DEVAL L. PATRICK 

Governor 

TIMOTHY P. TYIURRAY 

Lieutenant Governor 

COMMONWEALTH OF MASSACHUSETTS 

EXECUTIVE OFFICE OF ENERGY & ENVIRONMENTAL AFFAIRS 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

WESTERN REGIONAL OFFICE 

430 Dwight Street " Springfield, Massachusetts 01103 " (413) 784-1100 

Mr. John S. Murray 

Station Manager 

Mt. Tom Generating Company, LLC 

200 Northampton Street 

Hoiyoke, MA 01040 

Dear Mr. Murray : 

May 15, 2009 

RE : Holyoke 

Western Region 

310 CMR 7.29 

Power Plant Emission Standards 

Application No . 1-E-01-072 

Transmittal No. W025214 

IAN A. BONLES 

Secretary 

LAURIE BURT 

Commissioner 

AMENDED EMISSION CONTROL PLAN 

The Western Region of the Department of Environmental Protection, Bureau of Waste 

Prevention (MassDEP), has reviewed your Amended Emission Control Plan (ECP) application 

dated November 6, 2008, Including the December 1, 2004 ECP modification application . 

MassDEP originally Issued the ECP on June 7, 2002. This Amended ECP application was 

submitted in accordance with 310 CMR 7 .29(6)(a)(4) to Incorporate the Turbosorp© emissions 

control system and approve the use of coal with higher ash content In accordance with 310 

CMR 7 .05(3)(c) and higher sulfur content in accordance with 310 CMR 7 .05(1)(b)3 . This 

modification will require more stringent emission limits for particulate matter (PM) than 

previously required and actual stack emissions of sulfur dioxide (SOZ) lower than the 

requirements of 310 CMR 7.29. MassDEP's Amended ECP Final Approval Includes these limits 

as enforceable permit requirements 

This amended approval describes how emission limitations and compliance schedules 

for the control of certain designated pollutants contained In 310 CMR 7.29, "Emission 

Standards for Power Plants," will be Implemented for equipment and processes located at the 

Mt. Tom Generating Company, LL.C., Mt. Tom Station facility (ORISP 01606, hereinafter Mt. 

Tom) on Northampton Street In Hoiyoke, Massachusetts . This application for the approval of 

the ECP bears the signature of John P. Campbell, Sr. Vice President - Asset Operations as the 

company contact responsible for compliance with 310 CMR 7.29. . 

This Information Lt available In alternate rormat. Call Donald NO. Comes, ADA Coordinator at 6t7-556-1057. TDDq 866-539-7622 or 617-574-6868. 

DEP on the World Wide Web: htip:JMivnv.mass.govldep 

Q Printed on Recycled Paper 
Mt. Tom Generating Company, LLC. Amended ECP Final Approval 

Application 1-E-01-072, Transmittal W025214 

Page 2 of 13 

AMENDED ECP SUMMARY 

The amended ECP application Includes Mt. Tom's mercury (Hg) emission control plan, 

proposes the utilization of a Turbosorp© control device for the reduction of Hg and SOZ to 

meet the requirements of 310 CMR 7 .29, and requests approval to burn coal with a 12 percent 

ash content and a sulfur content of up to 3 Ib/MMBtu heat release potential on a 30-day rolling 

average. 

Mt. Tom Is In the process of installing a Babcock Power Environmental Turbosorp0 

dry scrubber system that was approved by the MassDEP on December 31, 2007 (1-P-07-

049) to control emissions of SOZ and Hg from the boiler . The Turbosorp system Is being 

Installed downstream from the electrostatic precipitator and upstream from the existing 

facility stack. Gases that exit the precipitator first enter the "Turbosorp" tower. Within the 

tower, the flue gas is cooled with water, then a fluidized bed of hydrated lime, PAC, B-PAC 

and/or sodium tetrasulflde reacts with the flue gas. The sorbent Is captured along with the 

particulate matter in the baghouse portion of the system . 

