flood 9 68 2,123,819 0.56 595 

Mount Tom 1 5,282 1,047,524 3.0 1,571 

Mystic 7 3,727 15,172,657 0.56 4,248 

Salem Harbor 1 3,425 631,606 3.0 947 

Salem Harbor 2 2,821 527,939 3.0 300 

Salem Harbor 3 4,999 974,990 Retired 0 

Salem Harbor 4 2,886 6,137,412 Retired 0 

Somerset 8 4,399 8,910,087 Retired 0 

Tota1 89,254 34,268 

SOZ Reduction 54,986 

40 CFR 51 .308(e)(3) provides a process for determining whether an alternative measure makes 

greater reasonable progress than would be achieved through the installation and operation of 

BART. If the geographic distribution of emissions reductions is similar between an alternative 

measure and BART, the comparison of the two measures may be made on the basis of emissions 

alone. The alternative measure may be deemed to make greater reasonable progress than BART 

if it results in greater emissions reductions than requiring sources subject to BART to install, 

operate and maintain BART. In this case, the Alternative to BART achieves greater emissions 

reductions than BART and the geographic distribution of emissions reductions is nearly identical 

since all of the units subject to BART are included in the Alternative to BART. 

Massachusetts' Alternative BART Program for NO, 
MassDEP's Alternative to BART for NO,, relies on : 

1 . 310 CMR 7.29, Emissions Standards for Power Plants, which establishes NO,, emissions 

rates for certain EGUs. 

2. An annual cap of 276 tons of NO,, for Salem Harbor Unit 1 and an annual cap of 50 tons 

of NO, for Unit 2, and a shutdown of Units 3 and 4 beginning June 1, 2014 . 

3. The retirement of Somerset Power in 2010. 

4. 310 CMR 7.19, Reasonably Available Control Technology (RACT) for Sources of Oxides 

of Nitrogen NOx, which establishes NO,, emissions standards for various sources, 

including EGUs. 

Each is described below: 

310 CMR 7 .29, Emissions Standards for Power Plants : MassDEP's existing regulation 310 

CMR 7.29 establishes a rolling 12-month average NOX emission rate of 1 .5 lbs/MWh and a 

monthly average emission rate of 3 lbs/MWh. 310 CMR 7.29 applies to Brayton Point, Canal 

Station, Mt. Tom Station, Mystic, Salem Harbor, and Somerset Power. 

Salem Harbor: On February 17, 2012, at Salem Harbor's request, MassDEP proposed an 

Amended Emission Control Plan (ECP) Approval (Appendix FF) that would require an annual 

cap of 276 tons of NOX for Salem Harbor Unit 1 and an annual cap of 50 tons of NOX for Unit 2, 

and a shutdown of Units 3 and 4 beginning June 1, 2014. 

Somerset Power Retirement : Somerset Power ceased operating in 2010, and on June 22, 2011, at 

Somerset Power's request, MassDEP issued a letter (Appendix HH) that revoked all air 

approvals and permits for the facility and deemed all pending permit applications withdrawn. 

310 CMR 7.19, Reasonably Available Control Technology (RACT,) ,for Sources of Oxides o 

NitroQen NO,: MassDEP's existing regulation 310 CMR 7.19 establishes NOX emissions rates 

for various stationary sources, including EGUs. Under 310 CMR 7.19, Cleary Flood Units 8 and 

9 are subject to a NO,, emission rate of 0.28 lbs/MMBtu. Mystic Unit 7 is subject to a NOX 

emission rate of 0.25 lbs/MMBtu. Mystic also is subject to 310 CMR 7.29 on a facility-wide 

basis; however, Mystic Unit 7 could exceed the 310 CMR 7 .29 NO,, rate of 1 .5 lbs/MWh while 

the facility as a whole complies with the rate because the other units at Mystic are natural gasfired with low NOX emissions, and therefore the 310 CMR 7 .19 unit-specific NO,, rate of 0.25 

lbs/MMBtu is the controlling factor for Unit 7. 

Analysis ofAlternative BART Program for NQ, 

Table 18 shows the BART benchmark projected NO,, emissions for the BART-eligible units, 

which were calculated by multiplying the lowest MANE-VU BART workgroup recommended 

BART emission rate of 0.1 lb/MMBtu (from Table 15 above) by the 2002 heat input in MMBtu. 

