# T E C H N I C A L 

# S U P P O R T 

# D O C U M E N T

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 generati ng 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 th e reliability of electrical service in the PJM region. PJM Inc. conducted the evalua tion 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 establishe d 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 th e facility and adopt regulations to establish an alternative emissions requirement for the facility.” These am endments establish limitati ons 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 am bient 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 co mply with the national ambient air quality standard for ozone. The Department will also review the 90% mercur y 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 reduc tion currently required.

14/21/2009 3:27 PM 2 Prior to the evaluation, the Departme nt will also request that PJM In c. reevaluate the need for the R. Paul Smith facility to operate to mainta in a reliable electricity supply in Maryland, in consideration of the effect of any new transmi ssion lines and electric ge nerating 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. Un it 3 is a wall-fired, dry bottom boiler which produces steam for a turbine rated at 40 megawa tts (MW), but is limited to 28 MW. Unit 3’s particulate emissions are controlled by a single co ld 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 Sm ith 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\Regul ation Development Division\R. P. Smith\TSD\R P Smith - TSD.doc