Mt. Tom Is stating that with the Installation of the Turbosorp® dry scrubber system 

to control emissions, the station will be able to utilize domestic sources of coal which 

typically have higher sulfur and higher ash content . Mt. Tom Is proposing to utilize coals 

that contain up to 12 percent ash and 3 Ib/MMBtu sulfur content and utilize controls to 

achieve lower stack emissions than required under 310 CMR 7 .29 . MassDEP agrees that the 

combustion of coals with lower stack emissions Is beneficial to the environment and 

approves the use of coal with ash content up to 12 percent by weight and sulfur content up 

to 3 Ib/MMBtu, provided that Mt. Tom meets the emission limits contained In Table 2 of this 

Approval and also revises their Title V Operating Permit renewal application to Include a 

limit of 0.025 Ib/MMBtu for PM (including condensables, based on concurrent BACT 

determination on similar project at Brayton Point Station Unit 3). Mt . Tom will use all 

reasonable efforts to meet the 0.025 Ib/MMBtu PM emission limit, Including, but not limited 

to, proper maintenance of the proposed baghouse filters In accordance with manufacturer's 

recommendations. A stack test will be performed within twelve months of installation of. the 

Turbosorp© system . If the stack tests show the proposed limit cannot be met, Mt. Tom will 

re-visit the emission limit with DEP. 

LEGAL AUTHORITY 

MassDEP has adopted 310 CMR 7 .29 - a regulation to lower emissions of sulfur 

dioxide (S02), carbon dioxide (C02), and nitrogen oxides (NOx) from certain power plants, 

and to establish a framework for reductions In emissions of carbon monoxide (CO), mercury 

(Hg), and fine particulate matter (PM 2.5) - pursuant to the Massachusetts General Laws, 

Chapter 111, Sections 142 A-M. 

Regulation 310 CMR 7 .29 requires any person who owns, leases, operates or controls 

an affected facility to comply with 310 CMR 7 .29 In Its entirety . An affected facility means a 

facility which emitted greater than 500 tons of SOZ and 500 tons of NO, during any of the 

calendar years 1997, 1998, or 1999, and which includes a unit which is a fossil fuel fired 

boiler or Indirect heat exchanger that: (1) is regulated by 40 CFR Part 72 (the Federal Acid 

Rain Program) ; (2) serves a generator with a nameplate capacity of 100 megawatts (MW) or 

more; (3) was originally permitted prior to August 7, 1977 ; and (4) had not subsequently 

received a Plan Approval pursuant to 310 CMR 7 .00 : Appendix A or a Permit pursuant to the 

regulations for Prevention of Significant Deterioration, 40 CPR Part 52, prior to October 31, 

1998. 
Mt. Tom Generating Company, LLC. Amended ECP Final Approval 

Application 1-E-01-072, Transmittal W025214 

Page 3 of 13 

The purpose of 310 CMR 7 .29 Is to control emissions of NO,, SOZ, Hg, CO, C02, and 

PM 2 .5 (together, "pollutants") from affected electric. generating facilities in Massachusetts. 

310 CMR 7 .29 accomplishes this by establishing maximum output-based emission rates for 

NO,, SO2, and COZ, and establishing a cap on COZ and Hg emissions from affected facilities . 

Emission limits for CO and PM 2 .5 have not been addressed at this time. 

Applicable requirements and limitations contained in 310 CMR 7.29 shall not 

supersede, relax or eliminate any more stringent conditions or requirements (e .g . emission 

limitatlon(s), testing, record keeping, reporting, or monitoring requirements) established by 

regulation or contained in a facility's previously Issued source specific Plan Approval(s) or 

Emission Control Plan(s) . 

On December 7, 2007, Mt. Tom entered Into an Administrative Consent Order (ACOPWE-07-7009) to Install and commence operation of the Turbosorp© system In order to meet 

the S02 and Hg emission rate specified under 310 CMR 7.29 (5) 2 and 3 respectively, without 

using Massachusetts SOZ Early Reduction Credits . The Consent Order also requires Mt. Tom to 

meet an average Hg emission rate of 0.0075 Ib/GWh for the period of January 1, 2008 through 

September 30, 2012 . I ¬ Mt. Tom falls to meet this rate then an offset of the excess emission 

shall be provided from offsite Hg reductions at a 20 to 1 ratio. 

Pursuant to 310 CMR 7.05(3)(c) and 310 CMR 7.05(1)(b)3 ., MassDEP may approve the 

use of a solid fuel with a higher sulfur content than those contained In Table i of 310 CMR 

7.05(1) and an ash content higher than 9 percent provided that this would not cause any 

applicable air pollution control regulations or ambient air quality standards to be violated . 

