Draft For FLM Review 

STATE IMPLEMENTATION PLAN 

FOR 

 REGIONAL HAZE 

State of Maine 

Department of Environmental Protection 

5/27/10 
5/27/2010 

Draft For FLM Review 

TABLE OF CONTENTS

INTRODUCTION ........................................................................................................................................ 8

1.1 WHAT IS REGIONAL HAZE? ................................................................................................................. 8

1.2 CLEAN AIR ACT REGIONAL HAZE REQUIREMENTS.............................................................................. 9

1.3 THE FEDERAL REGIONAL HAZE RULE ............................................................................................... 10

1.4 REGIONAL HAZE PLANNING AFTER THE VACATUR OF CAIR ............................................................ 12

1.5 MAINE CLASS I AREAS ....................................................................................................................... 14

1.5.1 Acadia National Park................................................................................................................. 14

1.5.2 Moosehorn Wildernesss Area, Moosehorn National Wildlife Refuge....................................... 15

1.5.3 Roosevelt Campobello International Park................................................................................ 15

1.6 VISIBILITY TRENDS AT MAINE CLASS I AREAS................................................................................... 17

1.7 SOURCES OF REGIONAL HAZE AT MAINE CLASS I AREAS................................................................. 17

1.8 CLASS I AREAS AFFECTED.................................................................................................................. 20

2. GENERAL PLANNING PROVISIONS AND COMMITMENT TO FUTURE SUBMITTAL .... 21

3. REGIONAL PLANNING ..................................................................................................................... 23

3.1 MANE-VU........................................................................................................................................ 23

3.2 REGIONAL CONSULTATION................................................................................................................. 24

3.3 MAINE-SPECIFIC CONSULTATION ...................................................................................................... 28

3.4 THE MANE-VU “ASK” ..................................................................................................................... 28

3.5 MEETING THE “ASK” – MANE-VU STATES ...................................................................................... 29

3.6 MEETING THE “ASK” – MAINE........................................................................................................... 30

3.7 MEETING THE “ASK” – STATES OUTSIDE OF MANE-VU .................................................................. 31

3.8 MEETING THE “ASK” - EPA............................................................................................................... 32

3.9 TECHNICAL RAMIFICATIONS OF DIFFERING APPROACHES ................................................................. 32

3.10 CONSULTATION ISSUES.................................................................................................................... 33

4. STATE/TRIBE AND FEDERAL LAND MANAGER COORDINATION ..................................... 36

5. ASSESSMENT OF BASELINE AND NATURAL CONDITIONS (WITH CLASS I AREAS)..... 38

5.1 REQUIREMENTS, DATA, AND METHODOLOGY .................................................................................... 38

5.2 MAINE BASELINE VISIBILITY.............................................................................................................. 40

5.3 NATURAL VISIBILITY.......................................................................................................................... 40

6. MONITORING STRATEGY............................................................................................................... 42

6.1 FEDERAL REGIONAL HAZE MONITORING REQUIREMENTS ................................................................. 42

6.2 MONITORING INFORMATION FOR MANE-VU CLASS I AREAS ........................................................... 44

6.2.1. Acadia National Park, Maine ................................................................................................... 44

6.2.2. Moosehorn Wilderness Area, Maine......................................................................................... 45

6.2.3. Roosevelt Campobello International Park, New Brunswick, Canada....................................... 46

7. SOURCES OF VISIBILITY IMPAIRING POLLUTANTS AND CONTRIBUTION .............. 47

ASSESSMENT............................................................................................................................................ 47

7.1 VISIBILITY EFFECTS OF PARTICULATE MATTER ................................................................................. 47

7.2 POLLUTANTS CONTRIBUTING TO VISIBILITY IMPAIRMENT AT CLASS I AREAS ................................. 48

7.3 GEOGRAPHIC CONSIDERATIONS AND HAZE CONTRIBUTION ATTRIBUTION ........................................ 50

7.3.1 Review of Technical Approaches ............................................................................................... 51

7.3.2 Summary of Analytical Techniques for Contribution Assessment.............................................. 55

8. EMISSIONS INVENTORY.................................................................................................................. 59

8.1 SOURCES OF VISIBILITY IMPAIRING POLLUTANTS IN MANE-VU....................................................... 59

8.1.1 Sulfur Dioxide (SO2) .................................................................................................................. 59

8.1.2 Volatile Organic Compounds (VOC) ......................................................................................... 61

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8.1.3 Oxides of Nitrogen (NOX) .......................................................................................................... 63

8.1.4 Primary Particle Matter (PM10 and PM2.5)................................................................................ 65

8.1.5 Ammonia Emissions (NH3)......................................................................................................... 70

8.2 BASELINE AND FUTURE YEAR EMISSION INVENTORIES FOR MODELING ............................................ 72

8.2.1 Baseline Inventory ..................................................................................................................... 72

8.2.2 Future Year Emission Control Inventories ................................................................................ 73

8.3 EMISSION PROCESSOR SELECTION AND CONFIGURATION................................................................... 74

8.4 INVENTORIES FOR SPECIFIC SOURCE TYPES ....................................................................................... 75

8.4.1 Stationary Point Sources............................................................................................................ 75

8.4.2 Stationary Area Sources............................................................................................................ 77

8.4.3 On-Road Mobile Sources .......................................................................................................... 78

8.4.4 Biogenic Emission Sources ....................................................................................................... 78

8.5 SUMMARY OF MAINE’S 2002 AND 2018 EMISSIONS INVENTORY........................................................ 79

9. MODELING ......................................................................................................................................... 82

9.1 METEOROLOGY.................................................................................................................................. 82

9.2 EMISSIONS DATA PREPARATION ........................................................................................................ 84

9.3 PRIMARY REGIONAL HAZE MODELING PLATFORMS.......................................................................... 84

9.3.1 CMAQ ........................................................................................................................................ 86

9.3.2 REMSAD.................................................................................................................................... 87

9.4 PRIMARY MODEL EVALUATION.......................................................................................................... 88

9.4.1 CMAQ ........................................................................................................................................ 88

9.4.2 REMSAD.................................................................................................................................... 90

9.5 ADDITIONAL MODELING PLATFORMS................................................................................................. 92

9.5.1 CALGRID.................................................................................................................................. 92

9.5.2 CALPUFF................................................................................................................................. 92

10. BEST AVAILABLE RETROFIT TECHNOLOGY........................................................................ 93

10.1 THE FEDERAL BART RULE .............................................................................................................. 93

10.1.1 Federal BART Requirements for Electric Generating Units (EGUs) ..................................... 94

10.2 MAINE STATE BART REQUIREMENTS ............................................................................................. 95

10.3 BART-ELIGIBLE SOURCES IN MAINE ............................................................................................... 95

10.4 SOURCES SUBJECT TO BART........................................................................................................... 97

10.5 MANE-VU BART MODELING......................................................................................................... 97

10.6 THE MAINE BART ANALYSIS PROTOCOL...................................................................................... 100

10.7 SUMMARY OF MAINE BART DETERMINATIONS ............................................................................ 100

10.7.1 Cap-Outs and Shutdowns....................................................................................................... 101

10.7.2 Maine BART Determinations ................................................................................................. 102

10.8 SCHEDULE FOR BART IMPLEMENTATION...................................................................................... 128

11. REASONABLE PROGRESS GOALS ........................................................................................... 129

11.1 CALCULATION OF UNIFORM RATE OF PROGRESS........................................................................... 129

11.2 REASONABLE PROGRESS GOALS FOR CLASS I AREAS IN MAINE.................................................... 130

11.3 IDENTIFICATION OF ADDITIONAL REASONABLE CONTROLS .......................................................... 132

10.4 THE FOUNDATIONS FOR DETERMINING REASONABLE CONTROLS ................................................. 133

11.4.1 Best Available Retrofit Technology (BART) Controls............................................................ 135

11.4.2 The MANE-VU Low Sulfur Fuel Strategy.............................................................................. 137

11.4.3 Targeted Strategy for Reducing SO2Emissions from EGU Stacks ........................................ 141

11.4.4 Non-EGU SO2 Emissions Reduction Strategy Outside the MANE-VU Region..................... 147

11.5 VISIBILITY IMPACTS OF ADDITIONAL REASONABLE CONTROLS .................................................... 155

12. LONG TERM STRATEGY ............................................................................................................. 157

12.1 OVERVIEW OF THE LONG TERM STRATEGY DEVELOPMENT PROCESS ............................................ 157

12.2 THE REGIONAL PROCESS FOR IDENTIFYING POTENTIAL STRATEGIES ............................................ 158

12. 3 THE TECHNICAL BASIS FOR STRATEGY DEVELOPMENT................................................................ 159

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12.4 EMISSION REDUCTIONS DUE TO ONGOING AIR POLLUTION REDUCTION PROGRAMS ..................... 161

12.4.1 EGU Emissions Controls Expected by 2018 .......................................................................... 161

12.4.2 Non-EGU Point Point Source Controls Expected by 2018................................................... 165

12.4.3 Area Source Controls Expected by 2018............................................................................... 166

12.4.4 Mobile Sources Controls Expected by 2018 ......................................................................... 167

12.4.5 Controls on Non-Road Sources Expected by 2018 ............................................................... 168

12.5 ADDITIONAL REASONABLE STRATEGIES........................................................................................ 169

12.5.1 BART...................................................................................................................................... 170

12.5.2 Low-Sulfur Oil Strategy ........................................................................................................ 171

12.5.3 Targeted EGU Strategy.......................................................................................................... 171

12.7 ADDITIONAL MEASURES CONSIDERED .......................................................................................... 175

12.7.1 Measures to Mitigate the Impacts of Construction Activities ............................................... 175

12.7.2 Agricultural and Forestry Smoke Management .................................................................... 176

12.7.3 Control of Residential and Commercial Wood Combustion Emissions ................................ 177

12.8 ESTIMATED EFFECTS OF THE LONG-TERM STRATEGY ON VISIBILITY............................................ 178

12.9 IMPLEMENTATION OF THE REGIONAL HAZE STRATEGIES IN MAINE .............................................. 180

12.9.1 The Maine Low Sulfur Oil Program ..................................................................................... 182

12.9.2 BART in Maine...................................................................................................................... 184

12.9.3 The Targeted EGU Strategy in Maine.................................................................................... 184

12.9.4 Wood Smoke Emission Reductions Strategies in Maine........................................................ 185

12.10 MAINE’S SHARE OF EMISSION REDUCTIONS ................................................................................ 185

12.10 EMISSION LIMITATIONS AND COMPLIANCE SCHEDULES ............................................................. 187

12.11 ENFORCEABILITY OF EMISSION LIMITATIONS AND CONTROL MEASURES.................................... 188

12.12 PREVENTION OF SIGNIFICANT DETERIORATION ........................................................................... 190

12.13 REASONABLY ATTRIBUTABLE VISIBILITY IMPAIRMENT .............................................................. 191

13. COMPREHENSIVE PERIODIC IMPLEMENTATION PLAN REVISIONS........................... 192

13. DETERMINATION OF THE ADEQUACY OF THE EXISTING PLAN .................................. 193

REFERENCES ......................................................................................................................................... 194

 

LIST OF TABLES

TABLE 1-1 STATES THAT CONTRIBUTE TO VISIBILITY IMPAIRMENT AT MAINE CLASS 1 AREAS.................. 20

TABLE 3-1 MANE-VU MEMBERS................................................................................................................ 24

TABLE 5-1 IMPROVE INFORMATION FOR MAINE CLASS I AREAS .............................................................. 38

TABLE 5-2 BASELINE VISIBILITY FOR THE 20 PERCENT WORST DAYS AND 20 PERCENT BEST DAYS FOR FIVE 

YEARS (FROM 2000-2004) IN MAINE CLASS I AREAS.......................................................................... 40

TABLE 5-3 SUMMARY OF BASELINE VISIBILITY AND NATURAL CONDITIONS FOR THE 20 PERCENT WORST 

AND 20 PERCENT BEST VISIBILITY DAYS FOR MAINE CLASS I AREAS ................................................ 41

TABLE 7-2 SUMMARY OF TECHNICAL APPROACHES FOR ATTRIBUTING STATE CONTRIBUTIONS TO 

OBSERVED SULFATE IN MANE-VU CLASS I AREAS ........................................................................... 51

TABLE 7-3 ANNUAL AVERAGE SULFATE IMPACT FROM Q/D (%) ................................................................. 52

TABLE 7-4 ANNUAL AVERAGE SULFATE IMPACT FROM THE EMISSIONS X UPWIND PROBABILITY TECHNIQUE

............................................................................................................................................................ 53

TABLE 7-5 AVERAGE ANNUAL SULFATE IMPACT AT NORTHEAST CLASS I AREAS AS MODELED USING 

REMSAD............................................................................................................................................ 54

TABLE 7-6 CONTRIBUTION TO SULFATE LEVELS AT ACADIA NATIONAL PARK USING THE CALPUFF MODEL

............................................................................................................................................................ 56

TABLE 7-7 INDIVIDUAL STATE RANKINGS PRODUCED BY DIFFERENT ASSESSMENT TECHNIQUES FOR 

ACADIA NATIONAL PARK.................................................................................................................... 58

TABLE 8-1 2002 EMISSIONS INVENTORY FOR MAINE ................................................................................... 79

TABLE 8-2 2018 OTB/OTW EMISSIONS INVENTORY FOR MAINE ................................................................ 80

TABLE 8-3 2018 BOTW EMISSIONS INVENTORY FOR MAINE....................................................................... 80

TABLE 8-4 2018 FINAL MODELING EMISSIONS INVENTORY FOR MAINE ...................................................... 80

TABLE 10-1 BART-ELIGIBLE SOURCES IN MAINE ....................................................................................... 98

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TABLE 10-2 MODELED IMPACTS (DECIVIEWS) OF MAINE BART-ELIGIBLE SOURCES AT SELECTED MANEVU CLASS I AREAS ........................................................................................................................... 101

TABLE 11-1 UNIFORM RATE OF PROGRESS CALCULATION......................................................................... 130

TABLE 11-2 REASONABLE PROGRESS GOALS—20% WORST DAYS........................................................... 131

TABLE 11-3 REASONABLE PROGRESS GOALS—20% BEST DAYS .............................................................. 132

TABLE 11-4 SUMMARY OF RESULTS FROM THE FOUR FACTOR ANALYSIS ................................................. 134

TABLE 11-5 ESTIMATED EMISSIONS FROM BART-ELIGIBLE FACILITIES MANE-VU STATES ................... 136

TABLE 11-6 ESTIMATED COST RANGES FOR SO2 CONTROL OPTIONS FOR COAL-FIRED EGU BOILERS..... 145

TABLE 11-7 AVAILABLE SO2 CONTROL OPTIONS FOR ICI BOILERS........................................................... 150

TABLE 11-8 ESTIMATED DRY SORBENT INJECTION (DSI) COSTS FOR ICI BOILERS ................................... 152

TABLE 11-9 ESTIMATED FGD COSTS FOR ICI BOILERS ............................................................................. 153

TABLE 12-1 ESTIMATED EMISSIONS FROM NON-CAIR UNIT BART-ELIGIBLE FACILITIES LOCATED IN 

MANE-VU USED IN FINAL MODELING............................................................................................. 173

TABLE 12-3 SO2 EMISSIONS FROM POINT, AREA AND MOBILE SOURCES IN MAINE................................... 187

TABLE 12-4 SO2 EMISSIONS FROM POINT, AREA AND MOBILE SOURCES IN THE MANE-VU REGION AND IN 

MAINE ............................................................................................................................................... 187

List of Figures 

FIGURE 1-1 LOCATIONS OF FEDERALLY PROTECTED MANDATORY CLASS I AREAS .................................... 10

FIGURE 1-2 STATES COVERED BY THE CLEAN AIR INTERSTATE RULE ......................................................... 13

FIGURE 1-3 MAINE CLASS I AREAS .............................................................................................................. 16

FIGURE 1-4 VISIBILITY TRENDS AT ACADIA NATIONAL PARK ..................................................................... 17

FIGURE 1-5 VISIBILITY TRENDS AT MOOSEHORN NATIONAL WILDLIFE REFUGE AND ROOSEVELT 

CAMPOBELLO INTERNATIONAL PARK.................................................................................................. 18

FIGURE 1-6 MODELED ANNUAL SULFATE CONTRIBUTION AT ACADIA NATIONAL PARK IN 2002................ 19

FIGURE 1-7 MODELED ANNUAL SULFATE CONTRIBUTION AT MOOSEHORN NATIONAL WILDLIFE REFUGE 

AND ROOSEVELT/CAMPOBELLO INTERNATIONAL PARK...................................................................... 19

FIGURE 3-1 EPA DESIGNATED REGIONAL PLANNING ORGANIZATIONS (RPOS) .......................................... 23

FIGURE 3-2 SUMMARY OF MANE-VU PRINCIPLES FOR REGIONAL HAZE PLANNING .................................. 25

FIGURE 3-3 SUMMARY OF CONSULTATIONS ................................................................................................. 27

FIGURE 6-1 MAP OF ACADIA NATIONAL PARK............................................................................................. 44

FIGURE 6-2 MAP OF THE BARING AND EDMUNDS DIVISIONS OF THE MOOSEHORN NATIONAL WILDLIFE 

REFUGE AND THE IMPROVE MONITOR.............................................................................................. 45

FIGURE 6-3 MAP OF ROOSEVELT CAMPOBELLO INTERNATIONAL PARK....................................................... 46

FIGURE 7-1 CONTRIBUTIONS TO PM2.5 EXTINCTION AT SEVEN CLASS I AREAS.......................................... 49

FIGURE 7-2 RANKED CONTRIBUTION TO SULFATE CONCENTRATIONS AT ACADIA NATIONAL PARK........... 57

FIGURE 8-1 STATE LEVEL SULFUR DIOXIDE EMISSIONS............................................................................... 60

FIGURE 8-2 2002 SO2 ................................................................................................................................... 60

FIGURE 8-3 2002 VOC ................................................................................................................................. 63

FIGURE 8-4 STATE LEVEL NITROGEN OXIDES EMISSIONS ............................................................................ 64

FIGURE 8-5 NOX........................................................................................................................................... 65

FIGURE 8-6 STATE LEVEL PRIMARY PM10EMISSIONS .................................................................................. 66

FIGURE 8-7 STATE LEVEL PRIMARY PM2.5EMISSIONS ................................................................................. 66

FIGURE 8-8 WOOD SMOKE SOURCE REGIONAL AGGREGATION ................................................................... 68

FIGURE 8-9 PRIMARY PM10 .......................................................................................................................... 69

FIGURE 8-10 PRIMARY PM2.5 ........................................................................................................................ 69

FIGURE 8-11 STATE LEVEL AMMONIA EMISSIONS ........................................................................................ 71

FIGURE 8-12 STATE AMMONIA EMISSIONS BY SOURCE CATEGORY.............................................................. 71

FIGURE 9-1 MODELING DOMAINS USED IN MANE-VU AIR QUALITY MODELING STUDIES WITH CMAQ...... 83

FIGURE 9-2 EXAMPLES OF PROCESSED MODEL-READY EMISSIONS ............................................................. 85

FIGURE 9-3 DOMAIN-WIDE PAIRED COMPARISON FOR SULFATE AND OTHER PM2.5SPECIES CMAQ VS 

IMPROVE/STN.................................................................................................................................. 89

FIGURE 9-4 SULFATE CONCENTRATIONS FROM THE IMPROVE/STN MEASUREMENTS AND THE REMSAD

MODEL ................................................................................................................................................ 91

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FIGURE 9-5 COMPARISON OF MEASUREMENT AND MODELED DATA FOR ALTERNATIVE ANNUAL MODEL 

SIMULATIONS ...................................................................................................................................... 91

FIGURE 11-1 AVERAGE CHANGE IN 24-HR PM2.5 DUE TO LOW SULFUR FUEL STRATEGIES RELATIVE TO 

OTB/OTW ........................................................................................................................................ 138

FIGURE 11-2 LOCATION OF 167 EGU STACKS CONTRIBUTING THE MOST TO VISIBILITY IMPAIRMENT AT 

MANE-VU CLASS I AREAS .............................................................................................................. 142

FIGURE 11-3 PRELIMINARY ESTIMATE OF AVERAGE CHANGE IN 24-HR PM2.5 DUE TO 90 PERCENT 

REDUCTION IN SO2 EMISSIONS FROM 167 EGU STACKS AFFECTING MANE-VU............................. 143

FIGURE 11-3 DEMONSTRATION OF REQUIRED AND REASONABLE VISIBILITY PROGRESS FOR 20% WORST 

VISIBILITY DAYS ............................................................................................................................... 156

FIGURE 11-4 DEMONSTRATION OF REQUIRED AND VISIBILITY MAINTENANCE FOR 20% BEST VISIBILITY 

DAYS ................................................................................................................................................. 156

FIGURE 12-1 167 EGU STACKS AFFECTING MANE-VU CLASS I AREA(S) ................................................. 174

FIGURE 12-2 PROJECTED VISIBILITY IMPROVEMENT AT ACADIA NATIONAL PARK BASED ON 2018 BEST AND 

FINAL PROJECTIONS .......................................................................................................................... 181

FIGURE 12-3 PROJECTED IMPROVEMENT IN VISIBILITY AT MOOSEHORN NATIONAL WILDLIFE REFUGE AND 

ROOSEVELT CAMPOBELLO INTERNATIONAL PARK BASED ON 2018 BEST AND FINAL PROJECTIONS . 181

FIGURE 12-4 PROJECTED VISIBILITY IMPROVEMENT AT GREAT GULF WILDERNESS BASED ON MOST RECENT 

PROJECTIONS FOR 2018 ..................................................................................................................... 182

FIGURE 12-5 CONTAMINATION OF ULTRA LOW SULFUR DISTILLATE (DIESEL) FUEL ................................. 184

List of Attachments 

ATTACHMENT A CONTRIBUTIONS TO REGIONAL HAZE IN THE NORTHEAST AND MID-ATLANTIC STATES

ATTACHMENT B INTER-RPO STATE/TRIBAL AND FLM CONSULTATION FRAMEWORK

ATTACHMENT C SUMMARY OF CONSULTATIONS

ATTACHMENT D THE MANE-VU “ASK” 

ATTACHMENT E VISTAS COMMENTS

ATTACHMENT F FLM COMMENTS-RESERVED

ATTACHMENT G BASELINE AND NATURAL VISIBILITY CONDITIONS

ATTACHMENT H TSD SUPPORT FOR 2002 MANE-VU SIP MODELING INVENTORY VERSION 3 

ATTACHMENT I DEVELOPMENT OF EMISSION PROJECTIONS FOR 2009, 2012, AND 2018 

FOR NONEGU POINT, AREA, AND NONROAD SOURCES

ATTACHMENT J DEVELOPMENT OF MANE-VU MOBILE SOURCE PROJECTION INVENTORIES FOR 

SMOKE/MOBILE6 APPLICATION

ATTACHMENT K NYS TECHNICAL SUPPORT DOCUMENTS FOR MODELING

ATTACHMENT L CALPUFF MODELING

ATTACHMENT M MAINE BART DETERMINATIONS

ATTACHMENT M-1 THE MAINE BART PROCESS

ATTACHMENT N FIVE-FACTOR ANALYSIS OF BART ELIGIBLE SOURCES

ATTACHMENT O BART RESOURCE GUIDE

ATTACHMENT P MANE-VU MODELING FOR REASONABLE PROGRESS

ATTACHMENT Q 2018 VISIBILITY PROJECTIONS

ATTACHMENT R ASSESSMENT OF CONTROL TECHNOLOGY OPTIONS FOR BART 

ATTACHMENT S DOCUMENTATION OF 2018 EMISSIONS FROM ELECTRIC GENERATION UNITS 

ATTACHMENT T ASSESSMENT OF REASONABLE PROGRESS FOR REGIONAL HAZE IN MANE-VU CLASS 1

AREAS

ATTACHMENT U COMPARISON OF CAIR AND CAIR PLUS PROPOSAL USING THE INTEGRATED PLANNING 

MODEL (IPM®) 

ATTACHMENT V THE NATURE OF THE FINE PARTICLE AND REGIONAL HAZE AIR QUALITY PROBLEMS IN 

THE MANE-VU REGION: A CONCEPTUAL DESCRIPTION

ATTACHMENT W TOP ELECTRIC GENERATING EMISSION POINTS CONTRIBUTING TO VISIBILITY

IMPAIRMENT IN MANE-VU 

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ATTACHMENT X TECHNICAL SUPPORT DOCUMENT ON MEASURES TO MITIGATE THE VISIBILITY IMPACTS 

OF CONSTRUCTION ACTIVITIES IN THE MANE-VU REGION

ATTACHMENT Y TECHNICAL SUPPORT DOCUMENT ON AGRICULTURAL AND FORESTRY SMOKE 

MANAGEMENT IN THE MANE-VU REGION

ATTACHMENT Z THE MAINE LOW SULFUR FUEL PROGRAM 

ATTACHMENT AA MAINE 2018 PROJECTED POINT SOURCE INVENTORY

ATTACHMENT BB 06-096 CMR CHAPTER 150 CONTROL OF EMISSIONS FROM OUTDOOR WOOD BOILERS
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Introduction 

1.1 What is Regional Haze? 

Haze is a form of air pollution that impairs visibility over a wide region, and is a problem 

affecting many areas throughout the U.S., especially national parks and wilderness areas. 

Average visual range in many parks in the western U.S. is 100–150 kilometers, or about 

one-half to two-thirds of the visual range that would exist without manmade air pollution. 

In most of the eastern half of the U.S., the average visual range is less than 30 kilometers, 

or about one-fifth of the visual range that would exist under natural conditions. Surveys 

have shown that visitors to national parks and wilderness areas consistently rank visibility 

and clear scenic vistas as one of the most important aspects of their experience. 

 The particle pollution that causes haze also poses a threat to human health, and it can 

cover an area of several hundred miles. Hazy days of summer are a result of human 

activity formed by emissions from many sources in a wide geographic area. The 

emissions come from power plants, factories, and vehicles that combine with moisture in 

the air. Haze is not just a summertime problem, it can occur at any time of the year. 

Air pollution, including particulates (soot) and related gases (sulfur dioxide and nitrogen 

dioxide) can scatter and absorb light, limiting the distance that one can see and obscuring 

color and clarity. Visibility can often be reduced over large regions, and is therefore 

called regional haze. 

Visibility impairment can be quantified using three different, but mathematically related 

measures: light extinction per unit distance (e.g., Mm-1)

1

; visual range (i.e., how far one 

can see); and deciviews (dv), a useful metric for measuring increments of visibility 

change that are just perceptible to the human eye. Each can be estimated from the 

ambient concentrations of individual particle constituents, taking into account their 

unique light-scattering (or absorbing) properties and making appropriate adjustments for 

relative humidity. Assuming natural conditions, visibility in the Northeast and MidAtlantic is estimated to be about 23 Mm-1, which corresponds to a visual range of about 

106 miles or 8 dv. Under current polluted conditions in the region, average visibility 

ranges from 103 Mm-1 in the south to 55 Mm-1 in the north; these values correspond to a 

visual range of 24 to 44 miles or 23 to 17 dv, respectively. On the worst 20 percent of 

days, visibility impairment in Northeast and Mid-Atlantic Class I areas ranges from about 

25 to 30 dv. 

The principal pollutants that affect fine particle formation, and thus contribute to regional 

haze, are sulfur oxides (SOX), organic carbon (OC), nitrogen oxides (NOX), volatile 

organic compounds (VOC), ammonia (NH3), and particles with an aerodynamic diameter 

less than or equal to 10 and 2.5 μm (i.e., primary PM10 and PM2.5). In the eastern U.S. 

1

 In units of inverse length. An inverse megameter (Mm-1) is equal to one over one thousand kilometers. 
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9 

ammonium sulfate, formed from sulfur oxides and ammonia, is responsible for more than 

50 percent of regional visibility impairment, and most regional control efforts are 

directed at reducing emissions of sulfur oxides. 

1.2 Clean Air Act Regional Haze Requirements 

Regional haze and visibility were first addressed in amendments to the Clean Air Act in 

1977, when Congress added Section 169 (42 U.S.C. 7491) establishing forth the 

following national visibility goal: 

“Congress hereby declares as a national goal the prevention of any future, 

and the remedying of any existing, impairment of visibility in mandatory 

Class I Federal areas which impairment results from man-made air 

pollution.” 

The "Class I" designation was given to each of 158 areas in existence as of August 1977 

that met the following criteria: 

 all national parks greater than 6000 acres 

 all national wilderness areas and national memorial parks greater than 5000 acres 

 one international park 

In 1980, Bradwell Bay, Florida, and Rainbow Lake, Wisconsin, were excluded for 

purposes of visibility protection as federal Class I areas. Figure 1-1 illustrates the 156 

national park and wilderness areas that remain as Class I visibility protection areas. 

Over the following years modest steps were taken to address the visibility problems in 

Class I areas. The control measures taken mainly addressed Plume Blight from specific 

pollution sources and did little to address regional haze issues in the Eastern United 

States. 

When the CAA was amended in 1990, Congress added Section 169B (42 U.S.C. 7492), 

authorizing further research and regular assessments of the progress made so far. In 1993, 

the National Academy of Sciences concluded that “current scientific knowledge is 

adequate and control technologies are available for taking regulatory action to improve 

and protect visibility.” 

In addition to authorizing creation of visibility transport commissions and setting forth 

their duties, Section 169B(f) of the CAA mandated creation of the Grand Canyon 

Visibility Transport Commission (GCVTC) to make recommendations to EPA for the 

region affecting the visibility of the Grand Canyon National Park. The Grand Canyon 

Visibility Transport Commission (Commission) submitted its report to EPA in June 1996, 

following four years of research and policy development. The Commission report, as well 

as the many research reports prepared by the Commission, contributed invaluable 

information to EPA in its development of the federal regional haze rule. 
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Figure 1-1 

Locations of Federally Protected Mandatory Class I Areas 

1.3 The Federal Regional Haze Rule 

The federal requirements that states must meet to achieve national visibility goals are 

contained in Title 40: Protection of Environment, Part 51 – Requirements for Preparation, 

Adoption, and Submittal Of Implementation Plans, Subpart P – Protection of Visibility 

(40 CFR 51.300-309)2. Known more simply as the Regional Haze Rule, these 

regulations were adopted on July 1, 1999, and went into effect on August 30, 1999. The 

rule seeks to address the combined visibility effects of various pollution sources over a 

 

2

 The specific requirements for States’ regional haze SIPs are set forth in 40 CFR 51.308, Regional Haze 

Program Requirements. 

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. 

 

large geographic region, with the result that all states – even those without Class I areas –

are required to participate in haze reduction efforts

In consultation with the states and tribes, EPA designated five Regional Planning 

Organizations (RPO) to assist with the coordination and cooperation needed to address 

the haze issue. The Mid-Atlantic / Northeast states, including the District of Columbia, 

formed the Mid-Atlantic / Northeast Visibility Union (MANE-VU).3

EPA’s Regional Haze Rule was the subject of considerable controversy, and was 

challenged on several legal grounds. On May 24, 2002 the U.S. Court of Appeals for the 

District of Columbia Circuit ruled on the challenge brought by the American Corn 

Growers Association against EPA’s Regional Haze Rule of 1999. The Court remanded 

the BART provisions of the rule to EPA, and denied industry’s challenge to the haze rule 

goals of natural visibility and no degradation requirements. On June 15, 2005, EPA 

finalized a rule addressing the Court’s remand. 

On February 18, 2005, the U.S. Court of Appeals for the District of Columbia Circuit 

issued another ruling vacating the Regional Haze Rule in part and sustaining it in part. 

For more information see Center for Energy and Economic Development v. EPA, no. 03-

1222, (D.C. Cir. Feb. 18, 2005)(“CEED v. EPA”). In this case, the court granted a 

petition challenging provisions of the Regional Haze Rule governing the optional 

emissions trading program for certain Western States and Tribes (the WRAP Annex 

Rule). 

EPA’s subsequent final rulemaking provided the following changes to the Regional Haze 

Regulations: 

1. Revised the regulatory text in 40 CFR Section 51.308(e)(2)(i) in response to the 

CEED court’s remand, to remove the requirement that the determination of BART 

“benchmark” be based on cumulative visibility analyses, and to clarify the process 

for making such determinations, including the application of BART presumptions 

for EGUs as contained in Attachment Y to 40 CFR 51. 

2. Added new regulatory text in 40 CFR Section 51.308(e)(2)(vi), to provide 

minimum elements for cap and trade programs or alternative measures in lieu of 

BART. 

3. Revised regulatory text in 40 CFR Section 51.309, to reconcile the optional 

framework for certain Western States and Tribes to implement the 

recommendations of the Grand Canyon Visibility Transport Commission 

(GCVTC) with the CEED decision. 

3 A description of MANE-VU and a full list of its members is described in the Regional Planning Section 

of this SIP. 
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12 

1.4 Regional Haze Planning After the Vacatur of CAIR 

On March 10, 2005, EPA issued the Clean Air Interstate Rule (CAIR). This important 

federal rule was designed to achieve major permanent reductions in sulfur dioxide (SO2) 

and nitrogen oxides (NOx) emissions in the eastern United States through a cap-and-trade 

system using emission allowances. As promulgated, CAIR permanently caps emissions 

originating in 28 eastern states and the District of Columbia (Figure 1-2). Although 

Maine was not designated as a participating CAIR state, this program would greatly 

affect future air quality in the state. 

According to EPA’s CAIR website, SO2 emissions in the affected states would be 

reduced by more than 70 percent from 2003 levels, and NOx emissions by more than 60 

percent from 2003 levels, upon full implementation of CAIR (See 

http://www.epa.gov/cair/). Resulting improvements in air quality would yield $85 to 

$100 billion in health benefits and nearly $2 billion in visibility benefits per year by 

2015, and premature mortality would be substantially reduced across the eastern U.S. 

This program came to an abrupt end, however, on July 11, 2008, when the U.S. Court of 

Appeals for the District of Columbia Circuit found that CAIR violated basic provisions of 

the Clean Air Act. The Court vacated CAIR in its entirety and remanded to EPA to 

promulgate a new rule consistent with the court’s opinion. On September 24, 2008, EPA 

petitioned the D.C. Circuit for a rehearing or rehearing en banc on the vacatur of CAIR. 

Thereafter, the D.C. Circuit issued an order requesting briefs on the issue of whether any 

party is seeking vacatur of CAIR, and whether the court should stay its vacatur until EPA 

promulgates a revised rule. Maine, along with more than 20 other states, filed an amicus 

brief in support of staying the court decision vacating CAIR while EPA promulgates a 

revised rule that complies with the Court’s decision. The states argued that because they 

“reasonably relied on CAIR in formulating long-term plans for improving air quality, in 

the short term, even a flawed rule is better than none at all.” 

The vacatur of CAIR presented a major difficulty for the individual states in attempting 

to comply with the Regional Haze Rule. Because CAIR formed the regulatory 

underpinnnings for most of the emission reductions that would produce visibility 

improvements in mandatory Class I areas, the probable demise of CAIR left a structural 

void around which states must build their regional haze SIPs. While all states have 

depended in varying degree on CAIR in the preparation of their Regional Haze SIPs, 

some Southeast states have relied almost entirely on CAIR to demonstrate compliance 

with the Regional Haze Rule. As a major ramification, the vacatur of CAIR invalidated 

EPA’s decision that CAIR satisfies the requirements for Best Available Retrofit 

Technology (BART) for the affected sources. The vacatur of CAIR also called into 

question the validity of MANE-VU’s and other RPO’s emission inventories and air 

quality modeling studies already completed for the member state’s regional haze SIPs. 
5/27/2010 

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Figure 1-2

States Covered by the Clean Air Interstate Rule 

However, on December 23, 2008, the D.C. Circuit decided that “a remand without 

vacatur is appropriate in this case” because “notwithstanding the relative flaws of CAIR, 

allowing CAIR to remaining in effect until it is replaced by a rule consistent with our 

opinion would at least temporarily preserve the environmental values covered by CAIR.” 

State of North Carolina v. EPA, No. 05-1244, slip op. at 3 (D.C. Cir. Dec. 23, 2008). 

In light of this decision, Maine believes that future emissions and air quality levels will 

not be vastly different from the values predicted by MANE-VU’s completed modeling, 

even though that modeling was based on implementation of CAIR and did not take into 

account the remand of CAIR to EPA. Consequently, the reasonable progress goals and 

long-term strategy developed for Maine’s regional haze SIP still represent a defensible 

position from which to move forward with measures to improve visibility in Maine’s 

Class I areas. 

Further, Maine and the other MANE-VU states have maintained all along that the 

Regional Haze SIPs should look beyond the provisions of CAIR to identify additional 

emission control measures that could be effectively employed to mitigate regional haze. 

In this respect, Maine and the rest of MANE-VU stand apart form the other states in 

asserting that additional measures beyond CAIR are essential to meeting the established 

visibility goals at MANE-VU’s Class I areas. 

13 
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14 

In describing Maine’s present situation, it may be helpful to note that the remand of 

CAIR without vacatur is a complicating factor for the long-term, but does not present an 

impediment to making visibility progress in the near term. The salient points to consider 

are as follows: 

 Because Maine is a non-CAIR state, CAIR does not directly affect any of Maine’s 

proposed in-state visibility improvement control strategies. 

 Maine will meet its “fair share” of emission reductions in comparison with other 

MANE-VU states and the original CAIR states, as Maine’s long-term strategy 

demonstrates (See Section 12). 

 Sources in upwind states release most of the pollutants contributing to visibility 

impairment at Maine’s Class I areas. Therefore, Maine will continue to be 

dependent on mitigative actions by other states if visibility goals are to be 

achieved for these Class I areas. 

 By the time the first regional haze SIP progress report, in 2013, the regulatory 

framework for the CAIR replacement should be clearer, and new modeling results 

should be available. It should then be possible to fine-tune regional haze plans to 

address any rule that EPA has promulgated to replace CAIR. Maine is committed 

to reviewing and updating its regional haze SIP as new information becomes 

available. 

Given the D.C. Circuit’s remand without vacatur of CAIR, Maine has chosen to retain 

appropriate references to CAIR in the completion of its Regional Haze SIP. We believe 

this will help to maintain continuity with the large body of completed work- much of it 

based on CAIR- that serves as the foundation for regional haze planning in the MANEVU states. 

1.5 Maine Class I Areas 

Maine has three Class I areas: 1) Acadia National Park; 2) Moosehorn National Wildlife 

Refuge Wilderness Area; and 3) Roosevelt Campobello International Park (See Figure 1-

3). 

1.5.1 Acadia National Park 

When Acadia National Park was designated in 1919, it was called Lafayette 

National Park and was the first national park designated east of the Mississippi River. 

Created with 6,000 acres of land, the park changed its name in 1929 and now 

encompasses about 40,000 acres of mixed ecology including Atlantic shoreline, mixed 

hardwood forests, spruce and fir forests, mountains, lakes and islands. Facilities at the 

park include 45 miles of carriage roads for walking and biking with 27 miles of scenic 

driving, plus 120 miles of hiking only trails, 2 campgrounds, a restaurant and 3 gift 
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15 

shops. Acadia averages 3 million visitors each year with the majority visiting during 

July and August (almost 700,000 visitors per month) and the fewest during December, 

January, and February (almost 38,000 visitors per month). Open year round, Acadia 

provides an abundance of recreational opportunities. The average park visitor stays at 

Acadia 1-4 days. 

1.5.2 Moosehorn Wildernesss Area, Moosehorn National Wildlife Refuge

Moosehorn National Wildlife Refuge, which was officially established in 1937, is 

comprised of two units, the Baring Unit (17,200 acres) and the Edmunds Unit (7,200 

acres). Within the refuge, a combined 7,460 acres of land (2780 acres from the Edmunds 

Unit and 4680 acres from the Baring Unit) are protected as a Class I wilderness area. The 

refuge includes rocky shores, rolling forested hills, lakes, bogs, and marshes that 

provide protected habitat and breeding grounds for migratory land and water birds. 

Moosehorn was the first migratory bird refuge to be established in what is now a chain 

of refuges extending south to Florida. It features American bald eagles, and the 

American woodcock among the more than 220 species of birds that have been spotted 

here. While birding is the primary attraction of Moosehorn Refuge, visitors also 

utilize over 50 miles of roads and trails for hiking, biking, cross country skiing, and 

snowmobiling. Non-motorized boats are also allowed access to streams and lakes in 

the refuge for fishing. In November, the refuge is open for white-tailed deer hunting. 

Education programs also draw visitors to the refuge, where wildlife biologists invite 

visitors to join them on bird banding operations. 

1.5.3 Roosevelt Campobello International Park

Roosevelt Campobello International Park is the only international park in North America. 

The park is located on Campobello Island in Canada, but is of historical 

significance to the U.S. as the life-long summer home of President Franklin Delano 

Roosevelt. U.S. President Lyndon Johnson and Canadian Prime Minister Lester 

Pearson established the park on January 22, 1964 by international agreement. The 

park remains a symbol of neighborly relations between the U.S. and Canada, and of 

the importance of FDR’s achievements to both nations. The Roosevelt Campobello 

International Commission manages the park. Commission members are appointed by 

the Governor General of the Council of Canada and by the U.S. President. The 

agreement splits equally all costs of development, operation, and management. 

The park itself is a mixture of historic cottages and scenic natural landscapes. There are 

8.4 miles of scenic roads in the park and 8 miles of walking paths. The 

grounds of the park include coastal headlands, rocky shores, beaches, wetlands, fields, 

forest, and the landscaped gardens of the cottages. The mix of habitat is excellent for 

a variety of migratory and shore birds. While the historic cottages are only open from 

Memorial Day to Columbus Day, the natural areas and visitor center are open year round. 
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Figure 1-3 

Maine Class I Areas 

This unique historic, natural area attracts approximately 150,000 visitors annually, with 

most arriving in August. The National Park Service recommends visitors plan on 2 to 4 

hours to view the cottages, and 8 or more hours for full appreciation of the natural 

areas. In addition to the historic setting, several recreational activities are permitted 

on the island. There are no admission fees for this park, although donations are 

accepted. 

16 
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1.6 Visibility Trends at Maine Class I Areas 

Figures 1-4 and 1-5 present recent visibility trends, baseline and natural conditions (in 

deciviews) at Acadia National Park, Moosehorn National Wildlife Refuge and Roosevelt 

Campobello International Park Class I areas for the 20 percent greatest and least impaired 

visibility days. The figures also illustrate the uniform rate of progress ‘glide path’ needed 

to reach natural background level goal established by the Clean Air Act. As of 2008, 

visibility conditions at all Class I areas in Maine are currently at or below the uniform 

rate of progress glide path. 

Figure 1-4 

Visibility Trends at Acadia National Park 

0

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1990199319961999200220052008201120142017202020232026202920322035203820412044204720502053205620592062

deciview (dv)

Worst 20% Worst 20% 2000-2004 Baseline

Worst 20% 5-yr Avg Worst 20% Glide Path

Worst 20% Default natural conditions Best 20%

Best 20% 2000-2004 Baseline Best 20% 5-yr Avg

Best 20% Glide Path Best 20% Default natural conditions

1.7 Sources of Regional Haze at Maine Class I Areas 

In order to identify states where emissions are most likely to influence visibility in 

MANE-VU Class I areas, MANE-VU identified and evaluated the major contributors to 

regional haze at MANE-VU Class I areas as well as Class I areas in nearby regional 

planning organizations (RPOs). The MANE-VU findings are available in a report 

produced by the Northeast States for Coordinated Air Use Management (NESCAUM) 

entitled “Contributions to Regional Haze in the Northeast and Mid-Atlantic United 

States,” August 2006, also known as the “Contribution Assessment” (Attachment A). 

Based on that work, MANE-VU concluded that it was appropriate to define an area of 

influence including all of the states participating in MANE-VU, plus other states that 

contributed at least 2% of the modeled sulfate ion at MANE-VU Class I areas in 2002. 

Figures 1-6 and 1-7 illustrate modeled annual sulfate ion contribution at Acadia 

17 
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Figure 1-5 

Visibility Trends at Moosehorn National Wildlife Refuge and Roosevelt Campobello 

International Park4

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199519982001200420072010201320162019202220252028203120342037204020432046204920522055205820612064

deciview (dv)

Worst 20% Worst 20% 2000-2004 Baseline

Worst 20% 5-yr Avg Worst 20% Glide Path

Worst 20% Default natural conditions Best 20%

Best 20% 2000-2004 Baseline Best 20% 5-yr Avg

Best 20% Glide Path Best 20% Default natural conditions

National Park and Moosehorn National Wildlife Refuge in 2002 based on the use of 

REMSAD (Regional Modeling System for Aerosols and Deposition) modeling. The 

REMSAD modeling clearly shows that Maine Class I Areas are most influenced by 

emissions from the northern states and Canada5. 

Rather than relying solely on a grid-based source model, such as REMSAD, Maine 

utilized a variety of analytical and assessment tools to determine the sources of visibility 

impairment at Maine Class I areas, including Lagrangian (air parcel-based) source 

dispersion models, as well as a variety of data analysis techniques that include source 

apportionment models, back trajectory calculations, and the use of monitoring and 

inventory data. Using these techniques, the states in Table 1-1 were identified as causing 

or contributing two percent or more of the visibility impairment in Acadia National Park, 

Moosehorn National Wildlife Refuge, and Roosevelt Campobello International Park. 

Additional information about procedures by which monitoring data and other information 

were used in determining the contribution of emissions from within these State to 

regional haze visibility impairment at MANE-VU Class I areas is included in Section 7 of 

the Maine State Implementation Plan for Regional Haze and in the MANE-VU 

Contribution Assessment in (Attachment A). Additional information on the sources of 

 

4 The Moosehorn National Wildlife Refuge IMPROVE monitor is also used for Roosevelt Campobello 

International Park. 

18 

5 Note that the large “other” fraction of sulfates includes all sources outside the analysis domain, which 

includes some portions of the VISTAS and CENWRAP RPO, Northern and Western Canada, in addition to 

all other (e.g., intercontinental) sources of SO2. 
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SO2 emissions and why sulfur is the key pollutant targeted by MANE-VU and Maine is 

included in Section 8, Emissions Inventory. 

Figure 1-6 

Modeled Annual Sulfate Contribution at Acadia National Park in 2002 

 (percent contribution) 

Average Annual Sulfate Impact by Source at Acadia National Park

ME, 6.54

MD, 2.20

MA, 10.11

NH, 2.25

NJ, 1.40

NY, 4.74

Other, 33.79

CT, 0.76

DE, 0.96

DC, 0.01

CENRAP, 0.88

MS, 0.01 NC, 1.45

KY, 1.17 WI, 0.85

SC, 0.43

VA, 1.48

WV, 2.35

IL, 1.37

MI, 2.02

RI, 0.28

PA, 6.81

VT, 0.13

Canada, 8.69

TN, 0.61

GA, 0.67 AL, 0.32

OH, 5.62

IN, 2.13

Canada CENRAP

CT DE

DC ME

MD MA

NH NJ

NY PA

RI VT

IL IN

MI OH

WI AL

GA KY

MS NC

SC TN

VA WV

Other

Figure 1-7 

Modeled Annual Sulfate Contribution at Moosehorn National 

Wildlife Refuge and Roosevelt/Campobello International Park 

 (percent contribution) 

19 

Average Annual Sulfate Impact by Source at Moosehorn Wildlife Refuge

ME, 8.01

MD, 1.60

MA, 6.78

NH, 1.74

NJ, 1.03

NY, 3.83

Other, 44.17

OH, 4.62 IN, 2.02

AL, 0.25

GA, 0.56

TN, 0.50

Canada, 7.85

VT, 0.09

PA, 5.53

RI, 0.19

MI, 1.74

IL, 1.30

WV, 1.75

VA, 1.13

SC, 0.36

WI, 0.72

KY, 0.98 NC, 1.14 MS, 0.01

CENRAP, 0.82

DC, 0.01

CT, 0.56 DE, 0.71

Canada CENRAP

CT DE

DC ME

MD MA

NH NJ

NY PA

RI VT

IL IN

MI OH

WI AL

GA KY

MS NC

SC TN

VA WV

Other
5/27/2010 

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20 

1.8 Class I Areas Affected 

In accordance with 40 CFR Section 51.308(d)(4)(iii), emissions sources within the State 

of Maine affect Class I areas in Maine along with the Great Gulf and Presidential-Dry 

River Wilderness Areas in New Hampshire6

. 

Table 1-1 

States that Contribute to Visibility Impairment at Maine Class 1 Areas 

State Assessment Technique

MANE-VU 

Member 

REMSAD Q/D Calpuff 

NWS 

Calpuff 

MM5 

% Time 

Upwind 

Connecticut X 

Delaware X 

District of Columbia X 

Georgia X 

Illinois X X X 

Indiana X X X X X 

Kentucky X X X X 

Maine X X X 

Maryland X X X 

Massachusetts X X X X X 

Michigan X X X X X 

New Hampshire X X X X 

New Jersey X 

New York X X X X X X 

North Carolina X X 

Ohio X X X X X 

Pennsylvania X X X X X 

Rhode Island X 

Tennessee X 

Vermont X 

Virginia X 

West Virginia X X X X X 

 

6 The modeled annual sulfate ion impact of Maine emissions at the Great Gulf and Presidential-Dry 

Wilderness Areas in New Hampshire is more than 2% of all modeled sulfate ion impacts. 
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21 

2. General Planning Provisions and Commitment to Future Submittal 

In accordance with 40 CFR Section 51.308(a) and (b), Maine is submitting this SIP to 

meet the requirements of EPA’s Regional Haze Rule. This SIP addresses the core 

requirements of 40 CFR Section 51.308(d) and the Best Available Retrofit Technology 

(BART) components of 40 CFR Section 50.308(e). In addition, this SIP addresses 

requirements pertaining to regional planning, and state/tribe and Federal Land Manager 

(FLM) coordination and consultation. 

40 CFR Section 51.308(f) requires the State of Maine to submit its SIP revision by July 

31, 2018 and every ten years thereafter. Maine acknowledges and commits to this 

schedule. 

40 CFR Section 51.308(g) requires Maine to submit a report to EPA every 5 years that 

evaluates progress toward the reasonable progress goal for each mandatory Class I area 

located within the state and each mandatory Class I area located outside the state that 

may be affected by emissions from within the state. Maine commits to submitting the first 

progress report, in the form of a SIP revision, no later than December 17, 2012. 

Pursuant to 40 CFR Section 51.308(d)(4)(v), Maine also commits to making periodic 

updates to the emissions inventory (see Section 7), and will complete these updates to 

coincide with the progress reports. 

Lastly, pursuant to 40 Section CFR 51.308(h), Maine will submit a determination of 

adequacy of its regional haze SIP revision whenever a progress report is submitted. 

Depending on the findings of its five-year review, Maine will take one or more of the 

following actions at that time, whichever actions are appropriate or necessary: 

 If Maine determines that the existing State Implementation Plan requires no 

further substantive revision in order to achieve established goals for visibility 

improvement, it will provide to the EPA Administrator a negative declaration that 

further revision of the existing plan is not needed. 

 If Maine determines that its implementation plan is, or may be, inadequate to 

ensure reasonable progress as a result of emissions from sources in one or more 

other state(s) which participated in the regional planning process, it will provide 

notification to the EPA Administrator and to those other state(s). Maine will also 

collaborate with the other state(s) through the regional planning process for the 

purpose of developing additional strategies to address any such deficiencies in its 

plan. 

 If Maine determines that its implementation plan is, or may be, inadequate to 

ensure reasonable progress as a result of emissions from sources in another 

country, it will provide notification, along with available information, to the EPA 

Administrator. 

 If Maine determines that the implementation plan is, or may be, inadequate to 

ensure reasonable progress as a result of emissions from sources within the State, 
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22 

it will revise its implementation plan to address the plan's deficiencies within one 

year from this determination. 
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3. Regional Planning 

In 1999, EPA and affected States/Tribes agreed to create five Regional Planning 

Organizations (RPOs) to facilitate interstate coordination on State Implementation Plans 

(SIPs) for regional haze. The RPOs and states/tribes within each RPO are required to 

consult on the development of emission management strategies directed towards visibility 

improvement in affected Class1 areas. Figure 3-1 illustrates the five RPOs—MANE-VU 

(Mid-Atlantic/Northeast Visibility Union), VISTAS (Visibility Improvement State and 

Tribal Association of the Southeast), MRPO (Midwest Regional Planning Organization), 

CenRAP (Central Regional Air Planning Association), and WRAP (Western Regional 

Air Partnership). As shown, Maine is part of MANE-VU. 

 

Figure 3-1 

EPA Designated Regional Planning Organizations (RPOs) 

3.1 MANE-VU 

MANE-VU’s work is managed by the Ozone Transport Commission (OTC) and carried 

out by the OTC, the Mid-Atlantic Regional Air Management Association (MARAMA), 

and the Northeast States for Coordinated Air Quality Management (NESCAUM). The 

states, tribes and federal agencies comprising MANE-VU are listed in Table 3-1. 

Individuals from the states, tribes and federal agencies, along with the professional staff 

23 
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24 

from OTC, MARAMA, and NESCAUM, make up the various committees and 

workgroups. 

Table 3-1 

MANE-VU Members 

1. Connecticut 10. Pennsylvania 

2. Delaware 11. Penobscot Nation 

3. District of Columbia 12. Rhode Island 

4. Maine 13. St. Regis Mohawk Tribe 

5. Maryland 14. Vermont 

6. Massachusetts 15. U.S. Environmental Protection 

Agency* 

7. New Hampshire 16. U.S. National Park Service* 

8. New Jersey 17. U.S. Fish and Wildlife Service* 

9. New York 18. U.S. Forest Service* 

 *Non-voting members 

MANE-VU established an active committee structure to address both technical and nontechnical issues related to regional haze. The primary committees are: 

 The Technical Support Committee (TSC), charged with assessing the nature and 

magnitude of the regional haze problem within MANE-VU, interpreting the 

results of technical work, and reporting on such work to the MANE-VU Board; 

and 

 The Communications Committee, charged with developing approaches to inform 

the public about the regional haze problem in the region and making any 

recommendations to the MANE-VU Board to facilitate that goal. 

