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 RICHARDK . SULLIVANJR. 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 MassDEPWebsite: 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, MassDEPhad 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, EPAdid 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 ofBest Available Retrofit Technology (BART) or an alternative to BART that achieves greater emission reductions. As described in Section 8of 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 differentAlternative to BART for EGUs that includes the following measures : 1 . Existing regulation 310 CMR 7.29, Emissions Standardsfor 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, SalemHarbor, and Mt . Tom Station that limit/retire SOZ and/or NO, emissions. 4 . Existing regulation 310CMR 7.19, ReasonablyAvailable Control Technology (RACT) 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 notjustified 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-VUto develop strategies for reducing regional haze. MANE-VUidentified 167 EGU stacks at power plants in the MANE-VU region and adjacent Mid-West and Southeast regions ofthe 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 fromthe power plant stacks by 90 percent from2002 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 2018would represent at least a 67% reduction in SOZ emissions compared to 2002 emissions. However, taking into account the addition ofEPA's recently finalized Mercury and Air Toxics Standards (MATS) rule', including the SOz compliance option and incentives for lowutilization of oil-fired units, MassDEPbelieves there is a likelihood that SOZ emissions in 2018will be up to 87% lower than 2002 emissions. Therefore, MassDEPbelieves that existing regulatory programs will lead to SOZ emission reductions that fulfill the MANE-VUTargeted EGU Strategy for Massachusetts. MassDEPwill reviewemissions and individual facility MATS compliance strategies in a mid-course planning reviewin 2013, and if emissions reductions are not projected to be close to 90%, MassDEPwill 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, MassDEPmust make any necessary changes and submit a final Regional Haze SIP Revision to EPAby June 20122to meet the requirements for addressing regional haze contained in Section 169A ofthe Clean AirAct and in EPA's Regional Haze Rule at 40 CFR51 .308(b) .

' www .,-Ypo.gov/fdsys/pkg/I'R-2012-02-16/pdf/2012-806.pdf Z Submittal of the final Regional Haze SIPto EPA by this date is necessary so EPAcan 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 EGUStrategy Appendices (Note to reviewers: lettering is continued fromthe Appendices in the December 30, 2011 Regional Haze SIP . Appendices priorto DD are available at www .mass. =o~ v/dep/air/priorities/llazeapps.htm ) . DD : 310 CMR 7.29, Emissions Standardsfor Power Plants EE: Mt . Tom

Station - Amended Emission Control Plan Final Approval ; MassDEP, May 2009. FF: SalemHarbor - 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 310CMR 7.00: Definitions and 310 CMR7.05: Fuels All Districts; MassDEP, February 2012

### 8.10. Alternative to BART

EPA's Regional Haze Rule at 40 CFR51 .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) . Astate can establish a BART benchmark (i .e., emissions reductions that would result fromthe application of source-specific BART), and then can compare the emissions reductions achieved fromthe alternative measure with the emissions reductions that would be achieved fromthe BART benchmark. If the reductions fromthe alternative measure are greater than the BART benchmark, the state can assume that the alternative measure results in greater reasonable progress than BART. MassDEPproposes 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 Standardsfor Power Plants. This includes the BARTeligible EGUs (Brayton Point Units 1-4, Canal Station Units 1-2, Mystic Unit 7, SalemHarbor Unit 4, and Cleary Flood Units 8-9), plus additional units subject to 310 CMR7.29, which include SalemHarbor 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 CMR7.29, Emissions Standardsfor Power Plants, which establishes NOXand SOZemissions 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, SalemHarbor, and Mt . Tom Station that limit/retire SOZ and/or NOx emissions. 4. Existing regulation 310 CMR7.19, ReasonablyAvailable Control Technology (RACT) for Sources of Oxides ofNitrogen 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 SOZand NOXthan 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 fromthese alternative measures exceed reductions fromthe 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 emissionslimits 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 (40CFR51, Appendix Y) establishes presumptive SOZ emission limits for 750 megawatt (MW) and larger power plants. Four facilities (Brayton, Canal, Mystic, and SalemHarbor) 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 EGUat a 750 MW or larger power plant, regardless of size, EPArecommends that, for SOZcontrol purposes, states evaluate limiting the sulfur content ofthe 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, EPAsuggests that use of such controls year round is BART. For each uncontrolled coal-fired EGUgreater 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 NOXannual 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 EPArecommended limits for SOZ for oil and for NO, Therefore, Massachusetts used the MANE-VUrecommended emission limits to establish the BART benchmark. Table 15: MANE-VU BARTworkgroup recommended BART emission