This approval meets this standard due to the reduction In emissions. In accordance with 310 

CMR 7 .05(3)(c)3 . and 310 CMR 7.05(1)(b)3, Mt. Tom must agree to the new fuel sulfur and 

ash content and emission limits (limits for Hg, SOz, and PM) before using the fuel referenced 

in this approval. Mt. Tom must notify MassDEP 30 days prior to burning fuel with a sulfur 

content greater than 1 .21 Ib/MMBtu or an ash content of greater than 9% on a rolling 12 

month average. The lower emission limits noted In this Amended ECP Final Approval will 

become effective when MassDEP Is notified of this fuel change. 

On April 7, 2009 MassDEP Issued for public comment an Amended ECP Draft Approval, A 

Public Notice on the proposed approval of the Amended ECP Draft Approval was published In 

the Springfield Republican on April 7, 2009. No oral or written public comments were received 

during the public comment period . 

Based upon the above, MassDEP has determined that the referenced Amended ECP 

application Is administratively and technically complete and that the proposed modifications 

are In conformance with current air pollution control engineering practices and hereby Issues 

this Amended ECP Final Approval for the proposed modifications of your power plant unit, 

with the conditions listed below. 
Mt. Tom Generating Company, LLC. Amended ECP Final Approval 

Application I-E-01-072, Transmittal W025214 

Page 4 of 13 

1. EQUIPMENT DESCRIPTION 

The following emission units (Table 1) are subject to and regulated by this Amended 

ECP Final Approval ; 

EU . # DESCRIPTION OF 

EMISSION UNIT 

EU DESIGN .CAPACITY. POLLUTION CONTROL. MEASURES.

. 

(PCM)1 , . - MMBTU/FiR MW NET 

EU 1 Mt. Tom Unit 1 Turbosorp© control device 

Riley Stoker Boller 1,480 147 Upgraded combustion controls and burner 

system 

Selective Catalytic Reduction (SCR) 

SOZ Early Reductions 

i SOZ Allowances 

._ . . .. 

Table 1 Notes: 

1. Details of Mt. Tom's Pollution Control Measures including alternatives under consideration are 

described In Section E, F, and G of their original ECP application and their ECP modification 

application . 

2. See Special Condition 2. 

3. See Special Condition 3. 

* Legend to Abbreviated Terms within Table 1 : 

EU# = Emission Unit Number 

MMBTU/HR = million British Thermal Units per hour 

MW (NET) = net electrical output In Megawatts 

SOZ = Sulfur Dioxide 
Mt. Tom Generating Company, LLC. Amended ECP Final Approval 

Application L-E-01-072, Transmittal W025214 

Page 5 of 13 

2. APPLICABLE REQUIREMENTS 

A. EMISSION LIMITS AND RESTRICTIONS 

Mt. Tom shall comply with the emission limits/restrictions as contained In Table 2 

below. The schedule for compliance with these emission limitations Is contained In Table 6 of 

this Amended ECP Final Approval. 

Table 

EU .#-. RESTRICTION/ :POLLUTANT . EMI$SION ;LIMIT/STANDARD., ; : . . _ . APPLICABLE REGULATION : 

OPERATING : = .AND/OR 

` RACTICES ; : 

, , 

; . . . . . 

APPROVAL NUMBER . . 

EO 1 NA NO,, Shall not exceed 1 .5 Ibs/MWh calculated over 310 CMR 7.29(5)(a)i .a . 

any consecutive 12 month period, recalculated 

monthly. 

Shall not exceed 3.0 Ibs/MWh calculated over 310 CMR 7.29(5)(a)l.b . 

any Individual month. 

SOz Shall not exceed 6.0 Ibs/MWh calculated over 310 CMR 7.29(5)(a)2.a . 

any consecutive 12 month period, recalculated 

monthly. 

Shall not exceed 3.0 Ibs/MWh calculated over 310 CMR 7 .29(5)(a)2.b.i . 

any consecutive 12 month period, recalculated 

monthly. 

Shall not exceed 6.0 Ibs/MWh calculated over 310 CMR 7.29(5)(a)2.b .ii . ' 

an Individual month . 

Shall not exceed 2.0 Ibs/MWh calculated over Approval 1-E-01-072a 

any consecutive 12 month period, recalculated 

monthly. 

Shall not exceed 3 .0 Ibs/MWh calculated over Approval i-E-01-0724 

an Individual month . 