In addition to the formal working committees, there are also three standing working 

groups of the TSC. They are broken down by topic area: Emissions Inventory, 

Modeling, and Monitoring/Data Analysis Workgroups. 

MANE-VU also established a Policy Advisory Group (PAG), which met on an as-needed 

basis to provide advice to decision-makers on policy questions. Ultimately, decisions are 

made by the MANE-VU Board. 

3.2 Regional Consultation 

On May 10, 2006, MANE-VU adopted the “Inter-RPO State/Tribal and FLM 

Consultation Framework” (Attachment B). The Inter-RPO State/Tribal and FLM 

Consultation Framework established the principles presented in Figure 3-2, which were 

applied to the consultation and SIP development process by the MANE-VU states and 

tribes. The MANE-VU consultations addressed (among others) regional haze baseline 
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determinations, natural background levels, and the development of reasonable progress 

goals, all of which are discussed at length in later sections of this SIP. 

Figure 3-2 

Summary of MANE-VU Principles for Regional Haze Planning 

25 

1) All State, Tribal, RPO, and Federal participants are committed to continuing dialogue and 

information sharing in order to create understanding of the respective concerns and needs of the 

parties. 

2) Continuous documentation of all communications is necessary to develop a record for inclusion in 

the SIP submittal to EPA. 

3) States alone have the authority to undertake specific measures under their SIP. This inter-RPO 

framework is designed solely to facilitate needed communication, coordination and cooperation 

among jurisdictions but does not establish binding obligation on the part of participating agencies. 

4) There are two areas which require State-to-State and/or State-to-Tribal consultations (“formal” 

consultations): (i) development of the reasonable progress goal for a Class I area, and (ii) 

development of long-term strategies. While it is anticipated that the formal consultation will cover 

the technical components that make up each of these policy decision areas, there may be a need for 

the RPOs, in coordination with their State and Tribal members, to have informal consultations on 

these technical considerations. 

5) During both the formal and informal inter-RPO consultations, it is anticipated that the States and 

Tribes will work collectively to facilitate the consultation process through their respective RPOs, 

when feasible. 

6) Technical analyses will be transparent, when possible, and will reflect the most up-to-date 

information and best scientific methods for the decision needed within the resources available. 

7) The State with the Class I area retains the responsibility to establish reasonable progress goals. The 

RPOs will make reasonable efforts to facilitate the development of a consensus between the State 

with a Class I area and other States affecting that area. In instances where the State with the Class I 

area can not agree with such other States that the goal provides for reasonable progress, actions 

taken to resolve the disagreement must be included in the State’s regional haze implementation plan 

(or plan revisions) submitted to the EPA Administrator as required under 40 CFR §51.308(d)(1)(iv). 

8) All States whose emissions are reasonably anticipated to contribute to visibility impairment in a 

Class I area, must provide the Federal Land Manager (“FLM”) agency for that Class I area with an 

opportunity for consultation, in person, on their regional haze implementation plans. The 

States/Tribes will pursue the development of a memorandum of understanding to expedite the 

submission and consideration of the FLM’s comments on the reasonable progress goals and related 

implementation plans. As required under 40 CFR §51.308(i)(3), the plan or plan revision must 

include a description of how the State addressed any FLM comments. 

9) States/Tribes will consult with the affected FLMs to protect the air resources of the State/Tribe and 

Class I areas in accordance with the FLM coordination requirements specified in 40 CFR §51.308(i) 

and other consultation procedures developed by consensus.. 

10) The consultation process is designed to share information, define and document issues, develop a 

range of options, solicit feedback on options, develop consensus advice if possible, and facilitate 

informed decisions by the Class I States. 

11) The collaborators, including States, Tribes and affected FLMs, will promptly respond to other 

RPO’s/States’/Tribes’ requests for comments. 
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26 

The following points highlight several of the many ways MANE-VU member states and 

tribes have cooperatively addressed regional haze. 

 Budget Prioritization: MANE-VU developed a process to coordinate 

MARAMA, OTC and NESCAUM staff in developing budget priorities, project 

rankings, and federal grant requests. 

 Issue Coordination: MANE-VU establishes a conference call and meeting 

schedule for each of its committees and workgroups. In addition, the MANE-VU 

Directors regularly discuss pertinent issues. 

 SIP Policy and Planning: MANE-VU states/tribes collaborated on the 

development of a SIP Template and the technical aspects of the SIP development 

process. 

 Capacity Building: To educate its staff and members, MANE-VU included 

technical presentations on conference calls and organized workshops with 

nationally recognized experts. Presentations on data analysis, BART work, 

inventory topics, modeling, control measures etc. were an effective education, and 

coordination tool. 

 Routine Operations: MANE-VU staff at OTC, MARAMA, and NESCAUM 

established a coordinated approach to: budget, grant deliverables/due-dates, 

workgroup meetings, inter-RPO feedback, etc. 

40 CFR Section 51.308(d)(3)(i) requires the State of Maine to consult with other 

States/Tribes to develop coordinated emission management strategies. This requirement 

applies both where emissions from the State/Tribe are reasonably anticipated to 

contribute to visibility impairment in Class I areas outside the State/Tribe, and when 

emissions from other States/Tribes are reasonably anticipated to contribute to visibility 

impairment in Class I areas within the State/Tribe. 

Maine consulted with other states and tribes by participation in the MANE-VU and interRPO processes that developed technical information necessary for development of 

coordinated strategies. Strategy development considered the impacts of the state and 

tribe’s emissions on Class I areas within and outside the state or tribe and culminated in 

the adoption by MANE-VU on June 20, 2007 of the “Statement of the MidAtlantic/Northeast Visibility Union (MANE-VU) Concerning a Request for a Course of 

Action by States Within MANE-VU Toward Assuring Reasonable Progress.” 

The consultations between the MANE-VU states and other states/tribes and provinces 

occurred throughout much of 2007. Documentation of consultation meetings and calls is 

summarized below, in Figure 3-3, with further documentation provided in Attachment C. 
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Figure 3-3 

Summary of Consultations 

27 

 MANE-VU Intra-Regional Consultation meeting, March 1, 2007 

o At this meeting, MANE-VU members reviewed the requirements for regional haze plans, 

preliminary modeling results, the work being done to prepare the MANE-VU report on 

reasonable progress factors, and control strategy options under review. 

 MANE-VU Intra-State Consultation meeting, June 7, 2007 

o At this meeting the MANE-VU Class I states adopted a statement of principles, and all 

MANE-VU members discussed draft statements concerning reasonable controls within and 

outside of MANE-VU. Federal Land Managers also attended the meeting, which was open to 

stakeholders. 

 MANE-VU Conference Call, June 20, 2007 

o On this call, the MANE-VU states concluded discussions of statements concerning reasonable 

controls within and outside MANE-VU and agreed on the statements called the MANE-VU 

“Ask,” including a statement concerning controls within MANE-VU, a statement concerning 

controls outside MANE-VU, and a statement requesting a course of action by the U.S. EPA. 

Federal Land Managers also participated in the call. Upon approval, all statements as well as 

the statement of principles adopted on June 7 were posted and publicly available on the 

MANE-VU web site. The MANE-VU “Ask” was determined to represent Maine’s needs for 

meeting Regional Haze rule requirements and was thus adopted as the Maine Regional Haze 

“Ask”. 

 MANE-VU Class I States’ Consultation Open Technical Call, July 19, 2007 

o On this call, the MANE-VU / Maine “Ask” was presented to states in other RPOs, RPO staff, 

and Federal Land Managers, and an opportunity was provided to request further information. 

This call was intended to provide information to facilitate informed discussion at follow-up 

meetings. 

 MANE-VU Consultation Meeting with MRPO, August 6, 2007 

o This meeting was held at LADCO offices in Chicago, Illinois and was attended by 

representatives of both MANE-VU and MRPO states as well as staff. The meeting provided 

an opportunity to formally present the MANE-VU / Maine “Ask” to MRPO states and to 

consult with them regarding the reasonableness of the requested controls. Federal Land 

Manager agencies also attended the meeting. 

 MANE-VU Consultation Meeting with VISTAS, August 20, 2007 

o This meeting was held at State of Georgia offices in Atlanta and was attended by 

representatives of both MANE-VU and VISTAS states as well as staff. The meeting provided 

an opportunity to formally present the MANE-VU / Maine “Ask” to VISTAS states and to 

consult with them regarding the reasonableness of the requested controls. Federal Land 

Manager agencies also attended the meeting. 

 MANE-VU – Midwest RPO Consultation Conference Call, September 13, 2007 

o This call was a follow-up to the meeting held on August 6 in Chicago and provided an 

opportunity to further clarify what was being asked of the MRPO states. The flexibility in the 

“Ask” was explained. Both MRPO and MANE-VU staff agreed to work together to facilitate 

discussion of further controls on ICI boilers and EGUs. 

 MANE-VU Air Directors’ Consultation Conference Call, September 26, 2007 

o This call allowed MANE-VU members to clarify their understanding of the “Ask” and to 

provide direction to modeling staff as to how to interpret the “Ask” for purposes of estimating 

visibility impacts of the requested controls. 
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3.3 Maine-Specific Consultation 

On February 26, 2007, Maine sent letters formally requesting consultation under the 

Regional Haze Rule to each state shown through modeling to contribute to at least 2 

percent of the sulfates to the Class I Areas in Maine and/or states located within MANEVU (See Table 3-2). As a matter of procedure, every member state (plus the District of 

Columbia) of MANE-VU was requested to consult with Maine. Additional states from 

outside of MANE-VU were also requested to join our consultation, based on the results 

of the MANE-VU Contribution Assessment (Attachment A). 

Table 3-2 

States Contributing to Visibility Impairment at Class I Areas in Maine 

(By Regional Planning Organization) 

MANE-VU VISTAS MRPO 

Connecticut Georgia Illinois 

Delaware Kentucky Indiana 

District of Columbia North Carolina Michigan 

Maine Tennessee Ohio 

Maryland Virginia 

Massachusetts West Virginia 

New Jersey 

New York 

Pennsylvania 

Rhode Island 

Vermont 

Formal inter-regional consultation meetings took place on August 6, 2007 in Rosemont, 

Illinois (for Midwestern states) and on August 20, 2007 in Atlanta (for Southern states). 

Consultation continues with the Midwestern states, seeking common approaches for 

reducing power plant emissions beyond the levels defined under the federal Clean Air 

Interstate Rule (CAIR), controls on industrial boilers, and cleaner burning fuels for 

mobile sources. While this consultation was mostly focused on the health benefits of 

reducing ozone and small particles, the measures would also result in visibility 

improvements. 

3.4 The MANE-VU “Ask” 

In addition to having a set of guiding principles for consultation (as described in Figure 

3-2, above), MANE-VU needed a consistent technical basis for emission control 

strategies to combat regional haze. After much research and analysis, on June 20, 2007, 

MANE-VU adopted a set of documents (See Attachment D), which provide the technical 

basis for consultation among the interested parties and define the basic strategies for 

controlling pollutants that cause visibility impairment at Class I areas in the eastern 

United States: 
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 “Statement of the Mid-Atlantic / Northeast Visibility Union (MANE-VU) 

Concerning a Course of Action within MANE-VU toward Assuring Reasonable 

Progress” 

 “Statement of the Mid-Atlantic / Northeast Visibility Union (MANE-VU) 

Concerning a Request for a Course of Action by States outside of MANE-VU 

toward Assuring Reasonable Progress” 

 “Statement of the Mid-Atlantic / Northeast Visibility Union (MANE-VU) 

Concerning a Request for a Course of Action by the U.S. Environmental 

Protection Agency (EPA) Towards Assuring Reasonable Progress”

Together, these documents are known as the MANE-VU “Ask.” Maine believes that 

these documents outline reasonable strategies for visibility improvement as required by 

the Clean Air Act, and fully supports the language and substance of these documents. 

The MANE-VU “Ask” is therefore the Maine “Ask”. The particular emission 

management strategies that comprise the Ask are described, in detail, below. 

3.5 Meeting the “Ask” – MANE-VU States 

The member states of MANE-VU stated their intention to meet the terms of the “Ask” in 

their SIPs. Maine conditionally supports the SIPs of each of its fellow MANE-VU 

members, with this support contingent upon the adoption and implementation of regional 

haze emission control measures and programs satisfying the MANE-VU “Ask”. The Ask 

for member states calls for each state to pursue the adoption and implementation of the 

following “emission management” strategies, as appropriate and necessary: 

 Timely implementation of BART requirements in accordance with 40 CFR 

51.308(e); 

 A low sulfur fuel oil strategy in the inner zone states (New Jersey, New York, 

Delaware and Pennsylvania, or portions thereof) to reduce the sulfur content of: 

distillate oil to 0.05% sulfur by weight (500 ppm) by no later than 2012, of #4 

residual oil to 0.25% sulfur by weight by no later than 2012, of #6 residual oil to 

0.3 – 0.5% sulfur by weight by no later than 2012, and to further reduce the sulfur 

content of distillate oil to 15 ppm by 2016; 

 A low sulfur fuel oil strategy in the outer zone states (the remainder of the 

MANE-VU region) to reduce the sulfur content of distillate oil to 0.05% sulfur by 

weight (500 ppm) by no later than 2014, of #4 residual oil to 0.25 – 0.5% sulfur 

by weight by no later than 2018, and of #6 residual oil to no greater than 0.5 % 

sulfur by weight by no later than 2018, and to further reduce the sulfur content of 

distillate oil to 15 ppm by 2018, depending on supply availability; 

 A targeted EGU strategy for each of the top 100 electric generating unit (EGU) 

emission points or stacks, identified by MANE-VU as contributing to visibility 

impairment at each mandatory Class I area in the MANE-VU region. (The 
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combined list for all seven MANE-VU Class I Areas contains 167 distinct 

emission points. Consequently, this strategy is sometimes referred to as the 167-

stack strategy.) The targeted EGU strategy calls for a ninety-percent or greater 

reduction in sulfur dioxide (SO2) emissions from all identified units. If it is 

infeasible to achieve that level of reduction from specific units, equivalent 

alternative measures will be pursued in such state7

; and 

 Continued evaluation of other control measures, including energy efficiency, 

alternative clean fuels, and other measures to reduce SO2 and nitrogen oxide 

(NOx) emissions from all coal-burning facilities by 2018 and new source 

performance standards for wood combustion. These measures and other measures 

identified will be evaluated during the consultation process to determine if they 

are reasonable and cost-effective. 

3.6 Meeting the “Ask” – Maine

Maine, being a MANE-VU member state, adopted the “Statement of the MidAtlantic/Northeast Visibility Union (MANE-VU) Concerning a Course of Action Within 

MANE-VU Toward Assuring Reasonable Progress” at the MANE-VU Board Meeting on 

June 7, 2007. Maine intends to meet the terms of this agreement by controlling its BART 

eligible sources with timely control strategies as well as adopting the low sulfur limits for 

“outer zone” MANE-VU states and targeted EGU strategies in the near future. 

Maine has already obtained statutory authority to modify the sulfur in fuel limits in 

accordance with the MANE-VU Ask. The 124th Second Regular Session of the Maine 

Legislature (2010) adopted LD 1662, “An Act To Improve Maine's Air Quality and 

Reduce Regional Haze at Acadia National Park and Other Federally 

Designated Class I Areas,” which implements the MANE-VU low sulfur fuel strategy in 

Maine. This legislation establishes a statewide sulfur limit for distillate fuels of 50 ppm 

in 2016, and 15 ppm in 2018. For residual (#6) fuel oil, the statewide sulfur limit will be 

reduced to 0.5% in 2018. 

Maine has one oil-fired EGU (Wyman Station Unit #4) that is on the list of top 100 

contributing EGUs, and this unit will use lower-sulfur fuel oil to comply with BART 

requirements by 2013. At this point in time, Maine does not believe that SO2 emissions 

from this unit can be cost-effectively controlled at the 90-percent level of the Ask through 

add-on controls such as flue gas desulfurization because of the very low capacity factor8

. 

In lieu of add-on controls for this unit, Maine will be requiring the use of 0.5 percent lowsulfur fuel oil providing an 84 percent reduction from baseline SO2 emissions9

. For more 

details, refer to Section 12.0, Long Term Strategy. 

7 For additional information on the targeted EGU strategy, see section 10.4.3, and Attachment W. 

8 The capacity factor for this unit averaged 11.35% during the period 2000-2007. 

9 Baseline (uncontrolled) sulfur concentrations for #6 fuel are assumed to be 3,000 ppm, or 3.0%. 
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3.7 Meeting the “Ask” – States Outside of MANE-VU 

For consulting states outside the MANE-VU region, Maine agrees with the MANE-VU 

“Ask” requesting pursuit of the adoption and implementation of the following control 

strategies, as appropriate and necessary: 

 Timely implementation of BART requirements, as described for the MANEVU states; 

 A targeted EGU strategy, as described for the MANE-VU states, for the top 167 

EGU stacks contributing the most to visibility impairment at mandatory Class 1 

areas in the MANE-VU region, or an equivalent SO2 emission reduction within 

each state10; 

 Installation of reasonable control measures on non-EGU sources by 2018 to 

achieve an additional 28% reduction in non-EGU SO2 emissions beyond current 

on-the-books/on-the-way (OTB/OTW) measures, resulting in an emission 

reduction that is equivalent to that from MANE-V’s low-sulfur fuel oil strategy; 

and 

 Continued evaluation of other measures including measures to reduce SO2 and 

nitrogen oxide (NOx) emissions from all coal-burning facilities by 2018 and 

promulgation of new source performance standards for wood combustion. These 

measures and other measures identified will be evaluated during the consultation 

process to determine if they are reasonable. 

Maine looks for each consulting states to specifically address their responses to each 

element of the Maine/MANE-VU “Ask” in their Regional Haze SIPs. 

Maine is concerned that non-MANE-VU states may not be inclined to easily adopt our 

“Ask” due to associated costs, conflicts, and relative lack of benefit within their 

jurisdictions. During consultations, MANE-VU members thought that some non-MANEVU states were not going to pursue reductions beyond CAIR controls and BART. 

There are some positive exceptions, however. Many states of the MRPO are working 

with MANE-VU states to investigate the potential for widespread low sulfur fuel use and 

controls on industrial boilers. Unfortunately, the low sulfur oil strategy does not lend 

itself very well to wide-spread application within the VISTAS states because they do not 

have the same degree of oil use and inventory infrastructure. States of both regions claim 

10 While many of the 167 identified stacks will be controlled under the Clean Air Interstate Rule (CAIR), 

cap and trade programs such as CAIR cannot, as currently formulated, ensure that specific stacks or 

contributing states will adequately reduce their emission contribution (as discussed in the July 11, 2008 

U.S. Court of Appeals for the District of Columbia Circuit decision on CAIR). The MANE-VU strategy is 

designed to provide a guarantee that those units having the greatest impact on visibility in the MANE-VU 

region will be adequately controlled. It should also be noted that the MANE-VU strategy also includes 

stacks located in non-CAIR states (e.g., Wyman Station in Yarmouth, Maine). 
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32 

that a substantial portion of the top 167 contributing EGU stacks will be controlled. 

However, instead of taking concrete actions on uncontrolled or under-controlled 

facilities, many of these states appear to be satisfied with meeting CAIR requirements 

and not looking beyond CAIR for additional emission reductions. 

3.8 Meeting the “Ask” - EPA 

Although the CAIR rule will result in substantial reductions in sulfur dioxide emissions 

from power plants in the Eastern United States, power plants will remain a significant 

source of visibility impairing pollutants in Maine and other MANE-VU Class I states. 

Maine supports the “Statement of the Mid-Atlantic / Northeast Visibility Union (MANEVU) Concerning a Request for a Course of Action by the U.S. Environmental Protection 

Agency (EPA) Towards Assuring Reasonable Progress,” which requests that EPA work 

with the eastern RPOs to develop a proposal for tightening the CAIR program to achieve 

an additional 18% reduction in SO2 by no later than 2018. ” 

3.9 Technical Ramifications of Differing Approaches 

MANE-VU states intended to develop a modeling platform that was common in terms of 

meteorology and emissions with each of the other nearby RPOs. The RPOs worked hard 

to form a common set of emissions with similar developmental assumptions. Even with 

the best of intentions, it became difficult to keep up with each RPO’s updates and 

corrections. Each rendition of emissions inventory improved its quality, but because 

when even a single update was made to one RPO’s emissions, each of the other RPOs 

then needed to adopt the updates. With each rendition, the revised emissions had to be 

re-blended with the full set of emission files for all associated RPOs in the modeling 

domain. 

The RPOs also took differing perspectives on which version of the EGU dispatching 

model (IPM) to use. At the beginning of the process, Integrated Planning Model (IPM) 

version 2.1.9 was available, and EPA agreed to its use for emissions preparation. IPM 

version 3.0 subsequently became available and became EPA’s preferred version because 

of its updated fuel costs. MRPO adopted IPM v3.0 for its use, but VISTAS stayed with 

IPM v2.1.9. Rather than develop non-comparative datasets for its previous IPM analyses, 

MANE-VU opted to also remain with IPM v2.1.9. Therefore, for each of the three 

eastern RPOs, differing emissions assumptions eventually worked their way into the final 

set of modeling assumptions. 

MANE-VU’s final modeling takes into account on-the-books/on-the-way (OTB/OTW) 

emissions programs for 2018, and goes further by also including additional reasonable 

controls in its region, as developed through the Maine/MANE-VU “Ask”. It should be 

noted that other RPOs may not have included such measures in their final modeling and 

as a result may have been able to complete their analyses ahead of the MANE-VU 

member states. In these instances, there will be an inconsistency in that these states will 

not have adequately addressed our “Ask” in their SIPs. 
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3.10 Consultation Issues 

40 CFR Section 51.308(d)(1)(iv) describes another consultation requirement for Class I 

States only. If a contributing State does not agree with a Class I State on its reasonable 

progress goal, the Class I State must describe in its SIP submittal the actions taken to 

resolve the disagreement. 

While states without Class I areas are required to consult at the request of states with 

Class I areas, the Regional Haze Rule does not actually require that the states agree on a 

common course of action. Instead, if agreement cannot be reached, the disagreement 

needs to be described in each state’s SIP along with a description of the actions taken to 

resolve the disagreement. As expected, most states willingly consulted with Maine and 

took Maine’s regional haze “Ask” under serious consideration. In fact, all of the MANEVU states worked together to strategize on how to develop a common approach to 

meeting the “Ask”. All states involved in these discussions found that working together 

helped them to develop plans that would produce region-wide haze and health benefits. 

Lowering ambient PM2.5 concentrations helped all the MANE-VU states meet the 

NAAQS as well as having direct benefits to public health and welfare. 

Some states in the MRPO and VISTAS regions had interpretations of the requirements 

for BART and for establishing reasonable progress goals which differed from those in the 

MANE-VU states. Some states claimed that CAIR alone set the standard for 

reasonableness. By this rationale, any measure more expensive than CAIR (on a costper-ton basis) would not be reasonable. A uniform rate of progress was all that some 

states felt was required; and if that set of conditions could be met with CAIR, then no 

other measures need be considered. Maine is also concerned that some states may have 

performed modeling for the establishment of reasonable progress goals without including 

the effects of a rigorous BART determination for BART-eligible sources. It is apparent 

that the various regions of the country have differing interpretations of how the Regional 

Haze Rule should be applied. 

In a letter to MANE-VU dated April 25, 2008 (Attachment E), VISTAS indicates that 

most actions beyond CAIR by states within this region would not be reasonable. MANEVU takes a more rigorous position with respect to additional control measures – 

including the belief that controls on ICI boilers and use of low-sulfur fuels are reasonable 

measures and that it is not reasonable to assume reductions from EGUs for planning 

purposes unless they are explicitly incorporated into State Implementation Plan. More 

specifically, MANE-VU believes that a sector-wide average of 50 percent control on 

coal-fired boilers and 75 percent control on oil-fired boilers are reasonable targets that 

can be achieved cost-effectively. MANE-VU also believes that low sulfur fuels – even 

though they are less widely available in the Southeast U.S. than in the Northeast – still 

represent a reasonable control measure in light of the widespread requirement for use of 

such fuels throughout the MANE-VU region. The reasonableness of these additional 

controls is examined more fully in Section 11.0, Reasonable Progress Goals. 
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West Virginia expressed concern that while MANE-VU included a 28 percent reduction 

from the non-EGU sector, they (West Virginia) did not have any measures to meet this 

additional reduction requirement. West Virginia also indicated that the implementation 

of CAIR would provide significant emission reductions above and beyond those modeled 

by MANE-VU, and that these reductions should be creditable toward the 28 percent nonEGU sector “Ask”. Maine believes that these additional EGU emission reductions 

should be creditable towards meeting the non-EGU emission reductions measure 

included in the MANE-VU “Ask,” as long as they are not offset by additional increases 

in EGU emissions under the CAIR or other cap and trade program. 

During the consultation process, disagreements were worked through as best as possible 

and are summarized below: 

Issue: BART analyses and projected controls were not fully incorporated in the VISTAS 

emissions inventory provided to MANE-VU. VISTAS stated they would further review 

BART applicable controls. 

Resolution: In MANE-VU’s modeling to determine reasonable progress goals, 

MANE-VU made no adjustments to controls in the VISTAS region to reflect 

application of BART beyond the information that VISTAS provided . 

Issue: The low sulfur oil strategy adopted by MANE-VU elicited concerns from MRPO 

and VISTAS as being unreasonable because of the limited availability of low-sulfur fuel 

oil and the historically lower usage of this fuel within their regions. 

Resolution: MANE-VU agreed to modify the “Ask” to reflect a greater degree of 

flexibility and provide for alternative measures that would produce a comparable rate 

of emission reductions. Accordingly, the “Ask” for non-MANE-VU states was 

modified to provide for an overall 28 percent reduction in SO2 emissions, wherever 

they were found to be reasonable. In MANE-VU’s modeling to determine reasonable 

progress goals, SO2 emissions from non-EGU sources in non-MANE-VU 

contributing states were reduced by this same amount. 

Issue: MANE-VU received no response from other RPOs concerning non-EGU control 

measures that they considered reasonable. 

Resolution: As a default position, MANE-VU’s modeling included emission 

adjustments for those regions based on MANE-VU’s own analysis of which nonEGU control measures were reasonable (See Section 11, Reasonable Progress Goals). 

Issue: The targeted EGU strategy was thought by some non-MANE-VU states to be too 

restrictive and too difficult to achieve. MANE-VU recognized that a 100 percent 

compliance with this portion of the “Ask” was unlikely to occur because the CAIR 

trading market would probably dominate. However, MANE-VU had hoped that nonMANE-VU states would make a more concerted effort toward meeting this request. 

MANE-VU did receive a partial list of facilities that were expected to comply. 
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Resolution: For the top contributing EGU stacks located within the MANE-VU, 

MRPO, and VISTAAS regions, expected emission reductions resulting from the 

“Ask” were distributed among facilities on the basis of recommendations received 

during inter- and intra-regional consultations. To maintain the CAIR emissions 

budget as predicted by the modeling, excess emission reductions (also predicted by 

the modeling) were uniformly added back to EGUs in all three regions. 

While CAIR is the primary determinant of which EGUs among the top 167 stacks are to 

be fitted with emission controls, at the same time, MANE-VU recognized that these units 

are the primary sources affecting visibility in the MANE-VU states. For the initial 

planning, MANE-VU expects that, over time, these actual facilities will need to be 

controlled if significant improvements in visibility at affected Class I areas are to be 

realized. 

MANE-VU believes that the goals of the “Ask” will be attained only by means of 

binding obligations to EGU emission reductions beyond what CAIR was expected to 

provide. MANE-VU therefore maintains that additional federal action is needed to 

achieve the visibility benefits shown to be feasible through sensitivity modeling (See 

Attachment P, “MANE-VU Modeling for Reasonable Progress Goals: Model 

Performance Evaluation, Pollution apportionment and Control Measure Benefits,” Feb. 7, 

2008) and demonstrated to be available at reasonable cost (See Attachment S, Alpine 

Geophysics, LLC, “Documentation of 2018 Emissions from Electric Generating Units in 

the Eastern United States for MANE-VU’s Regional Haze Modeling,” Revised Final 

Draft, April 28, 2008). 

MANE-VU’s position on this issue is formally expressed in its “Statement of the 

Mid/Atlantic/Northeast Visibility Union (MANE-VU Concerning a Request for a Course 

of Action by the U.S. Environmental Protection Agency (EPA) toward Assuring 

Reasonable Progress” adopted June 20, 2007. This statement, more commonly known as 

MANE-VU’s National “Ask,” is included in Attachment D. Although other RPOs did 

not adopt all of the same philosophies or processes for their regional haze Sips, the 

consultation process maintains a central role in regional haze planning. Maine is pleased 

with the significant opportunities identified for ongoing consultation with other states 

concerning long-term strategies, not only for regional haze mitigation, but also for 

improved air quality in general. 

Maine and other MANE-VU states are committed to continuing consultation with states 

in the MRPO and VISTAS regions, through participation in the State Collaborative 

process, in which new regional control strategies are discussed to reduce future emissions 

of multiple pollutants of common regional concern. 
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4. State/Tribe and Federal Land Manager Coordination 

40 CFR Section 51.308(f) requires the State of Maine to submit its SIP revision by July 

31, 2018 and every ten years thereafter. 

40 CFR Section 51.308(i) requires coordination between States/Tribes and the Federal 

Land Managers (FLMs). Opportunities have been provided by MANE-VU for FLMs to 

review and comment on each of the technical documents developed by MANE-VU and 

included in this SIP. Maine has provided agency contacts to the FLMs as required. In 

the development of this Regional Haze Plan, the FLMs were consulted in accordance 

with the provisions of 40 CFR Section 51.308(i)(2). The State of Maine has provided the 

FLMs an opportunity for consultation, in person and at least 60 days prior to holding any 

public hearing on the SIP. This SIP was submitted to FLMs on May 25, 2010 for formal 

review and comment. 

In accordance with 40 CFR Section 51.308(i)(3) the State of Maine has received 

comments regarding the SIP from FLMs. Comments received from the Federal Land 

Managers on the Plan were addressed. The comments and responses are included in 

Attachment F of this plan. 

40 CFR Section 51.308(i)(4) requires procedures for continuing consultation between the 

State/Tribe and FLMs on the implementation of the visibility protection program. The 

State of Maine will consult with the Federal Land Manager(s) on the status of the 

following implementation items: 

1. Implementation of emissions strategies identified in the SIP as contributing to 

achieving improvement in the worst-day visibility 

2. Summary of major new source permits issued 

3. Status of State/Tribe actions to meet commitments for completing any future 

assessments or rulemakings on sources identified as likely contributors to 

visibility impairment, but not directly addressed in the most recent SIP revision 

4. Any changes to the monitoring strategy or monitoring stations status that may 

affect tracking of reasonable progress 

5. Work underway for preparing the 5-year review and / or 10-year revision 

6. Items for FLMs to consider or provide support for in preparation for any visibility 

protection SIP revisions (based on a 5-year review or the 10-year revision 

schedule under EPA’s RHR) 

7. Summary of topics discussion (meetings, emails, other records) covered in 

ongoing communications between the State/Tribe and FLMs regarding 

implementation of the visibility program. 

The consultation will be coordinated with the designated visibility protection program 

coordinators for the National Park Service, U. S. Fish and Wildlife Service and the U.S. 

Forest Service, and will consist of an annual report to the respective FLMs, along with an 

opportunity for an in-person or teleconference consultation. 
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40 CFR Section 51.308(g) requires the State of Maine to submit a report to the EPA 

every 5 years evaluating progress towards the reasonable progress goal for each Class I 

Federal area located within the State and in each Class I area located outside the State 

that may be affected by emissions from within the State. The first progress report is due 5 

years from submittal of the initial implementation plan and must be in the form of 

implementation plan revisions. 

In accordance with 40 CFR Section 51.308(h), at the time of the report submission, the 

State of Maine will also submit a determination of the adequacy of its existing Regional 

Haze SIP revision. 
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5. Assessment of Baseline and Natural Conditions (with Class I Areas) 

5.1 Requirements, Data, and Methodology 

Under the Clean Air Act, the Regional Haze SIPs must contain measures to make 

reasonable progress toward the goal of achieving natural visibility. Each state containing 

a Class I area must determine baseline and natural visibility conditions for their Class I 

area(s) in consultation with FLMs and states identified as containing sources whose 

emissions contribute to visibility impairment in Class I areas. Comparing baseline 

conditions to natural visibility conditions determines the uniform rate of progress that 

must be considered as states set reasonable progress goals for each Class I area. 

The Interagency Monitoring of Protected Visual Environments (IMPROVE) program 

was initiated in 1985 to establish current visibility conditions, track changes in visibility, 

and help determine the causes of visibility impairment in Class I Areas. IMPROVE 

stands for Interagency Monitoring and Protected Visual Environments. IMPROVE data 

was used to calculate baseline and natural conditions for MANE-VU Class I areas. 

Data from the following IMPROVE monitors (see the table below) is representative of 

Class I Areas in Maine11. As described in the Monitoring Section of this SIP, Maine 

accepts the IMPROVE designation of these sites as representative of Class I areas in 

Maine in accordance with 40 CFR Section 51.308(d)(2)(i). 

Table 5-1 

IMPROVE Information for Maine Class I Areas 

Class I Area 

IMPROVE 

Site 

Location 

(latitude 

and 

longitude) 

Acadia National Park ACAD1 44.38, -68.26 

Moosehorn Wilderness Area and 

Roosevelt campobello International 

Park MOOS1 45.13, -67.27 

Source: VIEWS (http://vista.circa.colostate.edu/views/), prepared on 7/06/06 

In September 2003, EPA issued guidance for the calculation of natural background and 

baseline visibility conditions. The guidance provided a default method and describes 

certain refinements that states may wish to evaluate in order to tailor these estimates to a 

 

11 The IMPROVE program has utilized representative monitoring since its inception, since man-made 

structures such as monitoring sites are restricted in national wilderness areas. Since regional haze sources 

and impacts are distributed over broad geographic regions, a representative monitoring site does not need to 

be located in close proximity to the Class I area being represented. For additional information see “Spatial 

and Seasonal Patterns and Temporal Variability of Haze and its Constituents in the United States: Report 

III, Chapter 1 (http://vista.cira.colostate.edu/improve/Publications/Reports/2000/2000.htm). 
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specific Class I area if it is poorly represented by the default method. At that time, 

NESCAUM calculated natural visibility for each of the MANE-VU Class I areas using 

the default method for the 20 percent best and worst days. NESCAUM also evaluated 

ways to refine the estimates. Potential refinements included: increasing the multiplier 

used to calculate impairment attributed to carbon, adjusting the formula used to calculate 

the 20 percent best and worst visibility days, and accounting for visibility impairment due 

to sea salt at coastal sites. However, MANE-VU found that these refinements did not 

significantly improve the accuracy of the estimates and MANE-VU states desired a 

consistent approach. Therefore, default estimates were used with the understanding that 

use of the default methodology would be reconsidered as better scientific understanding 

warranted. 

Once the technical analysis was complete, MANE-VU provided an opportunity to 

comment to federal agencies and stakeholders. The proposed approach was posted on the 

MANE-VU website on March 17, 2004 and a stakeholder briefing was held on the same 

day. Comments were received by Electric Power Research Institute, Midwest Ozone 

Group, the Appalachian Mountain Club, the National Parks Conservation Association, 

the National Park Service, and the U.S. Forest Service. 

Several commenters supported the proposal and other comments addressed four main 

topics: the equation used to calculate visibility, the statistical technique used to estimate 

the 20 percent best and worst visibility days, the inclusion of transboundary effects and 

fires, and the timing of when new information should be included. All comments were 

reviewed and summarized by MANE-VU, and member state’s Air Directors were briefed 

on comments, proposed response options, and implications. 

The MANE-VU position on natural background conditions was issued in June 2004, and 

stated that, “Refinements to other aspects of the default method (e.g., refinements to the 

assumed distribution or treatment of Rayleigh extinction, inclusion of sea salt, and 

improved assumptions about the chemical composition of the organic fraction) may be 

warranted prior to submission of SIPs depending on the degree to which scientific 

consensus is formed around a specific approach...” 

In 2006, the IMPROVE Steering Committee adopted an alternative reconstructed 

extinction equation to revise certain aspects of the default method. The aspects revised 

were scientifically well understood, and the Committee determined that revisions 

improved the performance of the equation at reproducing observed visibility at Class I 

sites. 

In 2006, NESCAUM conducted an assessment of the default and alternative approaches 

for calculation of baseline and natural background conditions at MANE-VU Class I 

areas, and the baseline and natural conditions reported herein were calculated using the 

alternative method approved by the IMPROVE Steering Committee in 2006 (See the 

MANE-VU document, “Baseline and Natural Background Visibility Conditions: 

Considerations and Proposed Approach to the Calculation of Baseline and Natural 

Background Visibility Conditions at MANE-VU Class I Areas”, (Attachment G). 
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40 

MANE-VU will continue to participate in further research efforts on this topic and will 

reconsider the calculation methodology as scientific understanding evolves. 

5.2 Maine Baseline Visibility 

The IMPROVE program has calculated the 20 percent worst baseline (2000-2004) and 20 

percent best baseline conditions for each IMPROVE monitoring site at MANE-VU Class 

I Areas. These values are posted on the Visibility Information Exchange Web System 

(VIEWS) operated by the Regional Planning Organizations (available online at 

http://vista.cira.colostate.edu/views/). The values for the Maine Class I areas can be seen 

below in Table 5-2. Table 5-2 lists the baseline visibility for the 20 percent worst 

visibility days as a five-year average for 2000-2004 using the alternative IMPROVE 

algorithm approved in 2006 by the IMPROVE Steering Committee. 

Table 5-2 

Baseline Visibility for the 20 Percent Worst Days and 20 Percent Best Days for Five 

Years (from 2000-2004) in Maine Class I Areas 

Class I Area (IMPROVE Monitor) Year 

20 Percent Worst 

Days Deciviews 

(dv) 

20 Percent Best 

Days Deciviews 

(dv) 

Acadia National Park 2000 21.64 8.89 

 2001 23.28 8.87 

 2002 23.91 8.77 

 2003 23.65 8.77 

 2004 21.98 8.56 

 Five Year Average 22.89 8.77 

 

Moosehorn Wilderness Area and Roosevelt 

Campobello International Park 2000 20.63 8.93 

 2001 22.13 9.3 

 2002 23.06 9.12 

 2003 22.5 9.48 

 2004 20.28 8.93 

 Five Year Average 21.72 9.15 

Source: VIEWS (http://vista.circa.colostate.edu/views), prepared on 10/16/07 

5.3 Natural Visibility 

A five year average (2000 to 2004) visibility in deciviews was calculated for each 

MANE-VU Class I area for the 20 percent best and 20 percent worst days in accordance 

with 40 CFR 51.308(d)(2) and detailed in the NESCAUM Baseline and Natural 

Background document found in Attachment G. The deciview visibility for the worst and 

best days are based on calculations and data included in Attachment G of this SIP. 
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41 

Natural visibility represents the visibility for each Class I area representative of the 

conditions before human activities affected air quality in the area. Certain natural 

phenomena can reduce visibility. The Clean Air Act goal is to remedy visibility 

impairment resulting from human activity. 

Table 5-3 displays the baseline visibility for the 20 percent worst and the 20 percent best 

visibility days based on the five-year average for 2000-2004, natural visibility for the 20 

percent worst and the 20 percent best visibility days, and the difference between baseline 

and natural visibility conditions for the Maine Class I areas. 

Table 5-3 

Summary of Baseline Visibility and Natural Conditions for the 20 Percent Worst 

and 20 Percent Best Visibility Days for Maine Class I Areas 

Class I Area 

2000-2004 

Baseline (dv) 

Natural 

Conditions (dv) 

Difference (dv) 

 

Worst 

20 % 

Best 

20 % 

Worst 

20 % 

Best 

20 % 

Worst 

20 % 

Best 

20 % 

Acadia National Park 22.89 8.77 12.43 4.66 10.46 4.11 

Moosehorn Wilderness Area 

and Roosevelt campobello 

International Park 21.72 9.15 12.01 5.01 9.71 4.14 

Source: VIEWS (http://vista.circa.colostate.edu/views/), prepared on 6/22/2007 
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42 

6. Monitoring Strategy 

In the mid-1980’s, the IMPROVE program (Interagency Monitoring of Protected 

Visual Environments) was established to measure visibility impairment in mandatory 

Class I areas throughout the United States. The monitoring sites are operated and 

maintained through a formal cooperative relationship between the U.S. EPA, National 

Park Service, U.S. Fish and Wildlife Service, Bureau of Land Management, and U.S. 

Forest Service. In 1991, several additional organizations joined the effort: State and 

Territorial Air Pollution Program Administrators and the Association of Local Air 

Pollution Control Officials (which now goes by The National Association of Clean Air 

Agencies), Western States Air Resources Council, Mid-Atlantic Regional Air 

Management Association, and Northeast States for Coordinated Air Use Management. 

Data collected at these sites are used by land managers, industry planners, scientists, 

public interest groups, and air quality regulators to understand and protect the visual air 

quality resource in Class I areas. Most importantly, the IMPROVE program scientifically 

documents for American citizens, the visual air quality of their wilderness areas and 

national parks. Program objectives include: 

 Establish current visibility and aerosol conditions in mandatory Class I areas. 

 Identify chemical species and emission sources responsible for existing 

anthropogenic visibility impairment. 

 Document long-term trends for assessing progress towards the national visibility 

goals. 

 Provide regional haze monitoring representing all visibility-protected federal Class I 

areas where practical, as required by EPA’s Regional Haze Rule. 

6.1 Federal Regional Haze Monitoring Requirements 

Section 51.308(d)(4) of EPA’s Regional Haze Rule requires a monitoring strategy for 

measuring, characterizing, and reporting regional haze visibility impairment that is 

representative of all mandatory Class I Areas within the State of Maine. The monitoring 

strategy relies upon participation in the Interagency Monitoring of Protected Visual 

Environments (IMPROVE) network. 

The State of Maine participates in IMPROVE network, and will evaluate the monitoring 

network periodically and make those changes needed to be able to assess whether 

reasonable progress goals are being achieved in each of Maine’s mandatory Class I 

Areas. Maine is committing to continued support of the IMPROVE network at Acadia 

National Park and Moosehorn National Wildlife Refuge. 

40 CFR 51.308(d)(4)(i) requires states to establish additional monitoring sites or 

equipment as needed to assess whether reasonable progress goals are being achieved 
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43 

toward visibility improvement at mandatory Class I areas. At this time, the current 

monitors are sufficient to make this assessment. Maine’s commitment to maintain the 

current level of monitoring, and to expand monitoring and/or analysis should such action 

become necessary, will remain contingent on federal funding assistance. 

40 CFR Section 51.308(d)(4)(ii) requires the inclusion of procedures by which 

monitoring data and other information are used in determining the contribution of 

emissions from within the State to regional haze visibility impairment at mandatory Class 

I Federal areas both within and outside the State. MANE-VU and the State of Maine 

accepts the contribution assessment analysis completed by NESCAUM entitled, 

“Contributions to Regional Haze in the Northeast and Mid-Atlantic States.” (See 

Attachment A). We agree that NESCAUM is providing quality technical information by 

using the IMPROVE program data and the VIEWS site. Information about the use of the 

default and alternative approaches to the calculation of baseline and natural background 

conditions can be found in Section 5 “Assessment of Baseline, Natural and Current 

Conditions” of this SIP. 

Maine commits to meet the requirements under 40 CFR Section 51.308(d)(4)(iv) to 

report to EPA visibility data for each of Maine’s Class I Areas annually. 

40 CFR Section 51.305 requires each state containing a mandatory Class I Federal area to 

include in its SIP a strategy for evaluating reasonably attributable visibility impairment 

(RAVI) in any such Class I Area by visual observation or other appropriate monitoring 

techniques. The plan must provide for the consideration of available visibility data and 

must provide a mechanism for its use. This requirement does not apply to the State of 

Maine because no specific sources have been identified as subject to RAVI requirements. 

40 CFR Section 51.308(d)(4)(v) requires a statewide inventory of emissions of pollutants 

that are reasonably anticipated to cause or contribute to visibility impairment in 

mandatory Class I Federal areas within the State of Maine. The Emissions Inventory 

Section (Section 8) of this SIP addresses this requirement. 

EPA’s Regional Haze Rule (40 CFR Section 51.308(d)(4)(vi)) requires the inclusion of 

other monitoring elements, including reporting, recordkeeping, and other measures, 

necessary to assess and report visibility. While the State of Maine feels that the current 

IMPROVE network provides sufficient data to adequately measure and report progress 

toward the goals set for MANE-VU Class I sites that we contribute to, Maine has also 

found additional monitoring information useful to assess visibility and fine particle 

pollution in the region in the past. Examples of these data include results from the 

MANE-VU Regional Aerosol Intensive Network (RAIN), which provides continuous, 

speciated information on rural aerosol characteristics and visibility parameters; the EPA 

Clean Air Status and Trends Network (CASTNET), which has provided complementary 

rural fine particle speciation data at non-class I sites; the EPA Speciation Trends Network 

(STN), which provides speciated, urban fine particle data to help develop a 

comprehensive picture of local and regional sources; state-operated rural and urban 

speciation sites using IMPROVE or STN methods; and the Supersites program, which 

has provided information through special studies that generally expands our 
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understanding of the processes that control fine particle formation and transport in the 

region. Maine will continue to utilize these and other data -- as they are available 

and fiscal realities allow -- to improve our understanding of visibility impairment and to 

document progress toward our reasonable progress goals under the Regional Haze Rule. 

6.2 Monitoring Information for MANE-VU Class I Areas 

6.2.1. Acadia National Park, Maine

The IMPROVE monitor for Acadia National Park (indicated as ACAD1) is located at 

Acadia National Park Headquarters in Maine at an elevation of 157 meters, a latitude of 

44.38 ̊ and a longitude of -68.26 ̊. The haze data for Acadia National Park is collected by 

an IMPROVE monitor (ACAD1) that is operated and maintained by the National Park 

Service. The State considers the ACAD1 site as adequate for assessing reasonable 

progress goals of Acadia National Park and no additional monitoring sites or equipment 

are necessary at this time. The State routinely participates in the IMPROVE monitoring 

program by sending regional representatives to the IMPROVE meetings. 

Figure 6-1 

Map of Acadia National Park 

Acadia National Park IMPROVE Site

Created by Tom Downs, MEDEP 4/17/07

IMPROVE MONITOR LOCATION

ACADIA NATIONAL PARK

LEGEND

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6.2.2. Moosehorn Wilderness Area, Maine

The IMPROVE monitor for the Moosehorn Wilderness Area (indicated as MOOS1) is 

located near McConvey Road, about one mile northeast of the National Wildlife Refuge 

Baring Unit Headquarters in Maine at an elevation of 78 meters, a latitude of 45.13 ̊ and 

a longitude of -67.27 ̊. This monitor also represents the Roosevelt Campobello 

International Park in New Brunswick, Canada. The haze data for Moosehorn Wilderness 

Area is collected by an IMPROVE monitor (MOOS1) that is operated and maintained by 

the Fish & Wildlife Service. The State considers the MOOS1 site as the only current 

IMPROVE monitoring site in Maine adequate for assessing reasonable progress goals of 

the Moosehorn Wilderness Area and no additional monitoring sites or equipment are 

necessary at this time. The State routinely participates in the IMPROVE monitoring 

program by sending regional representatives to the IMPROVE meetings. 

Figure 6-2 

Map of the Baring and Edmunds Divisions of the Moosehorn National Wildlife 

Refuge and the IMPROVE Monitor 

(source: The Refuge Manager at Moosehorn Wilderness Area) 

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6.2.3. Roosevelt Campobello International Park, New Brunswick, Canada 

The IMPROVE monitor for the Moosehorn Wilderness Area is also the monitor for 

Roosevelt Campobello International Park (indicated as MOOS1) (see section 6.2.2, 

above). The State considers the MOOS1 site as the only current IMPROVE monitoring 

site in Maine or Canada adequate for assessing reasonable progress goals of Roosevelt 

Campobello International Park. No additional monitoring sites or equipment are 

necessary. 

Figure 6-3 

Map of Roosevelt Campobello International Park 

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47 

 

 

7. Sources of Visibility Impairing Pollutants and Contribution 

Assessment 

7.1 Visibility Effects of Particulate Matter 

Visibility impairment in the eastern United States is primarily due to the presence of fine 

particles in the atmosphere which absorb and scatter light. Visibility impairing particlelight interactions are sensitive to the chemical composition of the particles involved, and 

also depend strongly on ambient relative humidity. Secondary particles, which form in 

the atmosphere through chemical reactions, are generally smaller than one micrometer 

(m) which is the size range that is most effective at scattering visible light12. 

The degree of visibility impairment is expressed in deciviews, a unit-less value. The 

calculation of visibility impairment utilizes two equations, one to calculate light 

extinction coefficient (Bext), and then its transformation into visibility impairment as 

expressed in deciviews (dv). The latest equation,13 approved by the Interagency 

Monitoring of Protected Visual Environments (IMPROVE) Steering Committee, to 

calculate light extinction coefficient is: 

The Extinction Equation 

Bext = 2.2 x fS (RH) x [Small Sulfate] + 4.8 x fL (RH) x [Large Sulfate] 

+ 2.4 x fS (RH) x [Small Nitrate] + 5.1 x fL (RH) x [Large Nitrate] 

+ 2.8 x [Small Organic Mass] + 6.1 x [Large Organic Mass] 

+ 10 x [Elemental Carbon] + 1 x [Fine Soil Mass] 

+ 1.7 x fSS (RH) x [Sea Salt Mass] + 0.6 x [Coarse Mass] 

+ Rayleigh Scattering (Site Specific) + 0.33 x [NO2 (ppb)] 

Where: 

Bext = The light extinction coefficient in inverse megameters [Mm-1] 

fs (RH) and fL (RH) = Humidity factor associated with small and large mode mass size 

distributions 

fss (RH) = Humidity factor associated with Sea Salt 

The on-site air monitoring of visibility causing pollutants by the IMPROVE monitoring 

network is discussed in more detail in Section 6 of this document. In the extinction 

equation, total sulfate, nitrate and organic carbon compound concentrations are each 

divided into two particle size fractions, representing small and large size particle 

components. Site-specific Rayleigh scattering is calculated by IMPROVE for the 

12 The particles that contribute most to visibility impairment are also of concern under the health-based 

National Ambient Air Quality Standard (NAAQS) for fine particulate matter, which is defined as all 

particles with an aerodynamic diameter less than 2.5 m. 

13 Review of the IMPROVE Equation for Estimating Ambient Light Extinction Coefficients - Final Report 

Jenny L. Hand and William C. Malm, March 2006 
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elevation of the site as well as annual average temperature of each IMPROVE monitoring 

site. 

Once light extinction is calculated, visibility levels (in deciviews (dv)) can be calculated. 

The deciview equation is as follows: 

The Deciview Equation 

Deciviews (dv) = 10 ln (bext/10) 

Where: 

 ln is the natural log function and Bext is calculated using the IMPROVE equation 

previously described. The calculated deciviews are unit-less values where the higher 

the value, the greater amount of visibility impairment exists. 

The extinction and deciview equations were used to calculate the baseline and projected 

visibility impairment at Acadia National Park, Moosehorn Wilderness Area and 

Roosevelt Campobello International Park, and to set the progress goals as established in 

this Document.

7.2 Pollutants Contributing to Visibility Impairment at Class I Areas 

The pollutants primarily responsible for fine particle formation, and contributing to 

regional haze, include SO2, NO2, VOCs, NH3, PM10, and PM2.5. The MANE-VU 

Contribution Assessment (Attachment A) develops a conceptual model for regional haze 

in the Northeast and Mid-Atlantic states that identifies sulfate as the single most 

important constituent of haze forming fine particle pollution, and the principal cause of 

visibility impairment across the Northeast region. Sulfate alone accounts for anywhere 

from one-half to two-thirds of total fine particle mass on the 20 percent haziest days at all 

MANE-VU Class I sites, and 40 percent or more of total fine particle mass on the 20 

percent clearest days. 

After sulfate, organic carbon (OC) consistently accounts for the next largest fraction of 

total fine particle mass, contributing from 20-30 percent of total fine particle mass on the 

haziest days. Relative contributions to overall fine particle mass from nitrate (NO3), 

elemental carbon, and fine crustal material (i.e., soil) are all smaller, generally under 10 

percent of the total, with relative ranking of the three species varying with location. 

Nitrate plays a noticeably more important role at urban sites compared to Northeastern 

and Mid-Atlantic Class 1 sites. 

Almost all particle sulfate originates from sulfur dioxide (SO2) oxidation14 and typically 

associates with ammonium (NH4) in the form of ammonium sulfate ((NH4(SO4)). 

14 Sulfate is produced from SO2 in the atmosphere under two major pathways. In the gas phase, SO2 is 

oxidized to sulfuric acid (H2SO4), ammonium bisulfate (NH4HSO4), or ammonium sulfate, depending on 

the availability of ammonia (NH4). In the presence of small wet particles (typically smaller than fog), an 

aqueous phase process can oxidize SO2 to sulfate extremely quickly (@ 10 percent per hour). 
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Approximately 95 percent of SO2 emissions are from anthropogenic sources (primarily 

fossil fuel combustion), while the majority of ammonium comes from agricultural 

activities. 

Sulfate is not only the dominant contributor to fine particle mass in the region, but also 

accounts for anywhere from 60 percent to almost 80 percent of the difference between 

fine particle concentrations on the clearest and haziest days at Northeastern and MidAtlantic Class I sites, including those in Maine. Some of the dominant components of 

total fine particle mass have an even larger effect when considering the differential 

visibility impacts of different particle species. Sulfate typically accounts for more than 

70 percent of estimated particle-induced light extinction at Northeastern and Mid-Atlantic 

sites. Organic carbon is the second most important contributor to particle-induced light 

extinction on days with the greatest visibility impairment, with nitrate being the third 

greatest contributor to regional haze at Class I sites in the MANE-VU region, including 

those in Maine. 