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

### SOZ NO, 95% control or 0

.15 lb/MMBtu o In NO,, SIPcall 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 CMR7.29, Emissions Standardsfor Power Plants, which establishes SOZ emissions standards for certain EGUs. 2 . Permit restrictions for Mt. Tom Station, Brayton Point, and SalemHarbor that disallow the use of 310CMR7.29SOZ Early Reduction Credits and federal Acid Rain Allowances for compliance with 310 CMR7.29. 3 . An annual cap of 300tons of S02 for SalemHarbor 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 CMR7.29, Emissions Standards for Power Plants: MassDEP's existing regulation 310 CMR7.29 (Appendix DD) establishes a facility-wide rolling 12-month S02emissions 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 CMR7.29 S02 Early Reduction Credits (on a 1 ton credit to 1 ton excess emission basis) and the use of federal Acid Rain S02Allowances (on a 3 ton allowance to 1 ton excess emission basis) for compliance with the 3.0 pounds per megawatthour emissions rate. 310CMR7.29 applies to Brayton Point, Canal Station, Mt . Tom Station, Mystic, SalemHarbor, 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 310CMR7.29 SOZ Early Reduction Credits and federal Acid Rain Allowances forcompliance with 310CMR7.29 . 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 310CMR7.29 after June 1, 2014. SalemHarbor : On February 17, 2012, at SalemHarbor's request, MassDEPproposed an Amended Emission Control Plan (ECP) Approval (Appendix FF) that would prohibit the use of 310 CMR7.29S02 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 SalemHarbor Unit 23 and the shutdown of Units 3 and 4effective June 1, 2014. Somerset Power Retirement: Somerset Power ceased operating in 2010, and on June 22, 2011, at Somerset Power's request, MassDEPissued 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 fromservice as of December 31, 2011, which means that these units can no longer generate electricity for the power grid. These units are not restricted fromoperating for other purposes; therefore, MassDEPmust 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, MassDEPproposed amendments to 310CMR7.00: Definitions and 310 CMR 7.05, FuelsAll Districts (Appendix 11) to lower the allowable sulfur content ofdistillate oil and residual oil combusted by stationary sources. For residual oil, 310 CMR7.05 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 ofAlternative BARTProgram forS02 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 from2002 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 SalemHarbor 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- 4Except that allowable sulfur content in residual oil would remain at 2.2%in Berkshire County dueto a 1974 legislative exemption. None ofthe power plants in the Alternative to BART are located in Berkshire County. 7month 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 SalemHarbor, as well as the retirement of Somerset Power. The Alternative to BART results in a projected emissions reduction of 54,986 tons from2002 emissions, which is 4,234 tons more than the projected emissions reductions fromthe 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 SalemHarbor 1 3,425 631,606 3 .0 947 SalemHarbor 2 2,821 527,939 3.0 300 SalemHarbor 3 4,999 974,990 Retired 0 SalemHarbor 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 BARTProgram for NO,MassDEP's Alternative to BART for NO,, relies on:

1 . 310CMR7.29, Emissions Standardsfor Power Plants, which establishes NO,, emissions rates for certain EGUs. 2 . An annual cap of 276tons ofNO,, for SalemHarbor Unit 1 and an annual cap of 50 tons ofNO, for Unit 2, and a shutdown of Units 3 and 4 beginning June 1, 2014. 3 . The retirement of Somerset Power in 2010 . 4 . 310CMR7.19, Reasonably Available Control Technology (RACT)for Sources ofOxides ofNitrogen NOx, which establishes NO,, emissions standards for various sources, including EGUs. Each is described below : 310CMR7.29, Emissions Standards for Power Plants: MassDEP's existing regulation 310 CMR7.29establishes a rolling 12-month average NOXemission rate of 1 .5 lbs/MWh and a monthly average emission rate of 3 lbs/MWh. 310CMR 7.29 applies to Brayton Point, Canal Station, Mt. Tom

Station, Mystic, SalemHarbor, and Somerset Power. SalemHarbor : On February 17, 2012, at SalemHarbor's request, MassDEPproposed an Amended Emission Control Plan (ECP) Approval (Appendix FF) that would require an annual cap of 276tons of NOXfor SalemHarbor Unit 1 and an annual cap of 50tons of NOXfor Unit 2, and a shutdown ofUnits 3 and 4beginning June 1, 2014. Somerset Power Retirement : Somerset Power ceased operating in 2010, and on June 22, 2011, at Somerset Power's request, MassDEPissued a letter (Appendix HH) that revoked all air approvals and permits for the facility and deemed all pending permit applications withdrawn. 310CMR7.19, ReasonablyAvailable Control Technology (RACT,) ,for Sources ofOxides o NitroQen NO, : MassDEP's existing regulation 310CMR7.19 establishes NOXemissions rates for various stationary sources, including EGUs. Under 310 CMR7.19, Cleary Flood Units 8and 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 CMR7.29 on a facility-wide basis; however, Mystic Unit 7 could exceed the 310 CMR7.29 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

NOXemissions, and therefore the 310 CMR7.19 unit-specific NO,, rate of 0 .25 lbs/MMBtu is the controlling factor for Unit 7. Analysis ofAlternative BARTProgram 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 ofNO,, 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 SalemHarbor 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 310CMR7.29 NO,, emission rate in lbs/megawatt hour (MWh) and 310 CMR7.19 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 from2002 emissions . The estimated NO,, reductions fromthe Alternative to BART are 297 tons more than estimated reductions fromBART 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 SalemHarbor 1 920 631,606 Cap 276 SalemHarbor 2 755 527,939 Cap 50 SalemHarbor 3 1,331 974,990 Retired 0 SalemHarbor 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 ofthe units subject to BART are included in the Alternative to BART. 