The BART benchmark results in projected emissions reductions of 12,820 tons of NO,, from 

2002 emissions. 
Table 18 : BART Benchmark for NO,, 

ART-Eligible 

Facility nit 

2002 NO, 

Emissions 

(Tons) 

2002 Heat 

Input 

(MMBtu) 

MANE-VU 

Recommended 

BART NO, 

Emission Rate 

(Ibs/MMBtu) 

BART Benchmark 

Projected NO,, 

Emissions (Tons) 

Brayton Point 1 2,513 17,000,579 0.10 850 

Brayton Point 2 2,270 15,896,795 0.10 795 

Brayton Point 3 7,335 36,339,809 0.10 1,817 

Brayton Point 4 552 4,787,978 0.10 239 

Canal Station 1 3,339 27,295,648 0.10 1,365 

Canal Station 2 2,260 19,440,919 0.10 972 

Cleary Flood 8 12 92,567 0.10 5 

Cleary Flood 9 161 2,123,819 0.10 106 

Mystic 7 805 15,172,657 0.10 759 

Salem Harbor 4 787 6,137,412 0.10 307 

Total 20,034 7,214 

NO. Reduction 12,820 

Table 19 shows the Alternative to BART projected NO,, emissions, which were calculated by 

multiplying MassDEP's 310 CMR 7.29 NO,, emission rate in lbs/megawatt hour (MWh) and 310 

CMR 7 .19 NO,, emission rate in lbs/MMbtu by the 2002 electricity generation in MWh and 2002 

heat input in MMBtu, respectively, and accounting for permit restrictions proposed for Salem 

Harbor and the retirement of Somerset Power. The Alternative to BART results in projected 

emission reductions of 13,117 tons from 2002 emissions . The estimated NO,, reductions from the 

Alternative to BART are 297 tons more than estimated reductions from BART alone . 
Table 19: Alternative to BART for NO,, 

acility nit 

2002 NO, 

Emission 

(Tons) 

2002 Heat 

Input 

(MMBtu) or 

Generation 

(MWh) 

Alternative 

BART Emission 

Rate 

(Ibs/MMBtu or 

Ibs/MWh) 

Alternative BART 

Projected NO. 

Emissions (Tons) 

Brayton Point 1 2,513 1,951,839 1.5 1,464 

Brayton Point 2 2,270 1,855,515 1.5 1,392 

Brayton Point 3 7,335 4,294,957 1.5 3,221 

Brayton Point 4 552 401,305 1.5 301 

Canal Station 1 3,339 2,945,578 1.5 2,209 

Canal Station 2 2,260 1,910,079 1.5 1,433 

Cleary Flood 8 12 92,567 0.28 13 

Cleary Flood 9 161 2,123,819 0.28 297 

Mount Tom 1 1,969 1,047,524 1.5 786 

Mystic 7 805 15,172,657 0.25 1,897 

Salem Harbor 1 920 631,606 Cap 276 

Salem Harbor 2 755 527,939 Cap 50 

Salem Harbor 3 1,331 974,990 Retired 0 

Salem Harbor 4 787 508,342 Retired 0 

Somerset 8 1,445 8,910,087 Retired 0 

26,455 13,338 

I NO, Reduction 13,117 

As with SO2, the Alternative to BART achieves greater NO,, emission reductions than BART and 

the geographic distribution of NO, emissions reductions is nearly identical since all of the units 

subject to BART are included in the Alternative to BART. 

8.11. BART for PM10 Emissions 

MassDEP's proposed Alternative to BART does not cover PM10 emissions. An overview of 

2002 and 2009 PM10 emissions and PM controls at the EGU BART sources is contained in Table 

20. Collectively, these facilities emitted 1,531 tons of PM10 in 2002 that diminished visibility in 

New England Class I areas by 0.032-0 .037 deciviews (ddv). Through installation of controls, 

these facilities have significantly reduced PM emissions, so that in 2009 these facilities emitted a 

total of 109 tons of PMIo. 

11 
CALPUFF modeling of 2002 PM emissions at these facilities shows an impact that was well 

below 0.1 ddv on the worst day at affected Class I areass, for each unit and cumulatively, which 

is the level MANE-VU has identified that the degree of visibility improvement is so small (<0.1 

ddv) that no reasonable weighting could justify additional controls under BART. The visibility 

impact would be even lower today based on the emissions reductions achieved since 2002 as 

shown in Table 20. MassDEP considered MANE-VU's evaluation of PM control options ; 6 

however, MassDEP has determined that no additional controls are warranted for primary PMIo 

because controls have been added to all but one of the facilities, and the additional cost of further 

control is not justified since there would be no significant visibility improvement. 