Figure 7-1 shows the dominance of sulfate in visibility extinction calculated from 2000-

2004 baseline data for seven Northeast Class I Areas. 

Figure 7-1 

Contributions to PM2.5 Extinction at Seven Class I Areas 

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50 

 

Given the dominant role of sulfate in the formation of regional haze in the Northeast and 

Mid-Atlantic Regions, MANE-VU concluded that an effective emissions management 

approach would rely heavily on broad-based regional SO2 control measures in the eastern 

United States. The focus on SO2 as MANE-VU’s first priority makes sense not only 

because of its dominant role in regional haze but also because its emission sources are 

well understood. Moreover, the control measures needed for SO2 emission reductions are 

readily available, cost-effective, and could be implemented quickly. On the basis of the 

scientific evidence, it is apparent that the bulk of haze-causing pollution can be 

eliminated by pursuing SO2 emission controls. 

Organic carbon was found to be the next largest contributor to haze after sulfate, 

however, in comparison with sulfate, the emission sources of organic carbon are diverse, 

variable, more diffuse, and less well understood. Organic carbon particulates can be 

emitted as a primary organic aerosol, or they can be formed as a secondary organic 

aerosol. Secondary organics are formed when volatile organic compound (VOC) 

emissions react with oxides of nitrogen in the presence of sunlight to form ozone, which 

acts as a catalyst for particulate formation. VOCs may also condense to from particulate 

organic carbon. For these reasons, MANE-VU considered organic carbon to be the 

subject of possible future control measures but not a specific target pollutant in the initial 

strategy to mitigate regional haze.15

7.3 Geographic Considerations and Haze Contribution Attribution 

As noted in the Contribution Assessment (Attachment A), high levels of particle 

pollution in the eastern United States often causes hazy conditions extending over 

thousands of square kilometers (km2). As a result, visibility is often impaired at even the 

most remote and pristine Class I areas. 

To better identify the sources of visibility impairing pollutants, the MANE-VU 

Contribution Assessment utilized a variety of modeling, air quality data analysis, and 

emissions inventory analysis techniques to identify source categories and states that 

contribute to visibility impairment in MANE-VU and nearby Class I areas. The 

analytical and assessment tools utilized for the Contribution Assessment include Eulerian 

(grid-based) source models, Lagrangian (air parcel-based) source dispersion models, and 

a variety of data analysis techniques including source apportionment models, back 

trajectory calculations, and the use of monitoring and inventory data. Table 7-2 below, 

summarizes the methodological approaches of these analytical tools. 

15 Although sulfur is the primary regional haze pollutant of concern for this SIP, Maine has taken measures 

to address organic carbon emissions, primarily from residential wood burning activities. These measures 

are discussed in Section 12 “Long-Term Strategy .”
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Table 7-2 

Summary of Technical Approaches for Attributing State Contributions to 

Observed Sulfate in MANE-VU Class I Areas 

Analytical Technique Approach 

Emissions/distance Empirical

Incremental probability Lagrangian trajectory technique

Cluster-weighted probability Lagrangian trajectory technique

Emissions × upwind probability Empirical/trajectory hybrid

Source apportionment approaches Receptor model/trajectory hybrid

REMSAD tagged species Eulerian source model

CALPUFF with MM5-based meteorology Lagrangian source dispersion model

CALPUFF with observation-based meteorology Lagrangian source dispersion model

7.3.1 Review of Technical Approaches

The MANE-VU Contribution Assessment and Appendices (Attachments A, A-1, A-2, A3 and A-4) provide a detailed description of the multiple technical approaches used to 

assess regional haze (sulfate) contributions to the MANE-VU region. Following is a 

summary of four of these techniques. 

I. Emissions/Distance 

The emissions/distance empirical technique calculates the ratio of annual emissions (Q) 

to source-receptor distance (d), with the ratio (Q/d) which is then multiplied by a factor to 

account for the frequency effect of prevailing winds.16 The geographic domain of the 

sources included in the Q/d study consisted of U.S. states in the CENRAP, MANE-VU, 

VISTAS, and MRPO regions. Canadian provinces in the lower eastern region were also 

included. The categories of SO2 emission sources included in this analysis were area 

sources (e.g., residential boilers and heaters), non-road mobile sources (e.g., tractors and 

construction vehicles), and point sources (e.g., industrial smokestacks and power 

 

16 Aggregated over long periods of time and large geographic areas, the total atmospheric sulfate 

contribution from a specific source, state, or region should be approximately proportionate to its SO2

emissions. For specific receptor locations, like a Class 1 visibility area, relative impacts decrease with 

increasing distance from the source. Impacts diminish over distance as pollutants are dispersed in the 

atmosphere and removed through deposition. For non-reactive primary pollutant emissions, the relationship 

between atmospheric concentrations and distance (d) can be approximated as a function of 1/d2

. For 

secondary pollutants like sulfate, reductions in ambient concentrations that occur as a result of dispersion 

and deposition mechanisms are partially offset by the formation of secondary aerosol such that an 

increasing fraction of the remaining downwind sulfur is converted to aerosol sulfate. In these cases, the 

effects of distance are better characterized by the function 1/d. During regional sulfate episodes when sulfur 

conversion rates are enhanced by the presence of gas and aqueous-phase oxidants, pollutant concentrations 

decline even less rapidly with distance as accelerated aerosol formation rates work to both generate more 

sulfate and reduce the remaining sulfur available for deposition (deposition rates are roughly an order of 

magnitude slower for sulfate than for SO2). 
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generation facilities). Results were calculated for seven receptors in the MANE-VU and 

VISTAS regions including: Acadia National Park, Brigantine Wilderness in the Forsythe 

Wildlife Preserve, Dolly Sods Wilderness, Lye Brook Wilderness, Moosehorn 

Wilderness, Presidential Range-Dry River Wilderness, and Shenandoah National Park. 

To calculate the impact that each state had on a given receptor, the area and nonroad 

SO2 emission sources were summed across the entire state, and the distance to the 

receptor site for those emission sources was calculated based on that state’s geographic 

center, adjusted for population density. In this way, the area and non-road emissions 

were treated as a single point source located at the population-weighted center of each 

state. These impacts were then added to the impact of the point sources that were 

calculated individually. The sum of area, non-road, and point source impacts for each 

state was used to compare the contributions relative to other states in the eastern U.S. and 

parts of Canada. 

The principal contributors to the MANE-VU receptors, according to this method, include 

the Midwestern states of Indiana and Ohio, as well as Pennsylvania and New York. This 

is due not only to the large emissions from these states, but also to the predominantly 

westerly winds that carry Midwest pollution eastward. Table 7-3 shows the relative 

contribution of eastern states and Canadian provinces on several receptor sites in the 

region. 

Table 7-3 

Annual average Sulfate Impact from Q/D (%)

From: Table 8.2 of Contributions to Regional Haze in the Northeast and Mid-Atlantic United States, NESCAUM, 2006

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II. Emissions Times Upwind Probability 

Another empirical approach utilized in the Contribution Assessment is the emissions 

times upwind probability technique, which multiplies the back-trajectory calculated 

residence time probability for a grid cell with the total emissions (over the same time 

period) for that grid cell17. This technique results in an emissions-weighted probability 

field that can be integrated within state boundaries to calculate the relative probabilities 

of each state contributing to pollution transport. Table 7-4 illustrates the average ranked 

contributions to several MANE-VU and VISTAS Class I areas. 

Table 7-4 

Annual Average Sulfate Impact from the Emissions x Upwind Probability 

Technique 

From: Table 8.5 of Contributions to Regional Haze in the Northeast and Mid-Atlantic United States, NESCAUM, 2006

 

53 

17 A back trajectory is the path that an air parcel is calculated to have taken prior to arriving at a given 

receptor. The back trajectories utilized in this analysis were 72 hours in length, and have calculated 

endpoints, or locations, that specify the air mass path at hourly intervals. The endpoints from all 

trajectories were mapped into a matrix of residence times spent in the individual grid cells over the five 

year study period, with the result providing the likelihood that air spent time in a particular grid cell. By 

then multiplying the “residence time” by the MANE-VU SO2 emission inventory for the grid cell, the 

contribution of each grid cell (and state) can be calculated.
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III. REMSAD Tagged Species Modeling 

Table 7-5 displays the results of an Eulerian source model (the REMSAD model) used to 

assess state-by-state and regional contributions to annual sulfate impacts in nine Class I 

areas. The Regional Modeling System for Aerosols and Deposition (REMSAD) is a 

three-dimensional Eulerian model designed to support a better understanding of the 

distributions, sources, and removal processes relevant to fine particles and other airborne 

pollutants. It calculates the concentrations of both inert and chemically reactive pollutants 

by simulating the physical and chemical processes in the atmosphere that affect pollutant 

concentrations. The basis for the model is an atmospheric diffusion equation representing 

a mass balance in which all of the relevant emissions, transport, diffusion, chemical 

reactions, and removal processes are expressed in mathematical terms. 

Table 7-5

Average Annual Sulfate Impact at Northeast Class I Areas as Modeled Using 

REMSAD 

From: Table 8.1 of Contributions to Regional Haze in the Northeast and Mid-Atlantic United States, NESCAUM, 2006. 

As in the empirical analytical techniques, the REMSAD model identifies the States of 

Ohio, New York, and Pennsylvania as the predominant contributors to visibility 

impairment at MANE-VU Class I areas, including those in Maine. Unlike the 

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55 

 

previously-described empirical approaches, the REMSAD model identifies Maine as the 

single greatest contributor to visibility impairment at Maine Class I areas. 18 

IV. CALPUFF 

A fourth approach to contribution assessment is the use of a dispersion model such as 

CALPUFF. CALPUFF is commonly used study the impacts of pollutant plumes or 

specific point source emissions on surrounding areas. While the geographic scale of these 

models has traditionally been limited to a few hundred kilometers because of a perceived 

lack of ability to accurately reproduce horizontal dispersion beyond these distances, 

recent advances in the CALPUFF system have resulted in improved performance over 

much greater distances. The Contribution Assessment provides specific information 

related to two CALPUFF platforms that have been developed for MANE-VU by the 

Vermont Department of Environmental Conservation (VT DEC) Air Pollution Control 

Branch and by the State of Maryland’s Department of the Environment (MDE) and 

Department of Natural Resources (MDNR). The two platforms, one using MM5 

meteorological inputs, and the other National Weather Service (NWS)-based 

meteorological data, were used to model the entire 2002 calendar year. These simulations 

have been configured to provide estimates for both individual source impacts and 

cumulative state impacts, and to allow for inter-platform comparisons.19 The following 

table (Table 7-6) illustrates the contribution of emissions from individual states to overall 

sulfate levels at Acadia National Park.20 Once again, Ohio, New York, Indiana and 

Pennsylvania are among the greatest contributors to sulfate levels at Maine Class I areas. 

Unlike the previous contribution assessment techniques, Massachusetts is identified as a 

major contributor to visibility impairment in Maine by the CALPUFF modeling. 

7.3.2 Summary of Analytical Techniques for Contribution Assessment 

By normalizing the results of the four different empirical and modeling techniques 

summarized above, MANE-VU was able to identify those states having the largest 

influence on sulfate levels at each Class I site. Figure 7-2, below, compares the 

normalized results using different techniques for ranking state contributions to sulfate 

levels at Acadia National Park. While there is some variation in the contribution 

estimates among the different assessment techniques employed, there is a general 

consistency of results from one method to another. 

18 It should be pointed out that the listed values for VISTAS, CenRAP, and Canada understate the actual 

percentage contributions from those regions because they count only emissions originating within the 

modeling domain (see Table 7-5). Actual contributions, especially in the case of CenRAP, would be 

considerably higher than stated. Differences between actual and stated values are aggregated into “Other” 

category. These findings highlight the importance of emissions from outside MANE-VU to visibility 

impairment inside the region. 

19 Overall, the CALPUFF modeling results to date demonstrate reasonably good 

comparability between the two platforms but they also suggest a consistent pattern of under prediction for 

one platform relative to the other. 

20 See Attachment A-4 for the ranked contribution of emissions from individual states to overall sulfate 

levels at Moosehorn NWR and other MANE-VU Class I areas. 
5/27/2010 

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Table 7-6 

Contribution to Sulfate Levels at Acadia National Park Using the CALPUFF Model 

From: Table 7-2a of Contributions to Regional Haze in the Northeast and Mid-Atlantic United States, NESCAUM, 2006. 

An alternative means of displaying the above results is in Table 7-7, which shows the 

individual state rankings produced by different assessment techniques for Acadia 

National Park, Maine. In the left-side column of Table 7-7, states are colored according 

to their average ranking across the different assessment methods. Those states that are 

ranked in the top five on average, across all techniques are colored red, while states 

ranked in the top six through ten are colored magenta, and so on for each group of five 

going down the left-side column. Through this color scheme, one can see how the states’ 

average ranking compares to their rankings under each individual assessment method 

given in the other columns of the table. The fact that all techniques tend to come to 

consistent conclusions about which states are top contributors provides confidence that 

the source regions with the most influence on sulfate levels at MANE-VU Class I sites 

can be correctly identified. Note that the CENRAP states and several other states along 

the border of the analysis domain represent only partial state contributions. 

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Figure 7-2 

Ranked Contribution to Sulfate Concentrations at Acadia National Park 

The ranking of emissions contributions to visibility impairment in the MANE-VU Class I 

Areas by methods such as these has direct relevance to the consultation process described 

previously in Section 3, Regional Planning and Consultation. Using results from the 

results from the Contribution Assessment, Maine utilized the following criteria to identify 

states and regions for the purposes of consultation on regional haze: 

1. Any state/region that contributed 0.1 g/m3 sulfate or greater on the 20 percent 

worst visibility days in the base year (2002), 

 2. Any state/region that contributed at least 2 percent of total sulfate observed on 

the 20 percent worst visibility days in 2002, and 

3. Any state/region among the top ten contributors on the 20 percent worst 

visibility days in 2002. 

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Table 7-7 

Individual State Rankings Produced by Different Assessment Techniques for 

Acadia National Park 

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59 

8. Emissions Inventory 

8.1 Sources of Visibility Impairing Pollutants in MANE-VU 

This section explores the origin and quantity of haze-forming pollutants emitted in the 

Eastern and the mid-Atlantic United States. 

Section 51.308(d)(4)(v) of EPA’s Regional Haze Rule requires a statewide emission 

inventory of pollutants that are reasonably anticipated to cause or contribute to visibility 

impairment in any mandatory Class I area. The pollutants inventoried by Maine that 

affect fine particle formation, and thus contribute to regional haze, are sulfur oxides 

(SOX), nitrogen oxides (NOX), volatile organic compounds (VOC), ammonia (NH3), and 

particles with an aerodynamic diameter less than or equal to 10 and 2.5 μm (i.e., primary 

PM10 and PM2.5). 

The emissions dataset illustrated below is the 2002 MANE-VU Version 3 regional haze 

emissions inventory. The emission inventories include carbon monoxide (CO), but it is 

not considered here as it does not contribute to regional haze. The MANE-VU regional 

haze emissions inventory version 3.0, released in April 2006, has superseded version 2.0 

for modeling purposes. This inventory update was developed through the Mid-Atlantic 

Regional Air Management Association (MARAMA) for the MANE-VU RPO. This 

section describes emission characteristics by pollutant and source type (e.g., point, area, 

and mobile). 

8.1.1 Sulfur Dioxide (SO2)

SO2 is the primary precursor pollutant for sulfate particles. Sulfate particles commonly 

account for more than 50 percent of particle-related light extinction at northeastern Class 

I areas on the clearest days and for as much as or more than 80 percent on the haziest 

days. Hence, SO2 emissions are an obvious target of opportunity for reducing regional 

haze in the eastern United States. Combustion of coal and, to a lesser extent, of certain 

petroleum products accounts for most anthropogenic SO2 emissions. In fact, in 1998 a 

single source category, coal-burning power plants, was responsible for two-thirds of total 

SO2 emissions nationwide (NESCAUM, 2001a). 

Figure 8-1 shows SO2 emissions trends in the MANE-VU states as extracted from the 

2002 MANE-VU inventory (EPA, 2005). Most states in the region showed declines in 

annual SO2 emissions through 2002 compared with those in previous inventories. This 

decline can be attributed in part to implementation of Phase 2 of the Acid Rain Program, 

which in 2000 further reduced allowable emissions below Phase I levels and extended 

emission limits to a greater number of power plants. 

The bar graph in Figure 8-2 shows the percent contribution from different source 

categories to overall, annual 2002 SO2 emissions in the MANE-VU states. The graph 

shows that point sources dominate SO2 emissions, which primarily consist of stationary 
5/27/2010 

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Figure 8-1 

State Level Sulfur Dioxide Emissions 

Figure 8-2 

2002 SO2 

(Bar graph: Percentage fraction of four source categories, 

Circle: Annual emissions amount in 106

 tons per year)

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

0.0

0.2

0.4

0.6

0.8

1.0

1.2

million t/y

AREA NONROAD ONROAD POINT Emission

combustion sources for generating electricity, industrial energy, and heat. Smaller 

stationary combustion sources called “area sources” (primarily commercial and 

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61 

residential heating, and smaller industrial facilities) are another important source category 

in the MANE-VU states. By contrast, on-road and non-road mobile sources make only a 

relatively small contribution to overall SO2 emissions in the region (NESCAUM, 2001a). 

8.1.2 Volatile Organic Compounds (VOC)

Existing emission inventories generally refer to “volatile organic compounds” (VOCs) 

for hydrocarbons whose volatility in the atmosphere makes them particularly important 

from the standpoint of ozone formation. From a regional haze perspective, there is less 

concern with the volatile organic gases emitted directly to the atmosphere and more with 

the secondary organic aerosol (SOA) that the VOCs form after condensation and 

oxidation processes. Thus the VOC inventory category is of interest primarily from the 

organic carbon perspective of PM2.5. 

After sulfate, organic carbon generally accounts for the next largest share of fine particle 

mass and particle-related light extinction at northeastern Class I sites. The term organic 

carbon encompasses a large number and variety of chemical compounds that may come 

directly from emission sources as a part of primary PM or may form in the atmosphere as 

secondary pollutants. The organic carbon present at Class I sites includes a mix of 

species, including pollutants originating from anthropogenic (i.e., manmade) sources as 

well as biogenic hydrocarbons emitted by vegetation. Recent efforts to reduce manmade 

organic carbon emissions have been undertaken primarily to address summertime ozone 

formation in urban centers. Future efforts to further reduce organic carbon emissions may 

be driven by programs that address fine particles and visibility. 

Understanding the transport dynamics and source regions for organic carbon in 

northeastern Class I areas is likely to be more complex than for sulfate. This is partly 

because of the large number and variety of OC species, the fact that their transport 

characteristics vary widely, and the fact that a given species may undergo numerous 

complex chemical reactions in the atmosphere. Thus, the organic carbon contribution to 

visibility impairment at most Class I sites in the East is likely to include manmade 

pollution transported from a distance, manmade pollution from nearby sources, and 

biogenic emissions, especially terpenes from coniferous forests. 

Organic carbon emissions in the form of smoke from both natural (wildfire) and 

anthropogenic (prescribed and agricultural burning activities) have been shown to have a 

significant impact on visibility in Class I areas. In the western United States, organic 

carbon is responsible for a significant portion of visibility impacts at Class I areas, with 

wildfire and prescribed burning the principal emissions sources. In the eastern United 

States, organic carbon emissions play a lesser, but still important role in visibility 

degradation, with fire (both wildfire and anthropogenic) responsible for a smaller 

proportion of organic carbon emissions. 

The National Park Service investigated the impact of fire on regional air quality using 

several modeling and air quality analysis techniques21. One of the more interesting 

 

21 “Fire Effects on Regional Air Quality Including Visibility,” Draft Report, National Park Service, Air 

Resources Division, August 1, 2006. 
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62 

 

approaches analyzed the ratio of organic carbon to black (or elemental) carbon at 

IMPROVE monitor sites. The ratio of organic to elemental carbon (OC/EC) can be used 

to identify the likely source of organic carbon emissions, since this ratio displays 

significant variability, depending on the source of combustion. For example, internal 

combustion engines, which burn relatively efficiently, typically have a ratio of about 3, 

while less efficient combustion, which is characteristic of open fires, result in OC/EC 

ratios on the order of 10 or more. Using this approach, researchers estimated that fire 

was responsible for approximately 55% of all organic carbon monitored in the eastern 

United States.22 An alternative apportionment method utilizing a fire occurrence 

database and back trajectories was also utilized to estimate fire impacts on observed 

organic carbon measurements. This approach estimated that approximately 20% of 

organic carbon observed at eastern United States IMPRIOVE sites was due to wildland 

fires, but likely is an underestimation of the impact of fire on visibility, since the fire 

activity datasets and back trajectory databases are incomplete. 

Although organic carbon is responsible for approximately 13 percent of the baseline 

worst visibility (throughout the MANE-VU region), sulfates account for approximately 

75 percent of baseline visibility degradation.23 Conversely, for natural background 

visibility conditions, organic carbon is estimated to be responsible for approximately 50 

percent of visibility degradation, while sulfates are responsible for only about 20 percent 

of the visibility degradation on the worst visibility days. This result arises from the fact 

that organic carbon concentrations under worst day baseline conditions differ relatively 

little from estimated worst day concentrations under natural background conditions. 

Sulfate concentrations, however, are approximately 90 percent higher under worst day 

baseline conditions. With sulfates being responsible for the preponderance of visibility 

degradation, and many organic carbon emissions being biogenic in nature (as confirmed 

by the minimal difference between baseline and natural background estimated 

concentrations), it makes sense to target sulfate levels for the first (and perhaps 

subsequent rounds) of regional haze controls. As noted above, organic carbon could be 

the subject of future control measures to mitigate regional haze, but is not the focus of 

initial planning efforts. 

As shown in Figure 8-3, the VOC inventory is dominated by mobile and area sources. 

On-road mobile sources of VOCs include exhaust emissions from gasoline passenger 

vehicles and diesel-powered heavy-duty vehicles as well as evaporative emissions from 

transportation fuels. VOC emissions may also originate from a variety of area sources 

(including solvents, architectural coatings, and dry cleaners) as well as from some point 

sources (e.g., industrial facilities and petroleum refineries). 

22 This technique tends to overestimate the OC/EC ratio due to the presence of secondary organic aerosols, 

that are not associated with elemental carbon. 

23 Nitrate and elemental carbon at 8% and 4%, respectively, account for most of the rest of the visibility 

degradation on the 20 percent worst days. 
5/27/2010 

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Figure 8-3 

2002 VOC 

(Bar graph: Percentage fraction of four source categories, 

Circle: Annual emissions in million tons per year) 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

1.6

AREA NONROAD ONROAD POINT Emission

Biogenic VOCs may play an important role within the rural settings typical of Class I 

sites. The oxidation of hydrocarbon molecules containing seven or more carbon atoms is 

generally the most significant pathway for the formation of light-scattering organic 

aerosol particles (Odum et al., 1997). Smaller reactive hydrocarbons that may contribute 

significantly to urban smog (ozone) are less likely to play a role in organic aerosol 

formation, though it was noted that high ozone levels can have an indirect effect on 

visibility by promoting the oxidation of other available hydrocarbons, including biogenic 

emissions (NESCAUM, January 2001). In short, further work is needed to characterize 

the organic carbon contribution to regional haze in the Northeast and Mid-Atlantic states 

and to develop emissions inventories that will be of greater value for visibility planning 

purposes. 

8.1.3 Oxides of Nitrogen (NOX)

NOX emissions contribute to visibility impairment in the eastern U.S. by forming lightscattering nitrate particles. Nitrate generally accounts for a substantially smaller fraction 

of fine particle mass and related light extinction than sulfate and organic carbon at 

northeastern Class I sites. Notably, nitrate may play a more important role at urban sites 

and in the wintertime. In addition, NOX may have an indirect effect on summertime 

visibility by virtue of its role in the formation of ozone, which in turn promotes the 

formation of secondary organic aerosols (NESCAUM 2001a). 

Since 1980, nationwide emissions of NOX from all sources have shown little change. To 

a large extent, increases from the industrial and power plant combustion sectors have 

been offset by emission reductions from mobile source controls implemented during the 

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same time period. Figure 8-4 shows NOX emissions in the MANE-VU region at the state 

level. In the several years just prior to 2002, most MANE-VU states experienced 

declining NOx emissions. 

Figure 8-4 

State Level Nitrogen Oxides Emissions 

Power plants and mobile sources generally dominate state and national NOx emissions 

inventories. Nationally, power plants account for more than one-quarter of all NOx

emissions, amounting to over six million tons. The electric sector plays an even larger 

role, however, in parts of the industrial Midwest where high NOx emissions have a 

particularly significant power plant contribution. By contrast, mobile sources dominate 

the NOx inventories for more urbanized Mid-Atlantic and New England states to a far 

greater extent, as shown in Figure 8-5. In these states, on-road mobile sources - a 

category that mainly includes highway vehicles - represent the most significant NOx

source category. Emissions from non-road (i.e., off-highway) mobile sources, primarily 

diesel-fired engines, also represent a substantial fraction of the inventory. While there are 

fewer uncertainties associated with available NOx estimates than in the case of other key 

haze-related pollutants - including primary fine particle and ammonia emissions - further 

efforts could improve current inventories in a number of areas (NESCAUM, 2001a). 

In particular, better information on the contribution of area and non-highway mobile 

sources may be of most interest in the context of regional haze planning. First, available 

emission estimation methodologies are weaker for these types of sources than for the 

large stationary combustion sources. Moreover, because SO2 and NOX emissions must 

mix with ammonia to participate in secondary particle formation, emissions that occur 

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over large areas at the surface may be more efficient in secondary fine particulate 

formation than concentrated emissions from isolated tall stacks (Duyzer, 1994). 

Figure 8-5 

NOX 

(Bar graph: Percentage fraction of four source categories, Circle: Annual emissions amount in 106

tons per year) 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

0.0

0.3

0.6

0.9

AREA NONROAD ONROAD POINT Emission

8.1.4 Primary Particle Matter (PM10 and PM2.5)

Directly-emitted or “primary” particles (as distinct from secondary particles that form in 

the atmosphere through chemical reactions involving precursor pollutants like SO2 and 

NOX) can also contribute to regional haze. For regulatory purposes, a distinction is made 

between particles with an aerodynamic diameter less than or equal to 10 micrometers and 

smaller particles with an aerodynamic diameter less than or equal to 2.5 micrometers 

(i.e., primary PM10 and PM2.5, respectively). 

Figure 8-6 and Figure 8-7 show PM10 and PM2.5 emissions, respectively, for the MANEVU states as reported for the 2002 base year. Most states showed a steady decline in 

annual PM10 emissions over this time period. By contrast, emission trends for primary 

PM2.5 are more variable. 

Crustal sources are significant contributors of primary PM emissions. This category 

includes fugitive dust emissions from construction activities, paved and unpaved roads, 

and agricultural tilling. Typically, monitors estimate PM10 emissions from these types of 

sources by measuring the horizontal flux of particulate mass at a fixed downwind 

sampling location within perhaps 10 meters of a road or field. Comparisons between 

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estimated emission rates for fine particles using these types of measurement techniques 

and observed concentrations of crustal matter in the ambient air at downwind receptor 

sites suggest that physical or chemical processes remove a significant fraction of crustal 

Figure 8-6 

State Level Primary PM10 Emissions 

Figure 8-7 

State Level Primary PM2.5 Emissions* 

 

* 1996 and 1999 Maine PM2.5 data augmented. 

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67 

material relatively quickly. As a result, it rarely entrains into layers of the atmosphere 

where it can transport to downwind receptor locations. Because of this discrepancy 

between estimated emissions and observed ambient concentrations, modelers typically 

reduce estimates of total PM2.5 emissions from all crustal sources by applying a factor of 

0.15 to 0.25 to the total PM2.5 emissions before including it in modeling analyses. 

From a regional haze perspective, crustal material generally does not play a major role. 

On the 20 percent best-visibility days during the baseline period (2000-2004), it 

accounted for six to eleven percent of particle-related light extinction at MANE-VU 

Class 1 sites. On the 20 percent worst-visibility days, however, crustal material generally 

plays a much smaller role relative to other haze-forming pollutants, ranging from two to 

three percent. Moreover, the crustal fraction includes material of natural origin (such as 

soil or sea salt) that is not targeted under the Haze Rule. Of course, the crustal fraction 

can be influenced by certain human activities, such as construction, agricultural practices, 

and road maintenance (including wintertime salting). Thus, to the extent that these types 

of activities are found to affect visibility at northeastern Class I sites, control measures 

targeted at crustal material may prove beneficial and are within the purview of EPA and 

state agencies. 

Experience from the western United States, where the crustal component has generally 

played a more significant role in driving overall particulate levels, may be helpful to the 

extent that it is relevant in the eastern context. In addition, a few areas in the Northeast, 

such as New Haven, Connecticut and Presque Isle, Maine, have some experience with the 

control of dust and road-salt as a result of regulatory obligations stemming from their past 

non-attainment status with respect to the NAAQS for PM10. 

Current emissions inventories for the entire MANE-VU area indicate residential wood 

combustion represents 25 percent of primary fine particulate emissions in the region. This 

finding implies that rural sources can play an important role in addition to the 

contribution from the region’s many highly populated urban areas. An important 

consideration in this regard is that residential wood combustion occurs primarily in the 

winter months, while managed or prescribed burning activities occur largely in other 

seasons. The latter category includes agricultural field-burning activities, prescribed 

burning of forested areas and other burning activities such as construction waste burning. 

Particulate emissions from many of these sources can be managed by limiting allowed 

burning activities to times when favorable meteorological conditions can efficiently 

disperse the emissions. 

Although the data are currently limited, Maine and the other MANE-VU states are 

concerned about the growing use of residential woodstoves and outdoor wood boilers by 

homeowners seeking alternatives to petroleum-based fuels for home heating. Over the 

next several years, Maine will continue to evaluate monitored particulate mater levels in 

the state and in particular, assess the smoke component of the monitored particulate 

matter to determine if there is any trend in smoke levels in Maine. If smoke levels 

increase significantly, that might be cause for evaluating whether additional control 

measures for this source category may be necessary. 
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Figure 8-8, taken from Appendix B of the MANE-VU Contribution Assessment 

(Attachment A), represents the results of source apportionment and trajectory analyses on 

wood smoke in the region extending form the Gulf States to the Northeast. The greenhighlighted portion of the map depicts the wood smoke source region in the northeast 

states. The stars on the map represent air monitoring sites (including those at several 

Class I areas) whose data sets were determined to be useful to the modeling analysis. 

Figure 8-8 

Wood Smoke Source Regional Aggregation 

MANE-VU’s “Technical Support Document on Agricultural and Forestry Smoke 

Management in the MANE-VU Region, September 1, 2006 (Attachment Y), concluded 

that fire from land management activities was not a major contributor top regional haze in 

the MANE-VU Class I areas, and that the majority of emissions from fires were from 

residential wood combustion. 

Figures 8-9 and Figure 8-10 show that area and mobile sources dominate primary PM 

emissions. (The NEI inventory categorizes residential wood combustion and some other 

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combustion sources as area sources.) The relative contribution of point sources is larger 

in the primary PM2.5 inventory than in the primary PM10 inventory since the crustal 

component (which consists mainly of larger or “coarse-mode” particles) contributes 

mostly to overall PM10 levels. At the same time, pollution control equipment commonly 

installed at large point sources is usually more efficient at capturing coarse-mode 

particles.Figure 8-9 

Primary PM10 

(Bar graph: Percentage fraction of four source categories, Circle: Annual emissions amount in 106 

tons per year) 

0%

20%

40%

60%

80%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

0.0

0.1

0.2

0.3

0.4

0.5

AREA NONROAD ONROAD POINT Emission

Figure 8-10 

Primary PM2.5 

(Bar graph: Percentage fraction of four source categories, Circle: Annual emissions amount in 106 

tons per year) 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

0.00

0.05

0.10

0.15

0.20

AREA NONROAD ONROAD POINT Emission

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8.1.5 Ammonia Emissions (NH3)

Knowledge of ammonia emission sources will be necessary in developing effective 

regional haze reduction strategies because of the importance of ammonium sulfate and 

ammonium nitrate in determining overall fine particle mass and light scattering. 

According to 1998 estimates, livestock agriculture and fertilizer use accounted for 

approximately 86 percent of all ammonia emissions to the atmosphere (EPA, 2000b). 

However, improved ammonia inventory data are needed as inputs to the photochemical 

models used to simulate fine particle formation and transport in the eastern United States. 

States were not required to include ammonia in their emissions data collection efforts 

until fairly recently (See Consolidated Emissions reporting rule, 67 CFR 39602, June 10, 

2002). Therefore, emissions data for ammonia do not exist at the same level of detail or 

reliability as exist for other pollutants. 

Ammonium ion (formed from ammonia emissions to the atmosphere) is an important 

constituent of airborne particulate matter, typically accounting for 10–20 percent of total 

fine particle mass. Reductions in ammonium ion concentrations can be extremely 

beneficial because a more-than-proportional reduction in fine particle mass can result. 

Ansari and Pandis (1998) showed that a one g/m3

 reduction in ammonium ion could 

result in up to a four g/m3 reduction in fine particulate matter. Decision makers, 

however, must weigh the benefits of ammonia reduction against the significant role it 

plays in neutralizing acidic aerosol.24

To address the need for improved ammonia inventories, MARAMA, NESCAUM and 

EPA funded researchers at Carnegie Mellon University (CMU) in Pittsburgh to develop a 

regional ammonia inventory (Davidson et al., 1999). This study focused on three issues 

with respect to current emissions estimates: (1) a wide range of ammonia emission factor 

values, (2) inadequate temporal and spatial resolution of ammonia emissions estimates, 

and (3) a lack of standardized ammonia source categories. 

The CMU project established an inventory framework with source categories, emissions 

factors, and activity data that are readily accessible to the user. With this framework, 

users can obtain data in a variety of formats25 and can make updates easily, allowing 

additional ammonia sources to be added or emissions factors to be replaced as better 

information becomes available (Strader et al., 2000; NESCAUM, 2001b). 

Figure 8-11 shows that estimated ammonia emissions for the MANE-VU states in 2002. 

Area and on-road mobile sources dominate according to Figure 8-12. Specifically, 

emissions from agricultural sources and livestock production account for the largest share 

of estimated ammonia emissions in the MANE-VU region, except in the District of 

 

24 SO2 reacts in the atmosphere to form sulfuric acid (H2SO4). Ammonia can partially or fully neutralize this 

strong acid to form ammonium bisulfate or ammonium sulfate. If planners focus future control strategies on 

ammonia and do not achieve corresponding SO2 reductions, fine particles formed in the atmosphere will be 

substantially more acidic than those presently observed. 

25 For example, the user will have the flexibility to choose the temporal resolution of the output emissions 

data or to spatially attribute emissions based on land-use data.
5/27/2010 

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Figure 8-11 

State Level Ammonia Emissions 

Figure 8-12 

State Ammonia Emissions by Source Category 

(Bar graph: Percentage fraction of four source categories) 

(Circle: Annual emissions amount in 106 tons per year) 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

0.00

0.06

0.12

AREA NONROAD ONROAD POINT Emission

Columbia. The two remaining sources with a significant emissions contribution are 

wastewater treatment systems and gasoline exhaust from highway vehicles. 

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8.2 Baseline and Future Year Emission Inventories for Modeling 

40 CFR Section 51.308(d) (3) (iii) requires the State of Maine to identify the baseline 

emission inventory on which strategies are based. The baseline inventory is intended to 

be used to assess progress in making emission reductions. Based on EPA guidance 

entitled, “2002 Base Year Emission Inventory SIP Planning: 8-hour Ozone, PM 2.5, and 

Regional Haze Programs” which identifies 2002 as the anticipated baseline emission 

inventory year for regional haze, all of the MANE-VU states are using 2002 as the 

baseline year for regional haze inventories 

With contractor assistance, MARAMA developed a 2002 baseline modeling inventory 

using the inventories that Maine and other states submitted to EPA to meet their SIP 

obligations and the requirements of the Consolidated Emissions Reporting Rule (CERR). 

To create the 2002 baseline inventory for modeling, MARAMA and its contractor 

quality-assured and augmented states’ inventories and generated the necessary input files 

for the emissions processing model. 

Future-year inventories for 2009, 2012, and 2018 were projected from the 2002 base year. 

These future-year emissions inventories include emissions growth due to projected 

increases in economic activity as well as emissions reductions expected from the 

implementation of control measures. While the 2009 and 2012 emissions projections were 

originally developed in support of participating state’s ozone attainment demonstrations, the 

inventory for 2018 (the year targeted by the Regional Haze Rule) was developed for the 

specific purposes of regional haze SIP planning. Therefore, although the 2009 and 2012 

projected inventories are mentioned in subsequent sections, only the 2002 baseline inventory 

and 2018 projected inventory are described below in Section 7.5, Summary of Emissions 

Inventories. 

Accurate baseline and future-year emissions inventories are crucial to the analyses 

required for the regional haze SIP process. These emissions inventories were used to 

drive the air quality modeling simulations undertaken to assess the visibility 

improvements that would result from possible control measures. Air quality modeling 

was also used to perform a pollution apportionment, which evaluates the contribution to 

visibility impairment by geographic region and emission source sector. 

To be compatible with the air quality modeling simulations, the baseline and future-year 

emissions inventories were processed with the Sparse Matrix Operator Kernel Emissions 

(SMOKE) emissions pre-processor for subsequent input into the CMAQ and REMSAD 

air quality models. Further description of the base and future-year emissions inventories 

is provided below. 

8.2.1 Baseline Inventory

The starting point for the 2002 baseline emissions inventory was the 2002 inventory 

submittals that were made to EPA by state and local agencies as part of the Consolidated 

Emissions Reporting Rule (CERR). With contractor assistance (E.H. Pechan & 
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Associates), MANE-VU then coordinated and quality-assured the 2002 inventory data, 

and prepared it for input into the SMOKE emissions model. The 2002 emissions from 

non-MANE-VU areas within the modeling domain were obtained from other Regional 

Planning Organizations for their corresponding areas. These Regional Planning 

Organizations included the Visibility Improvement State and Tribal Association of the 

Southeast (VISTAS), the Midwest Regional Planning Organization (MRPO), and the 

Central Regional Air Planning Association (CENRAP). 

The 2002 baseline inventory went through several iterations. Work on Version 1 of the 

2002 MANE-VU inventory began in April 2004, and the final inventory and SMOKE 

input files were completed during January 2005. Work on Version 2 (covering the period 

of April through September 2005) involved incorporating revisions requested by some 

MANE-VU state/local agencies on the point, area, and on-road categories. Work on 

Version 3 (covering the period from December 2005 through April 2006) included 

additional revisions to the point, area, and on-road categories as requested by some states. 

Thus, the Version 3 inventory for point, area, and on-road sources was built upon 

Versions 1 and 2. This work also included development of the biogenic inventory. In 

Version 3, the non-road inventory was completely redone because of changes that EPA 

made to the NONROAD2005 non-road mobile emissions model. 

Version 3 of the MANE-VU 2002 baseline emissions inventory was used in the regional 

air quality modeling simulations, including performance testing of the air quality models 

used in the development of this SIP. Further description of the data sources, methods, 

and results for this version of the 2002 baseline inventory is presented in E.H. Pechan & 

Associates, Inc. “Technical Support Document for 2002 MANE-VU SIP Modeling 

Inventories, Version 3, November 20, 2006” (Attachment H). Emissions inventory data 

files are available on the MARAMA website at: 

http://www.marama.org/visibility/EI_Projects/index.html. 

8.2.2 Future Year Emission Control Inventories 

Future-year emissions inventories are provided in MACTEC’s technical support 

document “Development of Emissions Projections for 2009, 2012, and 2018 for 

NonEGU Point, Area, and Nonroad Sources in the MANE-VU Region,” Final Report, 

February 28, 2007, (Attachment I). This document describes the data sources, methods, 

and modeling results for three future years, five emission source sectors, two emission 

control scenarios, seven pollutants, and eleven states plus the District of Columbia. The 

following summarizes the basic framework of the future-year inventories that were 

developed: 

 Projection years: 2009, 2012, and 2018; 

 Emission source sectors: point-source electric generating units (EGUs), pointsource non-electric generating units (non-EGUs), area sources, non-road mobile 

sources, and on-road mobile sources. 

 Emission control scenarios: 

o A combined on-the-books/on-the-way (OTB/OTW) control strategy 
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accounting for emission control regulations already in place as of June 15, 

2005, as well as some emission control regulations that are not yet 

finalized but are expected to achieve additional emission reductions by 

2009. 

o A beyond-on-the-way (BOTW) scenario to account for controls from 

potential new regulations that may be necessary to meet attainment and 

other regional air quality goals, mainly for ozone. 

o An updated scenario (referred to as the “final modeling inventory”) to 

account for additional potentially reasonable control measures. For the 

MANE-VU region, these include: SO2 reductions at a set of 167 EGUs 

which were identified as contributing to visibility impairment at northeast 

Class I areas; implementation of a low-sulfur fuel strategy for non-EGU 

sources; and implementation of a BART strategy for BART-eligible 

sources not controlled under other programs. The final modeling 

inventory was used to develop the reasonable progress goals in this SIP. 

o Pollutants: ammonia, carbon monoxide (CO), oxides of nitrogen (NOx), 

sulfur dioxide (SO2), volatile organic compounds (VOCs), fine particulate 

matter (PM2.5, sum of filterable and condensable components), and coarse 

particulate matter (PM10, sum of filterable and condensable components). 

 States: The states are those that comprise the MANE-VU region. In addition to 

the District of Columbia, the 11 MANE-VU states are Connecticut, Delaware, 

Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, 

Pennsylvania, Rhode Island, and Vermont. 

8.3 Emission Processor Selection and Configuration 

The Sparse Matrix Operator Kernel Emissions (SMOKE) model (Version 2.1) was used 

by the New York State Department of Environmental Conservation (NYSDEC) to format 

the emissions inventories for use with the air quality models that are discussed in Chapter 

9. SMOKE is principally an emissions processing system, as opposed to a true emissions 

inventory preparation system, in which emissions estimates are simulated from “first 

principles.” This means that, with the exception of mobile and biogenic sources, its 

purpose is to provide an efficient, modern tool for converting emissions inventory data 

into the formatted emissions files required for a photochemical air quality model. A 

detailed description of all SMOKE input files such as area, mobile, fire, point and 

biogenic emissions files and the SMOKE model configuration are provided in 

Attachment I. 

As discussed in detail in Chapter 11, the MANE-VU member states selected several 

control strategies for inclusion in the modeling. Emission reduction requirements 

mandated by the Clean Air Act were also included in projecting future year emissions. In 

addition, 40 CFR Section 51.308(d)(3)(v)(D) requires the State of Maine to consider 

source retirement and replacement schedules in developing the future inventories and 

long-term strategy. 
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8.4 Inventories for Specific Source Types 

There are five emission source classifications in the emissions inventory as follows: 

1) Stationary point, 

2) Stationary area, 

3) Off-road mobile, 

4) On-road mobile, and 

5) Biogenic. 

Stationary point sources are large sources that emit greater than a specified tonnage per 

year. Stationary area sources are those sources whose emissions are relatively small 

but due to the large number of these sources, the collective emissions could be 

significant, i.e., dry cleaners, service stations, agricultural sources, fire emissions, etc. 

Off-road mobile sources are equipment that can move but do not use the roadways, i.e., 

lawn mowers, construction equipment, railroad locomotives, aircraft, etc. On-road 

mobile sources are automobiles, trucks, and motorcycles that use the roadway system. 

The emissions from these sources are estimated by vehicle type and road type. Biogenic 

sources are natural sources like trees, crops, grasses and natural decay of plants. 

Stationary point sources emission data is tracked at the facility level. For all other 

source types emissions are summed on the county level. 

The subsections below provide an overview of each of the source categories and the 

methods that were used to develop their corresponding baseline and future-year 

emissions estimates. All emissions data were prepared for modeling in accordance with 

EPA guidance. 

8.4.1 Stationary Point Sources

Point source emissions are emissions from large individual sources. Generally, point 

sources have permits to operate and their emissions are individually calculated based on 

source specific factors on a regular schedule. Emissions estimates for point sources are 

usually made on a regular basis, with the largest point sources inventoried annually. 

Sources with emissions greater than or equal to 100 tons per year (tpy) of a criteria 

pollutant, 10 tpy of a single hazardous air pollutant (HAP), or 25 tpy total HAP are 

considered to be major sources. Emissions from smaller sources are also calculated 

individually but less frequently. Point sources are grouped into EGU sources and other 

industrial point sources, termed as non-EGU point sources. 

8.4.1.1 Electric Generating Units

The base-year inventory for EGU sources were based on 2002 continuous emissions 

monitoring (CEM) data reported to EPA in compliance with the Acid Rain Program or 

2002 state emissions inventory data. The CEM data provided actual hourly emission 

values used in the modeling of SO2 and NOx emissions from these large sources. 

Emissions of other pollutants (e.g., VOCs, CO, NH3, and PM2.5) were provided by the 

states in most instances. 
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Future-year inventories of EGU emissions for 2009, 2012 and 2018 were developed 

using ICF International’s Integrated Planning Model (IPM) to forecast growth in electric 

demand and replacement of older, less efficient and more polluting power plants with 

newer, more efficient and cleaner units. This effort was undertaken by an inter-RPO 

workgroup. While the output of the IPM model predicts that a certain number of older 

plants will be replaced by newer units to meet future electric growth and state-specific 

NOx and SO2 caps, the MANE-VU/Maine inventory did not directly rely on the closure 

of any particular plant in establishing the 2018 inventory upon which the reasonable 

progress goals were set. 

The IPM model results do not provide a reliable basis upon which to predict EGU 

closures. Specific plant closures in the Maine inventory are addressed in Chapter 12, 

Reasonable Progress Goals. Preliminary modeling was performed with unchanged IPM 

2.1.9 model results. However, prior to the most recent modeling, future-year EGU 

inventories were adjusted as follows: 

• First, IPM predictions were reviewed by permitting and enforcement staff of the 

MANE-VU states. In many cases, staff believed that the IPM shutdown predictions 

were unlikely to occur. In particular, many oil-fired EGUs in urban areas were 

predicted to be shut down by IPM. Similar source information was solicited from 

states in both VISTAS and MRPO. As a result of this model validation, the IPM 

modeling output was adjusted before the most recent modeling to reflect staff 

knowledge of specific plant status in MANE-VU, VISTAS, and MRPO states. Where 

expected EGU operating status was contrary to what was predicted by IPM modeling, 

the future-year emissions inventory was adjusted to reflect the expected operation of 

those plants. 

• Second, as a result of inter- and intra-RPO consultations, MANE-VU agreed to 

pursue certain emission control measures (see Section 3.0, Regional Planning). For 

EGUs, the agreed-upon approach was to pursue emission reductions from each of the 

top 167 stacks located in MANE-VU, MRPO, and VISTAS that contributed the most 

to visibility impairment at any Class I area in the MANE-VU region. This approach, 

known as the targeted EGU strategy, is further described in Section 11.0 of this SIP.

8.4.1.2 Non-EGU Point Sources

The non-EGU category used annual emissions as reported by state and local agencies 

pursuant to the Consolidated Emission Reporting Rule (CERR) for the base year 2002 

(or MANE-VU Version 3). As described in section 8.2 , MANE-VU’s contractor, 

E.H. Pechan & Associates (Pechan), coordinated the quality assurance of the 

inventory and prepared the necessary files for input into the SMOKE emissions 

model. Further information on the preparation of the MANE-VU 2002 baseline point 

source modeling emissions inventory can be found in Chapter II of the Baseline 

Emissions Report (Attachment I). Projected non-EGU point source emissions were 

developed for the MANE-VU region by MACTEC Federal Programs, Inc. under 

contract to the Mid-Atlantic Regional Air Management Association (MARAMA). 
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The specific methodologies that were employed are described in Section 2 of the 

Emissions Projections Report (Attachment I). MACTEC used state-supplied growth 

factor data, where available, to project future-year emissions. Where state-supplied 

data were not available, MACTEC used EPA’s Economic Growth and Analysis 

System, Version 5.0 (EGAS 5.0) to develop applicable growth factors for the nonEGU component. MACTEC also incorporated the applicable federal and state 

emissions control program s to account for the expected emissions reductions that 

will take place under the OTB/OTW and BOTW scenarios. 

8.4.2 Stationary Area Sources

Stationary area sources include sources whose individual emissions are relatively small, 

but due to the large number of these sources, the collective emissions are significant. 

Some examples include solvent cleaning, service stations and residential heating. Area 

source emissions are estimated by multiplying an emission factor by some known 

indicator of collective activity, such as fuel usage, or number of households or 

population. 

The area source emissions inventory submittals made for the CERR became the basis for 

the area source portion of the 2002 baseline inventory. MANE-VU’s consultant, Pechan, 

prepared the area source modeling inventory using the CERR submittals as a starting 

point. Pechan quality-assured the inventory and augmented it with additional data, 

including MANE-VU sponsored inventories for categories such as residential wood 

combustion and open burning. Details on the preparation of MANE-VU’s 2002 baseline 

area source emissions inventory can be found in Chapter III of the Baseline Emissions 

report (Attachment H). 

In a similar fashion, MACTEC prepared future-year area source emission projections for 

the MANE-VU region. The specific methodologies employed are described in Section 3 

of the Emissions Projection Report (Attachment I). MACTEC applied growth factors to 

the 2002 baseline area source inventory using state-Supplied data, where available, or 

using the EGAS 5.0 growth factor model. MACTEC also accounted for the appropriate 

control strategies in the future year projections. 

8.4.2.2 Non-Road Mobile Sources

Non-road mobile sources are equipment that can move but do not use the roadways, such 

as construction equipment, aircraft, railroad locomotives, lawn and garden equipment. 

For the majority of the non-road mobile sources, the emissions for base year 2002 were 

estimated using the EPA’s NONROAD Model contained within the Mobile6 model. 

Aircraft, railroad locomotives, and commercial marine vessels are not included in the 

NONROAD model; their emissions are estimated using applicable references and 

methodologies. Again, Pechan prepared the 2002 baseline modeling inventory using the 

state and local CERR submittals as a starting point. Details on the preparation of the 2002 

baseline non-road inventory are described in Chapter IV of the Baseline Emissions 

Report (Attachment H). 
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Future-year non-road mobile source emissions were projected for the MANE-VU region 

by MACTEC. The methodologies employed are discussed in Section 4 of the Emission 

Projections Report (Attachment I). MACTEC used EPA’s NONROASD2005 non-road 

vehicle emissions model as contained in EPA’s National Mobile Inventory Model 

(NMIM). Since the calendar year is an explicit input into the NONROAD model, futureyear emissions for non-road vehicles could be calculated directly for the applicable 

projection years. For the non-road vehicle types that are not included in the NONROAD 

model (i.e., aircraft, locomotives and commercial marine vessels), MACTEC used the 

2002 baseline inventory and the projected inventories that EPA developed for these 

categories for the Clean Air Interstate Rule (CAIR) to develop emission ratios and 

subsequent combined growth and control factors. Since the future years for the CAIR 

projections did not precisely match those required for the purposes of ozone, particulate 

mater and the regional haze analyses (i.e., 2009, 2012, and 2018), MACTEC used linear 

interpolation to develop factors for the required future years. 

8.4.3 On-Road Mobile Sources 

The on-road emissions source category consists of vehicles that are meant to travel on 

public roadways, including cars, trucks, buses and motorcycles. The basic methodology 

used for on-road mobile source calculations is to multiply vehicle-miles-travelled (VMT) 

by emission factors developed using EPA’s MOBILE6.2 motor vehicle emission factors 

model. The on-road mobile category requires that SMOKE model inputs be prepared 

instead of the SMOKE/IDA emissions data format that is required by the other emission 

source categories. Therefore, for the 2002 baseline inventory, Pechan prepared the 

necessary VMT and MOBILE6 inputs in SMOKE format. 

Projected on-road mobile source inventories were developed by NESCAUM for the 

MANE-VU region for ozone, particulate matter, and regional haze SIP purposes. As 

with other emission source categories, projected on-road mobile inventories were 

developed for calendar years 2009, 2012, and 2018. As part of this effort, MANE-VU 

member states were asked to provide VMT data and MOBILE6 emissions model inputs 

for the applicable calendar years. Using the inputs supplied by the MANE-VU member 

states, NESCAUM compiled and generated the required SMOKLE/MOBILE6 emission 

model inputs. Further details regarding the on-road mobile source projections can be 

found in NESCAUM’s “Technical Memorandum, Development of MANE-VU Mobile 

Source Projection Inventories for SMOKE/MOBILE6 Application,” June 2006 

(Attachment J). 

8.4.4 Biogenic Emission Sources

Biogenic emissions for the 2002 baseline modeling emissions inventory were calculated 

for the modeling domain by the New York State Department of Environmental 

Conservation (NYSDEC). NYSDEC used the Biogenic Emissions Inventory System 

(BEIS) Version 3.12 as contained within the SMOKE emissions processing model. 

Biogenic emissions estimates were made for CO, nitrous oxide (NO) and VOCs. Further 

details about the biogenic emissions processing can be found in NYSDEC’s technical 
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support document TSD-1c, “Emission Processing for the Revised 2002 OTC Regional 

and Urban 12 km Base Case Simulations,” September 19, 2006, and in Chapter VI: 

Biogenic Sources, of the “Technical Support Document for 2002 MANE-VU SIP 

Modeling Inventories,” Version 3, November 20, 2006 (Attachment H) . Biogenic 

emissions were assumed to remain constant for the future-years analysis, a reasonable 

approximation reflecting the expectation that most of the region will remain heavily 

forested for the duration of the planning period. 