### 8.11 . BART for PM10Emissions 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.

11CALPUFF 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-VUhas identified that the degree ofvisibility improvement is so small (<0 .1 ddv) that no reasonable weighting couldjustify 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

. MassDEPconsidered MANE-VU's evaluation of PM control options; 6 however, MassDEPhas 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 notjustified since there would be no significantvisibility 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 ofthe Regional Haze SIP . 6As described in Appendix R(Five-Factor Analysis ofBART-Eligible Sources) and Appendix U (Assessment of Control Technology Optionsfor BART-Eligible Sources) . ' Values for MM5and NWS meteorological modeling platforms; see Tables 12 and 13. 1210.5. Additional Reasonable Strategies

Targeted EGUStrategy SOZ emissions frompower 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 frompower plants continue to dominate the inventory. Sulfate formed through atmospheric processes fromSOZ emissions are responsible for over half the mass and approximately 70-80percent ofthe 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 from167 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 2percent ofthe 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, SalemHarbor, and Somerset Power. Given the magnitude oftheir potential impact, controlling emissions fromthese 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 (from2002 emissions) fromthese 167 targeted stacks by 2018 as appropriate and necessary. MANE-VUconcluded 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 fromdry scrubbing technology. The cost for SOZemissions reductions will vary by unit, and the MANE-VUReasonable Progress report (Appendix T) summarizes the various control methods and costs available, ranging from$170to $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 fromthe 167 EGU stacks, NESCAUM used CMAQto 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 oftheir 2002 S02 emissions; sulfate concentrations were then converted to PM2,5 concentrations. This preliminary modeling showed that requiring SOZ emissions fromthe 167 EGUstacks to be reduced by 90 percent from2002 emission levels could reduce 24-hour PM2,5concentrations. 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 PM2,5concentrations would occur throughout the MANE-VUregion as well as for portions of the VISTAS and Midwest RPOregions, especially the Ohio River Valley.Figure 42: Average Change in 24-hr PM2,5due to 90 Percent Reduction in SOZ Emissions from167 EGU Stacks Affecting MANE-VU

Average Change in 24hr PM2 .5 dueto 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 of2018 EmissionsfromElectric Generating Units in the Eastern United Statesfor 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 CMR7.29, which limits SOZ emissions facility-wide. Several of the Massachusetts EGUs already have installed SOZ controls or are planning additional SOZ controls to help themmeet 310 CMR7.29 limits . Brayton Point has installed spray dryer absorbers on Units 1 and 2and plans to operate a dry scrubber on Unit 3 in 2013; Mt. Tom Station has installed a dry scrubber . SalemHarbor is currently using lower sulfur coal and oil to meet its 310CMR7.29 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 152010

. Canal Station is using lower sulfur oil to comply with 310 CMR7.29, and would be subject to MassDEP's proposed low sulfur oil regulation. Table 19 shows that SOZ emissions were reduced by 72% from2002 to 2011 at the targeted units. Additional reductions will occur in the 2012-14timeframe as the SalemHarbor units retire and the Brayton Point Unit 3 scrubber becomes operational . MassDEPbelieves 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 CMR7.29annual 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 EGUmust 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 ofthe 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 MassDEPto establish new SOZ emission rates that are more stringent than 310 CMR7.29 for Brayton Point, Mt. Tom Station, and Canal Station, as well as to establish emission rates for other large emitters of S02 . MassDEPwill 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 CMR7.29 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 S02emissions 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, MassDEPbelieves 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 S02emission $ www .izpo .pov'fdsys/pk,gIFR-2012-02-16/pdf/2012-806,pdf 9The 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 . 16reductions that fulfill the MANE-VUTargeted EGU Strategy for Massachusetts. MassDEP will

review emissions and individual facility MATS compliance strategies in a mid-course planning reviewin 2013, and if emissions reductions are not projected to be close to 90%, MassDEPwill 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

S02Emissions (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 SalemHarbor 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 fromthe targeted EGUs is more than enough to meet the level of SOZ emissions projected from Massachusetts EGUs that was used in the MANE-VU2018 regional modeling, as documented in NESCAUM's 2018 Visibility Projections (Appendix G) . Emission results fromthe 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. 1717,486 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 ofthe 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 EGUPrograms Assumed in 2018 EGUModeling Several other states have implemented state-specific EGU emission reduction programs. These commitments, identified below, are included in the long-termstrategy 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 8,900tons) . 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 ofa 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 SOZcredits

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 ofthe additional following consent agreements in the VISTAS states were reflected in the emissions inventory used for those states:

EKPC : AJuly 2, 2007 consentagreement between EPAand 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 8,000tons 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 fromthe plants will decrease between 50and 75 percent from2005 levels . As with all federal consent decrees, EKPC is precluded fromusing 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 174,000tons of SOzemissions each year by 2018 fromsixteen plants located in Indiana, Kentucky, Ohio, Virginia, and West Virginia.