Table 20: Massachusetts PMIO BART Sources, Emissions and Controls 

PM Emission 

2002 PMlo 2009 PM~o Limits 

PM, ~ Emissions Emissions IbsIMMBtu as 

LD. Source Unit ddv t t PM Controls of 2009 

Fabric Filter 0.08 

1200061 Bra ton Point 1 Ba house 

0 .031, 386 39 Fabric Filter 0.08 

1200061 Bra on Point 2 0.026 Ba house 

Fabric Filter 0.08 

1200061 Bra ton Point 3 Ba house Planned 

0.000, 6 0 0.03 

1200061 Bra ton Point 4 0.000 ESP 

1200054 Canal Station 1 0.000, ESP 0.02 672 60 1200054 Canal Station 2 0.000 ESP 0.02 

Mystic 0.002, 131 4 ESP 0.05 

1190128 Station 7 0.003 

Salem 0.001, 316 0 ESP 0.04 

1190194 Harbor 4 0.001 

0.12 

1200067 Clea Flood 8 0 003 _ None . , 

0.002 20 6 None 0.12 

1200067 Clea Flood 9 

5 For further discussion of CALPUFF modeling, see Sections 8.6 and 8 .7 of the Regional Haze SIP. 

6 As described in Appendix R (Five-Factor Analysis of BART-Eligible Sources) and Appendix U (Assessment of 

Control Technology Options for BART-Eligible Sources) . 

' Values for MM5 and NWS meteorological modeling platforms; see Tables 12 and 13 . 

12 
10.5 . Additional Reasonable Strategies 

Targeted EGU Strategy 

SOZ emissions from power plants (electric generating units or EGUs) are the single largest sector 

contributing to the visibility impairment experienced in the Northeast's Class I areas. The SOZ 

emissions from power plants continue to dominate the inventory . Sulfate formed through 

atmospheric processes from SOZ emissions are responsible for over half the mass and 

approximately 70-80 percent of the light extinction on the worst visibility days (Contribution 

Assessment, Appendix A). 

In order to properly target controls on EGUs, modeling was conducted to identify those EGUs 

with the greatest impact on visibility in MANE-VU. A list was developed that includes the 100 

largest impacts at each MANE-VU Class I site during 2002. These emissions were from 167 

EGU stacks and are illustrated below (a complete list can be found in Appendix W; see 

Appendix A). Some of the stacks identified as important were outside the states identified as 

contributing at least 2 percent of the sulfate at MANE-VU Class I areas and were dropped from 

the list . Massachusetts sources identified in the list include Brayton Point, Canal Station, Mt. 

Tom Station, Salem Harbor, and Somerset Power. Given the magnitude of their potential 

impact, controlling emissions from these stacks is important to improving visibility at MANEVU Class I areas . 

MANE-VU's agreed to regional approach for the EGU sector is to pursue a 90 percent reduction 

in SOZ emissions (from 2002 emissions) from these 167 targeted stacks by 2018 as appropriate 

and necessary. MANE-VU concluded that pursuing this level of sulfur reduction is both 

reasonable and cost-effective . Even though current wet scrubber technology can achieve sulfur 

reductions greater than 95 percent, historically a 90 percent sulfur reduction level includes lower 

average reductions from dry scrubbing technology . The cost for SOZ emissions reductions will 

vary by unit, and the MANE-VU Reasonable Progress report (Appendix T) summarizes the 

various control methods and costs available, ranging from $170 to $5,700 per ton, depending on 

site-specific factors such as the size and type of unit, combustion technology, and type of fuel 

used. 
Figure 41 : 167 Targeted EGU Stacks Affecting MANE-VU Class I Areas 

FaciNes with the Most SigniBcant Impact at MANE-VU Cless 1 Arees 

Top 187 stacks 

HW" wood 

ngAar iMW 

.~ High ivqat 

VANE-VU CIBR t M!8 

To evaluate the impact of reducing emissions from the 167 EGU stacks, NESCAUM used 

CMAQ to model sulfate concentrations in 2018 after implementation of this control program. 