8.5 Summary of Maine’s 2002 and 2018 Emissions Inventory 

Tables 8-1 through 8-4, below, summarize the Maine baseline and future-year emission 

inventories. As previously discussed in section 8.2.2, there are three projected control 

scenarios for the 2018 inventory. The on-the-books/on-the-way (OTB/OTW) control 

strategy scenario accounts for emission control regulations that were already in place as of 

June 15, 2005, as well as some regulations that are not yet finalized, but are expected to 

achieve additional emission reductions by 2009. The beyond-on–the- way (BOTW) 

scenario includes emission controls that may be necessary to for attainment of the ozone 

and PM NAAQS, along with meeting other regional air quality goals. The final modeling 

emission inventory accounts for additional potentially reasonable control measures for 

reducing regional haze as discussed in Section 11 and 12 of this SIP, and was used to 

generate Maine’s reasonable progress goals. 

Table 8-1 

 2002 Emissions Inventory for Maine 

 (tons per year) 

CO NH3 NOX PM10 PM25 SO2 VOC 

Mobile 410,958 1,468 54,687 1,239 934 1,804 23,037

Nonroad 153,424 11 9,820 1,437 1,329 917 31,144

EGU Point 7,962 145 7,831 1,169 888 9,299 842

Non-EGU Point 9,043 700 12,108 6,120 4,899 14,412 4,477

Area 109,223 8,747 7,360 168,953 32,774 13,149 100,621

Biogenics 64,936 2,018 600,205

Total 755,545 11,071 93,824 178,919 40,825 39,581 760,327
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Table 8-2 

 2018 OTB/OTW Emissions Inventory for Maine 

(tons per year) 

CO NH3 NOX PM10 PM25 SO2 VOC 

Mobile 237,170 1,715 12,828 272 266 894 10,414

Nonroad 166,679 15 6,543 1,086 978 82 21,988

EGU Point 4,057 139 1,827 296 279 5,436 53

Non-EGU Point 11,433 859 15,753 7,496 5,935 18,794 5,709

Area 94,181 12,312 7,424 189,619 33,820 13,901 92,410

Biogenics 64,936 2,018 600,205

Total 578,456 15,041 46,393 198,768 41,278 39,107 730,779

Table 8-3 

 2018 BOTW Emissions Inventory for Maine 

(tons per year) 

CO NH3 NOX PM10 PM25 SO2 VOC 

Mobile 237,170 1,715 12,828 272 266 894 10,414

Nonroad 166,679 15 6,543 1,086 978 82 21,988

EGU Point 4,057 139 1,827 296 279 5,436 53

Non-EGU Point 11,433 859 14,137 7,477 5,922 18,692 5,708

Area 94,181 12,312 7,036 188,928 33,201 4,940 90,866

Biogenics 64,936 2,018 600,205

Total 578,456 15,041 44,389 198,058 40,646 30,044 729,234

Table 8-4 

 2018 Final Modeling Emissions Inventory for Maine 

(tons per year)

CO NH3 NOX PM10 PM25 SO2 VOC 

Mobile 237,170 1,715 12,828 272 266 894 10,414

Nonroad 166,679 15 6,543 1,086 978 82 21,988

EGU Point 4,057 139 1,827 296 279 6,806 53

Non-EGU Point 11,433 859 14,137 7,477 5,922 13,082 5,708

Area 94,181 12,312 7,036 57,411 18,877 1,127 90,866

Biogenics 64,936 2,018 600,205

Total 578,456 15,041 44,390 66,54226 26,321 21,991729,235

 

26 An adjustment factor was applied during the processing of emissions data to restate fugitive particulate 

matter emissions. Grid models have been found to overestimate fugitive dust impacts when compared 

with ambient samples; therefore, an adjustment is typically applied to account for the removal of 

particles by vegetation and other terrain features. The summary emissions for PM10 in Table 8.4 reflect 

this adjustment. Comparable adjustments were not made to PM10 values listed in Tables 8.1 through 8.3. 
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9. Modeling 

Air quality modeling to assess regional haze has been done cooperatively by the MANEVU member states, with major modeling efforts being conducted by NESCAUM27 and 

screening modeling being conducted by the New Hampshire Department of 

Environmental Services (NHDES)28. These modeling efforts include emissions 

processing, meteorological input analysis, and chemical transport modeling to conduct 

regional air quality simulations for calendar year 2002 and several future periods, 

including the 2018 primary target period for this SIP. Modeling was conducted in order 

to assess contribution from upwind areas, as well as Maine’s contribution to its own 

Class I areas. Further, the modeling evaluated visibility benefits of control measures 

being considered for achieving reasonable progress goals and establishing a long-term 

emissions management strategy for MANE-VU Class I areas. The modeling tools 

utilized for these analyses include the following: 

 The Fifth-Generation Pennsylvania State University/National Center for Atmospheric 

Research (NCAR) Mesoscale Model (MM5) was used to derive the required 

meteorological inputs for the air quality simulations.

 The Sparse Matrix Operator Kernel Emissions (SMOKE) emissions modeling system 

was used to process and format the emissions inventories for input into the air quality 

models.

 The Community Mesoscale Air Quality model (CMAQ) was used for the primary SIP 

modeling.

 The Regional Model for Aerosols and Deposition (REMSAD) was used during 

contribution apportionment.

 The California Grid Model (CALGRID) and its associated EMSPROC6 emissions 

processor was used to screen specific control strategies.

Each of these tools has been evaluated and found to perform adequately, and the SIP 

pertinent modeling underwent full performance testing and the results were found to meet 

the specifications of EPA modeling guidance. 

For more details on the regional haze modeling, refer to the NESCAUM report “MANEVU Modeling for Reasonable Progress Goals, Model Performance Evaluation, Pollution 

Apportionment, and Control Measure Benefits,” February 7, 2008 (Attachment P). The 

detailed modeling approach for the most recent 2018 projected scenario can be found in 

the NESCAUM report “2018 Visibility Projections,” May 13, 2008 (Attachment Q). 

9.1 Meteorology

The meteorological inputs for the air quality simulations were developed by the 

University of Maryland (UMD) using the MM5 meteorological modeling system. 

Meteorological inputs were generated for 2002 to correspond with the baseline emissions 

inventory and analysis year. The MM5 simulations were performed on a nested grid as 

 

27 Along with the NYSDEC, NJDEP/Rutgers, VADEQ, and UMD. 28 Along with the VTDEP and MDEQ. 
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illustrated in Figure 9-1. As shown in the figure, the modeling domain is comprised of a 

36-km, 145 x 102 continental grid and a nested 12-km, 172 x 172 grid encompassing the 

Figure 9-1 

Modeling domains used in MANE-VU air quality modeling studies with CMAQ. 

Outer (blue) domain grid is 36 km and inner (red) domain is 12 km grid 

The gridlines are shown at 180 km intervals (5 × 5 36 km cells/15 × 15 12 km cells) 

Eastern United States and parts of Canada. In cooperation with the New York State 

Department of Conservation (NYSDEC), an assessment was made to compare the MM5 

predictions with observations from a variety of data sources, including: 

 Surface observations from the National Weather Service and the Clean Air Status 

and Trends Network (CASTNet); 

 Wind-profiler measurements from the Cooperative Agency Profilers (CAP) 

network; 

 Satellite cloud image data from the UMD Department of Atmospheric and 

Oceanic Science; and 

 Precipitation data from the Earth Observing Laboratory at NCAR. This 

assessment was performed for the period covering May through September 2002. 

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Further details regarding the MM5 meteorological processing and the modeling domain 

can be found in NYSDEC’s technical support document TSD-1a, “Meteorological 

Modeling Using Penn State/NCAR 5th Generation Mesoscale Model (MM5),” February 

1, 2006 (Attachment K), and in the NESCAUM report “MANE-VU Modeling for 

Reasonable Progress Goals, Model Performance Evaluation, Pollution Apportionment, 

and Control Measure Benefits,” November 27, 2007 (Attachment P). 

9.2 Emissions Data Preparation 

Emissions were prepared for input into the CMAQ and REMSAD air quality models 

using the SMOKE emissions modeling system. SMOKE supports point, area, mobile 

(both on-road and non-road), and biogenic emissions. The SMOKE emissions modeling 

system uses flexible processing to apply chemical speciation as well as temporal and 

spatial allocation to the emissions inventories. SMOKE incorporates the Biogenic 

Emission Inventory System (BEIS) and EPA’s MOBILE6 motor vehicle emission factor 

model to process biogenic and on-road mobile emissions, respectively. Vector-matrix 

multiplication is used during the final processing step to merge the various emissions 

components into a single model-ready emissions file. Examples of processed emissions 

outputs are shown below in Figure 9-2. 

Further details on the SMOKE processing conducted in support of the air quality 

simulations is provided in NYSDEC’s technical support document TSD-1c, “Emission 

Processing for the Revised 2002 OTC Regional and Urban 12 km Base Case 

Simulations,” September 19, 2006 (Attachment I), and in NESCAUM’s report, “MANEVU Modeling for Reasonable Progress Goals, Model Performance Evaluation, Pollution 

Apportionment, and Control Measure Benefits,” February 7, 2008 (Attachment P). 

Additional details on the emissions inventory preparation can be found in Section 8.0 of 

this report. 

9.3 Primary Regional Haze Modeling Platforms 

MANE-VU used two regional-scale air quality models to perform its primary air quality 

simulations. These are the Community Multi-scale Air Quality modeling system 

(CMAQ; Byun and Ching, 1999) and the Regional Modeling System for Aerosols and 

Deposition (REMSAD; SAI, 2002). CMAQ was developed by USEPA, while REMSAD 

was developed by ICF Consulting/Systems Applications International (ICF/SAI) with 

USEPA support. CMAQ has undergone extensive community development and peer 

review (Amar et al., 2005) and has been successfully used in a number of regional air 

quality studies (Bell and Ellis, 2003; Hogrefe et al., 2004; Jimenez and Baldasano, 2004; 

Mao and Talbot, 2003; Mebust et al., 2003). REMSAD has also has been peer reviewed 

(Seigneur et al., 1999) and used by USEPA for regulatory applications) to study ambient 

concentrations and deposition of sulfate and other PM species29. 

29 www.epa.gov/otaq/regs/hd2007/frm/r00028.pdf and www.epa.gov/clearskies/air_quality_tech.html
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Figure 9-2 

Examples of Processed Model-Ready Emissions 

(a) SO2 from Point; (b) NO2 from Area; (c) NO2 from On-road; (d) NO2 from Non-road; (e) ISOP 

from Biogenic; (f) SO2 from all source categories

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9.3.1 CMAQ

The CMAQ air quality simulations were performed cooperatively between five modeling 

centers, including NYSDEC, the New Jersey Department of Environmental Protection 

(NJDEP) in association with Rutgers University, the Virginia Department of 

Environmental Quality (VADEQ), UMD, and NESCAUM. NYSDEC also performed an 

annual 2002 CMAQ simulation on the 36-km domain shown in Figure 9-1; this 

simulation was used to derive the boundary conditions for the inner 12-km eastern 

modeling domain. Boundary conditions for the 36-km simulations were obtained from a 

run of the GEOS-Chem (Goddard Earth Observing System) global chemistry transport 

model that was performed by researchers at Harvard University. 

The CMAQ modeling system is a three-dimensional Eulerian model that incorporates 

output fields from emissions and meteorological modeling systems and several other data 

sources through special interface processors into the CMAQ Chemical Transport Model 

(CCTM). The CCTM then performs chemical transport modeling for multiple pollutants 

on multiple scales. With this structure, CMAQ retains the flexibility to substitute other 

emissions processing systems and meteorological models. CMAQ is designed to provide 

an air quality modeling system with a “one atmosphere” capability containing state-ofscience parameterizations of atmospheric processes affecting transport, transformation, 

and deposition of such pollutants as ozone, particulate matter, airborne toxics, and acidic 

and nutrient pollutant species (Byun and Ching, 1999). 

MANE-VU SIP modeling on both 36 km and 12 km domains used CMAQv4.5.1, IOAPI 

V2.2 and NETCDF V3.5 libraries. The CMAQ model is configured with the Carbon 

Bond IV mechanism (Gery et al., 1989) using the EBI solver for gas phase chemistry 

rather than the SAPRC-99 mechanism due to better computing efficiency with no 

significant model performance differences for ozone and PM as compared to 

observations. NY DEC completed annual 2002 CMAQ modeling on the 36 km domain 

to provide dynamic boundary conditions for all simulations performed on the 12 km 

domain. Three-hourly boundary conditions for the outer domain were derived from an 

annual model run performed by researchers at Harvard University using the 

GEOSCHEM global chemistry transport model (Park et al., 2004). Model resolution was 

species dependent at either 4° latitude by 5° longitude or 2° by 2.5°. 

Annual CMAQ modeling on the 12 km domain is divided into five periods. UMD was 

responsible for the period from January 1 to February 28; NJ DEP/Rutgers were 

responsible for the period from March 1 to May 14; NYSDEC was responsible for the 

period from May 15 to September 30; VADEQ was responsible for the period from 

October 1 to October 31; and NESCAUM was responsible for the period from November 

1 to December 31. Each period uses a 15-day spin-up run to minimize the impact of the 

default initial concentration fields. Each modeling group performed CMAQ simulations 

on its period for a series of scenarios including 2002 Base Case, 2009 Base Case, 2018 

Base Case, 2009 Control Case, and 2018 Control Case. All scenarios adopt the same 

meteorological field (2002) and boundary conditions, varying only emission inputs. To 

ensure consistency, a benchmark test was conducted by each modeling group. 
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In addition to the annual simulations conducted with CMAQ by the five modeling 

centers, NESCAUM conducted limited sensitivity analysis of several control measures 

using the beta version of CMAQ with the particle and precursor tagging methodology 

(CMAQ-PPTM) (ICF, 2006). The technical options that were used in performing the 

CMAQ simulations are described in detail in NYSDEC’s technical support document 

TSD-1d, “8hr Ozone Modeling using the SMOKE/CMAQ system,” February 1, 2006 

(Attachment K). Further technical details regarding the CMAQ model and its execution 

are also provided in NESCAUM’s report, “MANE-VU Modeling for Reasonable 

Progress Goals, Model Performance Evaluation, Pollution Apportionment, and Control 

Measure Benefits,” February 7, 2008 (Attachment P). 

9.3.2 REMSAD

The REMSAD modeling simulations were used to satisfy the haze rule requirement that a 

pollution apportionment be performed to assess contribution to visibility improvement by 

geographic region or source sector. REMSAD’s species tagging capability makes it an 

important tool for this purpose. The Regional Modeling System for Aerosols and 

Deposition (REMSAD) is a three-dimensional Eulerian model designed to support a 

better understanding of the distributions, sources, and removal processes relevant to fine 

particles and other airborne pollutants. It calculates the concentrations of both inert and 

chemically reactive pollutants by simulating the physical and chemical processes in the 

atmosphere that affect pollutant concentrations. The basis for the model is the 

atmospheric diffusion equation representing a mass balance in which all of the relevant 

emissions, transport, diffusion, chemical reactions, and removal processes are expressed 

in mathematical terms. The REMSAD model performs a four-step solution procedure: 

emissions, horizontal advection/diffusion, vertical advection/diffusion and deposition, 

and chemical transformations during one-half of each advective time step, and then 

reverses the order for the following half-time step. The maximum advective time step for 

stability is a function of the grid size and the maximum wind velocity or horizontal 

diffusion coefficient. Vertical diffusion is solved on fractions of the advective time step 

to keep their individual numerical schemes stable. 

REMSAD uses a flexible horizontal and vertical coordinate system with nested grid 

capabilities and user-defined vertical layers. It accepts a geodetic (latitude/longitude) 

horizontal coordinate system or a Cartesian horizontal coordinate system measured in 

kilometers. REMSAD uses a simplified version of CB-IV chemistry mechanism that is 

based on a reduction in the number of different organic compound species and also 

includes radical-radical termination reactions. The organic portion of the chemistry is 

based on three primary organic compound species and one carbonyl species. 

The model parameterizes aerosol chemistry and dynamics for PM and calculates 

secondary organic aerosol (SOA) yields from emitted hydrocarbons. REMSAD V7.12 

and newer versions have capabilities that allow model tags of sulfur species (up to 11 

tags), nitrogen (4 tags), mercury (up to 24 tags), and cadmium (up to 10 tags) to identify 

the impact of specific tagged species. Unlike CMAQ, REMSAD provides no choice of 

chemical and physical mechanisms. Due to the simplified chemistry mechanism, 

REMSAD may not simulate atmospheric processes as well as CMAQ. However, 
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advantages such as the tagging feature for sulfur, more efficient modeling, and reasonable 

correspondence with measurements for many species, make REMSAD an important 

source apportionment tool for MANE-VU. The MANE-VU REMSAD modeling utilized 

the same 12 km eastern modeling domain shown in Figure 9-1, above. Multiple runs are 

necessary to permit tagging of sulfur emissions for all of the states in the domain, 

Canada, and the boundary conditions. NESCAUM’s report, “MANE-VU Modeling for 

Reasonable Progress Goals, Model Performance Evaluation, Pollution Apportionment, 

and Control Measure Benefits,” February 7, 2008, further describes the REMSAD model 

and its application to the regional haze SIP efforts (See Attachment P). 

9.4 Primary Model Evaluation 

9.4.1 CMAQ

NYSDEC extensively analyzed the CMAQ model performance to evaluate model 

predictions against observations of ozone, PM2.5, and other chemical species. To do this, 

model predictions for the base year simulation are compared to the actual ambient data 

observed in the historical episode. This verification is a combination of statistical and 

graphical evaluations. If the model appears to be predicting fine particles and other 

airborne pollutants in the right locations for the right reasons, then the model can be used 

as a predictive tool to evaluate various control strategies and their effects on regional 

haze. CMAQ modeling was conducted for the year 2002 (completed by cooperative 

modeling efforts from NYDEC, UMD, NJDEP, Rutgers, VADEP, and NESCAUM) 

under the Base B4 emission scenario (See Attachment P). CMAQ performance for PM2.5 

species and visibility is examined based on this CMAQ run on a 12 km resolution 

domain. Measurements from IMPROVE and STN networks are paired with model 

predictions by location and time for evaluation. Figure 9-3 presents the domain-wide 

paired comparison for sulfate and other PM2.5 species including nitrate, OC, EC, fine 

soil, and PM2.5 daily average concentration from the CMAQ simulation and two sets of 

observations (STN and IMPROVE). It shows that predicted PM2.5 sulfate and measured 

sulfate are in a good 1:1 linear relationship with varying from 0.6 to 0.7. PM2.5 nitrate 

(top row right panel) also has close to a 1:1 linear relationship between the model and 

observations, although the values are much lower (from ~0.2 to ~0.5) than for sulfate. 

Paired OC (middle row left panel) concentrations have a scattered distribution with overand under-estimation and a very weak linear relationship (r2 of ~0.1). CMAQ tends to 

overestimate EC (middle row right panel) and fine soil (bottom row left panel) 

concentrations.30

 

30 EC and soil are inert species not involved in chemical transformation. Poor emission inventory data may 

be the main cause for the weak linear relationships between prediction and measurement. In addition, there 

are no fire emissions considered in CMAQ modeling. The wild fire in Quebec, Canada in early July of 

2002 led to high concentrations of observed OC, EC, and fine soil that are not predicted by CMAQ. 
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Figure 9-3 

Domain-Wide Paired Comparison For Sulfate And Other PM2.5 Species 

CMAQ vs IMPROVE/STN 

Because sulfate is the dominant PM2.5 species, modeled PM2.5 (bottom row right panel) 

shows a relatively strong near 1:1 linear relationship. 

Additional model performance evaluations include assessing the ability of the CMAQ 

model to correctly model PM2.5 species across the modeling domain (spatial distribution 

89 
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of the correlation coefficient between CMAQ predictions and Improve observations), 

mean fractional error of CMAQ predictions, mean fraction bias of CMAQ predictions, 

and paired comparisons of the haze index between CMAQ predictions and Improve 

measurements at selected Class I sites were undertaken. In summary, the CMAQ model 

was demonstrated to perform best for daily average SO4 mass and PM2.5. Many other 

species vary significantly over the course of a day, or from day to day, and small model 

over- or underprediction at low concentrations can lead to large biases on a composite 

basis. These model performance evaluations are described in detail in NYSDEC’s 

technical support document TSD-1e, “CMAQ Model Performance and Assessment, 8-Hr 

OTC Ozone Modeling,” February 23, 2006 (Attachment K) and in NESCAUM’s report , 

“MANE-VU Modeling for Reasonable Progress Goals, Model Performance Evaluation, 

Pollution Apportionment, and Control Measure Benefits,” February 7, 2008 (Attachment 

P). 

9.4.2 REMSAD

The Regional Modeling System for Aerosols and Deposition (REMSAD) model was 

utilized by MANE-VU for its contribution assessment. REMSAD model performance 

has been evaluated as part of several previous national and regional modeling exercises. 

EPA evaluated REMSAD performance as for their Clear Skies Act base case study using 

1996 meteorology and 1996 NET inventory.31 Modeling results were compared with 

IMPROVE measurement, with REMSAD found to perform better in the Eastern US than 

in the Western US on PM sulfate and PM2.5, although it underestimates ambient levels 

countrywide and performs relatively poorly on soil, carbonaceous aerosols and PM 

nitrate.32 

A spatial performance evaluation of REMASAD simulations for sulfate on the 12km 

northeast US domain for the year 2002 was conducted through comparison with 

IMPROVE/STN measurements, as illustrated in Figure 9-4. These comparisons are 

inexact, because the discrete measurements represent a uniform gridded concentration 

field. This approach, however, does provide a first order examination of measurement 

and modeling results, which is appropriate for an annual averaged analysis. 

In general, the REMSAD simulation field is well-matched with measurement data. 

Figure 9-5 shows the comparison of paired 24-hour surface sulfate concentrations 

between five different air quality model results (including REMSAD) and IMPROVE 

measurements during the year 2002 for Lye Brook Wilderness Area (Vermont) and 

 

31 See Clear Skies Act Air Quality Modeling Technical Support Document at 

http://www.epa.gov/air/clearskies/aq_modeling_tsd_csa2003.pdf

32 NESCAUM also performed REMSAD modeling using the 1996 meteorology, but with the 2001 Proxy 

emission inventory, therefore a direct comparison to the EPA CSA modeling results could not be 

completed. To evaluate REMSAD for this exercise, NESCAUM first compared its own modeling results 

with EPA’s CSA 2001 case modeling results, which also used the 1996 meteorology. NESCAUM’s results 

were an exact match with EPA’s REMSAD modeling on PM2.5 and PM sulfate distributions. In addition, 

NESCAUM also compared the long term modeling average (annual mean) of PM species to IMPROVE 

annual means for three sites. These comparisons show good agreement for REMSAD modeling of PM 

sulfate, NH4, OC and EC. 
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Shenandoah National Park (Virginia). The comparison illustrates that the two CMAQ 

model runs show the best performance in terms of slope, intercept and coefficient of 

correlation (r2), with the REMSAD results showing the 2nd best performance. Along 

with EPA’s previous evaluation (Timin B. et al., 2002) the NESCAUM performance 

evaluation confirms that REMSAD performs reasonably well for longer-term (annual 

averaged) sulfate simulation. 

Figure 9-4 

Sulfate Concentrations From the IMPROVE/STN Measurements and the REMSAD 

Model 

Figure 9-5 

Comparison of Measurement and Modeled Data for Alternative Annual Model 

Simulations

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9.5 Additional Modeling Platforms 

9.5.1 CALGRID

In addition to the SIP-quality modeling platforms that were described above, an 

additional modeling platform was developed for use as a screening tool to evaluate 

additional control strategies or to perform sensitivity analyses. The CALGRID model 

was selected as the basis for this platform. CALGRID is a grid-based photochemical air 

quality model that is designed to be run in a Windows environment. In order to make the 

CALGRID model the best possible tool to supplement the SIP-quality CMAQ and 

REMSAD modeling, the current version of the CALGRID platform was set up to be run 

with the same set of inputs as the SIP-quality models. The CALGRID air quality 

simulations were run on the same 12-km eastern modeling domain that was used for 

CMAQ and REMSAD. This model’s performance was relative to the performance of the 

already evaluated CMAQ and REMSAD models and was thus determined to perform 

adequately. 

Conversion utilities were developed to re-format the meteorological inputs, the boundary 

conditions, and the emissions for use with the CALGRID modeling platform. Pre-merged 

SMOKE emissions files were obtained from the modeling centers and re-formatted for 

input into EMSPROC6, the emissions pre-processor for the CALGRID modeling system. 

EMSPROC6 allows the CALGRID user to adjust emissions temporally, geographically, 

and by emissions category for control strategy analysis. The pre-merged SMOKE files 

that were obtained from the modeling centers were broken down into the biogenic, point, 

area, non-road, and on-road emissions categories. These files by component were then 

converted for use with EMSPROC6, thus giving CALGRID users the flexibility to 

analyze a wide variety of emissions control strategies. The MANE-VU CALGRID 

modeling is described in greater detail in Attachment P. 

9.5.2 CALPUFF

CALPUFF is a non-steady-state Lagrangian puff model that simulates the dispersion, 

transport, and chemical transformation of atmospheric pollutants. Two parallel 

CALPUFF modeling platforms were developed by the Vermont Department of 

Environmental Conservation (VTDEC) and the Maryland Department of the 

Environment (MDE). The VTDEC CALPUFF modeling platform utilized 

meteorological observation data from the National Weather Service (NWS) to drive the 

CALMET meteorological model. The MDE platform utilized the same MM5 

meteorological inputs that were used in the modeling done in support of the ozone and 

regional haze SIPs. These two platforms were run in parallel to evaluate individual 

states’ contributions to sulfate levels at Northeast and Mid-Atlantic Class I areas. The 

CALPUFF modeling effort is described in detail in NESCAUM’s report, “Contributions 

to Regional Haze in the Northeast and Mid-Atlantic United States,” August 2006 

(Attachment A). 
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10. Best Available Retrofit Technology 

The Best Available Retrofit Technology (BART) requirement of Section 169A of the 

Clean Air Act (42 U.S.C.§7491(b)(2)(A)) and implementing rules (40 C.F.R. Part 51, 

Attachment Y) are intended to reduce visibility impairing pollutants33 emitted from 

existing stationary sources which were grandfathered from the New Source Review 

(NSR) requirements of the Clean Air Act. The federal definition of BART in 40 CFR 

Part 51.301 is as follows: 

“Best Available Retrofit Technology (BART) means an emission limitation based 

on the degree of reduction achievable through the application of the best system of 

continuous emission reduction for each pollutant which is emitted by an existing 

stationary source facility. The emission limitation must be established, on a case-bycase basis, taking into consideration the technology available, the costs of 

compliance, the energy and nonair quality environmental impacts of compliance, any 

pollution control equipment in use or in existence at the source, the remaining useful 

life of the source, and the degree of improvement in visibility which may reasonably 

be anticipated to result from the use of such technology.” 

The BART requirements apply to certain older industrial sources that began operating 

before the federal Prevention of Significant Deterioration (PSD) rules were adopted in 

1977 to protect visibility in Class I areas. PSD and BART represent the two primary 

regulatory tools for protecting visibility and addressing regional haze from industrial 

sources. The PSD rules apply to new sources and major modifications of existing 

sources34, while BART applies to 26 types of stationary sources which began operation 

between August 7, 1962 and August 7, 1977 with the potential to emit more than 250 

tons per year of a visibility impairing pollutant. Once the Regional Haze SIP is approved 

by the EPA, the BART facility has up to five years to install the appropriate controls and 

comply with the established emission standards. Maine is requiring sources subject to 

BART to install, operate and maintain BART rather than implement an emissions trading 

program or other alternative measure. 

10.1 The Federal BART Rule 

In June 2005, EPA adopted the final BART rule. The BART rule requires states/tribes to 

develop an inventory of sources within each state or tribal jurisdiction that would be 

eligible for controls. The rule contains the following elements that: 

33 The visibility impairing pollutants are defined by the EPA as sulfur dioxide (SO2), oxides of nitrogen 

(NOx) and particles with an aerodynamic diameter less than or equal to 10 and 2.5 μm (i.e., PM10 and PM2.5, 

respectively). 

34 The PSD rules are part of the New Source Review rules, which apply to major new sources and major 

modifications of existing sources, to protect both visibility and air quality in general. See further 

description in Section 12. Since BART addresses existing sources, the evaluation of controls considers the 

effectiveness and the remaining life of the existing controls, and the cost of replacing them. While PSD 

and BART may end up evaluating similar types of controls, the criteria and selection of controls for BART 

is different due to the retrofit factors and visibility improvement that would result. 
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 Outline methods to determine if a source is “reasonably anticipated to cause or 

contribute to haze” 

 Defines the methodology for conducting a BART control analysis 

 Provides presumptive limits for electricity generating units (EGUs) larger than 

750 Megawatts 

 Provides a justification for the use of the Clean Air Interstate Rule (CAIR) as 

BART for CAIR affected EGUs 

Beyond the specific elements listed above, EPA provided the states with a great deal of 

flexibility in implementing the BART program. 

10.1.1 Federal BART Requirements for Electric Generating Units (EGUs)

According to 40 CFR Section 51.308(e)(4) of the Regional Haze Rule, a State that opts to 

participate in the Clean Air Interstate Rule (CAIR) Cap and Trade program under 40 CFR 

Part 96AAA-EEE need not require affected BART eligible EGUs to install, operate, and 

maintain BART. Since Maine and Maine sources were not included in the CAIR Cap 

and Trade Program, EGUs in Maine that are subject to BART must install, operate and 

maintain emission controls. 

Section V of the Regional Haze Regulations and Guidelines for Best Available Retrofit 

Technology (BART) Determinations Preamble sets forth presumptive requirements for 

States to require EGUs to reduce SO2 and NOx emissions for units greater than 200 MW 

in capacity at plants greater than 750 MW in capacity that significantly contribute to 

visibility impairment in Federal Class I areas. The analysis conducted presents alternative 

control scenarios of possible additional controls for EGUs located at plants less than 750 

MW in capacity. 

Under 40 CFR Section 51.308(e)(1)(i)(B) of the Regional Haze Rule, the determination 

of BART for fossil fuel fired power plants having a total generating capacity of greater 

than 750 megawatts must be made pursuant to the guidelines of Attachment Y of this part 

of the CFR (Guidelines for BART Determinations under the Regional Haze Rule). EPA 

adopted those guidelines on July 6, 2005. The guidelines provide a process for making 

BART determinations that States can use in implementing the regional haze BART 

requirements on a source-by-source basis, as provided in 40 CFR 51.308(e)(1). States 

must follow the guidelines in making BART determinations on a source-by-source basis 

for power plants of greater than 750 megawatts (MW), but are not required to use the 

process in the guidelines when making BART determinations for other types of sources. 

For oil-fired EGUs, the presumptive level of BART control for SO2 is the use of oil 

containing 1 percent or less sulfur by weight. Combustion controls constitute the 

presumptive BART control for NOx at these units. 
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10.2 Maine State BART Requirements 

In 2007, the Maine Legislature enacted enabling legislation establishing deadlines and 

control requirements/limitations for BART eligible units in Maine35. 38 MRSA §603-A, 

sub-§8 states: 

“8. Best available retrofit technology or BART requirements. For those BART 

eligible units determined by the department to need additional sulfur air pollution 

controls to improve visibility, the controls must: 

A. Be installed and operational no later than January 1, 2013; and 

B. Either: 

(1) Require the use of sulfur oil having 1% or less of sulfur by weight; or 

(2) Be equivalent to a 50% reduction in sulfur emissions from a BART 

eligible unit based on a BART eligible unit source emission baseline 

determined by the department under 40 Code of Federal Regulations, 

Section 51.308 (d)(3)(iii)(2006) and 40 Code of Federal Regulations, 

Section 51 Attachment Y (2006).” 

10.3 BART-Eligible Sources in Maine 

Determining BART-eligible sources is the first step in the BART process. The Maine 

BART-eligible sources were identified in accordance with the methodology in Appendix 

Y of the Regional Haze Rule, Guidelines for BART Determinations Under the Regional 

Haze Rule, Part II, How to Identify BART-Eligible Sources (70 FR 39158). This 

guidance consists of the following criteria: 

1. The facility contains emission units36 which fall into one or more of 26 source 

categories: 

 Fossil-fuel fired steam electric plants of more than 250 million British thermal units 

(BTU) per hour heat input 

 Coal cleaning plants (thermal dryers) 

 Kraft pulp mills 

 Portland cement plants 

 Primary zinc smelters 

 Iron and steel mill plants 

 Primary copper smelters 

 Municipal incinerators capable of charging more than 250 tons of refuse per day 

 Hydrofluoric, sulfuric, and nitric acid plants 

 

35 Sources may also cap their emissions below the 250 ton BART eligibility threshold. 36 EPA rules (40 CFR Part 51.166) define emission unit as “any part of a stationary source that emits or has 

the potential to emit any pollutant”. 
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 Petroleum refineries 

 Lime plants 

 Phosphate rock processing plants 

 Coke oven batteries 

 Sulfur recovery plants 

 Carbon black plants (furnace process) 

 Primary lead smelters 

 Fuel conversion plants 

 Sintering plants 

 Secondary metal production facilities 

 Chemical process plants 

 Fossil-fuel boilers of more than 250 million BTUs per hour heat input 

 Petroleum storage and transfer facilities with a capacity exceeding 300,000 barrels 

 Taconite ore processing facilities 

 Glass fiber processing plants 

 Charcoal production facilities 

2. The units “began operation” after August 7, 1962 (defined as “engaged in activity 

related to the primary design function of the facility”), and were the units “in 

existence on August 7, 1977 (defined as “the owner or operator has obtained all 

the necessary pre-construction approvals or permits required by Federal, State or 

local air pollution emissions and air quality laws or regulations and either has (1) 

begun, or caused to begin, a continuous program of physical on-site construction 

of the facility or (2) entered into a binding agreements or contractual obligation, 

which cannot be canceled or modified without substantial loss to the owner or 

operator, to undertake a program of construction of the facility to be completed in 

a reasonable time”). 

[Note: Sources that were in operation before August 7, 1962, but were 

reconstructed during the August 7, 1962 to August 7, 1977 time period are also 

subject to BART if “the fixed capital cost of the new component exceeds 50 

percent of the fixed capital cost of a comparable entirely new source”] 

3. The potential emissions from these units 250 tons per year or more for sulfur 

dioxide (SO2), nitrogen oxides (NOx), particulate matter (PM), volatile organic 

compounds (VOC), or ammonia (NH4). The BART Guidelines recommend 

addressing SO2, NOx, and particulate matter. The State of Maine addressed these 

three pollutants, and used particulate matter less than 10 microns in diameter 

(PM10) as an indicator for particulate matter to identify BART eligible units, as 

the Guidelines suggest. Consistent with the Guidelines, the State of Maine did 

not evaluate emissions of VOCs and ammonia in BART determinations for these 

reasons: 

 The majority of VOC emissions in Maine are biogenic in nature, with the 

areas near Maine Class I areas especially so (the ability to further reduce total 

ambient VOC concentrations at Class I areas is limited); 

 Point, area and mobile sources of VOCs in Maine are already 

comprehensively controlled as part of our ozone attainment and maintenance 

strategy;
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 The overall ammonia inventory is very uncertain, and the amount of 

anthropogenic emissions at sources that were BART-eligible was relatively 

small, and

 No additional sources were identified that had greater than 250 tons per year 

ammonia and required a BART analysis.

The identification of BART sources in Maine was undertaken as part of a multi-state 

analysis conducted by the Northeast States for Coordinated Air Use Management 

(NESCAUM). NESCAUM worked with Maine DEP licensing engineers to review all 

sources and determine their BART eligibility. Maine DEP identified 10 sources as 

BART-eligible. These sources are listed below in Table 10-1. 

10.4 Sources Subject to BART 

Maine, working with MANE-VU, found that every MANE-VU state with BART-eligible 

sources contributes to visibility impairment at one or more Class I areas to a significant 

degree (See the MANE-VU Contribution Assessment in Attachment A). As a result, 

Maine has found that all eligible sources within Maine are subject to BART. The State of 

Maine is utilizing this option for demonstrating its sources are reasonably anticipated to 

cause or contribute to visibility impairment at Class I areas for three reasons: (1) the 

BART sources represent an opportunity to achieve greater reasonable progress; (2) 

additional public health and welfare benefits will accrue for the resulting decreases in 

fine particulate matter; and (3) to demonstrate its commitment to federal land managers 

(FLMs) and other RPOs as it seeks the implementation of reasonable measures in other 

states.37

According to Section III of the 2005 Regional Haze Rule, once the state has compiled its 

list of BART-eligible sources, it needs to determine whether to make BART 

determinations for all of the sources or to consider exempting some of them from BART 

because they may not reasonably be anticipated to cause or contribute to any visibility 

impairment in a Class I area. 

Based on the collective importance of BART sources, Maine has decided that no 

exemptions would be given for sources; a BART determination will be made for each 

BART-eligible source. 

10.5 MANE-VU BART Modeling 

MANE-VU conducted modeling analyses of BART-eligible sources using CALPUFF in 

order to provide a regionally-consistent foundation for assessing the degree of visibility 

improvement which could result from installation of BART controls (See Attachment L). 

37 Maine’s decision that all BART eligible sources are subject to BART should not be misconstrued to 

mean that all BART-eligible sources must install BART. Maine’s approach simply requires the 

consideration of each of the five statutory factors before determining whether or not controls are warranted. 
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Table 10-1 

BART-Eligible Sources in Maine 

Source and Unit Location I.D BART Source Category 

FPLE Wyman Station 

 Boiler #3 

 Boiler #4 

Yarmouth, ME 2300500135 

 -004 

 -005 

SC 1- Fossil fuel fired electric 

plants 

Domtar 

 Power Boiler #9 

 Lime Kiln 

 

Woodland, ME 2302900020 

 -001 

 -002 

SC 3 - Kraft pulp mills 

Dragon Products 

 Kiln 

Thomaston, ME 2301300028 

 -005 

SC 4 – Portland cement plants 

Red Shield Acquisition, LLC 

 #4 Recovery Boiler 

 Lime Kiln 

Old Town, ME 2301900034 

 -002 

 -004 

SC 3 - Kraft pulp mills 

Verso Bucksport 

 #5 Boiler 

Bucksport, ME 2300900004 

 -001 

SC 22 – Fossil fuel fired boilers 

SAPPI Somerset 

 Recovery Boiler 

 Smelt Tanks #1, #2 

 Lime Kiln 

Hinckley, ME 2302500027 

 -003 

 -007 

 -004 

SC 3 - Kraft pulp mills 

Verso Androscoggin 

 Power Boiler #1 

 Power Boiler #2 

 Waste Fuel Incinerator 

 Recovery Boilers #1 and #2 

 Smelt Tank #1 

 Smelt Tank #2 

 Lime Kiln A 

 Lime Kiln B 

 Flash Dryer 

 

Jay, ME 2300700021 

 -001 

 -002 

 -003 

 -004/005 

 -009 

 -010 

 -007 

 -008 

 -018 

SC 3 - Kraft pulp mills 

Katahdin Paper 

 Power Boiler #4 

Millinocket, ME 2301900056 

 -004 

SC 22 – Fossil fuel fired boilers 

Lincoln Paper and Tissue 

 Recovery Boiler #2 

Lincoln, ME 2301900023 

 -002 

 

SC 3 - Kraft pulp mills 

Rumford Paper 

 Power Boiler #5 

Rumford, ME 2301700045 

 -003 

SC 3 – Kraft pulp mills 

While this modeling analysis differed slightly from the statutory language, it was 

intended to provide a first-order estimate of the maximum visibility benefit that could be 

achieved by eliminating all emissions from a BART source, and provides a useful metric 

for determining which sources are unlikely to warrant (additional) controls to satisfy 

BART. 
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The MANE-VU modeling effort analyzed 136 BART-eligible sources in the MANE-VU 

region using the CALPUFF modeling platform and two meteorological data sets: 1) a 

wind field based on National Weather Service (NWS) observations; and 2) a wind field 

based on the MM5 meteorological model (MM5 2006). Modeling results from both the 

NWS and MM5 platforms include each BART eligible unit’s maximum 24-hr, 8th highest 

24-hr, and annual average impact at the Class I area. These visibility impacts were 

modeled relative to the 20 percent best, 20 percent worst, and average annual natural 

background conditions. In accordance with EPA guidance, which allows the use of either 

estimates of the 20 percent best or annual average natural background visibility 

conditions as the basis for calculating the deciview difference that individual sources 

would contribute for BART modeling purposes, MANE-VU opted to utilize the more 

conservative best conditions estimates approach because it is more protective of the 

region. 

The 2002 baseline modeling provides an estimate of the maximum improvement in 

visibility at Class I Areas in the region that could result from the installation of BART 

controls (the maximum improvement is equivalent to a “zero-out” of emissions). In 

virtually all cases, the installation of BART controls would result in less visibility 

improvement than what is represented by a source’s 2002 impact, but this approach does 

provide a consistent means of identifying those sources with the greatest contribution to 

visibility impairment. 

In addition to modeling the maximum potential improvement from BART, MANE-VU 

also determined that 98 percent of the cumulative visibility impact from all MANE-VU 

BART eligible sources corresponds to a maximum 24-hr impact of .22 dv from the NWSdriven data and 0.29 dv from the MM5 data. As a result, MANE-VU concluded that, on 

the average, a range of 0.2 to 0.3 dv would represent a significant impact at MANE-VU 

Class I areas, and sources having less than 0.1 dv impact are unlikely to warrant 

additional controls under BART.38 

Table 10-2 illustrates the modeled impacts (maximum) of Maine BART-Eligible sources 

on selected Class I areas in Maine and New Hampshire. For this table, SO4, NO3 and 

PM10 modeled impacts at these Class I areas were totaled to provide an estimate of the 

maximum 24-hr impact at these nearby Class I areas. It should be noted that a number of 

BART-eligible sources (highlighted) have less than a 0.1 deciview impact on Class I 

areas. 

38 As an additional demonstration that sources whose impacts were below the 0.1 dv level were too small to 

warrant BART controls, the entire MANE-VU population of these units was modeled together to examine 

their cumulative impacts at each Class I suite. The results of this modeling demonstrated that the 

maximum 24-hour impact at any Class I area of all modeled sources with individual impacts below 0.1 dv 

was only a 0.35 dv change relative to the estimated best days natural conditions at Acadia National Park. 

This value is well below the 0.5 dv impact recommended by EPA for exemption modeling and used by 

most other RPOs. 
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10.6 The Maine BART Analysis Protocol 

40 CFR 51.308(e)(1)(ii)(A) requires that, for each BART-eligible source within the state, 

any BART determination must be based on an analysis of the best system of continuous 

emission control technology available and the associated emission reductions achievable. 

In addition to considering available technologies, this analysis must evaluate five specific 

factors for each source: 

1. The costs of compliance, 

2. The energy and non-air quality environmental impacts of compliance, 

3. Any existing pollution control technology in use at the source, 

4. The remaining useful life of the source, and 

5. The degree of visibility improvement which may reasonably be anticipated 

from the use of BART. 

Although Maine did not exempt any BART-eligible sources from a BART determination, 

it did utilize the MANE-VU zero-out modeling (described in the previous section) as a 

surrogate for estimating the visibility improvement reasonably expected from the 

application of controls. As previously highlighted in Table 10-2, there are ten BARTeligible sources with less than 0.1 deciview impact at any Class I area, with these impacts 

ranging from a low of 0.0018 deciviews to a higher (but still insignificant) 0.0822 

deciviews. Since zero-out modeling shows that the elimination of all emissions from 

these sources would provide only insignificant visibility benefits at nearby Class I areas, 

and recognizing that the majority of these units already have controls fully satisfying 

BART requirements, the Department used the “anticipated visibility improvement from 

BART” factor to determine the scope of the BART analysis and whether visibility impact 

modeling need be performed by specific sources. The Maine approach is consistent with 

that used by other MANE-VU states that are not allowing sources to utilize exemption 

modeling. With the Maine approach, all BART-eligible sources were required to 

undertake an engineering analysis of their existing and possible future controls. If an 

emissions unit was found to be well-controlled (in comparison with possible future 

controls), and the visibility impacts of the unit relatively small39 as determined by the 

MANE-VU zero-out modeling, BART was determined by existing controls, and 

additional visibility impact modeling was not necessary (for a more detailed look at 

Maine’s BART process, see Attachment M-1). 

10.7 Summary of Maine BART Determinations 

The following section details the BART determinations for all BART-eligible sources in 

Maine. All BART requirements are incorporated in a Title V air emissions license 

(operating permit) for each source; draft Title V licensee are included in Attachment M. 

 

39 Sources with less than 0.1 deciview impact on Class I areas are presumed to have a small impact. 
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Table 10-2 

Modeled Impacts (Deciviews) of Maine BART-Eligible Sources at Selected MANEVU Class I Areas 

(Sources with < 0.1 deciview total impact highlighted) 

Facility Name Stack Name NWS CALPUFF MM5 CALPUFF 

 Total SO4 NO3 PM10 Total SO4 NO3 PM10 

 24-hr dv impact 24-hr dv impact 

FPLE Wyman 

Station Boiler_4 0.1423 0.1276 0.0334 0.0010 0.4749 0.3846 0.1072 0.0005 

FPLE Wyman 

Station Boiler_3 0.2212 0.1715 0.0704 0.0004 0.3049 0.2545 0.0508 0.0014 

Domtar Ind. #9_Power_Boiler 1.3630 0.2828 0.7988 1.3134 1.6506 0.1815 0.7279 1.3717 

Domtar Ind. Lime_Kiln 0.5296 0.0559 0.4309 0.1207 0.4589 0.0427 0.3820 0.1048 

Dragon Products Kiln 2.0155 0.2434 1.7614 0.0604 1.8626 0.3208 1.7234 0.0413 

Red Shield 

Acquisition, Old 

Town #4_Recovery_Boiler 0.2425 0.0634 0.1633 0.0173 0.2631 0.0424 0.2070 0.0391 

Red Shield 

Acquisition, Old 

Town Lime_Kiln 0.0851 0.0171 0.0433 0.0278 0.1338 0.0138 0.0855 0.0463 

Verso, Bucksport Boiler_#5 0.0543 0.0260 0.0267 0.0021 0.1591 0.0817 0.0721 0.0098 

SAPPI Somerset Recovery_Boiler 0.2159 0.0151 0.1971 0.0087 0.4421 0.0179 0.4168 0.0158 

SAPPI Somerset Smelt_Tanks_#1_and_#2 0.0108 0.0034 0.0000 0.0095 0.0000 0.0000 0.0000 0.0000 

SAPPI Somerset Lime_Kiln 0.0380 0.0270 0.0105 0.0012 0.0651 0.0455 0.0187 0.0010 

Verso, 

Androscoggin Power_Boiler_#1 0.6948 0.5720 0.1235 0.0094 1.7631 1.2176 0.5867 0.0290 

Verso, 

Androscoggin Power_Boiler_#2 0.7223 0.5948 0.1287 0.0095 1.8289 1.2646 0.6105 0.0293 

Verso, 

Androscoggin 

Waste_Fuel_Incinerator 

Boiler_ 0.4256 0.0036 0.3651 0.0591 0.4956 0.0064 0.4544 0.0367 

Verso, 

Androscoggin Recovery_Boiler_#1_and_#2 0.1101 0.0454 0.0598 0.0078 0.3856 0.0952 0.2723 0.0215 

Verso, 

Androscoggin Smelt_Tank_#1 0.0139 0.0002 0.0000 0.0137 0.0122 0.0002 0.0000 0.0120 

Verso, 

Androscoggin Smelt_Tank_#2 0.0129 0.0004 0.0000 0.0125 0.0135 0.0006 0.0000 0.0129 

Verso, 

Androscoggin Lime_Kiln_A 0.0441 0.0001 0.0273 0.0167 0.0457 0.0004 0.0337 0.0123 

Verso, 

Androscoggin Lime_Kiln_B 0.0296 0.0001 0.0197 0.0098 0.0293 0.0004 0.0228 0.0062 

Verso, 

Androscoggin Flash_Dryer 0.0222 0.0044 0.0173 0.0005 0.0252 0.0097 0.0175 0.0003 

Katahdin Paper 

Millinocket PB_#4 0.8293 0.6630 0.1569 0.0210 0.4458 0.3832 0.1164 0.0216 

Lincoln Paper and 

Tissue Recovery_Boiler_#2 0.1151 0.0141 0.0806 0.0224 0.1200 0.0073 0.0882 0.0322 

Rumford Paper PB_#5 0.0369 0.0039 0.0327 0.0026 0.1025 0.0108 0.0897 0.0020 

> 0.1 dv TOTAL and a pollutant > 0.1 dv TOTAL only 

10.7.1 Cap-Outs and Shutdowns

EPA guidance allows BART-eligible sources to adopt a federally enforceable permit 

limit to permanently limit emissions of visibility impairing pollutants to less than 250 

tons per year, thereby “capping-out” of BART. Four Maine sources capped out of 

BART: 
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1. Katahdin Paper Company, LLC 

2. Red Shield Acquisition, LLC 

3. Rumford Paper Company 

4. Verso Bucksport, LLC 

These sources have actual emissions of visibility impairing pollutants of fewer than 250 

tons per year, and are BART-eligible only because their potential emissions (PTE) 

exceed the statutory threshold of 250 tons per year. Pursuant to their requests, the Maine 

DEP has established federally enforceable permit conditions that limit the PTE of these 

units to less than the statutory threshold of 250 tons per year for all visibility impairing 

pollutants, which makes these units not subject to BART requirements. 

Federally enforceable terms and conditions were established for each source that limit the 

PTE for SO2, PM10 and NOx to less than 250 TPY. Note that 

if, in the future, the source requests an increase in PTE greater than 250 tons per year per 

visibility impairing pollutant, then they shall be subject to the Best Available Retrofit 

Technology (BART) provisions of the Environmental Protection Agency’s (EPA) 

Regional Haze Program Requirements (40 Code of Federal Regulations, Part 51, Section 

308). 

10.7.2 Maine BART Determinations

In general, the following determinations summarize the controls and limits that are 

currently required under existing air emission licenses (as noted), or will be required 

specifically due to BART. 

1. Domtar Maine, LLC 

The Domtar Woodland Pulp facility is a pulp mill, which utilizes the Kraft Pulping 

process and produces market pulp. The Mill also operates support facilities including 

woodyards, wastewater treatment plant, sludge press, pulp production labs, 

environmental labs, finishing, shipping, and receiving operations, storage areas, a landfill, 

and a power boiler. There are two BART eligible units at the facility; the #9 Power 

Boiler, and the Lime Kiln. 

#9 Power Boiler is rated at 625 MMBtu/hr and was placed into operation in 1971. #9 

Power Boiler is fueled primarily by biomass but is also licensed to burn #6 fuel oil, 

sludge, TDF, specification waste oil, HVLC, LVHC, mill yard waste, oily rags, stripper 

off-gas, and propane. Emissions are controlled using a variable-throat wet venturi 

scrubber and low-NOx burners. The Lime Kiln is rated at 75 MMBtu/hr and was placed 

into operation in 1966. Emissions are controlled using a variable-throat wet venturi 

scrubber and a Ceilcote cross-flow scrubber. The Lime Kiln is fueled by #6 fuel oil. 
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BART Analysis Summary 

#9 Power Boiler 

PM: Domtar evaluated the use of Fabric Filters, Wet Electrostatic Precipitator (WESP), 

Dry Electrostatic Precipitator (DESP), and Wet Scrubbers to control PM at the #9 Power 

Boiler. Fabric filters were found not technically feasible due to fire risk from 

combustible fly-ash, while WESP is not technically feasible due to operational 

difficulties with multi-fuel boilers. A DESP could not be installed post-scrubber due to 

excess moisture levels, but could be installed upstream. A DESP was evaluated and 

found to provide a 98-99% control efficiency for biomass a 90% efficiency for oil (for 

comparison, a wet scrubber provides an 85-98% control efficiency) . Domtar estimated 

the cost for DESP installation at $4,640 per ton of PM removed, and found that DESP is 

not a cost-effective option. 

SO2: Power Boiler #9 is currently controlled through the use of a wet scrubber and low 

sulfur fuel (biomass). Domtar did not investigate other control technologies because the 

combination of low sulfur fuel and wet scrubber provides maximum emission reductions 

from this unit. 

NOx: Domtar identified a number of potential NOx control strategies for use on Power 

Boiler #9, including: NOx tempering, flue gas recirculation (FGR), selective noncatalytic reduction (SNCR), selective catalytic reduction (SCR), low NOx burners and 

good combustion practices. Several potential NOx controls were found to be technically 

infeasible, and did not warrant further investigation. NOx tempering is not technically 

feasible due to reduced thermal efficiency and increased fuel usage, SCR is not 

technically feasible due to the increased frequency of catalyst fouling from multi-fuel 

boilers, and FGR is not technically feasible based on previous failed FGR trials 

conducted on the #9 Power Boiler. SNCR, with a 30-40% control efficiency, and low 

NOx Burners, with 10% control efficiency, were identified as technically feasible control 

strategies. Domtar’s analysis estimated the cost-effectiveness of SNCR at $7,360 per 

ton, and noted that SNCR has a reduced effectiveness on boilers with significant load 

swings (such as Power Boiler #9). Given the low cost-effectiveness of SNCR, Domtar 

identified the continued use of low NOx burners as BART. 

Lime Kiln 

PM: The Lime Kiln is subject to the MACT standard for PM found in 40 CFR, Part 63, 

Subpart MM. According to 40 CFR, Part 51, Appendix Y, According to 40 CFR Part 51, 

Appendix Y, Section IV (C), an exemption is made that states “We believe that, in many 

cases, it will be unlikely that States will identify emission control standards more 

stringent than the Maximum Achievable Control Technology (MACT) standards without 

identifying control options that would cost many thousands of dollars per ton. Unless 

there are new technologies subsequent to the MACT standards which would lead to costeffective increases in the level of control, you may rely on the MACT standards for the 

purposes of BART.” Since this current MACT requirement satisfies the requirements of 

BART, no further analysis was undertaken. 
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SO2: Domtar identified the use of a wet scrubber and in-process capture as feasible 

technologies for the control of SO2 from the lime kiln. Since both technologies are 

currently employed by Domtar (including two wet scrubbers), no further analysis was 

necessary. 

