TECHNICAL SUPPORT DOCUMENT

Department of the Environment 

Amendments to COMAR 26.11.27 

R. Paul Smith

Statement of Purpose 

The purpose of this action is to establish NOx and SO2 emission limits for the R. Paul Smith 

Power Station electric generating units located in Washington County. An annual emissions cap 

will be set for NOx and SO2 and an ozone season emissions cap for NOx. 

Background

Under the Healthy Air Act (HAA), R. Paul Smith units 3 and 4 are defined as an affected facility 

subject to the requirements of § 2-1003(c). The exception provisions of the HAA authorize the 

Department to allow the R. Paul Smith facility, units 3 and 4, to operate without complying with 

the emissions requirements of the HAA if PJM Interconnection, Inc. (PJM Inc.) determines that 

the termination of operation of the facility will adversely affect the reliability of electrical service 

in the PJM region. PJM Inc. conducted the evaluation and determined that the R. Paul Smith 

facility is needed to maintain reliability. 

The HAA also requires that if R. Paul Smith units 3 and 4 are allowed to operate without 

complying with the emissions limitations established in the statute, then the following conditions 

must be met: “(1) The facility may not operate at emissions levels greater than the highest level 

measured at the facility during the calendar years 2000 through 2004; and (2) The Department 

shall review the operations of the facility and adopt regulations to establish an alternative 

emissions requirement for the facility.” These amendments establish limitations that comply with 

these conditions. 

The Maryland Department of the Environment has reviewed the R. Paul Smith facility’s 

operations and proposes the following alternative emissions requirement. 

At the end of 2011, the Department will evaluate the alternate limitations and determine whether 

more stringent emission limitations are warranted. The determination will include an assessment 

of whether more stringent NOx and SO2 limits are needed to enable the western Maryland 

region to comply with the most recent national ambient air quality standards for ozone and fine 

particulate matter. The Healthy Air Act requires an additional emission reduction from affected 

sources if Maryland does not comply with the national ambient air quality standard for ozone. 

The Department will also review the 90% mercury requirements in the HAA that take effect in 

2013 and determine whether alternative limits for mercury beyond 2012 are warranted for this 

source. The R. Paul Smith facility has installed new controls that allow the facility to comply 

with the 80% mercury reduction currently required. 

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Prior to the evaluation, the Department will also request that PJM Inc. reevaluate the need for the 

R. Paul Smith facility to operate to maintain a reliable electricity supply in Maryland, in 

consideration of the effect of any new transmission lines and electric generating stations which 

may be constructed in the interim. 

The Department will revise the regulations, if needed, based on PJM’s reevaluation and the 

Department’s findings. 

Sources Affected

The R. Paul Smith facility is the only source affected by these amendments. R. Paul Smith 

Electric Power Generation Station is a 62 year old power plant owned and operated by the 

Allegheny Energy Supply Company, L.L.C. The facility is located in Washington County, 

Maryland and operates two coal-fired boilers. Unit 3 is a wall-fired, dry bottom boiler which 

produces steam for a turbine rated at 40 megawatts (MW), but is limited to 28 MW. Unit 3’s 

particulate emissions are controlled by a single cold side, electrostatic precipitator (ESP) and 

NOx emissions are controlled by low NOx burner technology. Unit 4 is a tangentially-fired, dry 

bottom boiler and the turbine is rated at 88 MW. Particulate emissions are controlled by a 

primary cold side ESP and an electrostatically enhanced bag-house, and has low NOx burners 

and a separate over-fire air system for NOx controls. 

These amendments will: 

1. Establish an emissions cap of 1,390 tons of NOx beginning with the 12 month period 

January 1, 2009 to December 31, 2009; 

2. Establish an emissions cap of 545 tons of NOx beginning with the ozone season May 1, 2009 

to September 30, 2009; and 

3. Establish an emissions cap of 4,590 tons of SO2 beginning with the 12-month period 

January 1, 2010 to December 31, 2010. 

These requirements are based on the R. Paul Smith facility’s highest annual emissions reported 

to the Department for the years 2000-2004. 

Economic Impact

Meeting the NOx and SOx tax caps and SO2 caps will not require additional controls. The 

existing NOx control systems were installed to meet Reasonably Available Control Technology 

(RACT) requirements. 

L:\AQPlanning and Monitoring\Regulation Development Division\R. P. Smith\TSD\R P Smith - TSD.doc