2018 SOZ emissions for these stacks were modeled at levels equal to 10 percent of their 2002 

S02 emissions; sulfate concentrations were then converted to PM2,5 concentrations. This 

preliminary modeling showed that requiring SOZ emissions from the 167 EGU stacks to be 

reduced by 90 percent from 2002 emission levels could reduce 24-hour PM2,5 concentrations. 

Figure 42 shows the reduction in fine particle pollution in the Eastern U.S . that would result from 

implementing the targeted EGU SOZ strategy . Improvements in PM2,5 concentrations would 

occur throughout the MANE-VU region as well as for portions of the VISTAS and Midwest 

RPO regions, especially the Ohio River Valley . 
Figure 42: Average Change in 24-hr PM2,5 due to 90 Percent Reduction in SOZ Emissions 

from 167 EGU Stacks Affecting MANE-VU 

Average Change in 24hr 

PM2.5 due to 167 EGU 

-0.3-0 

0 - 0.15 

0.15-0.25 

OW 0.25 - 0.35 

® 0.35 - 0.47 

~ 0.47 - 0.63 

~ 0.63 - 0.94 

® 0.94 -1 .83 

Although the reductions are potentially large, MANE-VU determined, after consultation with 

affected states, that it was unreasonable to expect that the full 90-percent reduction in SOZ 

emissions would be achieved by 2018. Therefore, additional modeling was conducted to assess 

the more realistic scenario in which emissions would be controlled by the individual facilities 

and/or states to levels already projected to take place by that date . At some facilities, the actual 

emission reductions are anticipated to be greater or less than the 90 percent benchmark. For 

details, see Appendix W "Documentation of 2018 Emissions from Electric Generating Units in 

the Eastern United States for MANE-VU's Regional Haze Modeling." 

Massachusetts has five sources (Table 19) with a total of 10 EGUs on the 167 Stacks list, 

including Brayton Point (Units 1-3), Canal Station (Units 1-2), Mt. Tom Station (Unit 1), Salem 

Harbor (Units 1, 3, 4), and Somerset Power (Unit 8) . Each of these facilities is subject to 

MassDEP's 310 CMR 7.29, which limits SOZ emissions facility-wide. 

Several of the Massachusetts EGUs already have installed SOZ controls or are planning 

additional SOZ controls to help them meet 310 CMR 7.29 limits . Brayton Point has installed 

spray dryer absorbers on Units 1 and 2 and plans to operate a dry scrubber on Unit 3 in 2013 ; Mt. 

Tom Station has installed a dry scrubber . Salem Harbor is currently using lower sulfur coal and 

oil to meet its 310 CMR 7.29 limits (Unit 4 would be subject to MassDEP's proposed low sulfur 

oil regulation) and plans to shut down all units by June 2014. Somerset Power shut down in 

15 
2010. Canal Station is using lower sulfur oil to comply with 310 CMR 7.29, and would be 

subject to MassDEP's proposed low sulfur oil regulation . 

Table 19 shows that SOZ emissions were reduced by 72% from 2002 to 2011 at the targeted 

units. Additional reductions will occur in the 2012-14 timeframe as the Salem Harbor units 

retire and the Brayton Point Unit 3 scrubber becomes operational. 

MassDEP believes that there will be further emissions reductions at the tarpeted units as a result 

of EPA's recently issued Mercury and Air Toxics Standards (MATS) rule . MATS gives coal 

units with scrubbers a compliance option to meet an SOz emissions rate of 0.2 lbs/MMBtu as an 

alternative to a hydrogen chloride emissions rate, which is more stringent than MassDEP's 310 

CMR 7.29 annual SOZ emissions rate (3.O lbs/MWh, which is roughly equivalent to 0.3 

lbs/MMBtu). Brayton Point and Mt. Tom Station may choose this option for their coal units, 

thereby further reducing their permitted SOz emissions . 