NOx: A number of potential NOx control strategies were identified for the lime kiln, 

including: SNCR, SCR, non-selective catalytic reduction (NSCR), FGR, low NOx 

burners and good combustion practices. The impracticality of installing chemical 

injection nozzles inside a rotating Kiln drum makes SNCR technically infeasible. SCR 

and NSCR are not feasible due to the known presence of catalyst fouling substances in 

the Lime Kiln. FGR is not feasible as it reduces the temperature in the flame zone, thus 

hindering the chemical reaction taking place in the Lime Kiln. Low NOx burners are a 

non-demonstrated technology and are not listed in the EPA BACT/RACT/LEAR 

Clearinghouse for Lime Kiln emissions control. Good combustion practices are the only 

feasible option, which is already employed at the Lime Kiln. No further analysis is 

necessary. 

BART Determination for Domtar 

Unit PM SO2 NOx

Control 

Type 

Emission 

Limit and 

Reference 

Control Type Emission 

Limit and 

Reference 

Control 

Type 

Emission 

Limit and 

Reference 

#9 Power 

Boiler 

Wet 

scrubber 

0.15 

lb/MMBtu 

(Existing 

Title V 

license) 

Wet scrubber 0.3 

lbs/MMBtu 

on a 24-

hour basis 

(BART 

order) 

Low-NOx

burners 

0.4 

lb/MMBtu 

on a 24-

hour basis 

(Existing 

Title V 

license) 

Lime 

Kiln 

Wet 

scubber 

Compliance 

with 40 

CFR Part 63 

Subpart 

MM 

Wet 

scrubber/Process 

control 

8.3 lbs/hr. 

(Existing 

Title V 

license) 

Good 

combustion 

practices 

120 ppmvd 

@10% O2 

(Existing 

Title V 

license) 

2. Dragon Products Company 

Dragon operates a cement manufacturing facility in Thomaston. The facility, built in 

1971, was initially a wet process cement kiln that was converted to the more efficient dry 

cement manufacturing process beginning in 2003. The modernization project converted 

the existing wet process cement kiln to a dry process (preheater/precalciner type), 

converted the existing (wet) raw mill to a pregrinding finish cement mill, and improved 

other ancillary operations within the facility. The planned annual production rate of the 

new facility is approximately 766,500 tons of clinker.

The BART eligible kiln system is a single dry process rotary kiln and inline raw mill 

equipped with a preheater/precalciner. Various allowable fuels, including petcoke, #2 
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fuel oil, #4 fuel oil, specification waste oil, non-specification waste oil, whole tires, and 

tire chips provide thermal energy necessary to convert raw materials (limestone, silica, 

iron ore, fly ash, and/or other raw material additives) into calcium silicates or ‘clinker’. 

Hot flue gases from the kiln flow counter-current to the feed material up the length of the 

kiln. Heat is transferred to the fed material from the direct contact of the flue gases in the 

kiln and preheater/precaliner tower. 

BART Analysis Summary

Dragon submitted a 5-step BART analysis of the technical feasibility and cost of 

compliance, the energy and non-air quality impacts of compliance, any existing air 

pollution control technology in use at the source, the remaining useful life of the source, 

and the degree of visibility improvement anticipated from the use of BART (a CALPUFF 

version 5.8 analysis was performed by Dragon). 

PM: Emissions of PM from the kiln system are generated as a function of the clinker 

production process. The kiln system is subject to 40 CFR Part 63, Subpart LLL, National 

Emission Standards for Hazardous Air Pollutants from the Portland Cement 

Manufacturing Industry. Since the MACT is current and Dragon complies with the 

particulate matter limits in §63.1343 and uses a fabric filter dust collector for PM10

control, no further BART analysis was performed. 

SO2:Emissions of SO2 from cement kilns are generally related to the inherent SO2

removal efficiency present in the kiln system operation itself, the pyritic sulfur 

concentration of the raw feed materials, the sulfur to alkali ratio of the raw feed materials, 

and whether the prevailing condition of the system is oxidizing or reducing. Dragon 

identified wet scrubbing, semi-dry scrubbing, dry scrubbing, fuel switching, and process 

alterations as possible retrofit control technologies for reducing SO2 emissions. 

Wet caustic scrubbing, where one or more soluble components of an acid gas are 

dissolved in a liquid with a low volatility, semi-dry scrubbing, based on atomizing a 

reagent slurry stream containing lime and contacting the flue gases in a spray dryer type 

vessel, and dry scrubbing, consisting of injecting a dry reagent into the gas stream prior 

to the particulate matter control device, were considered technically feasible for the kiln 

system and were further evaluated40. The three scrubbing options were reviewed further, 

and the results are in the following table: 

 

40 A dry scrubbing system is currently installed on the kiln system but is not operated. 
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Control 

Technology 

Expected 

SO2

Emission 

Rate 

(tons/yr) 

Emissions 

Performance 

Level 

Expected 

SO2

Emissions 

Reductions 

(tons/yr) Cost of Compliance 

Wet 

Scrubbing 

49.0 95% 46.6 Total Cap. Investment: $9,419,115 

Total Annualized Cost:$2,238,950 

Ave Cost Effectiveness:$48,098/ton 

Ave Cost Effectiveness per deciview: 

 $12,508,101/dv 

Semi-Dry 

Scrubbing 

49.0 90% 44.1 Total Cap. Investment: $2,359,464 

Total Annualized Cost:$675,978 

Ave Cost Effectiveness:$15,328/ton 

Ave Cost Effectiveness per deciview: 

 $3,907,387/dv 

Dry 

Scrubbing 

49.0 50% 24.5 Total Cap. Investment: $0 

Total Annualized Cost:$245,737 

Ave Cost Effectiveness:$10,030/ton 

Ave Cost Effectiveness per deciview: 

 $2,254,468/dv 

Based on capital costs associated with the additional retrofit controls, the resultant SO2

control cost effectiveness values, and the predicted visibility at the nearest Class I area, it 

was determined that these are not viable BART options. 

 

Fuel switching and process alterations were also evaluated, but were not found to be 

viable control options. 

NOX: Emissions of NOX from cement kilns are generally related to thermal NOX, fuel 

NOX, and raw feed material NOX. Dragon identified fuel switching, process optimization, 

flue gas recirculation (FGR), indirect fuel firing, staged air combustion/mid-kiln firing, 

low NOX burners, selective Non-Catalytic Reduction (SNCR), and Selective Catalytic 

Reduction (SCR) as available NOx control retrofit technologies. 

Fuel switching was not considered technically feasible since the nitrogen content of the 

fuel used in the kiln burning zone has little or no effect on NOX generation in a portland 

cement kiln. Flue gas recirculation was not considered technically feasible since the 

effectiveness of FGR relies on cooling the flame and generating a reducing combustion 

atmosphere to reduce thermal NOX emissions, which is not compatible with the high 

flame temperature and an oxidizing combustion zone atmosphere in the kiln system 

required to produce quality clinker. SCR was not considered technically feasible since 

there are no full scale SCR systems (ammonia injection upstream of a catalyst bed) in 

operation at cement kilns in the United States due to various concerns including exhaust 

temperature and plugging. 

Process optimization is currently being used on the kiln system, with advanced computer 

controls and instrumentation to improve overall facility operation and fuel efficiency. 
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Indirect fuel firing is currently the kiln system’s method of operation, whereby pulverized 

solid fuel from a solid fuel mill is captured in a cyclone or fabric filter and is stored 

before being conveyed to the kiln. This separates the mill conveyance air from the fuel 

and the fuel is introduced in a controlled manner from storage, reducing primary kiln 

combustion air to less than 10% of the total combustion air (in a direct-fired cement kiln, 

the primary combustion air can make up to 20% of the total combustion air). Staged air 

combustion/mid-kiln firing is currently being used in the kiln system to reduce kiln 

stratification and improve combustion of the fuel, which aids in reducing emissions. Low 

NOX burners are currently being used on the kiln system. SNCR is currently being used 

on the kiln system, with ammonia injection at a location in the correct temperature range 

for proper reaction to reduce NOX emissions. 

Dragon initially proposed the use of the existing NOX controls as they are currently 

operated as BART. However, the Department requested additional information on the 

use of the SNCR technology at the facility relating to further NOX control. Dragon 

supplied possible operational changes to the existing SNCR control unit including: 

increasing the operating time of the SNCR control unit, relocating the reagent injection 

nozzles, changing the reagent used in the SNCR control unit, and increasing the injection 

rate of the SNCR control unit reagent. The unit is already operated whenever the kiln is 

in operation so changing the operating time is not feasible. Relocating the injection 

nozzles or changing the reagent (19% aqueous ammonia) is not feasible, since the SNCR 

unit operates at the optimum injection point and reagent type based on the original trial 

test. Increasing the injection rate is a feasible option. 

 

Records show that from April 2005 through December 2008, the SNCR operated at an 

average control efficiency of approximately 22%, and in 2008, the efficiency was slightly 

lower at 18%. Since the June 18, 2008 comments of the MACT standards for the 

Portland Cement amendments, EPA has stated that that ‘for an SNCR (control unit) with 

optimal injection configuration and reagent injection rate, a 50% NOX emission reduction 

represents a reasonable level of performance of SNCR over the long term,.” The 

Department requested that Dragon assess the operation of the SNCR at 50% efficiency. 

Dragon performed an operational change impact analysis with the following results: 

Control 

Technology 

Expected 

NOX

Emission 

Rate 

(tons/yr) 

Emissions 

Performance 

Level 

Expected 

NOX

Emissions 

Reductions 

(tons/yr) Cost of Compliance 

SNCR 

operating at 

50% 

1130.6 927.1 565.3 Total Cap. Investment: $0 

Total Annualized Cost:$1,483,877 

Ave Cost Effectiveness:$4101/ton 

Ave Cost Effectiveness per deciview: 

 $7,419,385/dv 

Dragon proposed no increased reagent reaction rate due to additional cost, additional 

ammonia slip, and no perceptible change in visibility at the nearest class I area (Acadia 
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National Park). However, the Department is setting a 45% removal efficiency 

requirement to further reduce NOX. 

BART Determination

The Department determined BART for Dragon as follows: 

BART Determination for Dragon Products Company 

Unit PM SO2 NOx

Control 

Type 

Emission 

Limit and 

Reference 

Control 

Type 

Emission 

Limit and 

Reference 

Control 

Type 

Emission 

Limit and 

Reference 

Kiln baghouse 9.3 lb/hr and 

0.3 lb/ton 

dry kiln feed 

(Existing 

Title V 

license; 40 

CFR Part 

63) 

N/A 70.00 lb/hr. 

on a 90-day 

rolling 

average 

(Existing 

Title V 

license) and 

200 

tons/year on 

a 12-month 

rolling 

average 

(BART 

order) 

SNCR 

45% control 

efficiency 

on a 24-hour 

basis 

(BART 

order) 

350.0 lb/hr 

on a 90-day 

rolling 

average and 

1533.0 tons 

per year on 

a 12-month 

rolling total 

basis 

(Existing 

Title V 

license) 

3. FPL Energy Wyman, LLC. 

FPLE Wyman is an 850-megawatt electric generating facility located on Cousins Island 

in Yarmouth, Maine. The plant consists of four generation units, all of which fire #6 

residual fuel oil. A fifth unit is a smaller oil-fired auxiliary boiler which provides building 

heat and auxiliary steam and a sixth unit is an emergency backup diesel generator that 

provides electricity for use on-site. There are two BART eligible units at the facilityUnit 3 and Unit 4. 

Boiler #3 is a Combustion Engineering boiler, installed in 1963, with a maximum design 

heat input capacity of 1190 MMBtu/hr firing #6 fuel oil (2% sulfur). The boiler is 

equipped with multiple centrifugal cyclones for control of particulate matter and 

optimization and combustion controls for NOX. Boiler #4 is a Foster Wheeler boiler, 

installed in 1975, with a maximum design heat input capacity of 6290 MMBtu/hr firing 

#2 or #6 fuel oil (0.7 % sulfur). The boiler is equipped with an electrostatic precipitator 

for control of particulate matter and optimization and combustion controls for NOX. 
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BART Analysis Summary

PM: Emissions of PM from oil fired boilers are a function of fuel firing.41 Both boilers 

#3 and #4 have high efficiency combustion systems in conjunction with PM control 

devices; boiler #3 having multiclones and boiler #4 having an ESP. The cost analysis of 

installing an ESP on boiler #3 resulted in pollutant removal cost effectiveness of 

$19,000/ton of PM removed and visibility improvement cost effectiveness of $143 

million per deciview of visibility improvement. This was determined to be excessive and 

not cost-effective. 

SO2: Emissions of SO2 from oil fired boilers are related to the sulfur in the fuel. FPLE 

Wyman identified the following available retrofit control technologies for reducing SO2

emissions from the oil fired boilers: low sulfur #2 fuel oil, reduced sulfur #6 fuel oil, and 

wet or dry scrubbers. Low sulfur #2 fuel oil (0.05% down to 0.0015%) and the use of 

reduced sulfur #6 fuel oil (1% or less) were considered technically feasible options. Post 

combustion controls of wet or dry scrubbers on large boilers were researched and 

generally only typically applied to coal fired boilers. The use of scrubbing systems on oil 

fired boilers is considered cost prohibitive and was not considered as a BART option. 

FPLE Wyman performed a cost analysis on lowering the sulfur content in both boilers. 

Boiler #3 currently fires 2% sulfur oil and boiler #4 currently fires 0.7% sulfur oil. The 

annual costs were calculated to be the following (based on the differential fuel costs): 

Boiler #3 Boiler #4 

% sulfur Annual Costs % sulfur Annual Costs

1.0 $0.68 million - - 

0.7 $0.80 million - - 

0.5 $3.2 million 0.5 $9.2 million 

0.3 $5.7 million 0.3 $18.3 million 

The visibility cost effectiveness, incremental visibility improvement, and incremental 

visibility cost effectiveness from switching from 2% sulfur to reduced sulfur content fuel 

oil for boiler #3 was the following: 

% Sulfur 

Ranked 

Visibility 

Impact 

Visibility Cost 

Effectiveness 

($/deciview) 

Incremental 

Visibility 

Improvement 

Incremental 

Visibility Cost 

Effectiveness 

($/deciview) 

1.0 1st 

8th 

$0.69 million 

$1.95 million 

- 

- 

- 

- 

0.7 1st 

8th 

$0.56 million 

$1.67 million 

0.44 dv 

0.13 dv 

$0.27 million 

$1.92 million 

 

41 It is estimated from the MANE-VU August 2006 document Contributions to Regional Haze in the 

Northeast and Mid-Atlantic United States, Tools and Techniques for Apportioning Fine Particle/Visibility 

Impairment in MANE-VU (pages 3-2, 4-7, 4-8) that course particulate matter has typically less than 4% of 

the contribution to visibility impairment at the MANE-VU Class I areas. 
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0.5 1st

 

8th 

$1.82 million 

$5.41 million 

0.35 dv 

0.12 dv 

$6.97 million 

$20.3 million 

0.3 1st 

8th 

$2.64 million 

$8.12 million 

0.37 dv 

0.10 dv 

$6.59 million 

$24.4 million 

The visibility cost effectiveness, incremental visibility improvement, and incremental 

visibility cost effectiveness from switching from 0.7% sulfur to reduced sulfur content 

fuel oil for boiler #4 was the following: 

% Sulfur 

Ranked 

Visibility 

Impact 

Visibility Cost 

Effectiveness 

($/deciview) 

Incremental 

Visibility 

Improvement 

Incremental 

Visibility Cost 

Effectiveness 

($/deciview) 

0.5 1st 

8th 

$22.3 million 

$39.8 million 

- 

- 

- 

- 

0.3 1st 

8th 

$19.5 million 

$35.2 million 

0.53 dv 

0.29 dv 

$17.3 million 

$31.6 million 

Based on the sulfur contributions in the Northeast and the information above, FPLE 

Wyman proposed 1% sulfur fuel oil for boiler #3 beginning in 2013, and the current 

sulfur limit of 0.7% for boiler #4 as BART. 

NOX: Emissions of NOX from oil fired boilers are from thermal and fuel NOX. In order 

to minimize NOX emissions, FPLE Wyman installed combustion control technologies 

pursuant to 06-096 CMR 145, NOX Control Program Regulation. FPLE Wyman 

installed combustion control technology upgrades including low NOX fuel atomizers, 

improved swirler design, and overfire and interstage air ports. The burners were 

optimized and fuel/air flows were balanced to the burners on each unit. The combustion 

control technology upgrades were completed in April 2003 and reductions of 29-35% 

have been documented with boiler #3 and reductions of 24-47% have been documented 

with boiler #4 depending on each unit’s load. These reductions are equivalent to the use 

of SNCR (Selective Non-Catalytic Reduction) technology on the boilers. 

The cost analysis of installing additional NOX controls of regenerative selective catalytic 

reduction (RSCR) on the boilers in addition to the current combustion controls resulted in 

a pollutant removal cost effectiveness of $125,000/ton and $83,000/ton of NOX removed 

for boiler #3 and boiler #4, respectively. This was determined to be excessive and not 

cost effective. 

BART Determination

The Department determined BART for FPLE Wyman as follows: 
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BART Determination for FPLE Wyman 

Unit PM SO2 NOx

Control 

Type 

Emission 

Limit and 

Reference 

Control 

Type 

Emission 

Limit and 

Reference 

Control 

Type 

Emission Limit 

and Reference 

Boiler 

#3 

multiclones 0.15lb/MMBtu 

(BART order) 

Lowsulfur oil 1% sulfur 

by weight 

oil 

(BART 

order) 

Combustion 

engineering 

0.175 lb/MMBtu 

on a 90-day 

rolling average* 

(Existing Title V 

license; 06-096 

CMR Chapter 

145) 

Boiler 

#4 

ESP 0.1 lb/MMBtu 

(Existing Title 

V license; 40 

CFR Part 60) 

Lowsulfur oil 0.7% 

sulfur by 

weight oil 

(Existing 

Title V 

license, 40 

CFR Part 

60) 

Combustion 

engineering 

0.170 lb/MMBtu 

on a 90-day 

rolling 

average*(Existing 

Title V license; 

06-096 CMR 

Chapter 145) 

Alternatively, the NOx limit from boilers #3 and #4 averaged shall be limited to 0.165 lbs/MMBtu on a 90—

day operating rolling average 

4. Lincoln Paper and Tissue, LLC 

Lincoln Paper & Tissue (LPT) is an integrated kraft pulp and paper mill. Currently, LPT 

operates a hardwood digester and a softwood sawdust digester to produce pulp with 

approximately 50% recycled content. LPT uses one recovery boiler and a lime kiln in the 

recaust process for reclamation of the pulping chemicals. Also, LPT has three oil-fired 

boilers and one multi-fuel boiler to supply the mill with steam. The two paper machines 

produce specialty paper and the two tissue machines produce multi-ply dyed tissue. The 

pulp dryer machine produces bailed pulp which is either used by LPT or sold to other 

paper manufacturers. 

At LPT, the only BART-eligible source is the Recovery Boiler #2, which is used to 

recover chemicals and produce steam. Emissions exit through two identical 175 foot 

stacks. The recovery boiler is a straight fire unit burning black liquor, typically without 

combustion support from fossil fuel. Normally, oil is used only during start-ups, 

shutdowns and to stabilize operation of the boiler. 

The Recovery Boiler is exhausted to a wet bottom electrostatic precipitator (ESP) to 

control particulate emissions. This unit also serves to re-introduce salt cake into the 

black liquor which further concentrates the solids content. 

BART Analysis Summary

The LPT BART analysis evaluated the best system of continuous emissions control 

technology available for each of the visibility-impairing pollutants (SO2, PM, and NOx). 

LPT’s BART analysis submittal demonstrated that additional emission controls are 

neither feasible nor necessary for Recovery Boiler #2. PM emissions are controlled with 
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the ESP to levels meeting compliance with MACT standards and therefore meet BART. 

SO2 emissions are controlled by proper operation of the recovery boiler, including a 

three-level staged combustion air control system, and limitations on fuel oil use and 

sulfur content. NOx emissions are minimized through staged combustion (having 

independently operating primary, secondary, and tertiary air dampers) and by the low 

nitrogen content of black liquor solids along with proper operation of the Recovery 

Boiler. Existing SO2 and NOx controls on the #2 Recovery Boiler were determined by 

the Department and EPA to meet BACT in the PSD/NSR licensing of the facility. As no 

new control technologies are available for further control of these pollutants from a 

recovery boiler the BACT determination constitutes BART compliance. Maine did not 

require additional visibility impact modeling because of the limited visibility impacts 

from this source.42 

BART Determination

The Department determined BART for Lincoln Paper and Tissue as follows: 

BART Determination for Lincoln Paper and Tissue 

Unit PM SO2 NOx

Control 

Type 

Emission 

Limit and 

Reference 

Control 

Type 

Emission 

Limit and 

Reference 

Control 

Type 

Emission 

Limit and 

Reference 

Recovery 

Boiler 

ESP 0.044 grains 

per dry 

standard 

cubic foot 

(0.044 

gr/dscf) 

(Existing 

Title v 

license; 40 

CFR Part 

63) 

Low-sulfur 

oil 

141 ppmv 

(dry basis) 

@8% O2 on 

a 24-hour 

block 

average 

basis 

(Existing 

Title v 

license) 

Combustion 

engineering 

233 ppmv 

(dry basis) 

@ 8% O2 on 

a 24-hour 

block 

average 

basis 

(Existing 

Title v 

license) 

5. SD Warren Company, Somerset 

SD Warren Company (SDW) is an integrated kraft pulp and paper mill. Whole logs, 

chips, and biomass, are delivered to the mill by truck and/or train. The logs are sawn, 

debarked, chipped and stored in the mill’s woodyard. The biomass is stored in piles and 

then conveyed to the boilers. The chips are stored in piles and then conveyed to the chip 

bin, chip steaming vessel, and then the digester. SDW operates one Kamyr continuous 

digester to produce pulp (hardwood, softwood, or any combination thereof), one recovery 

boiler and one lime kiln in the recaust process for reclamation of the pulping chemicals. 

There are two multi-fuel boilers and an oil fired package boiler to supply the mill with 

steam. SDW has three paper machines which produce paper. There are also two pulp 

machines. One pulp machine has a steam operated dryer and both machines produce 

 

42 Modeled visibility impacts attributable to Recovery Boiler #2 as 0.0073 deciviews (dv) for SO2, 0.0882 

dv for NOx, 0.0322 dv for PM, and 0.12 dv total impacts. 
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bailed pulp. The mill also operates support facilities, including the wood yard, 

wastewater treatment plant, sludge presses, pulp and paper production labs, 

environmental labs, roll wrapping, shipping and receiving operations, and a landfill. 

There are four emissions units that were determined to be BART eligible at this facility; 

the Recovery Boiler, Smelt Tanks #1 and #2, and the Lime Kiln. The Recovery Boiler 

was installed in 1975-1976. It is used to recover chemicals from spent pulping liquors 

and to produce steam for mill operations. The Recovery Boiler is licensed to fire black 

liquor (spent pulping liquor), residual (#6) fuel oil, distillate (#2) fuel oil, and used oil. 

The Recovery Boiler is also licensed to combust low volume-high concentration (LVHC) 

and high volume-low concentration (HVLC) gases produced at various points in the 

pulping process. The current black liquor firing rate is 5.1 million pounds per day of 

black liquor solids (BLS). The licensed maximum black liquor firing rate will become 

5.5 million pounds per day of BLS after the boiler upgrade project is completed 

(scheduled for October 2010). The Recovery Boiler is subject to MACT standards for 

Chemical Recovery Combustion Sources at Kraft Soda, Sulfite, and Stand-Alone 

Semichemical Pulp Mills (40 CFR 63, Subpart MM). 

SDW operates two smelt tanks which were installed in 1975-1976. The Smelt Tanks 

operate in conjunction with the Recovery Boiler. Recovered sodium-based pulping 

chemicals, in the form of molten salts, are discharged from the bottom of the Recovery 

Boiler into the Smelt Tanks, where they are mixed with a water/caustic solution to form 

green liquor. The Smelt Tanks are subject to MACT standards for Chemical Recovery 

Combustion Sources at Kraft Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills 

(40 CFR 63, Subpart MM). 

The Lime Kiln was installed in 1975-1976. It is used to convert lime mud (principally 

calcium carbonate) to lime (calcium oxide). Fuel is fired in the Lime Kiln to generate the 

heat that is needed to convert lime mud to lime. The Lime Kiln is licensed to fire 

residual (#6) fuel oil, distillate (#2) fuel oil, used oil, and propane. The Lime Kiln is also 

licensed to combust LVHC gases and foul condensate streams. 

BART Analysis Summary

Recovery Boiler 

PM: SDW currently operates a three-chamber electrostatic precipitator (ESP) on the 

Recovery Boiler. SDW identified the following available retrofit technologies for control 

of PM from Kraft mill recovery boilers: electrostatic precipitators, wet scrubbers, and 

fabric filters. Wet scrubbers were eliminated as a feasible control strategy because the 

ESP currently installed is capable of a greater degree of emissions control at a lower 

operating cost. Fabric filters are generally considered to be equivalent to ESPs in regards 

to pollution control. However, fabric filters have not been applied to recovery boilers at 

Kraft mills and have been eliminated as a feasible control alternative. Since the controls 

already in place are considered the most stringent available, and these controls are 

already required by a federally enforceable condition, SDW was not required to perform 

the remaining steps of the control analysis. 
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SO2: SDW’s Recovery Boiler is currently equipped with a three-level staged combustion 

air control system and, after the upgrade project, will be equipped with a four-level 

staged combustion air system. SDW identified staged combustion systems and wet 

scrubbers as available retrofit technologies for control of SO2 from Kraft mill recovery 

boilers. SO2 emissions from recovery boilers occur due to the volatilization and 

subsequent oxidation of sulfur compounds that are present in the black liquor. Proper 

operation of the recovery boiler maximizes the conversion of sulfur compounds in the 

liquor to the principal constituents of the pulping chemicals. This occurs through capture 

of these sulfur compounds in the combustion zone of the boiler by sodium fume released 

from the smelt bed. Consequently, proper combustion control achieved through the use 

of staged combustion air systems results in effective control of SO2 emissions. The only 

available alternative for SO2 emission control is a wet scrubber. However, recovery 

boilers with a properly operated staged air combustion system operate at much lower 

concentrations of SO2 in the flue gas than emission units to which wet scrubbers are 

routinely applied. Since the controls already in place are considered the most stringent 

available, and these controls are already required by a federally enforceable condition, 

SDW was not required to perform the remaining steps of the control analysis. 

NOx: SDW’s Recovery Boiler is currently equipped with a three-level staged combustion 

air control system and is in the process of upgrading with a four-level staged combustion 

air system. SDW identified the following available retrofit technologies for control of 

NOx from Kraft mill recovery boilers: staged combustion systems, Selective NonCatalytic Reduction (SNCR), Selective Catalytic Reduction (SCR), Low NOx Burners, 

Flue Gas Recirculation, and Low-Temperature Oxidation. Emission controls which have 

been demonstrated on conventional steam boilers, including SNCR, SCR, flue gas 

recirculation, and low NOx burners, cannot be applied to, or have not been demonstrated 

to be feasible on, Kraft mill recovery boilers. There has been some small-scale work 

done on “low-temperature oxidation” where pure oxygen is injected into the evaporation 

process to drive ammonia from the black liquor. However, the company currently 

looking into this technology has advised SDW that they are not aware of any commercial 

size case where this technology has been used. Therefore, this technology is not 

considered technically-feasible. There are no technically-feasible alternatives for control 

of NOx emissions from recovery boilers other than proper operation of the boiler and the 

staged combustion control system. Since the controls already in place are considered the 

most stringent available, and these controls are already required by a federally 

enforceable condition, SDW was not required to perform the remaining steps of the 

control analysis. 

Smelt Tanks 

PM: SDW currently operates a wetted fan scrubber on each of the smelt tanks for control 

of particulate emissions. The scrubbing media for the scrubbers is either water or weak 

wash from the white liquor clarification system. SDW identified the following available 

retrofit technologies for control of PM from smelt tanks: electrostatic precipitators, wet 

scrubbers, fabric filters, and mist eliminators. The most common PM emission control 

system employed on smelt tanks is wet scrubbers. The use of wet scrubbers also provides 
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a secondary environmental benefit by controlling reduced sulfur compound emissions. 

The high moisture content of the smelt tank exhaust gases makes dry PM control 

systems, including fabric filters and dry ESPs, technically infeasible on this type of 

emission unit. The only remaining control technology, mist eliminators, provide a lower 

degree of PM emission control than the use of wet scrubbers. Since the controls already 

in place are considered the most stringent available, and these controls are already 

required by a federally enforceable condition, SDW was not required to perform the 

remaining steps of the control analysis. 

SO2: Since no combustion takes place within smelt tanks, SO2 is not generated within the 

emission unit. SDW was not able to identify any retrofit control technologies applicable 

to the control of SO2 emissions from smelt tanks. 

NOx: Since no combustion takes place within smelt tanks, NOx is not generated within 

the emission unit. SDW was not able to identify any retrofit control technologies 

applicable to the control of NOx emissions from smelt tanks. 

Lime Kiln 

PM: Particulate emissions from the Lime Kiln are currently controlled by a variable 

throat venturi scrubber system followed by a cyclone separator. SDW identified the 

following available retrofit technologies for control of PM from lime kilns: electrostatic 

precipitators, wet scrubbers, and fabric filters. Fabric filters have never been applied to 

kraft pulp mill lime kilns. They are generally deemed to be technically infeasible on lime 

kilns. ESPs provide a greater degree of particulate matter control than venturi scrubbers. 

However, the possible annual reduction in emissions to be gained by replacing the 

existing scrubber with an ESP is relatively small (estimated at under 40 ton/year). 

Additionally, the scrubber also helps control emissions of SO2 and reduced sulfur 

compounds. This beneficial removal of other pollutants is not available to lime kilns 

equipped with ESPs. Consequently, replacement of the existing scrubber with an ESP 

would be expected to result in higher TRS and SO2 emissions from the Lime Kiln. With 

respect to any possible improvement in visibility impacts associated with retrofitting an 

ESP on the Lime Kiln, the modeling result for current PM emissions from the Lime Kiln 

was 0.0463 dv; well below the State’s de minimis level of 0.1 dv. Therefore, any 

additional emission reductions that might be achieved by retrofitting the Lime Kiln with 

an ESP could only result in visibility impacts that would similarly be de minimis. 

 SO2: SO2 forms in the Lime Kiln from either the combustion of sulfur in the fuel or 

combustion of TRS compounds in the LVHC gases. Currently emissions of SO2 are 

controlled by using a combination of the inherent sulfur removal provided by operation 

of the kiln itself (i.e. extensive contact between burner exhaust gases and the calcium 

compounds in the kiln) enhanced through the use of a venturi wet scrubber (postcombustion). SDW also uses a caustic scrubber (pre-combustion) on the LVHC gases 

fired in the boiler. Firing of LVHC gases in the Lime Kiln without pre-treatment with the 

caustic scrubber causes formation of rings within the Lime Kiln leading to excessive 

down-time of the equipment. Emissions of SO2 from the Lime Kiln can vary 

significantly based on the amount of LVHC gases being fired and whether or not the 
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caustic scrubber is in operation. SDW identified the following available retrofit 

technologies for control of SO2 from lime kilns: lime kiln operation and wet scrubbers. 

Since the controls already in place are considered the most stringent available, and these 

controls are already required by a federally enforceable condition, SDW was not required 

to perform the remaining steps of the control analysis. 

NOx: NOx emissions from the Lime Kiln are currently controlled by good combustion 

controls and operation of the unit’s combustion air system. SDW identified the following 

available retrofit technologies for control of NOx from lime kilns: Combustion Air 

Systems controls, SNCR, SCR, Low NOx Burners, Flue Gas Recirculation. There are no 

technically feasible alternatives for control of NOx from lime kilns beyond the measures 

currently employed. Low NOx burner systems, which seek to reduce thermal NOx

formation through either combustion air or fuel staging, are not possible on the lime kilns 

because such systems negatively impact the efficiency, energy use, and calcining 

capacity of a lime kiln. Post combustion controls, such as SCR and SNCR, are not 

feasible for lime kilns. The temperature window necessary for the SNCR process (1500 

– 2000 F) is unavailable in a Kraft lime kiln. The high PM load at the exit of the kiln 

precludes the placement of the catalyst grid needed for the SCR process upstream of the 

PM control device, and the requisite temperature window required for this process (550 – 

750 F) is not available downstream of the PM control system. Since the controls already 

in place are considered the most stringent available, and these controls are already 

required by a federally enforceable condition, SDW was not required to perform the 

remaining steps of the control analysis. 

BART Determination

BART Determination for SD Warren 

Unit PM SO2 NOx

Control 

Type 

Emission 

Limit and 

Reference 

Control Type Emission Limit 

and Reference 

Control Type Emission 

Limit and 

Reference 

Recovery 

Boiler 

ESP 0.030 gr/dry 

standard 

cubic foot 

(dscf) when 

all three ESP 

chambers are 

online and 

0.038 gr/dscf 

when less 

than three 

chambers are 

online; 207 

lb/hr (NSR 

License #A19-77-2-A, 

40 CFR Part 

63, subpart 

MM) 

Low-sulfur 

oil 

100 ppmv (dry 

basis) @8% O2

on a 24-hour 

block average 

basis (BART 

order) 

1975lbs/hr 

(NSR License 

#A-19-77-2-A) 

Combustion 

engineering 

120 ppmv 

(dry basis) 

@ 8% O2 on 

a 24-hour 

block 

average 

basis; 750 

lb/hr (NSR 

License #A19-77-2-A) 
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Smelt 

Tanks #1 

and #2 

Wet scrubber 26lb/hr; 0.2 

lbs/ton BLS 

40 CFR Part 

63, subpart 

MM 

(Existing 

Title V 

license) 

N/A 26lb/hr 

(Existing Title 

V license) 

N/A N/A 

Lime Kiln Wet scrubber 0.10 gr/dscf 

@10% O2; 

58 lb/hr 

(Existing 

Title V 

license; 40 

CFR Part 63) 

Wet scrubber 1.92 

lb/MMBtu; 100 

tons/year limit 

on a 12-month 

rolling average 

(Existing Title 

V license) 

Staged 

Combustion 

120 ppmvw 

@ @10% O2 

(Existing 

Title V 

license) 

6. Verso Androscoggin 

The Verso Androscoggin pulp mill produces bleached Kraft pulp and groundwood pulp. 

The bleached pulp is produced in two separate process lines, designated “A” and “B”. 

Groundwood pulp is produced in another separate process line. Logs and wood chips are 

received in the Woodyard area, where they are stored and processed for eventual use in 

the Pulp Mill or Groundwood Mill. The Pulp Mill consists of two separate, parallel 

Kraft chemical pulping process lines. Pulp produced at the Verso Jay Mill is either used 

in the paper mill area or dried in the Flash Dryer for storage and/or sale. 

The Paper Mill consists of all the equipment and operations used to convert pulp to paper, 

including stock preparation, additive preparation, coating preparation, starch handling, 

finishing, storage and paper machines. Non-condensable gases (NCGs) collected 

throughout the process from certain units in the Pulp Mill are sent to the Lime Kilns for 

combustion. The high-volume, low-concentration (HVLC) emission streams from certain 

other units are collected and sent to the Regenerative Thermal Oxidizer where they are 

incinerated. The Mill produces steam and electric power for mill operations with Power 

Boilers #1 and #2 and the Waste Fuel Incinerator (WFI). 

There are ten BART-eligible units at Verso Jay: (1) Power Boiler #1; (2) Power Boiler 

#2; (3) Waste Fuel Incinerator; (4) Recovery Boilers # 1; (5) Recovery Boiler #2; (6) 

Smelt Tank #1; (7) Smelt Tank #2; (8) Lime Kiln A; (9) Lime Kiln B; and (10) Flash 

Dryer. Power Boilers #1 and #2 are each rated at 680 MMBtu/hr and began operation in 

1965 and 1967, respectively. Power Boilers #1 and #2 are licensed to fire #6 fuel oil, #2 

fuel oil, and used oil. The license currently limits the sulfur content of the fuel oil to no 

more than 1.8%, by weight. In addition, each boiler is equipped with low NOx burners. 

The operation of the two boilers is related to whether or not and how the cogeneration 

plant (three natural gas fired turbines) at the Mill is operating. Typically when the 

cogeneration plant is operating, Power Boilers #1 and #2 do not operate. When the 

cogeneration plant is not operating, both boilers are operated, however, one boiler will 

typically carry the bulk of the load and the other boiler is idled or run at low load. There 
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are occasions when both boilers operate at high load, but this is not a routine operating 

mode. 

The Waste Fuel Incinerator (WFI) is rated at 480 MMBtu/hr on biomass and 240 

MMBtu/hr on oil and began operation in 1976. While the WFI primarily fires biomass, 

fuel oils (#6 and #2 fuel oils, waste oil, and oily rags) can also be fired in the boiler. 

Sulfur dioxide and particulate matter emissions are controlled using a variable throat 

venturi scrubber and demister arrangement. When #6 fuel oil is fired in significant 

amounts, caustic is used in the wet scrubber to meet the applicable SO2 emission limit. In 

addition, the WFI is equipped with a combustion system designed to ensure the optimal 

balance between control of NOx and limitation of CO and VOC. 

Recovery Boilers #1 and #2 generate steam while regenerating chemicals used in the 

wood pulping process, and began operation in 1965 and 1976, respectively. Recovery 

Boilers (#1 and #2) have rated processing capacities of 2.50 and 3.44 million pounds per 

day of dry black liquor solids (MMlb/day of BLS), respectively. Inorganic material 

(smelt) from the bottoms of the recovery boilers is used to produce green liquor, which is 

a solution of sodium sulfide and sodium carbonate salts, when it is dissolved in water or 

weak wash in the Smelt Dissolving Tanks (#1 and #2). Although the recovery boilers 

primarily fire black liquor, they also fire small quantities of #2 and #6 fuel oils during 

startup, shutdown, and load stabilization conditions. The license currently limits the 

sulfur content of the fuel oils to no more than 0.5%, by weight. Particulate matter 

emissions from both recovery boilers are currently controlled using an electrostatic 

precipitator (ESP). 

Smelt Dissolving Tank #1 is rated at 2.50 MMlb/day of dry BLS and began operation in 

1965. Smelt Dissolving Tank #2 is rated at 3.44 MMlb/day of dry BLS and began 

operation in 1975. Inorganic materials from the recovery boiler floors drain into Smelt 

Dissolving Tanks #1 and #2 as molten smelt. In the smelt dissolving tanks, the smelt is 

mixed with weak wash to form green liquor which is pumped to the causticizing area. 

Sulfur dioxide (SO2) and particulate matter (PM10) emissions from Smelt Dissolving 

Tank #1 are controlled with a dual-nozzle wet cyclonic scrubber which utilizes an 

alkaline scrubbing solution and was installed in 1983. Sulfur dioxide (SO2) and 

particulate matter (PM10) emissions from Smelt Dissolving Tank #2 are controlled with a 

triple-nozzle wet cyclonic scrubber which utilizes an alkaline scrubbing solution and was 

installed in 1976. 

The “A” and “B” Lime Kilns process lime mud (calcium carbonate) from the causticizing 

area to regenerate calcium oxide (CaO). Inside the lime kilns, the lime mud is dried and 

heated to a high temperature where the lime mud is converted to lime (calcium oxide or 

CaO). “A” and “B” Lime Kilns are each rated at an operating rate of 248 tons of calcium 

oxide (CaO) per day and a heat input of 72 MMBtu/hr and began operation in 1965 and 

1975, respectively. The lime kilns are licensed to fire #6 fuel oil, #2 fuel oil, propane, 

and used/waste oil. The license currently limits the sulfur content of the fuel oil to no 

more than 1.8%, by weight. The A and B Lime Kilns also serve as an incineration device 

(control device) for select sources of low volume high concentration (LVHC) noncondensable gases (NCG) from pulping operations at the mill. Particulate matter (PM10) 
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emissions are controlled from the “A” and “B” Lime Kilns using a fixed throat venturi 

scrubber. 

The Flash Dryer is used to dry pulp for resale or for storage and future use on one of 

Verso Androscoggin’s paper machines. The Flash Dryer has a rated heat input capacity 

of 84 MMBtu/hr and began operation in 1964. The flash dryer is licensed to fire #2 fuel 

oil, which contains a maximum sulfur content of 0.5% as defined by ASTM D396 

standards. Particulate matter emissions are controlled using a wet shower system and 

SO2 emissions are limited through the firing of #2 fuel oil. 

BART Analysis Summary

Power Boilers #1 and #2: 

PM: Verso did not identify or evaluate potential control technologies for the reduction of 

PM10 emissions from Power Boilers #1 and #2 because these units are subject to MACT 

Standards under section 112 of the CAA. In addition, Verso stated in their application 

that PM10 emissions are low based on the firing of fuel oil and that PM10 emissions from 

Power Boilers #1 and #2 have a minimal impact on visibility and a reduction in these 

emissions would have no impact on the contribution of either boiler to overall visibility 

impacts. Verso Androscoggin proposed that the final “Boiler MACT” standards (40 CFR 

Part 63, Subpart DDDDD) that the boilers are subject to will also represent BART for 

Power Boilers #1 and #2.

SO2: Verso Androscoggin identified and evaluated low sulfur fuels, wet scrubbing, dry 

scrubbing, and semi-dry scrubbing as potential control technologies in the reduction of 

SO2 emissions from Power Boilers #1 and #2. Low sulfur fuels and wet scrubbing 

control technologies were found to be technically feasible by Verso Androscoggin and so 

were evaluated further.43 A summary of Verso Androscoggin’s evaluation of the 

remaining viable SO2 control technologies (low sulfur fuels and wet scrubbing) is 

provided in the table below. 

SO2 BART Analysis Summary for Power Boilers #1 and #2 

 

43 Dry and semi-dry scrubbing control technologies were evaluated, however Verso Androscoggin found 

that control effectiveness levels would be low (<25%), downstream particulate matter control devices such 

as an ESP and/or fabric filter would need to be installed to collect and re-circulate the scrubbing material, 

and no applications of these technologies on fuel oil fired boilers like Power Boilers #1 and #2 were 

identified during Verso Androscoggin’s research of potential control technologies. 

Control 

Technology 

Control 

Effectiveness 

Cost 

Effectiveness 

($/ton removed) 

Energy and 

Other Impacts 

Greatest Visibility 

Improvement 

Natural 

Gas 

99% $3,334 Negligible 1.5 

#2 Fuel Oil 97% $3,341 Negligible 1.5 

0.7% 60% $631 Negligible 0.9 
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Sulfur #6 

Fuel Oil 

0.7% 

Sulfur #6 

Fuel Oil 

60% $631 Negligible 0.9 

Wet 

Scrubbing 

99% $2,278 Disposal 

Impacts 

1.5 

The cost effectiveness numbers in the table above are based on controlling SO2 emissions 

from Power Boilers #1 and #2 at the control effectiveness rates indicated in the table 

from the highest estimated two year average annual emissions between 2002 and 2008. 

In recent years (2008 and 2009) these boilers have been operating close to only 20% of 

the time, which for example, would result in an actual cost effectiveness of between 

$4,920 and $7,133 per ton of SO2 removed with the installation of a wet scrubber. The 

use of low sulfur fuels or a wet scrubber has the potential to reduce visibility impacts 

from Power Boilers #1 and #2 by a perceptible amount; however there are significant cost 

differences among the three low sulfur containing fuels evaluated by Verso 

Androscoggin and the wet scrubber. Based on Verso Androscoggin’s identification and 

evaluation of control technology options, they propose that the use of 0.7% sulfur #6 fuel 

oil is a feasible and justifiable cost at $631 per ton of SO2 reduced, but that the other low 

sulfur fuel options and the wet scrubbing option are not economically justifiable and do 

not represent BART. Therefore, Verso Androscoggin proposes that the use of lower 

sulfur (0.7%) #6 fuel oil in place of the higher sulfur (1.8%) #6 fuel oil currently fired, 

represents BART for control of SO2 emissions from Power Boilers #1 and #2.

NOx: Verso Androscoggin identified and evaluated selective catalytic reduction (SCR), 

low NOx burners (LNBs), selective non-catalytic reduction (SNCR), and combustion 

control methods (including an overfire air (OFA) system and a flue gas recirculation 

(FGR) system) as potential control technologies in the reduction of NOx emissions from 

Power Boilers #1 and #2. SCR and SNCR control technologies were found to be 

technically feasible and so were evaluated further. LNBs are currently installed and used 

on Power Boilers #1 and #2, and are estimated to provide a 15% reduction in NOx

emissions, so were not evaluated further. Combustion control methods were evaluated, 

however none were found to be viable control options for Power Boilers #1 and #2. 

Verso Androscoggin found that the size and design of Power Boilers #1 and #2 would 

provide little room for the installation of an overfire air system and that the application of 

a flue gas recirculation system would result in minimal reductions (7% to 15%) in NOx

emissions. A summary of Verso Androscoggin’s evaluation of the remaining viable NOx

control technologies (SCR and SNCR) is provided in the table below. 

Control 

Technology 

Control 

Effectiveness 

Cost 

Effectiveness 

($/ton removed) 

Energy and 

Other Impacts 

Greatest 

Visibility 

Improvement 

SCR 90% $5,271 Minor Impacts 1.7 

SNCR 35% $5,973 Minor Impacts 1.4 

120 
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121 

The cost effectiveness numbers in the table above are based on controlling NOx

emissions from Power Boilers #1 and #2 at the control effectiveness rates indicated in the 

table from the highest estimated two year average annual emissions between 2002 and 

2008. In recent years (2008 and 2009) these boilers have been operating close to only 

20% of the time, which for example, would result in an actual cost effectiveness of 

$16,313 per ton of NOx removed with the installation of SCR. Although the use of SCR 

or SNCR has the potential to reduce visibility impacts by a perceptible amount, Verso 

Androscoggin proposes that the cost effectiveness levels are not economically justifiable 

based on the limited use of Power Boilers #1 and #2. Based on Verso Androscoggin’s 

identification and evaluation of control technology options, they propose that the current 

use of LNBs represents BART for control of NOx emissions from Power Boilers #1 and 

#2 and that no additional level of control is justifiable as BART.

Waste Fuel Incinerator Boiler: 

PM: Verso Androscoggin did not identify or evaluate potential control technologies for 

the reduction of PM10 emissions from the Waste Fuel Incinerator Boiler (WFI) because 

this unit is subject to MACT Standards under section 112 of the CAA. Verso 

Androscoggin proposed that the final “Boiler MACT” standards (40 CFR Part 63, 

Subpart DDDDD) that the WFI is subject to will also represent BART for the WFI. 

SO2: Verso Androscoggin identified and evaluated low sulfur fuels, wet scrubbing, dry 

scrubbing, and semi-dry scrubbing as potential control technologies in the reduction of 

SO2 emissions from the WFI. While using low sulfur fuels is technically feasible, Verso 

Androscoggin believes that it is not a practically feasible option for the WFI based on the 

limited amount of fuel oil typically used in the boiler (less than 10% of the annual fuel oil 

heat input capacity). The WFI currently uses a water based wet scrubbing system for PM 

control with the addition of caustic to meet SO2 emission limits when firing #6 fuel oil in 

significant amounts. Dry and semi-dry scrubbing control technologies were not 

considered by Verso Androscoggin to be either practical or technically feasible for the 

WFI due to the fact that they could not find any applications of these technologies on any 

other biomass-fired grate type boilers like the WFI. Verso Androscoggin also believes 

that the cost of removing the existing wet scrubber and replacing it with a dry or semi-dry 

scrubbing system and a new ESP and/or fabric filter would be costly. A summary of 

Verso Androscoggin’s evaluation of the only remaining viable SO2 control technology 

(adding caustic to the existing wet scrubbing system) is provided in the table below. 

SO2 BART Analysis Summary for the Waste Fuel Incinerator

Control 

Technology 

Control 

Effectiveness 

Cost 

Effectiveness 

($/ton removed) 

Energy and Other 

Impacts 

Greatest 

Visibility 

Improvement 

Addition of 

Caustic to 

Existing Wet 

Scrubber 

50% $21,800 Disposal Impacts <0.1 
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The WFI has very low baseline SO2 emissions (~50 tons per year) due to the inherent low 

sulfur content and alkalinity of the primary fuel (biomass) and the small amount of fuel 

oil used in the WFI. In addition, during the limited amount of time that #6 fuel oil is used 

to provide a significant portion of the heat input to the WFI, caustic is added to the wet 

scrubber to control SO2 emissions. Based on Verso Androscoggin’s identification and 

evaluation of control technology options, they propose that additional control of SO2

emissions from the WFI cannot be justified as BART due to the imperceptible effect it 

would have on visibility. 

NOx: Verso Androscoggin identified and evaluated selective catalytic reduction (SCR), 

low NOx burners (LNB), selective non-catalytic reduction (SNCR), and combustion 

control methods (including an overfire air system and a flue gas recirculation system) as 

potential control technologies in the reduction of NOx emissions from the WFI. SCR and 

SNCR control technologies were found to be technically feasible and so were evaluated 

further. Since the WFI primarily fires biomass on the grate, LNBs would not be effective 

for the majority of the time that the WFI operates, thus Verso Androscoggin felt LNBs 

did not warrant further evaluation. Combustion control methods were evaluated, 

however none were found to be viable control options for the WFI due to the limited NOx

removal potential (<15%), potential impacts to other pollutants and boiler equipment, and 

the limited amount of room available for the installation of control equipment. A 

summary of Verso Androscoggin’s evaluation of technically feasible NOx control 

technologies (SCR, SNCR, and FGR) is provided in the table below. 

Control 

Technology 

Control 

Effectiveness 

Cost 

Effectiveness 

($/ton removed) 

Energy and 

Other Impacts 

Greatest 

Visibility 

Improvement 

SCR 90% $4,676 Minor Impacts 0.3 

SNCR 30% $5,944 Minor Impacts 0.1 

FGR 15% $17,010 Minor Energy 

Impacts 

<0.1 

Although the use of SCR has the potential to reduce visibility impacts by a perceptible 

amount, Verso Androscoggin proposes that the cost effectiveness levels are not 

economically justifiable for any of the control technologies evaluated, including SCR. 

Based on Verso Androscoggin’s identification and evaluation of control technology 

options, they propose that additional control of NOx emissions from the WFI cannot be 

justified as BART due to the capital costs ($3 million to more than $7.6 million) and cost 

effectiveness levels ($4,700 to more than $17,000 per ton of NOx removed). 

Recovery Boilers #1 and #2 

PM: Particulate matter (PM) emissions from Recovery Boilers #1 and #2 are currently 

controlled by an existing shared/common electrostatic precipitator (ESP). Verso 

Androscoggin did not identify or evaluate potential control technologies for the reduction 

of PM10 emissions from Recovery Boilers #1 and #2 because these units are subject to 

MACT Standards under section 112 of the CAA. Recovery Boilers #1 and #2 are 
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subject to MACT standards pursuant to 40 CFR Part 63, Subpart MM (MACT II). Verso 

Androscoggin reviewed the RACT/BACT/LAER Clearinghouse (RBLC) and believes 

that the current control configuration is the most current control technology in use on 

recovery boilers and that there are no new technologies subsequent to the MACT 

standard that should be considered. Based on this information, Verso Androscoggin 

proposed in its BART analysis that it was not necessary to expand the BART analysis for 

PM10 and therefore did not identify or evaluate potential control technologies for the 

additional reduction of PM10 emissions from Recovery Boilers #1 and #2. Verso 

Androscoggin proposes that “MACT II” standards (40 CFR Part 63, Subpart MM) that 

the boilers are currently subject to represent BART for PM10 emissions from Recovery 

Boilers #1 and #2.

SO2: Verso Androscoggin has found that sulfur dioxide (SO2) emissions from Recovery 

Boilers #1 and #2 are variable due to several factors including black liquor properties 

(e.g., sulfidity, sulfur to sodium ratio, heat value, and solids content), combustion air, 

liquor firing patterns, furnace design features, and type of startup fuel used. Both 

recovery boilers are low-odor design. Although each recovery boiler has the ability to 

utilize #2 fuel oil, #6 fuel oil, and used/waste oil for startup, shutdown, and load 

stabilizing conditions, fuel oil firing is not a typical operating scenario for the recovery 

boilers. SO2 emission levels during fuel oil firing conditions are directly related to the 

sulfur content of the fuel oils. Black liquor solids (BLS) firing produces sodium fume, 

which effectively scrubs SO2 emissions. Verso Androscoggin identified and evaluated 

wet scrubbing, dry scrubbing, and semi-dry scrubbing as potential control technologies in 

the reduction of SO2 emissions from Recovery Boilers #1 and #2, however none of these 

technologies were found to have been applied to recovery boilers and Verso 

Androscoggin believes that operation of these technologies could negatively affect the 

operation of Recovery Boilers #1 and #2. Based on Verso Androscoggin’s identification 

and evaluation of control technology options, they propose that each of the control 

technologies evaluated are not technically feasible and therefore were not evaluated 

further. Verso Androscoggin proposes that existing combustion controls represent BART 

for the control of SO2 emissions from Recovery Boilers #1 and #2. 

NOx: Kraft recovery boilers are a unique type of combustion source that inherently 

produce low levels of NOx emissions. Most of the NOx emissions produced by recovery 

boilers can be attributed to fuel based NOx resulting from the partial oxidation of the 

nitrogen contained in the black liquor. Both Recovery Boilers (#1 and #2) operate with a 

reducing zone in the lower part of the boiler and an oxidizing zone in the region of the 

liquor spray guns designed to provide secondary and tertiary staged combustion zones to 

complete combustion of the black liquor and minimize NOx emissions. 