To be subject to MATS in a given year, an EGU must fire coal or oil for more than 10 percent of 

the average annual heat input during the 3 previous consecutive calendar years, or for more than 

15 percent of the annual heat input during any one of the 3 previous calendar years. This 

provision provides an incentive to Canal Unit 2, which can burn oil or natural gas, to limit the 

amount of oil it burns so that it is not subject to MATS, which would result in future SOZ 

emissions continuing to be lower than permitted emissions. MATS also establishes work 

practices (versus emissions rates) for oil-fired units with an annual capacity factor of less than 

8% of its maximum heat input. Canal Station Unit 1's utilization was 1% in 2011, and thus has 

an incentive to remain below 8%, which would result in future SOZ emissions continuing to be 

lower than its permitted emissions. Even without MATS, oil-fired combustion at Canal Units 1 

and 2 is expected to be low well into the future because of the high cost of oil relative to natural 

gas. This cost differential is why Canal's utilization currently is very low. 

In addition, EPA's 1-hour SOZ National Ambient Air Quality Standards (NAAQS) may require 

MassDEP to establish new SOZ emission rates that are more stringent than 310 CMR 7.29 for 

Brayton Point, Mt. Tom Station, and Canal Station, as well as to establish emission rates for 

other large emitters of S02. MassDEP will be working with facilities in 2012 to determine 

whether their potential emissions could result in exceedances of the 1-hour SOZ NAAQS, and to 

develop permit conditions where necessary to limit SOZ emissions in order to meet the NAAQS. 

Taking into account 310 CMR 7 .29 SOz emission rates, permit restrictions and retirements, and 

MassDEP's proposed low-sulfur oil regulation, MassDEP conservatively projects SOZ emissions 

in 2018 would represent at least a 67% reduction in S02 emissions compared to 2002 emissions 

(see Table 19) .9 However, taking into account EPA's MATS, including the SOZ compliance 

option and incentives for low utilization of oil-fired units, MassDEP believes there is a 

likelihood that S02 emissions in 2018 will be up to 87% lower than 2002 emissions (see Table 

19). Therefore, MassDEP believes that existing regulatory programs will lead to S02 emission 

$ www.izpo .pov'fdsys/pk,gIFR-2012-02-16/pdf/2012-806,pdf 

9 The 67% projection is less than the 72% reduction already achieved in 2011 because it assumes the same unit 

utilization as in the 2002 baseline year, whereas the reduction achieved in 2011 is due in part to low utilization of 

several units, including Canal Units 1 and 2 and Mt. Tom Station . 

16 
reductions that fulfill the MANE-VU Targeted EGU Strategy for Massachusetts. MassDEP will 

review emissions and individual facility MATS compliance strategies in a mid-course planning 

review in 2013, and if emissions reductions are not projected to be close to 90%, MassDEP will 

assess whether other equivalent SOZ reduction strategies may be necessary. 

Table 19: Massachusetts Targeted EGUs 

Facility Unit 

2002 SO2 

Emissions 

2011 SO2 

Emissions 

2018 Projected 

SOZ Emissions 

(Conservative) 

2018 Projected 

S02 Emissions 

(Likely) 

2018 Projected 

S02 Emissions 

(90% Target) 

Brayton Point 1 9,254 4,298 2,928 1,700 925 

Brayton Point 2 8,853 3,535 2,783 1,590 885 

Brayton Point 3 19,450 10,769 6,442 3,634 1,945 

Canal Station 1 13,066 99 7,643 1,069 1,307 

Canal Station 2 8,948 29 5,443 1,479 895 

Mt Tom 1 5,282 129 1,571 1,033 528 

Salem Harbor 1 3,425 893 0 0 343 

Salem Harbor 3 4,999 2,344 0 0 500 

Salem Harbor 4 2,886 69 0 0 289 

Somerset 8 4,399 0 0 0 440 

Total 80,562 22,165 26,811 10,505 8,057 

Reduction 59,396 53,75110 70,057 72,505 

Percent 

Reduction 72% 67% 87% 90% 

It should be noted that even the conservative projection of a 67% reduction in SOZ emissions 

from the targeted EGUs is more than enough to meet the level of SOZ emissions projected from 

Massachusetts EGUs that was used in the MANE-VU 2018 regional modeling, as documented in 

NESCAUM's 2018 Visibility Projections (Appendix G) . Emission results from the 2018 InterRegional Planning Organization CAIR Case Integrated Planning Model v. 2.1 .9 estimated 

'° Note that this SOZ emissions reduction is less than the SOZ emissions reduction under the Alternative to BART 

(Table 17 in Section 8.10) because fewer units are included in the Targeted EGU Strategy . 