Verso Androscoggin identified and evaluated selective catalytic reduction (SCR), low 

NOx burners (LNB), selective non-catalytic reduction (SNCR), and combustion control 

methods (including the addition of a fourth level or quaternary air system and a flue gas 

recirculation system) as potential control technologies in the reduction of NOx emissions 

from Recovery Boilers #1 and #2. SCR has not been applied or demonstrated 

successfully on any recovery boilers according to Verso Androscoggin and they do not 

know how the unique characteristics of recovery boiler exhaust gas constituents would 
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react with a SCR catalyst, so they did not further evaluate this control technology. Verso 

Androscoggin’s evaluation of LNB technology is that it is not feasible to use this 

technology in the firing of black liquor given its tar-like qualities and the method by 

which it is injected into the boiler and that it would have minimal results in the firing of 

fuel oils given the small amounts of fuel oils that are fired in the recovery boilers. Verso 

Androscoggin’s evaluation of SNCR control technologies resulted in a finding that there 

have been no applications of this technology on recovery boilers in the United States for 

a variety of reasons, including safety concerns associated with the risk of a smelt/water 

explosion should boiler tube walls corrode and leak near urea injection points and risks 

associated with an ammonia handling system for the SNCR. Operational concerns 

associated with SNCR were found to include the potential formation of acidic sulfates 

that could result in corrosion and a catastrophic boiler tube failure. As a result of Verso 

Androscoggin’s initial evaluation of SNCR, no further evaluation was conducted. 

Recovery Boilers #1 and #2 are currently designed and operated using low excess air 

combined with three levels of staged combustion to minimize NOx emissions. Additional 

combustion control methods were evaluated by Verso Androscoggin, however none were 

found to be viable control options for Recovery Boilers #1 and #2 due to the limited 

amount of space in the boilers to install a fourth or quaternary air system and due to the 

technical challenges re-circulating recovery boiler exhaust gases in a FGR system due to 

the unique characteristics of the exhaust gases. Based on Verso Androscoggin’s 

identification and evaluation of control technology options, they proposed that the 

existing combustion control methods represent BART and that additional control of NOx

emissions from Recovery Boilers #1 and #2 are not technically feasible and warrant no 

further evaluation. 

Smelt Tanks #1 and #2 

PM: Particulate matter (PM) emissions from Smelt Dissolving Tanks #1 and #2 are 

currently controlled by existing wet cyclonic scrubbers. Verso Androscoggin did not 

identify or evaluate other potential control technologies for the reduction of PM10

emissions from Smelt Dissolving Tanks #1 and #2 because these units are subject to 

MACT Standards under section 112 of the CAA. Smelt Dissolving Tanks #1 and #2 are 

subject to MACT standards under 40 CFR Part 63, Subpart MM (MACT II). Verso 

Androscoggin reviewed the RACT/BACT/LAER Clearinghouse (RBLC) and believes 

that the current control configuration is the most current control technology in use on 

smelt dissolving tanks and that there are no new technologies subsequent to the MACT 

standard that should be considered. Verso Androscoggin proposes that “MACT II” 

standards (40 CFR Part 63, Subpart MM) that the smelt dissolving tanks are currently 

subject to represent BART for PM10 emissions from Smelt Dissolving Tanks #1 and #2.

SO2: Verso Androscoggin has found that sulfur dioxide (SO2) emissions from Smelt 

Dissolving Tanks #1 and #2 are dependent on how much sulfur carries over from the 

respective recovery boilers with the smelt. Controlled smelt-water explosions in the 

smelt dissolving tanks can create SO2 as a result of the oxidation of the sulfur in the 

smelt. SO2 emissions from both smelt dissolving tanks combined are very low at 

approximately 5 tons per year. Verso Androscoggin proposes that BART for SO2

emissions from Smelt Dissolving Tanks #1 and #2 is no additional control based on the 
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125 

following: (1) SO2 emissions from the smelt dissolving tanks during the BART baseline 

period were and are expected to continue to be extremely low (~5 TPY, combined); (2) 

the smelt dissolving tanks and associated scrubbers are designed and operated to 

minimize SO2 emissions; (3) SO2 emissions from the smelt dissolving tanks have a 

minimal impact on visibility (<0.1 deciviews); and (4)additional control of SO2 emissions 

from the smelt dissolving tanks would have a minimal impact on overall visibility. 

NOx: Smelt Tanks #1 and #2 do not emit NOx.

Lime Kilns A and B 

PM: Particulate matter (PM10) emissions from the “A” and “B” Lime Kilns consist 

primarily of dust entrained from the combustion section of the kilns. This dust consists 

of sodium salts, calcium carbonate, and calcium oxide. PM10 emissions are currently 

controlled by existing venturi scrubbers. These units are also subject to MACT Standards 

under section 112 of the CAA, and 40 CFR Part 63, Subpart MM (MACT II). Verso 

Androscoggin reviewed the RACT/BACT/LAER Clearinghouse (RBLC) and believes 

that there are two control technologies that represent the most stringent PM control (ESPs 

and venturi scrubbers). Both ESPs and venturi scrubbers have been used to control PM 

emissions from lime kilns and both are capable of a high level of control. Verso 

Androscoggin proposes that use of the existing venturi scrubbers to control PM10

emissions from the “A” and “B” represents BART for the following reasons: (1) the 

existing venturi scrubbers maintain compliance with the MACT II PM emission limits; 

(2) the replacement of the existing venturi scrubbers with dry ESPs could increase SO2

emissions from the lime kilns when compared to use of the venturi scrubbers; (3) the 

replacement of the existing venturi scrubbers with wet ESPs would result in high capital 

costs ($1.5 million per kiln); and (4)visibility impacts from the lime kilns are minimal 

and installation of additional control would result in inconsequential improvement in 

visibility. 

SO2: Verso Androscoggin has found that a significant portion of the sulfur dioxide (SO2) 

formed during the combustion process in the lime kilns is removed as the regenerated 

quicklime in the kilns functions as a scrubbing agent. In addition, the NCG collection 

system is equipped with a scrubber that uses white liquor (sodium hydroxide or NaOH) 

and thus the sulfur loading from the NCGs is minimized. SO2 emissions from both lime 

kilns combined are very low at less than 4 tons per year primarily due to the alkalinity of 

the lime. Verso Androscoggin proposes that BART for SO2 emissions from the “A” and 

“B” Lime Kilns is no additional control based on the following: (1) SO2 emissions from 

the lime kilns during the BART baseline period were and are expected to continue to be 

extremely low (<4 TPY, combined); (2) there are no control technologies available for 

lime kilns that are more cost effective than the inherent scrubbing that occurs for SO2 due 

to the alkalinity of the lime in the process; (3) SO2 emissions from the smelt dissolving 

tanks have a minimal impact on visibility (<0.1 deciviews); and (4)additional control of 

SO2 emissions from the lime kilns would have a minimal impact on overall visibility. 

NOx: Verso Androscoggin identified and evaluated selective catalytic reduction (SCR), 

low NOx burners (LNB), and selective non-catalytic reduction (SNCR) as potential NOx 
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control technologies. Verso Androscoggin’s evaluation of SCR and SNCR as potential 

NOx control technologies revealed that they have not been installed on any lime kilns in 

the pulp and paper industry, and were also found to be technically infeasible, so were not 

evaluated further. Verso Androscoggin’s research with respect to lime kilns and LNB 

technology revealed that the technology is actually a combination of passive combustion 

control measures used to minimize NOx formation primarily from thermal NOx and to a 

lesser extent fuel NOx. These combustion control measures include careful design of the 

fuel feed system in order to ensure proper mixing of the fuel with air and burner “tuning” 

or optimization which impacts fuel burning efficiency and overall flame length. Verso 

Androscoggin already incorporates burner “tuning” in the operation and maintenance of 

the “A” and “B” Lime Kilns to optimize the relationship between NOx emissions and 

operating efficiency. Based on Verso Androscoggin’s identification and evaluation of 

control technology options, they propose that the current use of LNB (referred to as 

combustion control measures on lime kilns) represents BART for control of NOx

emissions from “A” and “B” Lime Kilns and that no additional level of control is 

technically feasible. Verso Androscoggin also notes in their BART analysis that existing 

NOx emissions from the “A” and “B” Lime Kilns have a minimal impact on visibility 

(<0.1 deciviews) and that additional control of NOx emissions would have a minimal 

impact on the overall improvement to visibility. 

Flash Dryer 

PM: Particulate matter (PM10) emissions from the Flash Dryer are currently controlled 

by the use of a wet shower system. Verso Androscoggin proposes that the application of 

add-on controls and the use of cleaner fuels are not practical considerations for 

controlling PM emissions from the Flash Dryers and that with potential visibility impacts 

from the Flash Dryer being extremely low, any emission reductions would have an 

inconsequential impact on visibility improvement. 

SO2: The Flash Dryer is limited to firing #2 fuel oil with a maximum sulfur content of 

0.5%, by weight and so has relatively low SO2 emissions. Although Verso Androscoggin 

could replace the use of #2 fuel oil with lower sulfur containing fuels such as low sulfur 

(0.05%) diesel fuel or natural gas, the Flash Dryer is predicted to have peak visibility 

impacts of 0.1 deciviews or less. Based on Verso Androscoggin’s identification and 

evaluation of SO2 control technology options for the Flash Dryer, they propose that no 

additional level of control is representative of BART. 

NOx: The Flash Dryer is not equipped with any NOx control equipment. NOx emissions 

from the Flash Dryer are primarily generated from the nitrogen component in the fuel oil. 

Verso Androscoggin currently uses good maintenance practices to minimize NOx

emissions from the Flash Dryer. Verso Androscoggin’s investigation of conventional 

NOx combustion controls (e.g., LNB, OFA, and FGR) lead to findings that they are either 

unavailable for installation on the Flash Dryer or are not feasible for a combustion source 

as small as the Flash Dryer. 
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BART Determinations: 

BART Determination for VERSO Androscoggin 

Unit PM SO2 NOx

Control 

Type 

Emission 

Limit and 

Reference 

Control Type Emission Limit 

and Reference 

Control Type Emission 

Limit and 

Reference 

Power 

Boilers #1 

and #2 

Low sulfur 

oil/ 

combustion 

control 

Compliance 

with 40 CFR 

Part 63 

Subpart 

DDDD 

Low sulfur 

fuel 

Low sulfur fuel 

oil containing 

no more than 

0.7 % sulfur, by 

weight. (BART 

order) 

Low NOx

burners 

0.447 

lbs/MMBtu 

on a 24-hour 

block 

average basis 

(Existing 

Title V 

license) 

Waste 

Fuel 

Incinerator 

Combustion 

controls, wet 

scrubber

Compliance 

with 40 CFR 

Part 63 

Subpart 

DDDD 

Wet scrubber 0.8 lbs/MMBtu 

on a 3-hour 

average 

(Existing Title 

V license) 

Combustion 

controls 

0.4 lbs/ 

MMBtu on a 

24-hour 

block 

average basis 

(Existing 

Title V 

license) 

Recovery 

Boiler #1 

ESP Compliance 

with 40 CFR 

Part 63 

Subpart MM 

Staged air 

combustion 

120 ppmdv 

@8% O2 on a 

30-day rolling 

average basis 

when operating 

at a black liquor 

recover rate of 

50% or higher. 

SO2 emissions 

shall not exceed 

140 ppmdv 

@8% O2 on a 

30-day rolling 

average basis 

when operating 

at a black liquor 

recover rate of 

less than 50% 

(BART order) 

Combustion 

controls 

(NSR) 

150 ppmdv, 

when 

corrected to 

8% % O2 on 

a 24-hour 

block 

average basis 

(BART 

order) 

Recovery 

Boiler #2 

ESP Compliance 

with 40 CFR 

Part 63 

Subpart MM 

(Existing 

Title V 

license) 

Staged air 

combustion

120 ppmdv 

@8% O2 on a 

30-day rolling 

average basis 

(Existing Title 

V license) 

Combustion 

controls 

(RACT) 

206 ppm

corrected to 

8% % O2 on 

a 24-hour 

block 

average basis 

(Existing 

Title V 

license) 
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Smelt 

Tanks #1 

and #2 

Wet cyclonic 

scrubber 

Compliance 

with 40 CFR 

Part 63 

Subpart MM 

(Existing 

Title V 

license)

Wet cyclonic 

scrubber 

Smelt Tank #1- 

2.7 lbs/hr 

Smelt Tank #2- 

3.9 lbs/hr 

(Existing Title 

V license) 

N/A N/A 

Lime 

Kilns A 

and B 

Venturi 

scubber 

Compliance 

with 40 CFR 

Part 63 

Subpart MM 

Venturi 

scubber 

6.7 Lbs/hr, 74.6 

tpy 

(Existing Title 

V license) 

Combustion 

controls 

(RACT) 

120 ppm @ 

10% O2

(stack test) 

(Existing 

Title V 

license) 

Flash 

Dryer 

Wet shower 5 lbs/hr 

(Existing 

Title V 

license) 

Low sulfur 

fuel (#2 oil) 

Low sulfur fuel 

oil containing 

no more than 

0.5 % sulfur, by 

weight 

(Existing Title 

V license) 

Good 

combustion 

practices 

 (Existing 

Title V 

license) 

11.8 lbs/hr 

10.8 Schedule for BART Implementation 

As provided in 40 CFR Section 51.308(e)(1)(iv) BART must be in operation for each 

applicable source no later than five years after SIP/TIP approval. Pursuant to 38 

M.R.S.A. §603-A, sub-§8 (b), the State of Maine is requiring that each source subject to 

BART shall install and operate BART as expeditiously as practicable but in no event later 

than January 1, 2013. 

As provided in 40 CFR Section 51.308(e)(1)(v) the Title V operating permits for BART 

sources must include a requirement that each source maintain the control equipment and 

establish procedures to ensure such equipment is properly operated and maintained. This 

requirement will be included in the Title V operating permit for each source subject to 

BART. The BART requirements for Maine Bart eligible sources will be federally 

enforceable through the Title V operating permit program and through incorporation in 

the Maine Regional Haze SIP. 

Copies of the draft Title V operating permits for each source are included in Attachment 

M 
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129 

11. Reasonable Progress Goals 

The Regional Haze Rule (40 CFR Section 51.308 (d)(1)) requires each state with Class I 

areas to establish reasonable progress goals providing for reasonable progress towards 

achieving natural visibility in each Class I area. In addition, EPA released guidance on 

June 7, 2007 to use in setting reasonable progress goals. The goals must provide 

improvement in visibility for the most impaired days, and ensure no degradation in 

visibility for the least impaired days over the State Implementation Plan (SIP) period. The 

State of Maine must also provide an assessment of the number of years it would take to 

attain natural visibility conditions if improvement continues at the rate represented by the 

reasonable progress goal. 

Under 40 CFR Section 51.308 (d)(1)(iv), consultation is required in developing 

reasonable progress goals. The rule states: 

In developing each reasonable progress goal, the State must consult with those 

States which may reasonably be anticipated to cause or contribute to visibility 

impairment in the mandatory Class I Federal area. In any situation in which the 

State cannot agree with another such State or group of States that a goal provides 

for reasonable progress, the State must describe in its submittal the actions taken 

to resolve the disagreement. In reviewing the State's implementation plan 

submittal, the Administrator will take this information into account in determining 

whether the State's goal for visibility improvement provides for reasonable 

progress towards natural visibility conditions. 

As discussed in Section 3, Maine consulted with states that contribute to visibility 

impairment at its Class I areas and with states that requested consultation with Maine 

regarding their Class I areas (New Hampshire, Vermont and New Jersey). Maine worked 

closely with these states during the consultation process and agrees with the reasonable 

progress goals established by New Hampshire, Vermont and New Jersey. 

In developing the reasonable progress goals the Class I state must also consider four 

factors (cost, time needed, energy & non-air quality environmental impacts, and 

remaining useful life). The state also must show that it considered the uniform rate of 

improvement and the emission reduction measures needed to achieve it for the period 

covered by the implementation plan, and if the state proposes a rate of progress slower 

than the uniform rate of progress, assess the number of years it would take to attain 

natural conditions if visibility improvement continues at the rate proposed. 

11.1 Calculation of Uniform Rate of Progress 

As a benchmark to aid in developing reasonable progress goals, MANE-VU compared 

the baseline visibility conditions to natural visibility condition at each Class I area. The 

difference between baseline and natural visibility conditions at each MANE-VU Class I 

area was used to determine the uniform rate of progress that would be needed during each 
5/27/2010 

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130 

implementation period in order to attain natural visibility. Table 11-1 presents baseline 

visibility, natural visibility and required uniform rate of progress for each MANE-VU 

Class I area. Visibility values are expressed in deciviews (dv) where a single-unit 

decrease would represent a barely perceptible improvement in visibility. 

Table 11-1 

Uniform Rate of Progress Calculation 

(all values in deciviews) 

Class I Area 

(2000-2004)

Baseline 

Visibility 

(deciviews) 

(20% Worst 

Days) 

Natural 

Visibility 

Conditions 

(20% 

Worst 

Days) 

Deciview 

Improvement 

Needed by 

2018 

Total 

Deciview 

Improvement 

Needed by 

2064 

Uniform Rate 

of 

Improvement 

Annually 

Acadia National Park 22.9 12.4 2.4 10.5 0.174 

Roosevelt/Campobello 

International Park 21.7 12.0 2.3 9.7 0.162 

Moosehorn Wilderness 

Area 21.7 12.0 2.3 9.7 0.162 

Presidential Range/Dry 

River Wilderness Area 22.8 12.0 2.5 10.8 0.180 

Great Gulf Wilderness 

Area 22.8 12.0 2.5 10.8 0.180 

Lye Brook Wilderness 24.5 11.7 3.0 12.8 0.212 

Brigantine Wilderness 29.0 12.2 3.9 16.8 0.280 

Note: Both natural conditions and baseline visibility for the 5-year period from 2000 through 2004 were 

calculated in conformance with an alternative method recommended by the IMPROVE Steering 

Committee.

44 

The reasonable progress goals established for the Maine Class I areas are expected to 

provide greater visibility improvements than the uniform rate of progress shown in Table 

11-1, above. 

11.2 Reasonable Progress Goals for Class I Areas in Maine 

In accordance with the requirements of 40 CFR Section 51.308 (d)(1), this Regional Haze 

SIP establishes reasonable progress goals (RPG) for each Class I area in Maine for the 

period of the implementation plan. 

40 CFR Section 51.308(d)(1)(vi) requires that reasonable progress goals represent at least 

the visibility improvement expected from implementation of other Clean Air Act 

programs during the applicable planning period. As documented in Section 8 Emissions 

 

44“Baseline and Natural Visibility Conditions, Considerations and Proposed Approach to 

the Calculation of Baseline and Natural Visibility Conditions at MANE-VU Class I 

Areas,” NESCAUM, December 2006. 
5/27/2010 

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131 

Inventory, and Section 12 Long-Term Strategy, the modeling that formed the basis for 

reasonable progress goals in MANE-VU Class I areas included estimation of the effects 

of all other programs required by the Clean Air Act. Further information may be found 

in those sections of this SIP and in the documentation for the MANE-VU modeling. 

Both natural conditions and baseline visibility for the 5-year period from 2000 through 

2004 were calculated in conformance with an alternative method recommended by the 

IMPROVE Steering Committee. Progress toward the 2018 target will be calculated 

based on 5-year averages calculated in a nationally consistent manner consistent with 

EPA’s “Guidance for Tracking Progress Under the Regional Haze Rule” (EPA-454/B-03-

004, September 2003) as updated by the alternative method for calculating regional haze 

recommended by the IMPROVE Steering Committee. 

To determine the RPG in deciviews, MANE-VU conducted modeling with certain control 

measure assumptions. The control measures reflected in these reasonable progress goals 

are summarized below. In establishing its reasonable progress goals for 2018, Maine 

recognizes that contributing states have the flexibility to submit SIP revisions between 

now and 2018 as they are able to adopt control measures to implement these goals. This 

long-term strategy to reduce and prevent regional haze will allow each state up to 10 

years to pursue adoption and implementation of reasonable and cost-effective SO2, NOx

and PM control measures. 

Tables 11-2 and 11-3 below, provide a summary of the Reasonable Progress Goals for 

Maine Class I areas. 

Table 11-2 

Reasonable Progress Goals—20% Worst Days 

(all values in deciviews) 

Class I Area 

Baseline 

Visibility 

(deciviews) 

(20% 

Worst Days 

2000-2004) 

Reasonable 

Progress Goals, 

20% Worst 

Days (expected 

deciview level 

by 2018) 

Deciview 

Improvement 

Expected by 

2018 

Natural Visibility 

Conditions (20% 

Worst Days) 

 Acadia National Park 22.9 19.4 3.5 12.4 

 Moosehorn 

Wilderness Area/ 

Roosevelt Campobello 

International Park 

21.7 19.0 2.7 12.0 
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132 

Table 11-3 

Reasonable Progress Goals—20% Best Days 

(all values in deciviews) 

Class I Area 

Baseline 

Visibility 

(deciviews) 

(20% Best 

Days) 

Reasonable 

Progress Goals, 

20% Best Days 

(expected 

deciview level 

by 2018) 

Deciview 

Improvement 

Expected by 2018 

Natural Visibility 

(20% Best Days) 

(deciviews) 

 Acadia National Park 8.8 8.3 0.5 4.7 

 Moosehorn 

Wilderness Area/ 

Roosevelt Campobello 

International Park 

9.2 8.6 0.6 5.0 

11.3 Identification of Additional Reasonable Controls 

Maine and the other MANE-VU states have identified specific emission control 

measures- beyond those which individual states or RPOs have already made 

commitments to implement- that would be reasonable to undertake as part of a concerted 

strategy to mitigate regional haze. The proposed additional control measures were 

incorporated into the regional strategy adopted by MANE-VU on June 20, 2007, to meet 

the reasonable progress goals established in this SIP. The basic elements of this strategy 

are described in the MANE-VU “Ask” (see Subsection 3.4). States targeted for 

coordinated actions toward achieving these goals include all of the MANE-VU states plus 

Georgia, Illinois, Indiana, Kentucky, Michigan, North Carolina, Ohio, South Carolina, 

Tennessee, Virginia and West Virginia45 . 

In addition to proposed emission controls in the U.S., the MANE-VU Class I states 

determined that it was reasonable to include anticipated emission reductions in Canada in 

the modeling used to set reasonable progress goals. This determination was based on 

evaluations conducted before and during the consultation process (see description of 

relevant consultations in Subsection 3.3). Specifically, the modeling accounts for six 

coal-burning EGUs in Canada having a combined output of 6,500 MW that are scheduled 

to be shut down and replaced by nine natural gas turbine units with selective catalytic 

reduction (SCR) by 2018. 

The process of identifying reasonable progress measures and setting reasonable progress 

goals is described in the subsections which follow. Further elaboration on the reasonable 

progress measures which make up the Maine/MANE-VU long-term strategy is provided 

 

45 In addition, the State of Vermont identified at least one source in the State of Wisconsin as a significant 

contributor to visibility impairment at the Lye Brook Wilderness Class I Area. 
5/27/2010 

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133 

in Section 12 of this SIP. Under this plan, the affected states will have a maximum of 10 

years to implement reasonable and cost-effective control measures to reduce primarily 

SO2 and NOx emissions. For a description of how proposed emission control measures 

were modeled to estimate resulting visibility improvements, see Subsection 11.5, 

Visibility Effects of Additional Control Measures. 

10.4 The Foundations for Determining Reasonable Controls 

40 CFR Section (d)(1)(i)(A) of EPA’s Clean Air Visibility Rule requires that, in 

establishing reasonable progress goals for each Class I area, the State must consider the 

costs of compliance, the time necessary for compliance, the energy and non-air quality 

environmental impacts of compliance, and the remaining useful life of any potentially 

affected sources. The SIP must include a demonstration showing how these factors were 

taken into consideration in setting the reasonable progress goals. These factors are 

sometimes termed the “four statutory factors,” since their consideration is required by the 

Clean Air Act. 

Focus on SO2: MANE-VU conducted a Contribution Assessment (Attachment A) and 

developed a conceptual model that indicated particulate sulfate formed from emissions of 

SO2 wasthe dominant contributor to visibility impairment at all sites and during all 

seasons in the base year. While other pollutants, including organic carbon and NOx, will 

need to be addressed in order to achieve the national visibility goals, MANE-VU’s 

contribution assessment suggested that an early emphasis on SO2 will yield the greatest 

near-term benefit. Therefore, it is reasonable to conclude that the additional measures 

considered in establishing reasonable progress goals require reductions in SO2 emissions. 

Contributing Sources: The MANE-VU Contribution Assessment indicates that 

emissions in 2002 from within the MANE-VU region were responsible for about 25 to 30 

percent of the sulfate at MANE-VU Class I areas. Sources in the Midwest and Southeast 

regions were responsible for about 15 to 25 percent each, respectively. Point sources 

dominated the inventory of SO2 emissions. Therefore, the MANE-VU’s long-term 

strategy, includes additional measures to control sources of SO2 both within the MANEVU region and in other states that were determined to contribute to regional haze at 

MANE-VU Class I areas. 

The Contribution Assessment documented the source categories most responsible for 

visibility degradation at MANE-VU Class I areas. As described in the Section 12, Long 

Term Strategy, there was a collaborative effort between the Ozone Transport 

Commission and MANE-VU to evaluate a large number of potential control measures. 

Several measures that would reduce SO2 emissions were identified for further study. 

These efforts led MANE-VU to prepare the report entitled, “Assessment of Reasonable 

Progress for Regional Haze in MANE-VU Class I Areas” MACTEC, July 9, 2007 

otherwise known as the Reasonable Progress Report (Attachment T), which documented 

an analysis of the four statutory factors for five major source categories. Table 11-4 

summarizes the results of MANE-VU’s Reasonable Progress Report, which considered 

EGUs, ICI boilers, cement kilns, heating oil and residential wood combustion. 
5/27/2010 

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134 

Table 11-4 

Summary of Results from the Four Factor Analysis 

Source 

Category 

Primary 

Regional 

Haze 

Pollutant 

Control Measure(s)

Average 

Cost in 2006 

dollars 

(per ton of 

pollutant 

reduction) 

Compliance 

Timeframe 

Energy and 

Non-Air Quality 

Environmental 

Impacts Remaining 

Useful 

Life 

Electric 

Generating 

Units 

SO2 Switch to a low sulfur coal 

(generally <1% sulfur), 

switch to natural gas 

(virtually 0% sulfur), coal 

cleaning, Flue Gas 

Desulfurization (FGD)-Wet, 

-Spray Dry, or -Dry. 

IPM®* v.2.1.9 

predicts $775-

$1,690 

$170-$5,700 based 

on available 

literature 

2-3 years 

following SIP 

submittal 

Fuel supply issues, 

potential permitting 

issues, reduction in 

electricity production 

capacity, wastewater 

issues 

50 years or 

more 

Industrial, 

Commercial, 

Institutional 

Boilers 

SO2 Switch to a low sulfur coal 

(generally <1% sulfur), 

switch to natural gas 

(virtually 0% sulfur), switch 

to a lower sulfur oil, coal 

cleaning, combustion 

control, Flue Gas 

Desulfurization (FGD) - 

Wet, -Spray Dry, or -Dry. 

$130-$11,000 

based on available 

literature. Depends 

on size. 

2-3 years 

following SIP 

submittal 

Fuel supply issues, 

potential permitting 

issues, control device 

energy requirements, 

wastewater issues 

10-30 years 

Cement and 

Lime Kilns 

SO2 Fuel switching, Dry Flue 

Gas Desulfurization-Spray 

Dryer Absorption (FGD), 

Wet Flue Gas 

Desulfurization (FGD), 

Advanced Flue Gas 

Desulfurization (FGD). 

$1,900-$73,000 

based on available 

literature. Depends 

on size. 

2-3 years 

following SIP 

submittal 

Control device energy 

requirements, 

wastewater issues 

10-30 years 

Heating Oil SO2 Lower the sulfur content in 

the fuel. Depends on the 

state. 

$550-$750 based 

on available 

literature. There is 

a high uncertainty 

associated with 

this cost estimate. 

Currently feasible. 

Capacity issues 

may influence 

timeframe for 

implementation of 

new fuel standards 

Increases in 

furnace/boiler 

efficiency, Decreased 

furnace/boiler 

maintenance 

requirements 

18-25 years 

Residential 

Wood 

Combustion 

PM State implementation of 

NSPS, Ban on resale of 

uncertified devices, installer 

training certification or 

inspection program, pellet 

stoves, EPA Phase II 

certified RWC devices, 

retrofit requirement, 

accelerated changeover 

requirement, and accelerated 

changeover inducement. 

$0-$10,000 based 

on available 

literature 

Several years -

dependent on 

mechanism for 

emission reduction 

Reduce greenhouse gas 

emissions, increase 

efficiency of combustion 

device 

10-15 years 

* Integrated Planning Model® CAIR versus CAIR plus analysis conducted for MARAMA/MANE-VU by ICF. 
5/27/2010 

Draft For FLM Review 

The MANE-VU states reviewed the four-factor analysis presented in the Reasonable 

Progress Report, consulted with each other about the measures, and concluded by 

adopting the statements known as the MANE-VU Ask on June 20, 2007. These 

statements identify the control measures that would be pursued toward improving 

visibility in the region.. The following discussion focuses on the four basic control 

strategies chosen by MANE-VU and included in the modeling used to establish 

reasonable progress goals: BART, emissions reductions from specific EGUs, low sulfur 

fuel oil requirements, and additional measures determined to be reasonable. 

11.4.1 Best Available Retrofit Technology (BART) Controls

The MANE-VU states have identified approximately 100 BART-eligible sources in the 

region. Most of these facilities are already controlling emissions in response to other 

federal or state air programs, or are likely to install emission controls under new 

programs. Previously, EPA determined that CAIR fulfilled the BART requirement for all 

EGUs in CAIR-affected states. Although CAIR has been remanded to EPA, the 

determination that CAIR is equivalent to BART is still in place. Maine anticipates that 

those same units will be covered by successor legislation or new rulemaking undertaken 

in response to the CAIR remand. A complete compilation of BART-eligible sources in 

the MANE-VU region is available in Attachment A of MANE-VU’s “Assessment of 

Control Technology Options for BART-Eligible Sources,” March 2005 (Attachment R). 

To assess the benefits of implementing BART in the MANE-VU region, NESCAUM 

estimated reductions for twelve BART-eligible units in the MANE-VU states that would 

probably be controlled as a result of BART requirements alone. These sources include 

one EGU and eleven non-EGUs. The affected units were identified by staff members in 

each MANE-VU state, who then furnished data on potential control technologies and 

expected emission levels for these units under BART implementation. The twelve 

sources are listed in Table 11-5, along with their 2002 baseline and 2018 projected 

emissions. Information on these units was incorporated into the 2018 emissions 

inventory projections that were used to establish reasonable progress goals. 

Best Available Retrofit Technology is Reasonable: BART controls are part of the 

strategy for improving visibility at MANE-VU Class I areas. MANE-VU prepared 

reports to provide states with information about available control technologies (e.g., 

MANE-VU’s “Assessment of Control Technology Options for BART-Eligible Sources,” 

March 2005), estimated cost ranges and other factors associated with those controls. The 

reasonable progress goals established in this Regional Haze SIP assume that states whose 

emissions affect MANE-VU Class I areas will make determinations demonstrating the 

reasonableness of BART controls for sources in their states. 

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Table 11-5 

Estimated Emissions from BART-Eligible Facilities MANE-VU States 

State 

Facility Name Unit 

Name 

SCC 

Code 

Plant ID * Point 

ID * 

Facility Type Fuel 

2002 

SO2

Emis

sions 

(tons) 

2018 

SO2

Emissions 

(tons) 

MD 

EASTALCO 

ALUMINUM 28 30300101 021-0005 28 

Metal 

Production 1506 1356 

MD 

EASTALCO 

ALUMINUM 29 30300101 021-0005 29 

Metal 

Production 1506 1356 

MD 

LEHIGH 

PORTLAND 

CEMENT 39 30500606 013-0012 39 Portland Cement 9 8 

MD 

LEHIGH 

PORTLAND 

CEMENT 16 30500915 021-0003 16 Portland Cement 1321 1,189 

MD 

LEHIGH 

PORTLAND 

CEMENT 17 30500915 021-0003 17 Portland Cement 976 878 

MD 

WESTVACO 

FINE PAPERS 2 10200212 001-0011 2 Paper and Pulp 8923 1338 

ME Wyman Station Boiler 3 10100401 2300500135 004 EGU Oil 616 308 

ME SAPPI Somerset 

Power 

Boiler 

#1 10200799 2302500027 001 Paper and Pulp 

Oil/Wood 

Bark/Process 

Gas 2884 1442 

ME IP Jay 

Power 

Boiler 

#2 10200401 2300700021 002 Paper and Pulp Oil 3086+ 1543 

ME IP Jay 

Power 

Boiler 

#1 10200401 2300700021 001 Paper and Pulp Oil 2964+ 1482 

NY 

KODAK PARK 

DIVISION U00015 10200203 8261400205 U00015 

Chemical 

Manufacturer 23798 14216 

NY 

LAFARGE 

BUILDING 

MATERIALS 

INC 41000 30500706 4012400001 041000 Portland Cement 14800 4440 

*(from the MANE-VU Inventory) 

+1999 emissions 

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11.4.2 The MANE-VU Low Sulfur Fuel Strategy

The MANE-VU region, especially the northeast, is heavily reliant on distillate oil for 

home space heating, with more than with more than 4 million gallons used, according to 

2006 estimates from the Energy Information Administration46. Likewise, the heavier 

residual oils are widely used by non-EGU sources, and to a lesser extent the EGU sector. 

The sulfur content of distillate fuels currently averages above 2000 ppm (0.2percent). 

Although the sulfur content of residual oils varies by source and across the region, it can 

exceed 2.0 percent. In 2002, combustion of distillate and residual fuel in the MANE-VU 

region resulted in SO2 emissions totaling approximately 380,000 tons. 

As the second component of MANE-VU’s long term strategy, the member states agreed 

to pursue measures that would require the sale and use of fuel oils having reduced sulfur 

content. This strategy would be implemented in two phases: 

1. Phase 1 would require reducing the sulfur content in distillate (#1 and #2) fuel oils 

from current levels of 2,000 to 2,3000 ppm (0.20 to .23 percent) to a maximum of 

500 ppm (0.05 percent) by weight. It would also restrict the sale of heavier 

blends of residual (#4 and # 5 and #6) fuel oils that have a sulfur content greater 

than 2,500 ppm (0.25 percent) and 5, ppm (0.5 percent) by weight, respectively. 

2. Phase 2 would require further reducing the sulfur content of the distillate fraction 

from 500 ppm (0.05 percent) to 15 ppm (0.0015 percent) while keeping the sulfur 

limits on residual oils at first-phase levels. 

The two phases are to be introduced in sequence with slightly different timing for an 

inner zone of the MANE-VU states47 and the remainder of the MANE-VU states. While 

all MANE-VU states have agreed to pursue implementation of both phases to full effect 

by the end of 2018, it is possible that not every state can make a firm commitment to 

these measures today. States are expected to review the situation by the time of the first 

five-year regional haze progress report. 

Reductions in sulfur dioxide emissions will occur as a direct consequence of the lowsulfur fuel strategy. For both phases combined, it is estimated that SO2 emissions in the 

MANE-VU region will decline from 2002 levels by 168,222 tons per year for combustion 

of light distillates, and by 42,875 tons per year for combustion of the heavier fuels. 

Together, these reductions represent a 35 percent decrease in the projected 2018 SO2 

emissions inventory for non-EGU sources in the region. 

NESCAUM analyzed both steps of the program separately, but it is the combined benefit 

of implementing the program that is relevant to the question of visibility improvement by 

2018. To estimate the total 2018 emissions reductions from this strategy, MANE-VU 

applied the expected sulfur dioxide emission reductions to all non-EGU sources burning 

#1, #2, #4, #5, or #6 fuel oil. These emission reductions would result directly from the 

 

46 U.S. Department of Energy, EIA, Table F3a, at http://www.eia.doe.gov/emeu/states/sep_fuel/html/fuel_use_df.html. 47 The inner zone includes Delaware, Maryland, New Jersey, New York, and possibly portions of eastern 

Pennsylvania. 

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lowering of fuel sulfur content from original levels to 0.0015 percent for #1 and #2 oil, to 

0.25 percent for #4 oil and to 0.5 percent for #5 and #6 oil. 

The reduction in SO2 emissions by 2018 will yield corresponding reductions in sulfate 

aerosol, the main culprit in fine particle pollution and regional haze. The full benefits of 

MANE-VU’s low-sulfur fuel strategy is represented in Figure 11-1, which displays the 

estimated average change in 24-hr average PM2.5 for the combined first and second 

phases of the low-sulfur fuel strategy as calculated by the CMAQ model. 

Figure 11-1 

Average Change in 24-hr PM2.5 Due to Low Sulfur Fuel Strategies Relative to 

OTB/OTW 

(g/m3) 

 

Low Sulfur Fuel Oil Requirements are Reasonable: The MANE-VU Contribution 

Assessment documented source apportionment analyses that linked visibility impairment 

in MANE-VU Class I areas with SO2 emissions from sources burning fuel oil. The 

reasonable assumption underlying the low-sulfur fuel oil strategy is that refiners can, by 

2018, produce home heating and fuel oils that contain 50 percent less sulfur for the 

heavier grades (#4 and #6 residual oil), and a minimum of 75 percent and maximum of 

99.25 percent less sulfur in #2 fuel oil (also known as home heating oil, distillate, or 

diesel fuel) at an acceptably small increase in price to the consumer. 

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Four-Factor Analysis- Low sulfur Fuel Oil Strategy 

 The MANE-VU Reasonable Progress Report discussed the four factors as they apply to 

low sulfur fuel use for industrial, commercial, and institutional boilers and residential 

heating systems. MANE-VU’s Reasonable Progress Report identified switching to lower 

sulfur oil as an available SO2 control option that would achieve 50 to 90 percent 

reductions in SO2 emissions from ICI Boilers. The report also noted that home heating 

oil use generates an estimated 100,000 tons of SO2 emissions in the Northeast each year, 

and that SO2 emissions would decline in proportion to reductions in fuel sulfur content. 

The following discussion summarizes information concerning the four factors for the 

low-sulfur fuel strategy. 

Costs of Compliance

The MANE-VU Reasonable Progress Report noted that because of requirements for 

motor vehicle fuels, refineries have already performed the capital investments required 

for the production of low sulfur diesel (LSD) and ultra-low sulfur diesel (ULSD). The 

report estimated a cost per ton of SO2 removed by switching to lower sulfur fuel would 

range from $554 to $734 per ton (Converted from 2001 to 2006 dollars using a 

conversion factor of 1.1383). In some seasons and some locations, low sulfur diesel is 

actually cheaper than regular diesel fuel. (See Chapter 8 of the Reasonable Progress 

Report.) 

The sulfur content of #4 and #6 fuels can also be cost-effectively reduced. Residual oil is 

essentially a by-product of the refining process, and is produced in several grades that can 

be blended to meet a specified fuel sulfur content limit. New York Harbor residual fuel 

prices for the week ended March 21, 2008 ranged from a low of $71.38 a barrel for 2.00 

and 2.2 percent sulfur fuel; to a high of $91.38 per barrel for 0.3 percent sulfur fuel. Low 

pour48 fuel oil with 0.5 percent sulfur sold for $80.83 per barrel in this same period49. 

While the costs for achieving the projected emissions reductions with the low-sulfur fuel 

strategy are somewhat dependent on market conditions, they are believed to be 

reasonable in comparison to costs of controlling other sectors. Some MANE-VU states 

are proceeding with low-sulfur oil requirements much sooner than 2018; however, all of 

the MANE-VU states concur that a low-sulfur oil strategy is both reasonable and 

achievable by 2018. MANE-VU has concluded that the cost of requiring lower sulfur 

fuel is reasonable. 

Time Necessary for Compliance

MANE-VU’s Reasonable Progress Report indicated that furnaces and boilers would not 

have to be retrofit and would not require expensive control technology to burn ULSD 

distillate fuel oil. Therefore, the time necessary for compliance would be determined by 

the availability of the fuel. 

 

48 Low pour refers to a low-temperature pour point (or reduced viscosity at low temperature) for the fuel. 49 During this same period, residual oil with a fuel sulfur content limit of 0.7 percent and 1.0 percent traded 

at $75.13 and $72.63, respectively. 

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The MANE-VU Reasonable Progress Report notes that, on a national scale, more ULSD 

is produced than both LSD and high sulfur fuel, and concludes that there is sufficient 

domestic infrastructure to produce adequate stocks of LSD and ULSD. The NESCAUM 

Low Sulfur Heating Oil Report50 also observes that the federal rules for heavy-duty 

highway diesel fuel are flexible, so that if there is a shortage of 15 ppm fuel, the 15 to 

500 ppm fuel could be used to relieve the shortage. With this flexibility, the report 

concludes that the likelihood of a fuel shortage in the short term due to use of ULSD for 

heating oil is diminished. The volatile nature of heating supply and demand presents 

unique challenges to the fuel oil industry. The success of a low sulfur fuel oil program is 

predicated on meeting these challenges. The Northeast states are assessing a variety of 

business strategies and regulatory approaches that could be used to minimize any 

potential adverse supply and price impacts that could result from a regional 500 ppm 

sulfur standard for heating oil. Suppliers can increase pre-season reserves and look to 

increase imports from offshore refiners producing low sulfur product. Blending 

domestically produced biodiesel into heating oil offers opportunity to reduce imports, 

stabilize supplies and minimize supply-related price spikes. 

Potential supply disruptions and price spikes for residual fuels were a particular concern 

for several northern MANE-VU states. While the potential for disruptions in the supply 

of residual fuels is greater than that for distillate oil, these disruptions would affect only a 

limited number of states during extreme weather events. 

MANE-VU has identified several mechanisms that could be implemented to address 

disruptions, including seasonal averaging and emergency waivers. A seasonal averaging 

approach would reduce potential supply constraints by allowing the use of higher sulfur 

fuel during periods of peak demand (and limited supply), and then requiring the increased 

sulfur content of these fuels to be offset through the use of a lower sulfur fuel at other 

times. This approach would provide regulatory certainty and greater flexibility during 

the winter months when fuel supplies may be subject to weather-related disruptions, but 

at a cost of increased recordkeeping and compliance monitoring. Since many states 

already have statutory authority to waive fuel sulfur limits for an emergency waiver, 

states could also utilize their discretionary powers to address short-term supply 

disruptions. 

The strategy adopted by Maine and the other MANE-VU states proposes to phase in the 

required use of lower-sulfur fuels over the next 8 years, providing adequate time for full 

implementation. 

Energy and Non-Air Quality Environmental Impacts of Compliance

According to MANE-VU’s Reasonable Progress Report, reducing the sulfur content of 

fuel oil would have a variety of beneficial consequences for boilers and furnaces using 

this fuel. Low-sulfur distillate fuel is cleaner burning and emits less particulate matter, 

thereby substantially reducing the rate of fouling of heating units and allowing longer 

time intervals between cleanings. The MANE-VU report cites a study by the New York 

 

50 “Low Sulfur Heating Oil in the Northeast States: An Overview of Benefits, Costs and Implementation 

Issues”, December 31, 2005 by NESCAUM.

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State Energy Research and Development Authority (NYSERDA) showing that boiler 

deposits are reduced by a factor of two by lowering the fuel sulfur content from 1,400 

ppm to 500 ppm. The use low-sulfur oil could extend the useful life of a source by 

reducing the maintenance required because low-sulfur oil is less damaging to the 

combustion equipment. The report also notes that decreasing sulfur levels in fuel would 

enable manufacturers to develop more efficient furnaces and boilers by using more 

advanced condensing equipment that recovers energy normally lost to the heating of 

water vapor in the exhaust gases. 

Furthermore, SO2 controls would also have beneficial environmental impacts by reducing 

acid deposition and helping to decrease concentrations of PM2.5. Reductions in PM2.5

would potentially help nonattainment areas meet health-based National Ambient Air 

Quality Standards. 

Remaining Useful Life of Any Potentially Affected Sources

Residential furnaces and boilers have finite life spans, but they do not need to be replaced 

to burn low- or ultra-low-sulfur fuel. The Energy Research Center estimates that the 

average life expectancy of a residential heating oil boiler is 20-25 years. As noted above, 

use of low-sulfur fuel is less damaging to equipment and could therefore extend the 

useful life of an oil-fired residential furnace or boiler. 

Available information on the remaining useful life of ICI boilers indicates a wide range 

of life expectancies, depending on unit size, capacity factor51, and level of maintenance 

performed. The typical life expectancy of an ICI boiler ranges from 10 years to more 

than 30 years. As in the case of residential units, use of lower-sulfur fuels could extend 

the lifespan of an ICI boiler. 

11.4.3 Targeted Strategy for Reducing SO2Emissions from EGU Stacks

EGUs are the single largest sector contributing to visibility impairment at MANE-VU 

Class I areas. SO2 emissions from power plants continue to dominate the emissions 

inventory. Sulfate formed through atmospheric processes from SO2 emissions are 

responsible for over half the mass and approximately 70-80 percent of the extinction on 

the days of worst visibility (NESCAUM’s Contribution Assessment and Conceptual 

Model, Attachment A). 

To ensure that EGU controls are targeted at those EGUs with the greatest impact on 

visibility at MANE-VU Class I areas, a modeling analysis was conducted to identify the 

individual sources responsible for the greatest contributions to visibility impairment. 

Accordingly, MANE-VU developed a list of the 100 EGUs having the greatest impacts at 

each MANE-VU Class I area during 2002 The combined list for all seven MANE-VU 

Class I areas identified a total of 167 distinct emission points, with these stacks located 

throughout the Northeast, Midwest and Southeast (Figure 11-2) 

 

51 Capacity factor is defined as the actual amount of energy a boiler generates in one year divided by the 

total amount it could generate if it ran full time at full capacity. 

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Figure 11-2 

Location of 167 EGU Stacks Contributing the Most to Visibility Impairment at 

MANE-VU Class I Areas 

After consultations with its member states and other RPOs MANE-VU requested a 90-

percent reduction in SO2 emissions from the top 167 stacks no later than 2018 (See the 

MANE-VU “Ask,” described in Section 3.4 of this SIP). NESCAUM’s preliminary 

modeling for MANE-VU showed that reducing SO2 emissions from the targeted facilities 

by 90 percent would also produce measurable improvements in ambient 24-hour PM2.5

concentrations. Assuming a control level equal to 10 percent of the 2002 baseline 

emissions (i.e., 90 percent emission reduction), NESCAUM used CMAQ to model 

sulfate concentrations in 2018 after implementation of controls. The modeled sulfate 

values were then converted to estimates of PM2.5 concentrations. 

Figure 11-3 illustrates the reduction in fine particle pollution in the Eastern U.S. that 

would result from implementing the targeted EGU SO2 strategy. Improvements in PM2.5

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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 11-3 

Preliminary Estimate of Average Change in 24-hr PM2.5 Due to 90 Percent 

Reduction in SO2 Emissions from 167 EGU Stacks Affecting MANE-VU 

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 SO2 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 a detailed description of this analysis, see 

Alpine Geophysics’ report for MARAMA entitled “Documentation of 2018 Emissions 

from Electric Generating Units in the Eastern United States for MANE-VU’s Regional 

Haze Modeling, Revised Final Draft, April 21, 2008 (Attachment S). 

Targeted EGU SO2 Emissions Reductions are Reasonable: MANE-VU identified 

specific EGU stacks that were significant contributors to visibility degradation at MANEVU Class I areas in 2002 based on CALPUFF modeling analyses documented in the 

Contribution Assessment. MANE-VU obtained information about existing and planned 

controls on emissions from those stacks. These analyses and the information on proposed 

EGU controls are presented in the MANE-VU Reasonable Progress Report, and the 

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Contribution Assessment (specifically Attachment D),as well as in Section 8.0 

(Emissions Inventory), and Section 12.0 (Long Term Strategy) of this SIP. 

Based on information gathered from the states and RPOs, MANE-VU anticipates that 

emissions from many of the specific EGU stacks will be controlled as a result of EPA’s 

Clean Air Interstate Rule (CAIR). Since CAIR is a cap and trade program, it is not 

possible to predict with certainty which of the 167 stacks will in fact be controlled under 

CAIR in 2018. 

Four-Factor Analysis – Targeted EGU SO2 Reduction Strategy 

Costs of Compliance

Technologies to control the precursors of regional haze are commercially available.52

Because EGUs are the most significant stationary source of SO2, NOx, and PM, they have 

been subject to extensive federal and state regulations to control all three pollutants. The 

technical feasibility of control technologies has been successfully proven for a large 

number of small (@100MW) to very large boilers (over 1,000 MW) using different types 

of coal used. Over the last few years, the cost data clearly indicate that many technologies 

provide substantial and cost-effective reductions. 

Both wet and dry flue gas desulfurization (“scrubbers”) are in wide commercial use in the 

U.S. for controlling SO2 emissions from coal-fired power plants. The capital costs for 

new or retrofit wet or dry scrubbers are higher than the capital costs for NOx and PM 

controls. Capital costs ranged from $180/kW for large units (larger than 600 MW) to as 

high as $350/kW for small units (200 to 300 MW). (See pages 2-22 of the NESCAUM 

report “Assessment of Control Technologies for BART Eligible Sources,” March 2005, 

Attachment R). However, the last few years have seen a general trend of declining 

capital costs due to vendor competition and technology maturation. Also, the costeffectiveness (in dollars per ton of emissions removed) is very attractive because the high 

sulfur content of the coal burned by these units results in a very large amount of SO2 

removed by the control devices. The typical cost-effectiveness is in the range of 200 to 

500 dollars per ton of SO2 removed, although the cost rises steeply for small units 

burning low-sulfur coals and operating at low capacity factors. For any unit, the overall 

cost effectiveness is determined mostly by the baseline pre-controlled SO2 emission rate 

(or fuel sulfur content), size and capacity factor of the unit, as well as the capital cost of 

flue gas desulfurization (generally ranges from $150 to $200/Kw). 

The MANE-VU Reasonable Progress Report reviewed options for controlling coal-fired 

EGU boilers, including switching to lower-sulfur coal, switching to natural gas, coal 

cleaning, and flue gas desulfurization (FGD). The most effective control option (but not 

necessarily appropriate for all installations) is FGD, which can achieve up to a 95 percent 

reduction in SO2 emissions. The cost varies considerably among units and was estimated 

 

52The information in this and the next paragraph comes from the “Assessment of Control Technology 

Options for BART-Eligible Sources: Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper 

and Pulp Facilities,” March 2005, prepared by NESCAUM, in partnership with MANE-VU.

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to range from as low as $170/ton to as high as $5,700/ton. Table 11-6 summarizes the 

estimated SO2 control costs on a dollar per ton of SO2 removed basis. 

Table 11-6 

 Estimated Cost Ranges for SO2 Control Options for Coal-Fired EGU Boilers 

(2006 dollars per ton of SO2 removed) 

To predict future emissions and further evaluate the costs of emission controls for electric 

generating units, MANE-VU and other RPOs have followed the example of EPA in using 

the Integrated Planning Model (IPM®), an integrated economic and emissions model for 

EGUs. This model projects electricity supplies based on various assumptions while at the 

same time developing least-cost solutions to electrical generating needs within the 

specified emissions targets. IPM also provides estimates of the costs of complying with 

various policy requirements. 

EPA developed IPM version 2.1.9 and used this model to evaluate the impacts of CAIR 

and the Clean Air Mercury Rule (CAMR)53. Recently, EPA updated their input data and 

53 CAMR was also vacated by the federal courts and is no longer in effect. 

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developed IPM v3.0. However, because of time constraints, all MANE-VU modeling 

runs were based on EPA IPM v2.1.9 with changes made to the input assumptions. As 

stated previously, CAIR has recently been remanded to EPA and it is unknown at this 

time when EPA will propose a revised or new rule in accordance with the court’s July 11, 

2008 decision. 

The RPOs collaborated with each other to update EPA Base Case v.2.1.9 using more 

current data about EGUs with more realistic fuel prices, creating an IPM run called 

VISTAS PC_1f. The VISTAS IPM run is the basis for regional air quality modeling for 

regional haze SIPs in MANE-VU. 

MANE-VU, through MARAMA, contracted with the consulting firm ICF International to 

prepare two new IPM runs54. The first modeling run, known as the MARAMA CAIR 

Base Case run, was based on the VISTAS PC_1f run and underlying EPA IPM v.2.1.9 

with some updated information on fuel prices, control constraints, etc. This run also goes 

by the name MARAMA_5c. The second run, called the MARAMA CAIR Plus run (also 

known as MARAMA_4c), was similarly based on VISTAS PC_1f run and the underlying 

EPA IPM v.2.1.9, and included updated information used in the VISTAS run, but 

assumed lower NOX emission caps and higher SO2 retirement ratios. 

Based on modeling results, MANE-VU estimates that the marginal cost of SO2

reductions (the cost of reducing an additional ton of emissions) ranges from $640/ton in 

2008 to $1,392 ton in 2018.55

Costs will vary for individual plants to reduce emissions by 90 percent, as recommended 

in the MANE-VU Ask. However, this strategy provides states with the flexibility to 

pursue controls on specific sources as appropriate and to control emissions from 

alternative sources, if necessary, to meet the 90 percent target established in the Ask. 

Given the significance of SO2 emissions from specific EGU’s to visibility impairment in 

MANE-VU Class I areas, the MANE-VU Commissioners, after weighing all factors- the 

availability of technology to reduce emissions, the estimated cost of controls, the costs of 

alternative measures, the flexibility to achieve alternative reductions if necessary, etc. - 

concluded that the costs of reducing emissions from the identified key stacks was 

reasonable. Maine agrees with this conclusion for base-load coal-fired units, but 

recognizes add-on controls may not be cost-effective for oil-fired peaking units. 

Time Necessary for Compliance

MANE-VU’s Reasonable Progress Report indicates that, generally, sources are given a 2- 

to 4-year phase-in period to comply with new rules. Under Phase I of the NOx SIP call, 

EPA provided a compliance date of about 3.5 years from the SIP submittal date. Most 

MACT standards allow a 3-year compliance period. Under Phase II of the NOx SIP Call, 

 

54 See the report, Comparison of CAIR and CAIR+ Proposal using the Integrated Planning Model (IPM®),

ICF Resources LLC, May 2007, Attachment U. 

55 See Table 6, “Allowance Prices (Marginal Costs) of Emissions Reductions...” p. 9, ICF, May 2007, 

Attachment U. 

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EPA provided a 2-year compliance period from the SIP submittal date. The MANE-VU 

states concluded that there is more than sufficient time between 2008 and 2018 for 

affected states to adopt requirements and for affected sources to install necessary 

controls. Maine agrees with this conclusion 

Energy and Non-Air Quality Environmental Impacts of Compliance

The MANE-VU Reasonable Progress Report identified several energy and non-air 

quality impacts as a result of additional EGU controls. These included potential adverse 

impacts on fuel supplies if there were large-scale fuel switching, the triggering of NSR 

requirements, and the generation of wastewater and sludge from flue gas desulfurization 

systems. Conversely, additional controls for SO2, NOx, and ammonia would have 

beneficial environmental impacts by reducing mercury emissions, acid deposition and 

nitrogen deposition to water bodies and natural landscapes. Reductions would also result 

in decreases in ambient levels of PM2.5 with corresponding health benefits. The MANEVU states concluded that the energy and non-air quality impacts of additional EGU 

controls are reasonable. Maine agrees with this conclusion 

Remaining Useful Life of Any Potentially Affected Sources

As noted in the MANE-VU Reasonable Progress Report, remaining useful life estimates 

of EGU boilers indicate a wide range of operating lifetimes, depending on unit size, 

capacity factor, and level of maintenance performed. Typical life expectancies range to 

50 years or more. Additionally, implementation of air pollution regulations over the 

years has necessitated emission control retrofits that have increased the expected life 

spans of many EGUs. The lifetime of an EGU may be extended through repair, repowering, or other strategies if the unit is more economical to run than to replace with 

power from other sources. Extending facility lifetime may be particularly likely for a 

unit serving an area with limited transmission to bring in other power. The remaining 

useful life of a unit should not be confused with the economic decision of whether or not 

to continue operating a unit or to re-power or replace it. The cost of environmental 

compliance is only one of many factors involved in such a decision. 

11.4.4 Non-EGU SO2 Emissions Reduction Strategy Outside the MANE-VU Region

In addition to the measures described above, (i.e., BART, low sulfur fuel within MANEVU, and targeted controls on specific EGUs), MANE-VU asked states in neighboring 

regional planning organizations to consider further non-EGU emissions reductions 

comparable to those achieved by states located within the MANE-VU region through the 

application of MANE-VU’s low sulfur fuel strategy. Previous modeling indicated that 

the MANE-VU low sulfur fuel strategy would achieve a greater than 28 percent reduction 

in non-EGU SO2 emissions by 2018. After consultation with other states and 

consideration of comments received, the MANE-VU Class I States decided to include, in 

the latest modeling for the VISTAS and MRPO regions, implementation of measures 

capable of achieving SO2 emission reductions equivalent to MANE-VU’s 28 percent 

reduction in non-EGU SO2 emissions in 2018. 

To model the impact of this strategy on visibility at MANE-VU Class I areas, MANEVU had to make reasonable assumptions about where the requested emissions reductions 

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would occur in the VISTAS and MRPO states without knowing precisely how those 

reductions would be realized. As a means to approximate a 28 percent reduction in nonEGU SO2 emissions, the following reductions were modeled: 

 For control measures in VISTAS and MRPO states: 

 Coal-Fired ICI Boilers: SO2 emissions were reduced by 60 percent 

 Oil-Fired ICI boilers: SO2 emissions were reduced by 75 percent 

 ICI Boilers lacking fuel specification: SO2 emissions were reduced 

by 50 percent 

 For additional controls only in the VISTAS states: SO2 emissions from 

other area oil-combustion sources were reduced by 75 percent (based on 

the same SCCs identified in MANE-VU’s oil strategies list) 

This modeling scenario represents just one example of realistic strategies that states 

outside of MANE-VU could employ to meet the non-EGU SO2 emissions reductions 

requested by MANE-VU. 

A number of non-MANE-VU states have not included, or may not include, the requested 

28 ercent reduction in non-EGU SO2 emissions in their initial SIPs. The MANE-VU 

states encourage EPA to hold these states responsible for satisfying the MANE-VU Ask 

in the course of preparing their first five-year progress reports in order to meet the CAA 

national goal of remedying any existing visibility impairment in Class I areas. 

Non-EGU SO2 Emission Reductions Measures Outside the MANE-VU Region are 

Reasonable: After EGUs, ICI boilers and heaters are the next largest class of SO2

emitters. ICI boilers are thus a logical choice among non-EGU sources for consideration 

of additional SO2 control measures. 

ICI Boiler Control Options

Air pollution reduction and control technologies for ICI boilers have advanced 

substantially over the past 25 years. However, according to the 1998 survey of industrial 

boilers by EPA (2004), only 2 percent of gas-fired boilers and 3 percent of oil-fired 

boilers had installed any kind of air pollution control device. A larger percentage of coalfired boilers had installed air pollution control devices: specifically, 47 percent had 

installed some type of control device, mainly to control particulate matter (PM). Postcombustion SO2 controls were used by less than one percent of industrial boilers in 1998, 

with the exception of boilers firing petroleum coke (2 percent of boilers firing petroleum 

coke had acid scrubbers). A small percentage of industrial boilers had combustion 

controls in place in 1998, although since 1998, additional low-NOX firing systems may 

have been installed since that date. 

Almost all SO2 emission control technologies fall in the category of reducing SO2 after its 

formation, as opposed to minimizing its formation during combustion. The method of 

SO2 control appropriate for any individual ICI boiler is dependent upon the type of boiler, 

type of fuel, capacity utilization, and the types and staging of other air pollution control 

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devices. However, cost-effective emissions reduction technologies for SO2 are available 

and are effective in reducing emissions from the exhaust gas stream of ICI boilers. Postcombustion SO2 control is accomplished by reacting the SO2 in the gas with a reagent 

(usually calcium- or sodium-based) and removing the resulting product (a sulfate/sulfite) 

for disposal or commercial use, depending on the technology used. SO2 reduction 

technologies are commonly referred to as Flue Gas Desulfurization (FGD) and are 

usually described in terms of the process conditions (wet versus dry), byproduct 

utilization (throwaway versus saleable) and reagent utilization (once-through versus 

regenerable). 

The exceptions to the nearly universal use of post-combustion controls are found in fuel 

switching, coal cleaning, and fluidized bed boilers, in which limestone is added to the 

fuel in the combustion chamber. SO2 control options for ICI boilers are outlined in Table 

11-7. Further descriptions of these SO2 control technology options are available in 

Chapter 4 of the MANE-VU Reasonable Progress Report (Attachment T). 

The SO2 removal efficiency of these controls varies from 20 to 99+ percent, depending 

upon the fuel type and control strategy. For coal-fired boilers, options include switching 

to low-sulfur coal, coal cleaning, wet FGD, dry FGD, and spray dryers. The overall SO2

reductions vary from a low of 20 to 25 percent for switching to low-sulfur fuel(s) to a 

high of 60 to 95 percent for wet FGD and spray dry FGD. The majority of control 

strategies, however, are capable of achieving a 60 percent or greater reduction. Thus, 

assuming that coal-fired ICI boilers adopt varying levels of controls, with most choosing 

a 50 to 70 percent reduction strategy and fewer choosing either the 20 percent or the 90 

percent reduction strategy, the region-wide average is likely to be in the range of a 60 

percent reduction in SO2 emissions. This assumption is validated by the data which 

documents that wet FGD systems represent 85 percent of the FGD systems in use in the 

United States and that FGD systems have an average SO2 removal efficiency of 78 

percent. MANE-VU’s modeling of a 60 percent reduction in SO2 emission from coalfired ICI boilers is therefore reasonable. 

For oil-fired boilers, options include switching to a lower sulfur fuel (e.g., oil or natural 

gas), dry FGD, and spray dryers. The overall SO2 reductions vary from a low of 40 to 60 

percent for dry FGD, to a high of 60 to 95 percent for spray dry FGD. For comparison, 

the MANE-VU low sulfur fuel strategy assumes a 50 to 90 percent reduction in SO2

emissions from oil-fired ICI boilers. Assuming a typical distribution of control strategies 

chosen by the sources, MANE-VU’s modeling of an average 75 percent reduction in SO2

emission from oil-fired ICI boilers is reasonable. 

For ICI boilers in which a fuel was not specified, a 50 percent reduction in SO2 emissions 

was assumed. ICI boilers in this category include those outside the MANE-VU region 

for which the current inventory did not specify the type of fuel burned. Because a 

response was not received from the MRPO, this assumption also encompasses some of 

the uncertainty regarding the implementation of MANE-VU’s non-EGU Ask. Given the 

paucity of data, a lower reduction in SO2 emissions (50 percent) was assumed in this 

category than for coal- or oil-fired ICI boilers. Implementation of one or more of the 

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suggested SO2 control options capable of achieving an average 50 percent SO2 reduction 

at these sources is a reasonable assumption. 

Table 11-7 

Available SO2 Control Options for ICI Boilers

Technology Description Applicability Performance 

Switch to a Low Sulfur Coal 

(generally <1% sulfur)

Replace high-sulfur 

bituminous coal combustion 

with lower-sulfur coal

Potential control measure 

for all coal-fired ICIs 

currently using coal with 

high sulfur content 

50-80% reduction in SO2 

emissions by switching to a 

lower-sulfur coal

Switch to Natural Gas 

(virtually 0% sulfur)

Replace coal combustion 

with natural gas

Potential control measure 

for all coal-fired ICIs 

Virtually eliminate SO2 

emissions by switching to 

natural gas 

Switch to a Lower Sulfur Oil Replace higher-sulfur 

residual oil with lower-sulfur 

distillate oil. Alternatively, 

replace medium sulfur 

distillate oil with ultra-low 

sulfur distillate oil

Potential control measure 

for all oil-fired ICIs 

currently using higher 

sulfur content residual or 

distillate oils 

50-80% reduction in SO2 

emissions by switching to a 

lower-sulfur oil 

Coal Cleaning Coal is washed to remove 

some of the sulfur and ash 

prior to combustion 

Potential control measure 

for all coal-fired ICI boilers 

20-25% reduction in SO2 

emissions

Combustion Control A reactive material, such as 

limestone or bi-carbonate, is 

introduced into the 

combustion chamber along 

with the fuel

Applicable to pulverized 

coal-fired boilers and 

circulating fluidized bed 

boilers 

40%-85% reductions in SO2 

emissions

Flue Gas Desulfurization 

(FGD) - W et

SO2 is removed from flue 

gas by dissolving it in a lime 

or limestone slurry. (Other 

alkaline chemical are 

sometimes used) 

Applicable to all coal-fired 

ICI boilers

30-95%+ reduction in SO2 

emissions 

Flue Gas Desulfurization 

(FGD) - Spray Dry

A fine mist containing lime or 

other suitable sorbent is 

injected directly into flue gas

Applicable primarily for 

boilers currently firing low 

to medium sulfur fuels

60-95%+ reduction in SO2 

emissions 

Flue Gas Desulfurization 

(FGD) - Dry

Powdered lime or other 

suitable sorbent is injected 

directly into flue gas

Applicable primarily for 

boilers currently firing low 

to medium sulfur fuels

40-60% reduction in SO2 

emissions

For emissions from other area oil-combustion sources in the VISTAS region, an SO2 

reduction of 75 percent was assumed. This is equivalent to the MANE-VU low sulfur 

fuel strategy. The four factor analysis of this strategy was presented in Section 11.3.2. 

Four-Factor Analysis – Non-EGU SO2 Emission Reduction Measures Outside 

MANE-VU

Based on the survey of available technologies outlined above and the four-factor analysis 

summarized below, MANE-VU concludes that each of the strategies assumed for 

modeling purposes to meet the MANE-VU Ask of a 28 percent reduction in non-EGU 

SO2 emissions is reasonable. States should have no difficulty in meeting this benchmark 

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in light of the control efficiencies that are attainable at reasonable costs with retrofit 

technologies that are available for ICI boilers today. 

Costs of Compliance

Industrial boilers have a wider range of sizes than EGUs and often operate over a wider 

range of capacities. Thus, cost estimates for the same technologies will generally span a 

relatively larger range, and costs for individual boilers will depend on the capacity of the 

boiler and typical operating conditions. In general, cost-effectiveness increases as boiler 

size and capacity factor (a measure of boiler utilization) increases.

 

MANE-VU’s Reasonable Progress Report (Attachment T) provides emission control cost 

estimates for ICI boilers in the range of $130 per ton to $11,000 per ton, a very wide 

range due to the variability of sources and control options in this category.56 All costs 

presented below for emission controls on ICI boilers are borrowed from this report. 

Dollar amounts originated from EPA publications cited in the report and have been 

converted to 2006 dollars using a conversion factor from www.inflationdata.com. 

o Cost of Fuel Switching: 

Although fuel switching can be a very effective means of reducing SO2 emissions 

(reductions of 50 to 99.9 percent are possible), burning low-sulfur fuel may not be a 

technically feasible or economically practical SO2 control alternative for every ICI coalfired boiler. Factors impacting applicability include the characteristics of the plant and 

the particular type of fuel change being considered. Additionally, switching to a lower 

sulfur coal can affect fuel handling systems, boiler performance, PM control 

effectiveness, and ash handling systems. Oil-fired boilers switching to a lower sulfur fuel 

of the same grade (e.g., switching from #6 fuel oil at 2.0%S to #6 fuel oil at 0.5% S) do 

not typically encounter these issues; please see Section 11.4.2 for a discussion of the 

costs and issues associated with switching to low sulfur fuel oil. 

The costs of coal fuel switching, including substitution or blending with a low-sulfur 

coal, can be attributed to two main reasons: the cost of low-sulfur coal compared to 

higher sulfur coal (including coal’s heating value), and the cost of any necessary boiler or 

coal handling equipment modifications. Many plants will be able to switch from highsulfur to low-sulfur bituminous coal without serious difficulty, but switching from 

bituminous to sub-bituminous coal may require potentially significant investments and 

modifications to an existing plant. Even if a lower sulfur fuel is available, it may not be 

cost competitive if it must be transported long distances from the supplier or supplied in 

small quantities. It also may be more cost-effective to burn a higher sulfur fuel supplied 

by nearby suppliers and to use a post-combustion control device. 

Switching from coal combustion to natural gas combustion virtually eliminates SO2

emissions. It is technically feasible to switch from coal to natural gas, but the wide 

variation in natural gas process means that it may be uneconomical to consider this option 

for large ICIs due to the fuel quantity necessary and the price of natural gas. Natural gas 

 

56MANE-VU’s Reasonable Progress Report is entitled “Assessment of Reasonable Progress for Regional 

Haze in MANE-VU Class I Areas” prepared by MACTEC for MARAMA, dated July 9, 2007. 

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83 363 294 231

14 1,286 1,040 818

50 360 291 229

83 212 171 134

3.43%-sulfur 

coal

85

is currently about twice times the price of coal in terms of heating value, but has been as 

high as seven times the price of coal in recent years. 

o Cost of Coal Cleaning

The World Bank, an organization which assists with economic and technological needs in 

developing countries, reports that the cost of physically cleaning coal varies from $1 to 

$10 per ton of coal cleaned, depending on the coal quality, the cleaning process used, and 

the degree of cleaning desired. In most cases the costs were found to be between $1 and 

$5 per ton of coal cleaned. The effectiveness of coal cleaning is typically a 20 to 25 

percent reduction in SO2 emissions. Coal cleaning also increases the heating value of the 

fuel by a small amount. 

o Cost of Combustion Controls

Dry sorbent injection (DSI) systems have lower capital and operation costs than postcombustion FGD systems because of the simplicity of the DSI design, lower water use 

requirements, and smaller land area requirements. Table 11-8 presents the estimated 

costs of adding DSI-based SO2 controls to ICI boilers based for different boiler sizes, fuel 

types, and capacity factors. 

o Cost of FGD 

Installation of post-combustion SO2 controls in the form of FGD has several impacts on 

facility operations, maintenance, and waste handling procedures. FGD systems generally 

require substantial land area for construction of the absorber towers, sorbent tanks, and 

waste handling equipment. The facility costs therefore depend on the cost and 

availability of space for construction of the FGD system. Solid waste handling is another 

factor that influences the cost of FGD control systems. Significant waste material may be 

generated that requires disposal. These costs may be mitigated, however, by utilization 

of a forced oxidation FGD process that produces commercial-grade gypsum, which may 

be sold as a raw material for other commercial processes. 

Table 11-8 

Estimated Dry Sorbent Injection (DSI) Costs for ICI Boilers 

(2006 dollars) 

152 

100 

MMBTU/hr

250 

MMBTU/hr

1,000 

MMBTU/hr

14 4,686 3,793 2,979

50 1,312 1,062 834

83 772 624 490

14 2,732 2,212 1,737

50 765 619 486

83 450 364 286

14 2,205 1,786 1,402

50 617 500 392

Cost Effectiveness ($/Ton of SO2 )

Fuel

SO2 

Reduction 

(%)

Capacity 

Factor (%)

2%-sulfur coal

3.43%-sulfur 

coal

2%-sulfur coal

40

40

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Table11-9 presents the total estimated cost effectiveness of adding FGD-based SO2

controls for different boiler sizes, fuel types, and capacity factors. There is no indication 

that these cost data include revenue from gypsum sales, which would partially offset the 

costs of FGD controls. 

Carbon dioxide is also emitted as a by-product of FGD, therefore impacts of increased 

carbon emissions would need to be considered. CO2 emissions will become more of an 

issue in the future if they are limited under climate change mitigation strategies. Given 

the uncertainty of such future strategies, costs related to increased carbon emissions from 

FGD cannot yet be assessed. 

MANE-VU’s request for a 28 percent reduction in non-EGU SO2 emissions allows states 

flexibility in determining which sources to control, so that the most cost-effective control 

measures can be adopted and implemented over the next 10 years. Given the wide range 

of control options and costs available for this purpose, MANE-VU has concluded that its 

request for a 28 percent reduction in non-EGU SO2 emissions is reasonable. Maine 

concurs with this conclusion. 

Time Necessary for Compliance

For pre- and post-combustion SO2 emission controls, engineering and construction lead 

times will vary between 2 and 5 years, depending on the size of the facility and specific 

control technology selected. Generally, sources are given a 2-4 year phase-in period to 

comply with new rules, as previously described, and states generally have a 2-year period 

for compliance with RACT rules. 

Table 11-9 

Estimated FGD Costs For ICI Boilers 

(2006 dollars) 

100 

MMBTU/hr

250 

MMBTU/hr

1,000 

MMBTU/hr

14 3,781 2,637 1,817

50 1,379 1,059 828

83 1,006 814 676

14 4,571 3,150 2,119

50 1,605 1,207 928

83 1,147 906 744

14 4,183 2,786 1,601

50 1,290 899 567

83 843 607 407

14 3,642 2,890 1,909

50 1,116 875 601

83 709 563 398

14 4,797 3,693 2,426

50 1,415 1,106 751

83 892 705 492

14 10,843 8,325 5,424

Fuel

SO2 

Reduction 

(%)

Capacity 

Factor (%)

Cost Effectiveness ($/Ton of SO2 )

Technology

High-sulfur 

coal

40

Lowersulfur coal40

FGD (Dry)

FGD (Dry)

Coal 85

High-sulfur 

coal

85

FGD (Spray 

dry)

FGD (Spray 

dry)

Lowersulfur coalFGD (W et) 40

Oil FGD (W et) 40

153 50 2,269 1,765 1,184

83 1,371 1,079 740
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For the purposes of this review, it is assumed that a 2-year period after SIP submittal is 

adequate for the installation of pre-combustion controls (fuel switching or cleaning) and a 

3-year period for the installation of post-combustion controls. MANE-VU has therefore 

concluded that there is sufficient time between 2008 and 2018 for the affected states to 

adopt emission control requirements and for affected sources to install controls necessary 

to meet MANE-VU’s requested SO2 emission reductions from non-EGU sources. Maine 

concurs with this conclusion. 

Energy and Non-Air Quality Environmental Impacts of Compliance

The primary energy impact of pre- or post-combustion control alternatives is a potential 

increase in electricity usage. Fuel switching and cleaning do not significantly affect the 

efficiency of the boiler itself, but require additional energy to clean or blend coal. FGD 

systems typically operate with high-pressure drops across the control equipment, and 

therefore consume significant amounts of electricity to operate blowers and circulation 

pumps. In addition, some combinations of FGD technology and plant configuration may 

require flue gas reheating to prevent physical damage to equipment, resulting in higher 

fuel usage. 

The primary non-air environmental impacts of fuel switching derive from transportation 

of the fuel. Secondary environmental impacts derive from waste disposal and material 

handling operations (e.g. fugitive dust). For FGD systems, the generation of wastewater 

and sludge from the SO2 removal process is a consideration. Wastewater from the FGD 

systems will increase sulfate, metals, and solids loading at the receiving wastewater 

treatment facility, resulting in potential impacts to operating cost, energy requirements, 

and effluent water quality. Processing of the wastewater sludge can require energy for 

stabilization and/or dewatering, and transporting the sludge to the landfill has additional 

environmental impacts. 

Fuel switching to a low-sulfur distillate fuel oil has a variety of beneficial consequences 

for ICI boilers. Low-sulfur distillate fuel is cleaner burning and emits less particulate 

matter, which reduces the rate of fouling of heating units substantially and permits longer 

time intervals between cleanings. According to a study conducted by the New York State 

Energy Research and Development Authority, (NYSERDA)57, lowering the fuel sulfur 

content from 1,400 ppm to 500 ppm will reduce boiler deposits by a factor of two. These 

reductions in buildup of deposits result in longer service intervals between cleanings. 

Reducing SO2 emissions from ICI boilers would have positive environmental and health 

impacts. SO2 controls would reduce acid deposition, helping to preserve aquatic life, 

forests, crops, and buildings and sculptures made of acid-sensitive materials. These 

emission reductions would also help to decrease ambient concentrations of PM2.5, a 

significant contributor to premature morbidity and illness in individuals with heart or 

lung conditions. 

 

57 Reference 10 in Attachment T. 

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MANE-VU has concluded that the energy and non-air environmental impacts of 

controlling SO2 emissions from ICI boilers are justified in light of the beneficial impacts 

on regional haze, fine particulate air pollution, acid rain, and equipment operation, as 

described above. Maine concurs with this conclusion. 

Remaining Useful Life of Any Potentially Affected Sources

Available information for remaining useful life estimates of ICI boilers indicates a wide 

range of operating time, depending on size of the unit, capacity factor, and level of 

maintenance performed. Typical life spans range from about 10 years up to over 30 

years. However, the remaining useful life of a source is highly variable; and older units 

are not likely to be retrofitted with expensive emission controls. Given the typical range 

of life expectancies of ICI boilers, the technical options available, and the flexibility that 

non-MANE-VU states would have to meet the Ask, MANE has concluded that its request 

for a 28 percent reduction in non-EGU SO2 emissions is reasonable. Maine concurs with 

this conclusion. 

11.5 Visibility Impacts of Additional Reasonable Controls 

MANE-VU’s evaluations included modeling to estimate the visibility effects of various 

elements of the Maine/MANE-VU Ask. This modeling is described in NESCAUM’s 

report entitled “MANE-VU Modeling for Reasonable Progress Goals,” February 2008, 

(Attachment P). NESCAUM also conducted more recent, revised modeling to assess the 

effects of all haze reduction strategies combined. The latter modeling is described in 

NESCAUM’s report entitled “2018 Visibility Projections,” March 2008, (Attachment Q). 

The following information about the effects of specific strategies is taken from these 

reports. 

The NESCAUM modeling demonstrates that significant visibility benefits will accrue 

from implementation of the additional reasonable control measures described in 

Subsection 11.4, above. Figures 11.3 and 11.4 describe the results of this modeling. In 

the first of the two figures, the light yellow bars represent expected visibility at MANEVU Class I areas in 2018. Comparison of these values with the 2018 “glide slope” 

values (the plum-colored second bars from the left) shows that all areas are expected to 

experience visibility improvements that meet or exceed the uniform rate of progress 

calculated for each area. The second figure shows that, for the 20 percent of days having 

the best visibility, expected visibility in 2018 will be better than it is today at all 

locations. 

In conclusion, the reasonable progress goals for Class I areas proposed by the MANE-VU 

states are found to be consistent with the stated national goals of preventing further 

visibility degradation while making timely progress toward achieving natural visibility 

conditions in Class I areas by 2064. 

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Figure 11-3 

Demonstration of Required and Reasonable Visibility Progress for 20% Worst 

Visibility Days 

Visibility Progress for 20% Worst Days 

0

5

10

15

20

25

30

35

Acadia Brigantine Great Gulf Lye Brook Moosehorn

Visibility (deciviews)

2002 Baseline 2018 Glideslope 2018 Projected Progress Natural

(Visibility Improvements Must be Made at Reasonable Rate)

Figure 11-4 

Demonstration of Required and Visibility Maintenance for 20% Best Visibility Days 

Visibility Progress For 20% Best Days

0

2

4

6

8

10

12

14

16

Acadia Brigantine Great Gulf Lye Brook Moosehorn

Visibility (deciviews)

2002 Baseline 2018 Projected Progress

(Baseline Visibility Must be Maintained or Improved)

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12. Long Term Strategy 

40 CFR Section 51.308(d)(3) requires the State of Maine to submit a long-term strategy 

that addresses regional haze visibility impairment for each mandatory Class I Federal 

area within and outside the State which may be affected by emissions from within Maine. 

These Class I areas include: Acadia National Park; Great Gulf Wilderness Area; 

Presidential Range-Dry River Wilderness; Moosehorn Wilderness and Roosevelt 

Campobello International Park. The long-term strategy must include enforceable 

emissions limitations, compliance schedules, and other measures necessary to achieve the 

reasonable progress goals established by States/Tribes where the Class I areas are 

located. As described in Section 3.0, Regional Planning and Consultation, Maine 

consulted with states and tribes both within and outside MANE-VU when developing the 

emission management strategies in this SIP. The following describes how Maine meets 

the long-term strategy requirements of the Regional Haze Rule. 

Maine’s long term strategy includes enforceable emissions limitations, compliance 

schedules, and other measures necessary to achieve the reasonable progress goals 

established in Section 11. Additional measures may be reasonable to adopt at a later date 

after further consideration and review. In developing this long-term strategy, Maine also 

considered the requirements of the Clean Air Act, Section 110(a)(2)9D)(i)(ii), pertaining 

to interstate and international transport of pollutants. Maine has previously addressed 

this issue in its “Transport SIP Revision,” submitted to EPA on April 24, 2008. As that 

document observed, states must include provisions in their implementation plans to 

prohibit any source or activity from emitting air pollutants in amounts that would 

interfere with another state’s ability to prevent significant deterioration of air quality and 

visibility. The long-term strategy presented herein is designed to protect visibility in 

Maine as well as in areas outside of Maine that are affected by Maine emissions. 

12.1 Overview of the Long Term Strategy Development Process 

The regional strategy development process identified reasonable measures that would 

reduce emissions contributing to visibility impairment at MANE-VU Class I areas by 

2018 or earlier. The process for identifying potential emission reduction measures and 

the technical basis for the long term strategy is discussed in the following sections.

As a MANE-VU member and participant, Maine supported a number of technical 

analyses that were developed to assist the MANE-VU states in deciding which regional 

haze control measures to pursue. These analyses are documented in the following 

reports: 

 “Contributions to Regional Haze in the Northeast and Mid-Atlantic United 

States” (also known as the Contribution Assessment), August 3, 2006, 

NESCAUM (Attachment A). 

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 “Comparison of CAIR and CAIR Plus Proposal using the Integrated Planning 

Model®” (also known as the CAIR+ Report), May 30. 2007, ICF/MARAMA 

(Attachment U). 

 “Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I 

Areas” (also known as the Reasonable Progress Report), July 9, 2007, 

MACTEC/MARAMA (Attachment T). 

 “Five-Factor Analysis of BART-Eligible Sources: Survey of Options for 

Conducting BART Determinations,” June 1, 2007, NESCAUM (Attachment 

N). 

 “Assessment of Control Technology Options for BART-Eligible Sources: 

Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and Pulp 

Facilities,” March 7, 2005, NESCAUM (Attachment R). 

12.2 The Regional Process for Identifying Potential Strategies 

MANE-VU reviewed a wide range of potential control measures to reduce regional haze 

at the affected Class I areas by the 2018 milestone. The process of choosing a set of 

proposed regional haze control measures started in late 2005. The Ozone Transport 

Commission (OTC) selected a contracting firm to assist with the analysis of ozone and 

regional haze control measure options, and provided the contractor with a “master list” of 

some 900 potential control measures, based on experience and previous state 

implementation plan work. With the help of an internal OTC control measure workgroup, 

the contractor narrowed the list of available regional haze control measures for further 

consideration by MANE-VU. 

MANE-VU then developed an interim list of control measures for regional haze. The 

identified control measures can be divided into three general categories: 

 Beyond-CAIR sulfate reductions from electricity generating units (EGUs) and 

related control measures targeted at specific EGUs in the eastern United States; 

 Low-sulfur heating oil (residential and commercial); 

 Controls on ICI boilers (both coal and oil-fired); 

 Controls on lime and cement kilns; and 

 Controls on residential wood combustion, and outdoor burning (including outdoor 

wood boilers). 

The next step was to further refine this list, with the aid of several of the reports named 

above. The CAIR Plus Report (Attachment U) documents MANE-VU’s assessment of 

the costs of CAIR and provides a cost analysis for additional SO2 and NOx controls at 

EGUs in the eastern United States. The Reasonable Progress Report documents the 

assessment of control measures for EGUs and the other source categories selected for 

analysis. Further analysis is provided in the NESCAUM document entitled, “Assessment 

of Control Technology Options for BART-Eligible Sources: Steam Electric Boilers, 

Industrial Boilers, Cement Plants and Paper and Pulp Facilities.” 

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The beyond-CAIR EGU strategy quickly became central to the MANE-VU long term 

strategy planning efforts, since EGU sulfate emissions are the largest contributor to 

visibility impairment at MANE-VU Class I areas. Similarly, a low-sulfur oil strategy 

gained traction after a NESCAUM-initiated conference with refiners and fuel-oil 

suppliers concluded that such a strategy could fully implemented by 2018. Thus the lowsulfur heating oil and the oil-fired ICI boiler sector control measures merged into an 

overall strategy requiring the use of low-sulfur oil. Under this strategy, low-sulfur oil 

would be required for all residential and commercial heating units and all ICI boilers 

burning #2, #4, or #6 fuel oils. 

During MANE-VU’s internal consultation meeting in March 2007, member states 

reviewed the interim list of control measures to make additional refinements. States 

determined, for example, that there may be too few coal-fired ICI boilers in the MANEVU states for that to be considered as a “regional” strategy, but those sources could be 

controlled on a state-by-state basis. The MANE-VU members also decided that lime and 

cement kilns, of which there are few in the MANE-VU region, would best be handled via 

the BART determination process. Residential wood burning and outdoor wood boilers 

remained on the list for those states where localized visibility impacts are a consideration, 

even though emissions from these sources are primarily organic carbon and direct 

particulate mater. Finally, the MANE-VU membership decided that the issue of outdoor 

wood burning should be examined further by individual states, because of concerns 

related to enforcement and penetration of existing state regulations58. 

12. 3 The Technical Basis for Strategy Development 

40 CFR Section 51.308(d)(3)(iii) requires Maine to document the technical basis for the 

State’s apportionment of emission reductions necessary to meet reasonable progress goals 

in each Class I area affected by its emissions. Maine relied on the technical analyses 

developed by MANE-VU to demonstrate that the Maine emission reductions, when 

coordinated with those of other States and Tribes, are sufficient to achieve reasonable 

progress goals in Class I areas affected by emissions originating in Maine. 

The emission reductions necessary to meet reasonable progress goals in the Class I areas 

affected by Maine are described in the following documents: 

 “Baseline and Natural Background Visibility Conditions—Considerations and 

Proposed Approach to the Calculation of Baseline and Natural Background 

Visibility Conditions at MANE-VU Class I Areas,” December 31, 2006, 

NESCAUM (Attachment G). 

 “The Nature of the Fine Particle and Regional Haze Air Quality Problems in 

the MANE-VU Region: A Conceptual Description,” November 2, 2006, 

NESCAUM (Attachment V). 

58 Maine regulates outdoor burning activities through statute at 12 MRSA §9321 et seq. and through its 06-

096 CMR Chapter 102 Open Burning and 06-096 CMR Chapter 150 Control of Emissions From Outdoor 

Wood Boilers rule. 

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 “Contributions to Regional Haze in the Northeast and Mid-Atlantic United 

States (also known as the Contribution Assessment),” August 31, 2006, 

NESCAUM (Attachment A). 

 “Comparison of CAIR and CAIR Plus Proposal using the Integrated Planning 

Model® (also known as the CAIR+ Report) May 30, 2007, ICF/MARAMA 

(Attachment U). 

 “Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I 

Areas” (called the Reasonable Progress Report), July 9, 2007, 

MACTEC/MARAMA) (Attachment T). 

 “Five-Factor Analysis of BART-Eligible Sources: Survey of Options for 

Conducting BART Determinations,” June 1, 2007, NESCAUM (Attachment 

N). 

 “Assessment of Control Technology Options for BART-Eligible Sources: 

Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and Pulp 

Facilities,” March 7, 2005, NESCAUM (Attachment R). 

 “MANE-VU Modeling for Reasonable Progress Goals: Model Performance 

Evaluation, Pollution Apportionment, and Control Measure Benefits,” 

February 7, 2008, NESCAUM (Attachment P). 

 “2018 Visibility Projections,” March 31, 2008, NESCAUM (Attachment Q). 

In addition, Maine relied on analyses conducted by neighboring RPOs, including the 

following documents, which are available upon request but are not incorporated into this 

SIP: 

 VISTAS Reasonable Progress Analysis Plan by VISTAS, dated September 

18, 2006. 

 Reasonable Progress for Class I Areas in the Northern Midwest-Factor 

Analysis, by EC/R, dated July 18. 2007.. 

As described in Subsection 12.2, above, Maine worked with the other members of 

MANE-VU and with the Ozone Transport Commission to evaluate a large number of 

potential emission reduction strategies covering a wide range of sources of SO2 and other 

pollutants contributing to regional haze. 40 CFR 51.308(d)(3)(v) requires states to 

consider several factors in developing their long-term strategies. Operating within this 

framework and using the available information about emissions and potential impacts, the 

MANE-VU Reasonable Progress Workgroup selected the following source categories for 

detailed analysis: 

 Coal and oil-fired electric generating units, (EGUs); 

 Point and area source industrial, commercial and institutional (ICI) boilers; 

 Cement and lime kilns; 

 Sources capable of using low-sulfur heating oil; and 

 Residential wood combustion and open burning. 

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These efforts led to the selection of the emission reductions strategies presented in this 

SIP. 

12.4 Emission Reductions Due to Ongoing Air Pollution Reduction Programs 

40 CFR Section 51.308(d)(3)(v)(A) requires Maine to consider emission reductions from 

ongoing pollution control programs. In developing its Long Term Strategy, Maine 

considered emission control programs being implemented between the 2002 baseline 

period and 2018. The emission reduction programs described in Subsection 12.4.1, 

12.4.2 and 12.4.3 below represent commitments already made by Maine and other states 

to implement air pollution control measures for EGU point sources, non-EGU point 

sources, and area sources, respectively. These control measures are the very same 

measures that were included in the 2018 emissions inventory and used in the modeling. 

While these control measures were not designed expressly for the purpose of improving 

visibility, the pollutants they control include those that contribute to visibility impairment 

in MANE-VU Class I Areas. 

MANE-VU’s 2018 “beyond on the way” (BOTW) emissions inventory accounts for 

emission controls already in place as well as emission controls that are not yet finalized 

but are likely to achieve additional reductions by 2018. The BOTW inventory was 

developed based on the MANE-VU 2002 Version 3.0 inventory and the MANE-VU 2018 

on the books/on the way (OTB/OTW) inventory. Inventories used for other RPOs reflect 

anticipated emissions controls that will be in place by 2018. The inventory is termed 

“beyond on the way” because it includes control measures that were developed for ozone 

SIPs that were not yet on the books in some states. For some states it also included 

controls that were under consideration for Regional Haze SIPs that have not yet been 

adopted. More information may be found in the following documents: 

 “Development of Emissions Projections for 2009, 2012, and 2018 for NonEGU Point, Area, and Non-road Sources in the MANE-VU Region,” February 

2007, MACTEC/MARAMA (Attachment J) 

 “Documentation of 2018 Emissions from Electric Generating Units in Eastern 

U.S. for MANE-VU Regional Haze Modeling,” April 28, 2008, Alpine 

Geophysics/MARAMA (Attachment S) 

 “MANE-VU Modeling for Reasonable Progress Goals: Model Performance 

Evaluation, Pollution Apportionment, and Control Measure Benefits,” February 

7, 2008, NESCAUM (Attachment P) 

 “2018 Visibility Projections,” March 31, 2008, NESCAUM (Attachment Q) 

12.4.1 EGU Emissions Controls Expected by 2018 

The following EGU emission reduction programs were included in the modeling used to 

develop the reasonable progress goals. These programs represent the greatest 

opportunities for reducing SO2 emissions at Class I areas in the MANE-VU region and 

serve as the starting point for MANE-VU’s long-term strategy to mitigate regional haze. 

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Clean Air Interstate Rule (CAIR). This major federal rule has been remanded to EPA to 

correct deficiencies. The original CAIR imposed permanent caps on sulfur dioxide (SO2) 

and nitrogen oxides (NOx) in the eastern United States by 2015. When fully effective, 

this program was expected to reduce SO2 emissions in the CAIR region by up to 70 

percent. The first phase of CAIR was implemented on an interim basis in 2009, and EPA 

is expected to issue a revised CAIR rule in response to the remand in 2010 or 2011. To 

predict future emissions from EGUs after implementation of CAIR, MANE-VU used the 

Integrated Planning Model (IPM).59 Adjustments to the IPM output were made to 

provide a more accurate representation of anticipated controls at specific EGU sou

documented in the Alpine Geophysics report listed above. In making these adjustments, 

emission controls originating from the following states and regional programs were 

considered. 

rces as 

Connecticut EGU Regulations: Connecticut adopted the following regulations governing 

EGU emissions: 

 

 Regulations of Connecticut State Agencies (RCSA) section 22a-174- 19a, limiting 

the SO2 emission rate to 0.33 lb SO2/MMBtu for fossil fuel-fired EGUs greater 

than 15 MW that are also Title IV sources. (Implementation status - 2007). 

 RCSA section 22a-174-22, limiting the non-ozone seasonal NOX emission rate to 

0.15 lb NOX/MMBtu for fossil fuel-fired EGUs greater than 15 MW. 

(Implementation status - 2007). 

 Connecticut General Statutes section 22a-199, limiting the mercury (Hg) 

emission rate to 0.0000006 lb Hg/MMBtu for all coal-fired EGUs or alternatively 

coal-fired EGUs can meet a 90% Hg emission reduction. (Implementation status 

- 2008). 

Delaware EGU Regulations: Delaware adopted the following regulations governing 

EGU emissions: 

1. Reg. 1144, Control of Stationary Generator Emissions, SO2, PM, VOC and NOx

emission control, state-wide, effective January 2006. 

2. Reg. 1146, EGUs, Electric Generating Unit (EGU) Multi-Pollutant Regulation, 

SO2 and NOx emission control, state-wide, effective December 2007. SO2

reductions will be more than regulation specifies. 

 

59 The IPM model runs also anticipated the implementation of EPA’s Clean Air Mercury Rule (CAMR), 

which was recently vacated by the courts. However, MANE-VU believes that the adjustments made to the 

predicted SO2 emissions from EGUs will have a larger effect on the air quality modeling analysis 

conducted for this SIP than will the vacatur of the CAMR rule. The emission adjustments were based on 

state’s comments on the actual levels of SO2 controls expected to be installed in response to state-specific 

regulations and EPA’s CAIR rule. MANE-VU believes these adjustments improve the reliability of both 

the emission inventory and modeling results. 

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3. Regulation No. 1148, Control of Stationary Combustion Turbine Electric 

Generating Unit Emissions, requiring SO2, NOx and PM2.5 emission controls, 

state-wide, effective January 2007. 

Delaware estimates that these regulations will result in the following emission reductions 

for affected units: SO2 emissions of 32,630 tons in 2002 will decline to 8,137 tons in 

2018 (a 75 percent reduction); NOx emissions of 8,735 tons in 2002 will decline to 3,740 

tons in 2018 (a 57 percent reduction). 

Also, Delaware anticipates the following reductions resulting from the consent decree 

with the Valero Refinery Delaware City, DE (formerly Motiva, Valero Enterprises). 2002 

SO2 levels of 29,747 tons will drop to 608 tons in 2018 (a 98 percent reduction). NOx

2002 levels of 1,022 tons will fall to 102 tons in 2018 (a 90 percent reduction). 

Maine EGU Regulations: Chapter 145 NOX Control Program, limits the NOX emission 

rate to 0.22 lb NOX /MMBtu for fossil fuel-fired units greater than 25 MW built before 

1995 with a heat input capacity between 250 and 750 MMBtu/hr, and which also limits 

the NOX emission rate to 0.17 lb NOX /MMBtu for fossil fuel-fired units greater than 25 

MW built before 1995 with a heat input capacity greater than 750 MMBtu/hr. (effective 

2007) 

Massachusetts EGU Regulations: Based on the Massachusetts Department of 

Environmental Protection’s 310 CMR 7.29, Emissions Standards for Power Plants,

adopted in 2001, six of the largest fossil fuel-fired power plants in Massachusetts must 

comply with emissions limitations for NOx, SO2, mercury, and CO2. These regulations 

will achieve an approximately 50 percent reduction in NOx emissions and a 50 - 75 

percent reduction in SO2 emissions compared to previous emissions. Depending upon 

the compliance path selected by the affected facilities, the facilities will comply with the 

output-based NOx and SO2 standards between 2004 and 2008. This regulation also limits 

the six grandfathered EGUs to a CO2 emisison rate of 1,800 lb/MWh. 

New Hampshire EGU Regulations: New Hampshire adopted the following regulations 

governing EGU emissions: 

 Chapter Env-A 2900 capping NOx emissions at 3,644 tons NOX per year, SO2

emissions at 7,289 tons SO2 per year, and CO2 emissions at 5,425,866 tons CO2 per 

year for all existing fossil steam units by December 31, 2006. 

 Chapter Env-A 3200 NOx Budget Trading Program limiting ozone season NOX

emissions on all fossil fuel-fired EGUs greater than 15 MW to 0.15 lb/MMBtu, 

effective November 2, 2007. 

New Jersey New Source Review Settlement Agreements: The New Jersey settlement 

agreement with PSEG required the following actions for specific EGUs: 

 Bergen Unit #2: Repower to combined cycle by December 31, 2002. 

 Hudson Unit #2: install Dry FGD or approved alternative technology by Dec. 31, 

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2006 to control SO2 emissions, and operate the control technology at all times the 

unit operates to limit SO2 emissions to 0.15 lb SO2/MMBtu; install SCR or 

approved alternative technology by May 1, 2007 to control NOX emissions and 

operate the control technology year-round to limit NOX emissions to 0.1 lb 

NOx/MMBtu; and install a baghouse or approved alternative technology by May 1, 

2007 to control PM emissions and limit PM emissions to 0.015 lb PM/MMBtu. 

 Mercer Unit #1: install Dry FGD or approved alternative technology by Dec. 31, 

2010 to control SO2 emissions and operate the control technology at all times the 

unit operates to limit SO2 emissions to 0.15 lb SO2/MMBtu, and install SCR or 

approved alternative technology by 2005 to control NOX emissions, and operate the 

control technology ozone season only in 2005 and year-round by May 1, 2006 to 

limit NOX emissions to 0.13 lb NOX/MMBtu. 

 For Mercer Unit #2: install Dry FGD or approved alternative technology by Dec. 

31, 2012 to control SO2 emissions, and operate the control technology at all times 

the unit operates to limit SO2 emissions to 0.15 lb SO2/MMBtu, and install SCR or 

approved alternative technology by 2004 to control NOX emissions, and operate the 

control technology ozone season only in 2004 and year-round by May 1, 2006 to 

limit NOX emissions to 0.13 lb NOX /MMBtu. 

The New Jersey settlement also requires coal with monthly average sulfur content no 

greater than 2% at units operating an FGD. 

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

EGUs: 

Title 6 NYCRR Parts 237, Acid Deposition Reduction NOx Budget Trading Program, 

limits NOX emissions on all fossil fuel-fired EGUs greater than 25 MW to a non-ozone 

season cap of 39,908 tons in 2007. 

Title 6 NYCRR Parts 238, Acid Deposition Reduction SO2 Budget Trading Program

limits annual SO2 emissions from all fossil fuel-fired EGUs greater than 25 MW to an 

annual SO2 cap of 197,046 tons SO2/year, starting in 2007 and an annual SO2 cap of 

131,364 tons SO2/year starting in 2008. 

North Carolina Clean Smokestacks Act: Enacted in 2002, this legislation requires that 

coal-fired EGUs achieve a 77 percent cut in nitrogen oxide (NOx) emissions by 2009 and 

a 73 percent cut in sulfur dioxide (SO2) emissions by 2013. This legislation also 

establishes annual caps on both SO2 and NOx emissions for the two primary utility 

companies in North Carolina, Duke Energy and Progress Energy. These reductions must 

be made in North Carolina, and allowances are not saleable. 

Consent Agreements in the VISTAS region: The effects of the following consent 

agreements in the VISTAS states were reflected in the emissions inventories used for 

those states: 

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 Santee Cooper: A 2004 consent agreement calls for Santee Cooper in South 

Carolina to install and commence operation of continuous emission control 

equipment for PM/SO2/NOx emissions; comply with system-wide annual 

PM/SO2/NOx emissions limits; agree not to buy, sell or trade SO2/NOx 

allowances allocated to Santee Cooper System as a result of said agreement; 

and to comply with emission unit limits of said agreement. 

 TECO: Under a settlement agreement, by 2008, Tampa Electric in Florida will 

install permanent emissions-control equipment to meet stringent pollution 

limits; implement a series of interim pollution reduction measures to reduce 

emissions while the permanent controls are designed and installed; and retire 

pollution emission allowances that Tampa Electric or others could use, or sell 

to others, to emit additional NOx, SO2 and PM.

 VEPCO: Virginia Electric and Power Co. agreed to spend $1.2 billion 

between by 2013 to eliminate 237,000 tons of SO2 and NOx emissions each 

year from eight coal-fired electricity generating plants in Virginia and West 

Virginia. 

 Gulf Power 7: A 2002 agreement calls for Gulf Power to upgrade its operation 

to cut NOx emission rates by 61 percent at its Crist 7 generating plant by 2007 

with major reductions beginning in early 2005. The Crist plant is a significant 

source of nitrogen oxide emissions in the Pensacola Florida, area. 

12.4.2 Non-EGU Point Point Source Controls Expected by 2018 

For non-EGU sources within MANE-VU, Maine relied on MANE-VU’s Version 3.0 

Emission Inventory for 2002. MACTEC conducted an analysis of various control 

measures as documented in “Development of Emission Projections for 2009, 2012, and 

2018 for Non-EGU, Area, and Nonroad sources in the MANE-VU Region” (Attachment 

I). Control factors were applied to the 2018 MANE-VU inventory for non-EGUs to 

represent the following national, regional, or state control measures: 

 NOx SIP Call Phase I (NOx Budget Trading Program) (except ME, NH and 

VT) 

 NOx SIP Call Phase II (except ME, NH and VT ) 

 NOx RACT in 1-hour Ozone SIPs (already included in the 2002 inventory) 

 NOx OTC 2001 Model Rule for ICI Boilers 

 2-, 4-, 7-, and 10-year MACT Standards 

 Combustion Turbine and RICE MACT (NOx co-benefits not includedassumed to be minimal) 

 Industrial Boiler/Process Heater MACT60 

 

60 The inventory was prepared before the MACT for Industrial Boilers and Process Heaters was vacated. 

Control efficiency was assumed to be at 4 percent for SO2 and 40 percent for PM. 

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 EPA’s Refinery Enforcement Initiative (Fluid catalytic cracking units and 

fluid coking units; process heaters and boilers; flare gas recovery; leak 

detection and repair; and benzene (wastewater)) 

In addition, states provided specific control measure information about specific non-EGU 

sources or regulatory programs in their state. For example, several states developed 

additional control measures in the course of their planning efforts to reduce ozone within 

the Ozone Transport Region (OTR). These control measures were included by MANEVU in their inventories used for regional haze modeling. (The affected states may or may 

not have committed to adopting these measures in their ozone SIPs). For specific states, 

the ozone reduction strategies included in the modeling would reduce NOx emissions 

from the following non-EGU point sources: 

 Asphalt production plants in Connecticut, New Jersey, New York, and the District 

of Columbia; 

 Cement kilns in Maine, Maryland, New York, and Pennsylvania; and 

 Glass and fiberglass furnaces in Maryland, Massachusetts, New Jersey, New York 

and Pennsylvania. 

For other regions, MANE-VU used emission inventory data developed by the RPOs for 

those regions, including VISTAS Base G2, MRPO’s Base K, and CenRAP’s emissions 

inventory. Non-EGU source controls incorporated into the modeling include the 

following consent agreements reflected in the VISTAS inventory: 

 Dupont: A 2007 agreement calls for E. I. Dupont Nemours & Company’s 

James River plant to install dual absorption pollution control equipment by 

September 1, 2009, resulting in emission reductions of approximately 1,000 

tons SO2 annually. The James River plant is a non-EGU located in the state of 

Virginia. 

 Stone Container: A 2004 agreement calls for the West Point Paper Mill in 

Virginia owned by Smurfit/Stone Container to control with a wet scrubber the 

SO2 emissions of the #8 Power Boiler. This control device should result in 

reductions of over 3,500 tons of SO2 in 2018. 

12.4.3 Area Source Controls Expected by 2018 

For area sources within MANE-VU, Maine utilized MANE-VU’s Version 3.0 Emissions 

Inventory for the 2002 base year. In general, MANE-VU developed the 2018 inventory 

for area sources by applying growth and control factors to the 2002 Version 3.0 

inventory. Area source control factors were developed and incorporated in the modeling 

for the following national or regional control measures: 

 OTC VOC Model Rules (Consumer Products, Architectural and Industrial 

Maintenance Coatings, Portable Fuel Containers, Mobile Equipment Repair 

and Refinishing and Solvent Cleaning); 

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 Residential Woodstove NSPS; and 

 State-specific control strategies implemented since 2002. 

The following additional control measures were included in the 2018 analysis to reduce 

VOC and NOx emissions for the following area source categories for some states (as 

identified below): 

 VOC control measures for adhesives and sealants (controls added in all 

MANE-VU states except VT); 

 VOC control measures for emulsified and cutback asphalt paving (controls 

added in all MANE-VU states except ME, and VT); 

 VOC control measures for consumer products (controls added in all MANEVU states except VT); 

 VOC control measures for portable fuel containers (controls added in all 

MANE-VU states except VT); and; 

 NOx control measures for the combustion of natural gas, no. 2, 4 and 6 fuel 

oil, and coal (CT, NJ, NY). 

As noted above, inventory data for other regions were obtained from those Region’s 

RPOs. Some of the area source control measures listed above may have been developed 

by states for the primary purpose of reducing ozone within the Ozone Transport Region 

(OTR)- see Subsection 12.4.2 for information on other measures included in state’s ozone 

SIPs. 

12.4.4 Mobile Sources Controls Expected by 2018 

For the on-road mobile source emission inventory, Maine relied on MANE-VU’s version 

3.0 emission inventory, which included the following post-2002 emission control 

measures: 

On-Board Refueling Vapor Recovery (ORVR) Rule: The 1990 Clean Air Act (CAA) 

Amendments contain provisions that require passenger cars to capture refueling 

emissions. In 1994, EPA published the ORVR rule establishing standards for refueling 

emissions controls for passenger cars and light trucks. The onboard controls were 

required to be phased in for all new car production by 2000 and for all light trucks by 

2006. The rule established a refueling emission standard of 0.20 grams per gallon of 

dispensed fuel, which was expected to yield a 95 percent reduction of VOC emissions 

over uncontrolled levels. The CAA authorizes EPA to allow state and local agencies to 

phase out Stage II programs, even in the worst nonattainment areas, once EPA has 

determined that onboard systems are in “widespread use”. 

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Heavy Duty Diesel (2007) Engine Emission Standards for Trucks and Buses: EPA set 

a PM emissions standard for new heavy-duty engines of 0.01 grams per brakehorsepower-hour (g/bhp-hr), to take full effect for diesel engines in the 2007 model year. 

This rule also includes standards for NOx and non-methane hydrocarbons (NMHC) of 

0.20 g/bhp-hr and 0.14 g/bhp-hr, respectively. These NOx and NMHC standards will be 

phased-in together between 2007 and 2010 for diesel engines. Sulfur in diesel fuel must 

be lowered to enable modern pollution-control technology to be effective on these trucks 

and buses. EPA began requiring the use of 500 ppm low sulfur diesel fuel in 1993. In 

2006, the highway diesel sulfur content was lowered to 15ppm (ultra low sulfur diesel). 

Tier 2 Motor Vehicle Standards: Tier 2 is a fleet averaging program, modeled after the 

California LEV II standards. Manufacturers can produce vehicles with emissions ranging 

from relatively dirty to zero, but the mix of vehicles a manufacturer sells each year must 

have average NOx emissions below a specified value. Tier 2 standards became effective 

in the 2005 model year and are included in the assumptions used for calculating mobile 

source emissions inventories used for 2018. 

12.4.5 Controls on Non-Road Sources Expected by 2018 

For non-road emission sources, Maine used Version 3.0 of the MANE-VU 2002 

Emissions Inventory. Because the NONROAD Model used to develop the nonroad 

source emissions did not include aircraft, commercial marine, and locomotives, MANEVU’s contractor, MACTEC, developed the inventory for these source categories. 