17 
17,486 tons of S02 emissions for Massachusetts (See Appendix W, Table 1) . However, MANEVU planners recognized that CAIR allows emissions trading, and that reductions at one unit 

could offset increases at another unit within the CAIR region . Because most states do not restrict 

trading, MANE-VU decided that projected emissions should be increased to represent the 

implementation of the strategy for the 167 stacks within the limits of the CAIR program, and 

therefore increased the projected emissions from states subject to the CAIR cap and trade 

program . For Massachusetts, this modification resulted in projected S02 emissions of 45,941 

tons for Massachusetts (see Appendix W, Table 9), effectively doubling Massachusetts' SOZ 

emissions inventory for EGUs. As shown in Table 19, MassDEP's conservative 67% reduction 

projection for targeted EGUs results in 2018 emissions of 26,811 tons of SOZ~ 1, well below the 

45,941 tons of SOZ that is needed to meet the modeled 2018 reasonable progress goals for the 

Class I areas Massachusetts affects. 

Other State EGU Programs Assumed in 2018 EGU Modeling 

Several other states have implemented state-specific EGU emission reduction programs. These 

commitments, identified below, are included in the long-term strategy as reasonable measures to 

meet MANE-VU's reasonable progress goals and were used in the Best and Final 2018 CMAQ 

modeling (Appendix G). 

Maryland Healthy Air Act: Maryland adopted the following requirements governing EGU 

emissions: 

1 . For NO,,: 

a. Phase 1(2009): Sets unit-specific annual caps (totaling 20,216 tons) and ozone 

season caps (totaling 8,900 tons). 

b. Phase 11(2012): Sets unit-specific annual caps (totaling 16,667 tons) and ozone 

season caps (totaling 7,337 tons). 

2. For S02: 

a. Phase 1 (2010) : Sets unit-specific annual caps (totaling 48,818 tons) . 

b. Phase lI (2013) : Sets unit-specific annual caps (totaling 37,235 tons) . 

3. For mercury: 

a. Phase I (2410) : 12-month rolling average of a minimum of 80% removal 

efficiency . 

b. Phase II (2013) : 12-month rolling average of a minimum of 90% removal 

efficiency . 

The specific EGUs covered are: Brandon Shores (Units 1 and 2), C.P .Crane (Units 1 and 2), 

Chalk Point (Units l, and 2), Dickerson (Units 1, 2, and 3), H.A. Wagner (Units 2 and 3) 

Morgantown (Units 1 and 2) and R. Paul Smith (Units 3 and 4). No out-of-state trading, no 

inter-company trading, and no banking from year to year is permitted. 

New Hampshire EGU Regulations: New Hampshire adopted the following regulations governing 

EGU emissions _Chapter Env-A 2900 requires the installation of scrubbers on Merrimack Station 

" Two additional EGUs beyond the "167 Stack" Targeted EGUs were projected to have 2018 SOZ emissions, 

totaling 3,588 tons, which would bring the total 2018 emissions to 30,399 tons, which is still well below the 45,941 

tons used in the 2018 modeling. 

18 
(Units 1 and 2) by July 1, 2013 to control SOZ and mercury emissions with state-level SOZ credits 

for over- or early- compliance. 

New Jersey Hg MACT Rule: All coal-fired EGUs must have a mercury removal efficiency of 

90%. 

Consent Agreements in the VISTAS region : The impacts of the additional following consent 

agreements in the VISTAS states were reflected in the emissions inventory used for those states : 

EKPC: A July 2, 2007 consent agreement between EPA and East Kentucky Power 

Cooperative requires the utility to reduce its emissions of SOZ by 54,000 tons per year 

and its emissions of NO,, by 8,000 tons per year by installing and operating selective 

catalytic reduction (SCR) technology, low-NOx burners, and PM and mercury 

Continuous Emissions Monitors at the utility's Spurlock, Dale and Cooper Plants . 

According to EPA, total emissions from the plants will decrease between 50 and 75 

percent from 2005 levels . As with all federal consent decrees, EKPC is precluded 

from using reductions required under other programs, such as CAIR, to meet the 

reduction requirements of the consent decree . EKPC is expected to spend $654 

million to install pollution controls . 

AEP: American Electric Power agreed to spend $4.6 billion dollars to eliminate 

72,000 tons of NO,, emissions each year by 2016 and 174,000 tons of SOz emissions 

each year by 2018 from sixteen plants located in Indiana, Kentucky, Ohio, Virginia, 

and West Virginia.