Nonroad mobile source emissions for the 2018 emission inventory were calculated with 

EPA’s NONROAD2005 emissions model as incorporated in the NMIM2005 (National 

Mobile Inventory Model) database. The NONROAD model accounts for the emissions 

benefits associated with Federal non-road equipment emissions control measures such as 

the following: 

 “Control of Air Pollution; Determination of Significance for Nonroad Sources 

and Emissions Standards for New Nonroad Compression Ignition Engines At or 

Above 37 Kilowatts,” 59 FR 31306, June 17, 1994. 

 “Control of Emissions of Air Pollution From Nonroad Diesel Engines,” 63 FR 

56967, October 23, 1998. 

 “Control of Emissions From Nonroad Large Spark-Ignition Engines and 

Recreational Engines (Marine and Land-Based); Final Rule,” 67 FR 68241, 

November 8, 2002. 

 “Control of Emissions of Air Pollution From Nonroad Diesel Engines and Fuel; 

Final Rule,” 69 FR 38958, June 29, 2004. 

As noted above, the inventory information used for other regions was obtained from 

those regions’ RPOs. 

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12.5 Additional Reasonable Strategies 

As required under 40 CFR Section 51.308(d)(3)(v), Maine and the other MANE-VU 

states applied a four-factor analysis to potential control measures for the purpose of 

establishing reasonable progress goals (See Subsection 11.4 for a detailed description). 

Reasonable measures include those that the affected states have already committed 

themselves to implementing, as described in Subsection 12.4, above. In addition, the 

MANE-VU states have identified other control measures that were found to be 

reasonable and were included in the modeling that was used to set reasonable progress 

goals. (These additional measures surpass the “beyond-on-the-way” emission controls 

and inventories). All of the control measures- those embodied in the states’ 

commitments to existing or planned programs and the additional reasonable control 

measures described below- comprise the long-term strategy for improving visibility at 

MANE-VU Class I Areas. 

Specifically, the MANE-VU long-term strategy includes the following additional 

measures to reduce pollutants that cause regional haze: 

 Timely implementation of BART requirements; 

 A low sulfur fuel oil strategy in the inner zone states (New Jersey, New York, 

Delaware, and Pennsylvania, or portions thereof) to reduce the sulfur content of: 

o Distillate oil to 0.05 percent sulfur by weight (500 ppm) by no later than 

2012, 

o #4 residual oil to 0.25 percent sulfur by weight by no later than 2012, 

o #6 residual oil to 0.3 – 0.5 percent sulfur by weight by no later than 2012, 

and 

o Further reduce the sulfur content of distillate oil to 15 ppm by 2016; 

 A low sulfur fuel oil strategy in the outer zone states (the remainder of the 

MANE-VU region) to reduce the sulfur content of: 

o Distillate oil to 0.05 percent sulfur by weight (500 ppm) by no later than 

2014, 

o #4 residual oil to 0.25 percent-0.50 percent sulfur by weight by no later 

than 2018, 

o #6 residual oil to no greater than 0.5 percent sulfur by weight by no later 

than 2018, and 

o Further reduce the sulfur content of distillate oil to 15 ppm by 2018 

depending on supply and availability; 

 A 90 percent or greater reduction in sulfur dioxide (SO2) emissions from each of 

the electric generating unit (EGU) stacks identified by MANE-VU (Attachment 

W) comprising a total of 167 stacks, dated June 20, 2007) as reasonably 

anticipated to cause or contribute to impairment of visibility in each mandatory 

Class I Federal area in the MANE-VU region. If it is infeasible to achieve that 

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level of reduction from a unit, alternative measures will be pursued in such State; 

and 

 Continued evaluation of other control measures including energy efficiency, 

alternative clean fuels, and other measures to reduce SO2 and nitrogen oxide 

(NOx) emissions from all coal-burning facilities by 2018 and new source 

performance standards for wood combustion. 

This suite of additional control measures are those that the MANE-VU states have agreed 

to pursue for the purpose of mitigating regional haze. The corollary is that the MANEVU Class I states (Maine, New Hampshire, Vermont, and New Jersey) are asking states 

outside the MANE-VU region that contribute to visibility impairment inside the region to 

pursue similar measures. The control measures that non-MANE-VU states choose to 

pursue may be directed toward the same emission source sectors identified by MANEVU for its own emission reductions, or they may be equivalent measures targeting other 

source sectors. Under the MANE-VU long-term strategy, states will be allowed until 

2018 to pursue adoption and implementation of proposed control measures. 

12.5.1 BART

Implementation of the BART provisions of the Regional Haze Rule (40 CFR 51.308(e)) 

is one of the reasonable strategies included in this SIP61. BART controls in Maine are 

identified in Section 10 of this SIP. 

To assess the benefits of implementing the BART provisions of the Regional Haze Rule 

for non-EGU facilities, NESCAUM included estimated reductions anticipated for BARTeligible facilities in the MANE-VU region in the final 2018 CMAQ modeling analysis, as 

described previously in Subsection 11.5 of this SIP. The modeling assumed that 12 units 

at seven BART-eligible sources in MANE-VU would be controlled as a result of BART 

requirements alone. (see Table 12.1 

Note that additional emission reductions will occur at many other BART-eligible 

facilities within MANE-VU as a result of controls achieved by either programs that serve 

as BART but are not specifically identified as such (e.g., RACT). While not specifically 

identified as being attributable to BART, these additional emission reductions were 

accounted for in the 2018 CMAQ modeling. 

Additional visibility benefits are likely to result from the installation of new emissions 

controls at BART-eligible facilities that are located in neighboring RPOs. However, the 

MANE-VU modeling did not account for BART controls in other RPOs, and 

consequently, did not include the visibility improvements at MANE-VU Class I Areas 

that would likely result from such measures. 

 

61 For EGU’s , EPA determined that CAIR would fulfill the BART requirement for his sector. 

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12.5.2 Low-Sulfur Oil Strategy

The important assumption underlying MANE-VU’s low-sulfur fuel oil strategy is based 

on the production and use of home heating and fuel oils that contain 50% less sulfur for 

the heavier grades (#4 and #6 residual), and a minimum of 75% and maximum of 99.25% 

less sulfur in #2 fuel oil (also known as home heating oil, distillate, or diesel fuel) at an 

acceptably small increase in price to the end user. As much as three-fourths of the total 

sulfur reductions achieved by this strategy come from using the low-sulfur #2 distillate 

for space heating in the residential and commercial sectors. The costs of these emission 

reductions are estimated at $550 to $750 per ton, as documented in the MANE-VU 

Reasonable Progress Report. While the costs of the low-sulfur fuel oil strategy vary 

depending on market conditions, they appear to be reasonable when measured against the 

costs of controlling other sectors. 

 

Maine has already adopted a low sulfur fuel strategy. The 124th Second Regular Session 

of the Maine Legislature (2010) adopted LD 1662, “An Act To Improve Maine's Air 

Quality and Reduce Regional Haze at Acadia National Park and Other Federally 

Designated Class I Areas,” which implements the MANE-VU low sulfur fuel strategy in 

Maine. This legislation establishes a statewide sulfur limit for distillate fuels of 50 ppm 

in 2016, and 15 ppm in 2018. For residual (#6) fuel oil, the statewide sulfur limit will be 

reduced to 0.5% in 2018. The legislation also directs the Department to undertake 

rulemaking (to be completed by 2014) to adopt rules that provide an opportunity for a 

licensed air contamination source that holds a license on the effective date of the statute 

to apply for an equivalent alternative sulfur reduction strategy to the residual fuel oil and 

distillate fuel requirements. The rules must provide for the achievement of equivalent 

sulfur emission reductions through other means, including, but not limited to, reductions 

in consumption of residual fuel oil and distillate fuel, early sulfur emission reductions 

from a baseline emissions inventory year of 2002, and conversions. LD 1662, as adopted 

by the Maine Legislature and signed by Governor Baldacci on April 5, 2010, is attached 

in Attachment Z. 

12.5.3 Targeted EGU Strategy

MANE-VU has identified emissions from the top 167 EGU emission points that 

contribute most to visibility impairment at MANE-VU Class I Areas (see Figure 12-1). 

Controlling emissions from these contributing facilities is crucial to mitigating haze 

pollution in wilderness areas and national parks of the northeast states. 

MANE-VU’s agreed regional approach for the EGU source sector is to pursue a 90 

percent control level on SO2 emissions from the 167 identified stacks by 2018. MANEVU has concluded that pursuing this level of sulfur reduction is both reasonable and costeffective. Even though current wet scrubber technology can achieve sulfur reductions 

greater than 95 percent, and overall 90-percent sulfur reduction level would include the 

effects of lower average reduction rates from dry scrubbing technology, consistent with 

historic experience. The costs of SO2 reductions will vary by unit. The MANE-VU 

Reasonable Progress Report (Attachment T) summarizes the various control methods and 

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172 

costs, which range 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. Maine has one 

EGU identified in the MANE-VU analysis, Wyman Station Unit #4, which is located in 

located in Yarmouth, Maine. As a signatory to the MANE-VU statement of principles 

(Attachment D), Maine is committed to pursue additional emission reductions at this 

facility through its low sulfur fuel oil program. Maine DEP believes that the use of lowsulfur fuel at this facility (in lieu of add-on controls) will provide the most cost-effective 

sulfur reductions, and that additional controls at this unit should be subsumed under the 

low-sulfur fuel strategy. For more detail on Maine’s implementation of the Targeted 

EGU Strategy, see Section 12.9, below. 

Several 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. 

Maryland Healthy Air Act: Maryland adopted the following requirements governing 

EGUs: 

 For NOx: 

 Phase I (2009) sets unit specific annual caps (totaling 20,216 tons) and 

ozone season caps (totaling 8,900 tons). 

 Phase II (2012) sets unit specific annual caps (totaling 16,667 tons) and 

ozone season caps (totaling 7,337 tons). 

 For SO2: 

 Phase I (2010) sets unit specific annual caps (totaling 48,818 tons). 

 Phase II (2013) sets unit specific annual caps (totaling 37,235 tons). 

 For mercury: 

 Phase I (2010) requires a 12-month rolling average of a minimum of 80% 

removal efficiency. 

 Phase II (2013) requires a: 12-month rolling average of a minimum of 

90% removal efficiency. 

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

2), Chalk Point (Units 1, 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 of emission allowances, no inter-company trading and no banking from year-toyear were included in this analysis
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Table 12-1 

 Estimated Emissions from Non-CAIR Unit BART-Eligible Facilities Located in MANE-VU Us

Facility Name Unit 

Name 

SCC 

Code 

Plant ID 

(from the 

MANE-VU 

Inventory) 

Point ID 

(from the 

MANE-VU 

Inventory) 

Facility Type Fuel 

MD EASTALCO ALUMINUM 28 30300101 021-0005 28 Metal Production MD EASTALCO ALUMINUM 29 30300101 021-0005 29 Metal Production MD 

LEHIGH PORTLAND CEMENT 39 30500606 013-0012 39 Portland Cement 

MD 

LEHIGH PORTLAND CEMENT 16 30500915 021-0003 16 Portland Cement 

MD 

LEHIGH PORTLAND CEMENT 17 30500915 021-0003 17 Portland Cement 

MD WESTVACO FINE PAPERS 2 10200212 001-0011 2 Paper and Pulp ME Wyman Station Boiler 3 10100401 2300500135 004 EGU OME SAPPI Somerset 

Power 

Boiler #1 10200799 2302500027 001 Paper and Pulp 

Oil/W

Bark/P

G

ME IP Jay 

Power 

Boiler #2 10200401 2300700021 002 Paper and Pulp O

ME IP Jay 

Power 

Boiler #1 10200401 2300700021 001 Paper and Pulp O

NY KODAK PARK DIVISION U00015 10200203 8261400205 U00015 

Chemical 

Manufacturer 

NY 

LAFARGE BUILDING MATERIALS INC 41000 30500706 4012400001 041000 Portland Cement 

° 1999 emissions

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Figure 12-1 

167 EGU Stacks Affecting MANE-VU Class I area(s) 

Massachusetts EGU Regulations: Based on the Massachusetts Department of 

Environmental Protection’s 310 CMR 7.29, Emissions Standards for Power Plants, 

adopted in 2001, six of the largest fossil fuel-fired power plants in Massachusetts must 

comply with emissions limitations. For mercury (Hg), 6 facilities must comply with: 

85% Hg reduction or 0.0075 lbs Hg/GWh in 2008 and 90% Hg reduction or 0.0025 lbs 

Hg/GWh in 2012. The specific EGUs included are: Brayton Point (Units 1, 2, 3, 4, IC1, 

IC2, IC3, and IC4), Mystic (Units 4, 5, 6, 7, 307, 308, 309 and 310), NRG Somerset 

(Units 8, J1, and J2), Mount Tom (Unit 1), Canal (Units 1 and 2), and Salem Harbor 

(Units 1, 2, 3 and 4). 

New Hampshire EGU Laws and Regulations: New Hampshire amended the following 

laws and regulations governing EGU emissions: 

 RSA 125-O requires the installation of scrubbers on Merrimack Station (Units 1 

and 2) by July 1, 2013 to control SO2 and mercury emissions. This law allows 

State-level SO2 credits for over- or early- compliance. 

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 Env-A 2900 sets limits for NOx, SO2, and CO2 emissions by December 31, 2006 for 

all existing fossil EGUs. 

New Jersey Hg MACT Rule: Under this rule, all coal-fired EGUs will have a mercury 

removal efficiency of 90%. (Some SO2 reductions may occur as a result of this mercury 

rule.) 

Consent Agreements in the VISTAS Region: The following consent agreements in the 

VISTAS states were reflected in the emissions inventories used for those states: 

 East Kentucky Power Cooperative: A July 2, 2007 consent agreement between 

the EPA and East Kentucky Power Cooperative requires the utility to reduce its 

emissions of SO2 by 54,000 tons per year and its emissions of NOx 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 the 

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. 

 American Electric Power: Under this agreement, American Electric Power will 

spend $4.6 billion dollars for emission controls at sixteen plants located in 

Indiana, Kentucky, Ohio, Virginia and West Virginia. These control measures 

will eliminate 72,000 tons of NOx emissions each year by 2016 and 174,000 tons 

of SO2 emissions each year by 2018. 

12.6 Source Retirement and Replacement Schedules 

40 CFR Section 51.308(d)(3)(v)(D) requires Maine to consider source retirement and 

replacement schedules in developing reasonable progress goals. Source retirement and 

replacement were considered in developing the 2018 emission inventory described 

previously in Subsection 11.2, Reasonable Progress Goals for Class I Areas in Maine. 

See also Table b-5 in the Emission Projections Report (Attachment N). 

12.7 Additional Measures Considered 

12.7.1 Measures to Mitigate the Impacts of Construction Activities

40 CFR Section 51.308(d)(3)(v)(B) requires Maine to consider measures to mitigate the 

impacts of construction activities on regional haze. MANE-VU’s consideration of 

measures to mitigate the impacts of construction activities is documented in “Technical 

Support Document on Measures to Mitigate the Visibility Impacts of Construction 

Activities in the MANE-VU Region,” Draft, October 20, 2006, MARAMA (Attachment 

X). 

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The construction industry is already subject to requirements for controlling pollutants that 

contribute to visibility impairment. For example, EPA’s off-road engine standards and 

low sulfur fuel requirements result in reductions of PM and precursor emissions (SO2 and 

NOx) from construction vehicles. 

At the state level, Maine currently regulates emissions of fugitive dust through its 06-096 

CMR Chapter 101, Visible Emissions rules, which establishes opacity limits for 

emissions from several categories of air contaminant sources, including fugitive 

emissions from construction activities. Maine also regulates emissions from both on-road 

vehicles and construction activities through its 06-096 CMR Chapter 127 New Motor 

Vehicle Emission Standards rules (new motor vehicle emission standards), the 06-096 

CMR Chapter 147 Diesel-Powered Motor Vehicle Emission Standards rules (opacity 

standards), and the 06-096 CMR General Permit Regulations for Nonmetallic Mineral 

Processing Plants rules. Non-road vehicles are subject to federal regulations. 

MANE-VU’s Contribution Assessment (Attachment B) found that, from a regional haze 

perspective, crustal material generally does not play a major role at MANE-VU Class I 

Areas. On the 20 percent best visibility days during the 2000-2004 baseline period, 

crustal material accounted for 6 to 11 percent of the particle-related light extinction at 

MANE-VU Class I Areas. On the 20 percent worst visibility days, however, the ratio 

was reduced to between 2 and 3 percent. Furthermore, the crustal fraction is largely 

made up of pollutants of natural origin (e.g., soil or sea salt) that are not targeted under 

the Regional Haze Rule. Nevertheless, the crustal fraction at any given location can be 

heavily influenced by the proximity of construction activities; and construction activities 

occurring in the immediate vicinity of MANE-VU Class I Areas could have a noticeable 

effect on visibility. The need for additional control measures for construction activities 

and their possible implementation will be evaluated in the first regional haze progress 

report. 

12.7.2 Agricultural and Forestry Smoke Management

40 CFR Section 51.308(d)(3)(v)(E) requires Maine to consider smoke management 

techniques related to agricultural and forestry management in developing its long-term 

strategy. MANE-VU’s analysis of smoke management in the context of regional haze 

SIPs is documented in “Technical Support Document on Agricultural and Forestry 

Smoke Management in the MANE-VU Region,” September 1, 2006, MARAMA 

(Attachment Y). 

As noted in this report, fires used for resource management are of far less significance to 

the total inventory of fine-particle pollutant emissions than other sources of wood smoke 

in the region. The largest wood smoke source categories, with respect to PM2.5 

emissions, are residential wood combustion (73 percent); open burning (15 percent); and 

industrial, commercial and institutional wood combustion (9 percent). Unwanted fires 

involving buildings and wild lands make up only a minor fraction of wood burning 

emissions and cannot be reasonably addressed in this SIP. Fires that are covered under 

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smoke management plans, including agricultural and prescribed forest burning, constitute 

less than one percent of total wood smoke emissions in MANE-VU62. 

Moreover, smoke emissions from all sources represent only a minor fraction of fineparticle mass that is the cause of regional haze. MANE-VU’s Contribution Assessment 

(Attachment A) found that elemental carbon, the main ingredient of smoke, contributed 

only 3 to 4 percent of fine particle mass on days of worst and best visibility. 

Additionally, elemental carbon absorbs light more readily than it scatters light. It is 

therefore reasonable to conclude that smoke emissions from controlled agricultural and 

forestry burning contribute, on average, only a small fraction of one percent of total light 

extinction on days of both good and poor visibility. Maine has no information to indicate 

that this situation would change significantly over the next decade. 

12.7.3 Control of Residential and Commercial Wood Combustion Emissions

As noted in Section 8, residential wood combustion is responsible for 25 percent of 

primary fine particulate emissions in the MANE-VU region, and is a significant 

contributor to regional haze. Maine has adopted regulations to address emissions from 

outdoor wood and pellet boilers, an outdoor wood boiler replacement and buy-back 

program, and a woodstove replacement buy-back program. 

The Chapter 150 Control of Emissions from Outdoor Wood Boilers Rule

In June 2007, the Maine Legislature adopted the EPA Phase I particulate emission limit 

of 0.60 lbs/MMBtu/hr heat input as the standard for new outdoor wood-fired hydronic 

heaters (OWHH), also known as outdoor wood boilers, sold in Maine beginning April 1, 

2008. Beginning April 1, 2010 new OWHH sold in Maine are required to meet a more 

stringent particulate emission standard of 0.32 lbs/MMBTU heat output (Phase II). 

06-096 CMR Chapter 150 Control of Emissions from Outdoor Wood Boilers, which 

incorporated the OWHH particulate emission standards adopted by the Legislature, 

became effective November 1, 2007, and also established setback, stack height, 

particulate emission limits, and fuel requirements for outdoor wood boilers (See 

Attachment BB). Chapter 150 was subsequently amended63 to control the sale, 

installation, use, and siting of outdoor wood boilers that combust biomass pellets as fuel. 

Maine is submitting this rule to EPA for incorporation into the Regional Haze SIP. 

The Chapter 160, Outdoor Wood Boiler Replacement and Buy Back Program:

In April 2008, the Maine Legislature also enacted Public Law, Chapter 680, An Act 

Establishing an Outdoor Wood Boiler Fund. This Public Law established a nonlapsing 

fund administered by commissioner to be used by the Department to upgrade, purchase 

and replace outdoor wood boilers that create a nuisance condition as defined in the 

 

62 For example, PM2.5 and PM10 emissions from agricultural burning and forestry management activities 

account for only 0.139% and 0.157% of total wood smoke emissions (Source: 2002 MANE-VU Modeling 

Inventory Version 3.0). 

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Department’s rules or threat to public health or safety, and directed the Department to 

develop a rule that includes, but not limited to, criteria for determining whether an 

outdoor wood boiler constitutes a nuisance condition or threat to public health or safety 

and is eligible for use of the fund, compensation criteria and amounts and procedures for 

certification and verification of removal and possible replacement of eligible outdoor 

wood boilers. 

Pursuant to this legislation, the Department adopted the 06-096 CMR Chapter 160, 

Outdoor Wood Boiler Replacement and Buy Back Program rules, which establish a 

replacement and buy back program to remove nuisance outdoor wood boilers that were 

installed prior to February 1, 2008 and replace them with approved heating appliances. 

The Department will maintain a list of nuisance outdoor wood boilers and prioritize them 

for the program based on the threat to public health and safety and proximity to neighbors 

and sensitive populations. To receive compensation, the owner of the outdoor wood 

boiler must have explored all possible remedies, including increasing the stack height and 

setback distances to neighbors and potential retrofits to eliminate the nuisance conditions. 

Compensation may include the cost of installation and disposal and shall not exceed 

$15,000. 

The Residential Wood Stove Replacement Fund

On April 8, 2010, the Maine Legislature enacted 38 MRSA §610-D, which established a 

residential woodstove replacement program in the Maine Department of Environmental 

Protection. Under this program, eligible participants will be able to receive funding 

toward the purchase of new cleaner-burning residential heating appliances to replace 

older wood stoves that are not certified by the EPA lower emitting residential heating 

appliances, such as EPA certified wood, pellet or vented gas stoves. The Department 

will be establishing eligibility criteria for program participation, benefits, and approved 

methods for replacement and disposal of non-certified wood stoves. 

12.8 Estimated Effects of the Long-Term Strategy on Visibility 

40 CFR 51.308(d)(3)(v)(G) requires Maine to consider, in developing its long-term

strategy, the anticipated net effect on visibility due to projected changes in point, area and 

mobile source emissions over the period addressed by the long-term strategy. 

NESCAUM conducted modeling to evaluate the expected improvements to visibility at 

affected Class I Areas by 2018 as a consequence of implementing MANE-VU’s longterm strategy. Those visibility improvements will result, in part, from the efforts 

identified in this SIP to reduce emissions that originate in Maine. 

All Class I states affected by emissions originating in Maine have (or will have) 

established reasonable progress goals for 2018 for each of their Class I Areas. The 

control measures included in this SIP represent the reasonable efforts of Maine, in 

conjunction with the efforts of other MANE-VU states, toward achieving the reasonable 

progress goals established by the affected states. 

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Based on the most recent MANE-VU modeling, the proposed control measures will 

reduce sulfate levels at affected Class I Areas by about one-third on the worst visibility 

days and by 6 to 31 percent on the best visibility days by 2018. Nitrate and elemental 

carbon levels will also show substantial reductions across all areas for both bets and 

worst days, while smaller reductions in organic carbon will occur. Small increases are 

predicted for the fine soil component of regional haze. There is the possibility that the 

predicted increases in this component are not real but, rather, related to structural 

differences in the data sets used in the modeling for the baseline and future years64. No 

changes were predicted for sea salt because the model does not track this component. 

The 2000-2004 visibility readings at affected Class I areas provide the baseline against 

which future visibility readings will be measured to assess progress deriving from 

implementation of Maine’s Regional Haze SIP and those of the other MANE-VU states. 

To determine baseline visibility for affected Class I areas, the 2000-2004 IMPROVE 

monitoring data was used to calculate the average deciview values for the 20 percent best 

visibility days and the 20 percent worst visibility days over that period. Thus, the 20 

percent best day and 20 percent worst day values represent average visibility conditions 

for the top and bottom quintiles. 

To create the series of visibility graphs which follow, 2018 visibility estimates were made 

in accordance with EPA modeling guidance. First, 2002 daily average baseline 

concentrations were multiplied by their corresponding relative reduction factors to obtain 

2018 projected concentrations for each day. The 2018 projected concentrations were 

then used to derive daily visibility in deciviews. As a final step, the deciview values for 

the 20 percent of days having best visibility were averaged, and the process repeated for 

the 20 percent of days having worst visibility. The resulting averages represent the 

projected upper and lower quintiles of visibility in 2018. 

The following is provided to assist with interpretation of the line graphs in Figures 12.2

through 12.7. Note that lower deciview values indicate better visibility. 

 The irregular blue line (~) represents the 20 percent best visibility average value 

as determined from monitoring data for each year of the period 2001-2005. 

 The irregular red line (~) represents the 20 percent worst visibility average value 

as determined from monitoring data for each year of the period 2001-2005. 

 The straight orange line (__) represents the 20 percent best visibility average value 

as determined from monitoring data for the 5-year period of 2000-2004. (This 

line represents the 20 percent best visibility baseline condition.) 

 The straight blue line (__) represents the 20 percent worst visibility average value 

as determined from monitoring data for the 5-year period of 2000-2004. (This 

line represents the 20 percent worst visibility baseline condition.) 

64 Specifically, the fire emissions inventory used in VISTAS for the base year relied on an earlier version of 

fire emissions data than the one used for the 2018 inventory. 

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 The straight broken line (····) is a continuation of the 20 percent best visibility 

baseline, representing the 20 percent best visibility condition as it would be with 

no further degradation or improvement. 

 The straight green line (__) represents the 20 percent worst visibility values that 

establish the uniform rate of progress for the period 2004-2064. (This line is 

sometimes referred to as the uniform progress line, or “glide slope.” It was 

created by linear interpolation between the 20 percent worst visibility baseline 

value in 2004 and the 20 percent worst visibility value under natural conditions in 

2064. If visibility improvements match this rate of progress, actual visibility will 

return to natural conditions in 2064). 

 The light-green dash (---) shown at 2064 represents the theoretical 20 percent best 

visibility value under natural conditions (i.e., no anthropogenic emissions). 

 The purple star (*) represents the 20 percent best visibility value in 2018 after 

implementation of MANE-VU’s long-term strategy, as predicted by the CMAQ 

model. (This value is a reasonable progress goal.) 

 The blue star (*) represents the 20 percent worst visibility value in 2018 after 

implementation of MANE-VU’s long-term strategy, as predicted by the CMAQ 

model. (This value is a reasonable progress goal.) 

Figures 12-2 through 12-4 are line graphs showing anticipated visibility improvements 

for the MANE-VU Class I Areas affected by emissions originating in Maine. Figures 12-

2 and 12-3 illustrate the predicted visibility improvement at Acadia National Park and 

Moosehorn National Wildlife Refuge/Roosevelt Campobello International Park by 2018 

resulting from the implementation of the long-term strategy (See the blue cross mark). 

This improvement is compared to the Uniform Rate of Progress for affected Class I areas 

(see green sloping line). Note that the blue cross mark is below than the green line as it 

passes over the 2018 date marked at the bottom of the chart. This indicates that the 

control measures identified in this SIP provide visibility improvements exceeding the 

uniform rate of progress for reaching natural visibility in 2064. The lower number of 

deciviews means better visibility.) Figure 12-4 demonstrates that Great Gulf Wilderness 

Class I area in New Hampshire, which is significantly affected by Maine emissions, is 

also projected to meet or exceed the uniform rate of progress goal for 2018. All Class I 

areas affected by Maine emissions are also projected to have no degradation from current 

baseline best visibility. 

 

12.9 Implementation of the Regional Haze Strategies in Maine 

40 CFR Section 51.308(d)(3)(ii) of the Regional Haze Rule requires Maine to 

demonstrate that its implementation plan includes all measures necessary to obtain the 

emission reductions needed to meet the reasonable progress goals. The modeling 

analysis referenced in Subsection 12.8 (Figures 12-2 through 12-4) above, which 

demonstrates that Maine’s long-term strategy is sufficient to meet reasonable progress 

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goals, is predicated on Maine (and other MANE-VU) states reducing their SO2 emissions 

as a result of a number of emission control programs. 

Figure 12-2 

Projected Visibility Improvement at Acadia National Park Based On 2018 Best and 

Final Projections 

Figure 12-3 

Projected Improvement in Visibility at Moosehorn National Wildlife Refuge and 

Roosevelt Campobello International Park based on 2018 Best and Final Projections 

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Figure 12-4 

Projected Visibility Improvement at Great Gulf Wilderness 

Based on Most Recent Projections for 2018 

As previously noted, Maine has adopted, and will implement, the following measures as 

part of its long-term strategy to meet the reasonable progress goals: 

1. A low sulfur fuel oil strategy in accordance with the MANE-VU statement providing 

SO2 reductions for Wyman Station, ICI boilers, and residential heating units; 

2. Timely implementation of BART requirements yielding a 50 percent or greater 

reduction in SO2 emissions from Maine sources subject to BART; 

3. A program to reduce SO2 emissions at the Wyman Station #4 boiler by at least 84 

percent from uncontrolled levels; and 

4. A comprehensive program to reduce wood smoke emissions from outdoor wood 

and pellet boilers, woodstoves and other wood-burning devices. 

12.9.1 The Maine Low Sulfur Oil Program

The Maine Low Sulfur Oil Program, as enacted by Public Law Chapter 604, (See 

Attachment Z), instituted the following restrictions on fuel sulfur content for residual (#4, 

#5, and #6) and distillate oil: 

(1) Beginning January 1, 2018; a person may not use residual oil with a sulfur content 

greater than 0.5% by weight; 

(2) Beginning January 1, 2016, a person may not use distillate oil with a sulfur 

content greater than 0.005 % by weight; and 

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(3) Beginning January 1, 2018, a person may not use distillate oil with a sulfur 

content greater than 0.0015 % by weight. 

In addition to the low sulfur requirements for distillate and residual oil, the program 

contains two elements not included in the MANE-VU Low Sulfur Oil Strategy. These 

elements include: 

1) An exemption from the low sulfur content limits for sources using distillate fuel 

for manufacturing purposes; and 

2) Equivalent alternative sulfur reduction application. The Department of 

Environmental Protection is required to adopt major substantive rules65 that 

provide an opportunity for a licensed air contamination source that holds a license 

on the effective date of this subsection to apply for an equivalent alternative sulfur 

reduction strategy to the residual fuel oil and distillate fuel requirements. The 

rules must provide for the achievement of equivalent sulfur emission reductions 

through other means, including, but not limited to, reductions in consumption of 

residual fuel oil and distillate fuel, early sulfur emission reductions from a 

baseline emissions inventory year of 2002 and conversions to alternative fuels. 

Approved alternate sulfur reduction strategies must be in effect by January 1, 

2018. 

The Distillate Fuel Exemption

The Department does not believe that the low sulfur content limit exemption for 

manufacturing purposes will have a significant impact on the emission reductions 

afforded by this strategy for 2018 and beyond. While the exemption allows the continued 

use of high-sulfur66 distillate oil at several manufacturing facilities, there are structural 

impediments to the actual use of these fuels. First, since there is only a limited potential 

market for high-sulfur distillate67 the Department believes that this fuel will not be 

readily available, and will likely be more expensive than the more widely-used 15 ppm 

distillate. Distributors and wholesalers of distillate fuels have noted that supplying highsulfur distillate to a limited market introduces additional costs to their industry in the 

form of segregated storage and transportation/delivery systems, since even incidental 

contamination (co-mingling) can lead to non-compliance issues. 

Very small amounts of higher sulfur product can contaminate ultra low sulfur distillate, 

as illustrated in Figure 12-5, below. Since less than 7 gallons of high sulfur distillate can 

contaminate an entire truck load of ultra-low sulfur distillate fuel, segregated storage and 

transportation/delivery systems are probably the only mechanism that can assure 

compliance with federal and state ULSD requirements for the petroleum marketing 

industry. Given the low demand, and additional storage, transportation and delivery 

costs, the Department does not believe that high sulfur distillate fuel will be widely used 

by the manufacturing sector in 2018 and later. 

 

65 Rules must be adopted and submitted to the Maine Legislature for approval by January 1, 2014. 66 Containing 2,000-5,000 ppm sulfur. 67 All other users of distillate (diesel) fuel in Maine will be subject to the 15 ppm sulfur limits (including 

general use and space heating at manufacturing facilities). 

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Figure 12-5 

Contamination of Ultra Low Sulfur Distillate (Diesel) Fuel 

Fuel Type Amount of non-ULSD added to 7,500 gallons of ULSD 

7 gallons (0.1%) 37 gallons (0.5%) 75 gallons (1%) 

500-ppm Fuel +0.5 ppm +2.5 ppm + 5.0 ppm 

2,000 ppm Fuel +2.0 ppm +10.0 ppm + 20.0 ppm 

5,000 ppm Fuel +5.0 ppm + 25.0 ppm +50.0 ppm 

As noted above, Maine believes that future (2018) use of distillate fuel by the 

manufacturing sector will be limited due to cost and compliance concerns. Nevertheless, 

projected 2018 SO2 emissions for Maine have been adjusted to address this exemption, 

and its impact on non-EGU point source emissions, as discussed in Section 12.10, below. 

The Equivalent Alternative Sulfur Reduction Application

Under this provision of the Maine low sulfur oil program, the Department of 

Environmental Protection is required to adopt rules providing an opportunity for a 

licensed source that holds an air emission license to apply for an equivalent alternative 

sulfur reduction strategy to the residual fuel oil and distillate fuel requirements. Since 

these rules will require sulfur emission reductions that are equivalent to the use of 0.5% 

sulfur residual or 0.0015% sulfur distillate fuel, there will be no net change to the 

predicted SO2 emission reductions provided by this strategy. The Department will be 

working with EPA to develop these rules, and will submit them for inclusion into the SIP. 

12.9.2 BART in Maine 

As required by 40 CFR §51.308(e), the Maine Regional Haze SIP includes emission 

limitations representing Best Available Retrofit Technology (BART) and schedules for 

compliance with BART for each BART-eligible source that may reasonably be 

anticipated to cause or contribute to any impairment of visibility in any mandatory Class I 

Federal area. Maine’s implementation of the BART requirements is fully discussed in 

Section 10. 

12.9.3 The Targeted EGU Strategy in Maine 

As noted in section 12.5.3, above, MANE-VU’s agreed regional approach for the EGU 

source sector is to pursue a 90 percent control level on SO2 emissions from the 167 

identified stacks by 2018. Maine has one EGU identified in the MANE-VU analysis; 

FPL Energy (FPLE) Wyman Station Unit #4. 

FPLE Wyman Station is an 850-megawatt electric generating facility located on Cousins 

Island in Yarmouth, Maine. The facility consists of four generation units, all of which 

fire #6 residual fuel oil. The fifth unit is a smaller oil-fired auxiliary boiler which 

provides building heat and auxiliary steam, and the sixth unit is an emergency backup 

diesel generator that provides electricity for use on-site. 

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Unit #4 is powered by a Foster Wheeler boiler with a maximum design heat 

input of 6290 MMBtu/hr, firing #6 and #2 fuel oil. This unit is equipped with 30 

front wall fired burners capable of firing up to 41,333 gal/hr. Boiler #4 was 

manufactured in 1974 and installed in 1975, and therefore is subject to the New 

Source Performance Standards (NSPS) Subpart D, but not Subpart Da. Unit #4 is a 

peaking unit, and operated at an average annual capacity factor of less than 10 percent 

between 2002 and 200968, with annual SO2 emissions of 1,170 tpy in 2002. 

Although flue gas desulfurization (FGD) through the use of a wet, semi-dry or dry 

scrubber is technically feasible, this technology is cost prohibitive due to the lowcapacity factor of this unit and site-specific restrictions. In lieu of requiring add-on 

controls, Maine will be utilizing its low-sulfur fuels program to implement the MANEVU Targeting EGU Strategy at this unit. The Maine Low Sulfur Fuel Program will 

require the use of low-sulfur fuel containing no more than 0.5% sulfur beginning January 

1, 2018, providing an 84 percent reduction from baseline (3.0% sulfur) fuel. 

Maine is also committing to further analyze the visibility benefits that would be provided 

by the use of 0.3% sulfur fuel, and to require the use of this fuel (or an equivalent 

emissions rate) no later than January 1, 2018, if necessary to meet the reasonable progress 

goals at Class I areas in Maine or any other Class I area significantly affected by Maine 

emissions. Maine is committing to undertake this analysis no later than January 1, 2013 

as part of its 5-year periodic implementation plan revision. 

12.9.4 Wood Smoke Emission Reductions Strategies in Maine 

Strategies to reduce wood smoke emissions in Maine will also provide significant 

reductions in regional haze. As detailed in Section 12.7.3, Maine has adopted a 

comprehensive suite of programs designed to reduce wood smoke emissions from 

outdoor wood and pellet boilers and residential wood stoves. Since the visibility 

improvements provided by these programs were not modeled as part of the MANE-VU 

process, Maine has included these programs in its Regional Haze SIP as SIP 

enhancements, or strengthening measures. The 06-096 CMR Chapter 150 Control of 

Emissions from Outdoor Wood Boilers (Attachment BB), is included for incorporation in 

the Maine Regional Haze SIP. 

12.10 Maine’s Share of Emission Reductions 

Implementation of the long-term strategy will produce significant reductions in Maine’s 

emissions inventory by the end of the first planning period, or 2018. Changes to the 

emissions inventory will also occur as a result of population growth; changes in land use 

and transportation; development of industrial, energy, and natural resources; and other air 

pollution measures not directly relate to regional haze. However, it is the expected 

reductions in SO2 emissions that will have the greatest effect on visibility improvement at 

MANE-VU Class I Areas; and those reductions will be largely due to the implementation 

of the control measures developed in this SIP. 

 

68 For comparison, the nationwide capacity factor for coal-fired generation in 2008 was 72.2 percent. 

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As noted in Subsection 12.9 (above) the emission controls included in the Maine 

Regional Haze SIP are generally consistent with those modeled in MANE-VU’s 

development of reasonable progress goals for Maine and the other MANE-VU Class 1 

states (see Section 11.2, above). However, since the Maine Low Sulfur Oil Program and 

efforts to reduce emissions at Wyman Station Unit #4 differ slightly from the programs 

and emission reductions modeled as reasonable progress goals, Maine must demonstrate 

that its long-term strategy will achieve the reasonable progress goals established by the 

Regional Haze SIP. 

In an effort to demonstrate that the long-term strategy established by this SIP will achieve 

the modeled reasonable progress goals, Maine undertook a more refined analysis of its 

projected 2018 SO2 emissions that is based on the 2008 Maine DEP Point Source 

Inventory.69 The Maine analysis updated projected SO2 emissions for point sources that 

included only the reductions provided by the use of 0.5% sulfur residual oil as 

implemented by the Maine Low Sulfur Fuel Program.70 While this approach is 

necessarily very conservative, and does not capture all of the reductions provided by the 

use of low sulfur residual and ultra-low sulfur distillate fuel in Maine, it is more than 

sufficient to demonstrate that projected future emissions in Maine will be well below the 

level used to establish reasonable progress goals. The documentation for this effort and 

the updated Maine 2018 Projected Point Source Inventory are contained in Attachment 

AA. 

After accounting for all facilities that ceased operation and/or surrendered their air 

emission licenses between 2001 and 2009 (25 sources) and accounting for the reductions 

provided by the use of 0.5% residual fuel, Maine’s updated 2018 projected point source 

emissions were 8,445 tpy for all point sources (EGU and non-EGU combined); well 

below the 19,888 tpy utilized in the MANE-VU reasonable progress modeling. 

Table 12-3, below, illustrates the MANE-VU 2002 (baseline) and MANE-VU 2018 

(modeling) inventories for Maine, along with the Maine updated 2018 [projected 

inventories. The emission inventory for Maine projects changes to point, area and mobile 

source inventories by the end of the first implementation period resulting from population 

growth; industrial, energy and natural resources development; land management; and air 

pollution control. Table 12-4 compares the percentage reductions (SO2) for the MANEVU region and Maine for each source category. The implementation of the Long Term 

Strategy will reduce Maine’s SO2 emissions by 73.4 percent, as compared to the 

compared to the projected reduction of 67.5 percent in the MANE-VU region. Further 

information on Maine’s emissions inventory, including other pollutants that contribute to 

visibility impairment, is available in Section 8.0, Emissions Inventory, and in 

Attachments I and AA. 

69 Since the Maine long-term strategies for non-point sources do not differ from those modeled, it is not 

necessary to update other source categories at this point in time. 

70 The Department’s analysis did not include any reductions from the use of ULSD (15 ppm) at point 

sources. 

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Table 12-3 

SO2 Emissions from Point, Area and Mobile Sources in Maine 

(tpy) 

Source Category 

MANE-VU 

2002 

 Baseline 

MANE-VU 

2018 

Modeling 

Maine (Updated) 

2018 

Projected 

On-Road Mobile 1,804 894 894 

Non-Road Mobile 917 82 82 

EGU Point 9,299 6,806 

Non-EGU Point 14,412 13,082 8,445 

Area 13,149 1,127 1,127 

TOTAL 39,581 21,991 10,548 

Table 12-4 

SO2 Emissions from Point, Area and Mobile Sources in the MANE-VU Region and 

in Maine 

(tpy) 

Source Category 

MANE-VU 

Region 

Percent 

Reduction 

2002-2018 

Maine 

Percent 

Reduction 

2002-2018 

On-Road Mobile 78.2 50.5 

Non-Road Mobile 84.9 91.1 

EGU Point 77.6 

Non-EGU point 65.4 

64.4 

Area 54.8 91.4 

TOTAL 67.5 73.4 

12.10 Emission Limitations and Compliance Schedules 

40 CFR 51.308(d)(v)(C) requires Maine to establish emission limitations and compliance 

schedules to meet reasonable progress goals. Emission limitations and compliance 

schedules are in place for the Maine programs outlined in Subsection 12.9. Final BART 

determinations and control requirements for all Maine BART-eligible sources are 

included in the Regional Haze SIP, and include emission limitations and compliance 

schedules for all BART-eligible sources. The Maine Low Sulfur Fuel Program, 

implementing the MANE-VU low sulfur fuel strategy and the targeted EGU strategy in 

Maine was enacted by the Maine Legislature on March 25, 2010, and signed into law by 

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Governor John Baldacci on April 5, 2010. As noted in Section 12.9.3, Maine is 

committing to further analyze the visibility benefits that would be provided by the use of 

0.3% sulfur fuel, and to require the use of this fuel (or an equivalent emissions rate) no 

later than January 1, 2018, if necessary to meet the reasonable progress goals at Class I 

areas in Maine or any other Class I area significantly affected by Maine emissions. 

Maine is committing to undertake this analysis no later than January 1, 2013 as part of its 

5-year periodic implementation plan revision. 

12.11 Enforceability of Emission Limitations and Control Measures 

 

40 CFR 51.308(d)(3)(v)(F) requires Maine to ensure that emission limitations and control 

measures used to meet reasonable progress goals are enforceable. All control measures 

incorporated into law or codified in administrative rules will be enforceable. Any facility 

subject to state or federal permit requirements, including BART-eligible and V facilities, 

will be required to comply with the specific permit conditions that reference the 

applicable provisions of those laws and rules. 

In Maine, the authority to create rules, issue permits and enforce laws related to regional 

haze is established in Title 38 Maine Revised Statutes Annotated (MRSA), Chapter 2, 

Department of Environmental Protection, Subchapter 1, Organization and Powers and in 

Title 38 MRSA, Chapter 4, Protection and Improvement of Air. Under 38 MRSA 

Chapter 2 and Chapter 4, the Department is authorized to enforce the state’s air laws and 

regulations, establish a permit program, accept and administer grants, and exercise all 

incidental powers necessary to carry out the its statutory obligations. 

Sections of Maine law of particular relevance to the regional haze SIP are: 

 Title 38 Maine Revised Statutes Annotated (MRSA) section 581, Declaration of 

findings and intent, which declares the Legislature’s intent to: 

“exercise the police power of the State in a coordinated state-wide program to 

control present and future sources of emission of air contaminants to the end that 

air polluting activities of every type shall be regulated in a manner that 

reasonably insures the continued health, safety and general welfare of all of the 

citizens of the State” 

 38 MRSA section 585. Establishment of emission standards, which states: 

“The board may establish and may amend standards, herein called "emission 

standards", limiting and regulating in a just and equitable manner the amount 

and type of air contaminants which may be emitted to the ambient air within a 

region. Such emission standards shall be designed to prevent air pollution and to 

achieve and maintain the ambient air quality standards within the region in which 

applicable” 

 38 MRSA section585, Establishment of emission standards, which states: 

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“The board may establish and amend regulations to implement ambient air 

quality standards and emission standards. These regulations shall be designed to 

achieve and maintain ambient air quality standards and emission standards 

within any region and prevent air pollution” 

 38 MRSA section 590, Licensing, which states, in relevant part: 

“1. License required. After ambient air quality standards and emission standards 

have been established within a region, the board may by rule provide that a person 

may not operate, maintain or modify in that region any air contamination source or 

emit any air contaminants in that region without an air emission license from the 

department” 

 38 MRSA sections 347-A, 347-C, and 349, which provide for the enforcement of 

all SIP measures; and 

 38 MRSA section 353-A, which establishes annual air emission license fees and 

38 MRSA section 353A (1) A, which establishes an annual fee surcharge for 

emissions of hazardous air pollutants. 

The Maine regulations also provide for enforceable emission control measures and 

compliance schedules to meet the applicable requirements of the Clean Air Act and rules 

promulgated by EPA. The following regulations are of particular relevance to the Maine 

Regional Haze SIP: 

06-096 CMR Chapter 100 Definitions Regulation 

06-096 CMR Chapter 101 Visible Emissions Regulation 

06-096 CMR Chapter 102 Open Burning Regulation 

06-096 CMR Chapter 103 Fuel Burning Equipment Particulate Emission Standard 

06-096 CMR Chapter 104 Incinerator Particulate Emission Standard 

06-096 CMR Chapter 105 General Process Source Particulate Emission Standard 

06-096 CMR Chapter 106 Low Sulfur Fuel 

06-096 CMR Chapter 109 Emergency Episode Regulation 

06-096 CMR Chapter 110 Ambient Air Quality Standards 

06-096 CMR Chapter 114 Classification of Air Quality Control Regions 

06-096 CMR Chapter 115 Major and Minor Source Air Emission License 

 Regulations 

06-096 CMR Chapter 116 Prohibited Dispersion Techniques 

06-096 CMR Chapter 117 Source Surveillance 

06-096 CMR Chapter 121 Emission Testing of Resource Recovery Facilities 

06-096 CMR Chapter 126 Capture Efficiency Test Procedures 

06-096 CMR Chapter 127 New Motor Vehicle Emission Standards 

06-096 CMR Chapter 138 Reasonably Available Control Technology for 

 Facilities that Emit Nitrogen Oxides 

06-096 CMR Chapter 140 Part 70 Air Emission License Regulations 

06-096 CMR Chapter 145 NOx Control Program 

06-096 CMR Chapter 146 Diesel-Powered Motor Vehicle Emission Standards 

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06-096 CMR Chapter 148 Emissions from Smaller-Scale Electric Generating 

 Resources 

06-096 CMR Chapter 149 General Permit Regulation for Nonmetallic Mineral 

 Processing Plants 

06-096 CMR Chapter 150 Control of Emissions from Outdoor Wood Boilers 

06-096 CMR Chapter 160 Outdoor Wood Boiler Replacement and Buy Back 

 Program 

The Maine regulations provide for enforceable emission control measures and 

compliance schedules to meet the applicable requirements of the clean Air Act and rules 

promulgated by EPA. The Maine rules also define the State’s air emission licensing 

(permit) program for stationary sources to ensure that national ambient air quality 

standards are achieved. 

12.12 Prevention of Significant Deterioration 

Prevention of Significant Deterioration (PSD) requirements for new major stationary 

sources and major modifications (emitting > 50 tons of any air contaminant) are 

implemented in Maine through the 06-096 CMR Chapter 100 Definitions Regulation 

which was approved into the SIP on October 15, 199671, the 06-096 CMR Chapter 113 

Growth Offset Regulation which was approved into the SIP on February 14, 199672, and 

the 06-096 CMR Chapter 115 Major and Minor Source Air Emission License 

Regulations which were approved into the SIP by EPA on February 14, 1996.73,74 PSD is 

applicable to all major sources (or existing sources making a major modification), 

triggering significance thresholds, located in an area that is in attainment with the 

National Ambient Air Quality Standards or unclassified. One of the intentions of the 

PSD program is to protect air quality in national parks, wilderness areas, and other areas 

of special natural, scenic, or historic value. The PSD permitting process requires a 

technical air quality analysis and additional analyses to assess the potential impacts on 

soils, vegetation and visibility. 

The required procedures for evaluating the impacts of a proposed PSD source on air 

quality and visibility are provided in Section 7 of Maine’s 06-096 CMR Chapter 115 

Major and Minor Source Air Emission License Regulations. The Ambient Air Quality 

Impact Analysis must demonstrate that the new allowable emissions will not result in an 

exceedence of the remaining increments for SO2, NO2 or PM10 in any Class I area. The 

applicant must also demonstrate “that the increase in allowable emissions will not cause 

an adverse impact on visibility in any sensitive area or in any Class I area, and will not 

interfere with reasonable progress toward the remedying of existing man-made visibility 

impairment in a sensitive area. The analysis must be submitted to the Department and the 

71 61 FR 53639 

72 61 FR 5694 

73 61 FR 5694 

74 Although these rules have been amended several times since being incorporated into the SIP, these 

revisions did not change any of the major source permitting requirements relevant to PSD, and the current 

state regulations are consistent with the SIP-approved versions for the purposes of implementing the PSD 

requirements. 

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appropriate Federal land Manager at least 60 days prior to the close of the public 

comment period on the source or modification. In this manner, new major sources and 

existing sources making major modifications will be constructed in a manner that will not 

degrade air quality or visibility. The PSD permitting program is an integral part of 

Maine’s long-term strategy for meeting its regional haze goals. 

12.13 Reasonably Attributable Visibility Impairment 

40 CFR Section 51.302 (c) provides for general plan requirements in cases where the 

affected FLM has notified the State that Reasonably Attributable Visibility Impairment 

(RAVI) exists in a Class I Area in the state. There are no RAVI sources in the MANEVU region. 

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13. Comprehensive Periodic Implementation Plan Revisions 

40 CFR Section 51.308(f) requires a State/Tribe to revise its regional haze 

implementation plan and submit a plan revision to EPA by July 31, 2018 and every ten 

years thereafter. In accordance with the requirements listed in 40 CFR Section 51.308(f) 

of the federal rule for regional haze, Maine commits to revising and submitting this 

regional haze implementation plan by July 31, 2018 and every ten years thereafter. 

In addition, 40 CFR Section 51.308(g) requires periodic reports evaluating progress 

towards the reasonable progress goals established for each mandatory Class I area. In 

accordance with the requirements listed in 40 CFR Section 51.308(g) of the federal rule 

for regional haze, Maine commits to submitting a report on reasonable progress to EPA 

every five years following the initial submittal of the SIP. The report will be in the form 

of a SIP revision submitted by no later than December 17, 2012. The reasonable progress 

report will evaluate the progress made towards the reasonable progress goal for each 

mandatory Class I area located within Maine and in each mandatory Class I area located 

outside Maine, which may be affected by emissions from within Maine. All 

requirements listed in 51.308(g) shall be addressed in the SIP revision for reasonable 

progress. 

Section (d)(4)(v) requires periodic updates of the emission inventory. Maine commits to 

update the inventory by no later than December 17, 2012. 

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13. Determination of the Adequacy of the Existing Plan 

As required by 40 CFR Section 51.308(h), depending on the findings of the five-year 

progress report, required under 40 CFR Section 51.308 (g), Maine commits to taking one 

of the following actions at the same time the State submits the 5-year progress report: 

(1) If the State determines that the existing implementation plan requires no further 

substantive revision in order to achieve established goals for visibility improvement and 

emissions reductions, the State will provide to the Administrator a negative declaration 

that further revision of the existing implementation plan is not needed. 

(2) If the State determines that the implementation plan is or may be inadequate to ensure 

reasonable progress due to emissions from sources in another State(s) which participated 

in a regional planning process, the State will provide notification to the Administrator and 

to the other State(s) which participated in the regional planning process with the States. 

The State will also collaborate with the other State(s) through the regional planning 

process for the purpose of developing additional strategies to address the plan's 

deficiencies. 

(3) If the State determines that the implementation plan is or may be inadequate to ensure 

reasonable progress due to emissions from sources in another country, the State will 

provide notification, along with available information, to the Administrator. 

(4) If the State determines that the implementation plan is or may be inadequate to ensure 

reasonable progress due to emissions from sources within the State, the State will revise 

its implementation plan to address the plan's deficiencies within one year. 

The findings of the five-year progress report will determine which action is appropriate 

and necessary. 

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References

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Environ. Sci. Technol., 32, 2706-2714, 1998. 

Byun D.W., and J.K.S. Ching. Science Algorithms of the EPA Models-3 Community 

Multiscale Air Quality (CMAQ) Modeling System. EPA/600/R-99/030. March 

1999. 

Davidson, C., Strader, R., Pandis, S., and Robinson, A., Preliminary Proposal to MARAMA 

and NESCAUM: Development of an Ammonia Emissions Inventory for the Mid-Atlantic 

States and New England. Carnegie Mellon University, Pittsburgh, PA. 7-Jan. 1999. 

Duyzer, J., “Dry Deposition of Ammonia and Ammonium Aerosols over Heathland,” J. 

Geophys. Res., 99(D9):18,757 – 18,763, 1994. 

EarthTech, 2004, http://src.com/calpuff/calpuff1.htm 

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