Hg Shall achieve an averalqe total mercury removal 310 CMR 7.29(5)(a)3 .e . 

efficiency of 85 percent or greater; or shall have 

a facility average total mercury emission rate of 

0 .0075 ibs. GWh or less .Z 

Shall achieve an average total mercury removal 310 CMR 7.29(5)(a)3 .f .l . or II . ~ 

efficiency of 95 percent' or greater ; or shall have 

a facility average total mercury emission rate of 

0 .0025 Ibs./GWh or less. 

CO Reserved.3 310 CMR 7.29(5)(a)4. 

COz Emissions of carbon dioxide from the affected 310 CMR 7.29(5)(a)5.a . 

facility In the calendar year, expressed in tons, 

from Part 72 units located at the affected facility 

shall not exceed historical actual emissions of 

1,117,569 tons.5 

Shall not exceed 1800 Ibs/MWh In the calendar 310 CMR 7.29(5)(a)5.b . 

year. 

PM 2.5 Reserved. 3 310 CMR 7 .29(5)(a)6. 
Mt. Torn Generating Company, LLC. Amended ECP Flnal Approval 

Application 1-E-01-072, Transmittal W025214 

Page 6 of 13 

Table _ 2 Notes : 

1. Removal efficiency shall be based on the average historic mercury Inlet emissions determined 

under 310 CMR 7.29(5)(a)3.d .il . 

2. ACOP WE-07-7009 requires Mt. Tom to meet this average rate of the period from January 1, 

2008 through September 30, 2012 . If Mt. Tom fails to meet this rate than an offset of the 

excess emission shall be provided from offslte Hg reductions at a 20 to 1 ratio pursuant to 

ACOP WE-07-7009. 

3. MassDEP has reserved these areas in the regulations for further development. 

4. SOZ emissions are actual measured emissions from the facility . Mt. Tom shall not use any SOZ 

early reductions or SOZ allowances to achieve this emission rate . 

5. If MassDEP has received a technically complete Plan Approval application under 310 CMR 7.02 

for a new or re-powered electric generating unit subject to 40 CFR Part 72 at an affected 

facility prior to May 11, 2001, then the emissions from the new or re-powered unit may be 

included In the calculation of historical actual emissions . The calculation of historical actual 

emissions which Includes emissions from a new or re-powered unit shall not include emissions 

from any unit shutdown or removed from operation at the affected facility that Is included in 

the technically complete Plan Approval application pursuant to 310 CMR 7.02 . MassDEP Is in 

the process of developing provisions for the quantification and certiflcation of Greenhouse Gas 

(GHG) reductions for use In demonstrating compliance with the CO2 emission limitations 

contained In 310 CMR 7.29 . MassDEP will review and approve or deny proposals for off-site, 

sequestration, or non-contemporaneous reductions (l.e. early on-site reductions) of COZ or 

other GHG after adoption of amendments to 310 CMR 7 .00 ; Appendix B, and other regulatory 

sections, If necessary . 

* Legend to Abbreviated Terms within Table 2: 

EU# = Emission Unit Number 

Ibs/MWh = pounds per Megawatt-hour of net electrical output 

Ibs/GWh = pounds per Gigawatt-hour of net electrical output 

NO, = Nitrogen Oxides 

SOZ = Sulfur Dioxide 

Hg = Mercury 

CO = Carbon Monoxide 

COZ = Carbon Dioxide 

PM 2.5 = Fine Particulate Matter 

NA = not applicable 
Mt. Tom Generating Company, LLC. Amended ECP Final Approval 

Application 1-R-O1-072, Transmittal W025214 

Page 7 of 13 

B. COMPLIANCE DEMONSTRATION 

The facility Is subject to the monitoring/testlng, record keeping, and reporting 

requirements as contained In Tables 3, 4 and 5 below and 310 CMR 7,29, as well as the 

applicable requirements contained In Table 2: 

: : ---- - 

, . . Table 3, :'~ ; . 

' . EU#. . '. ' . MO,NITORING/TESTING,:REQUIREM,ENT.$, . : . , .` . ; . ., , . ., 

EU 1 Actual emissions shall be monitored for the Individual unit In the calculation for 

demonstrating compliance. Actual emissions shall be monitored in accordance with 40 CF 

Part 75 for SO2, CO2, and NO,. MassDEP shall detail the monitoring methodology for CO an 

PM 2.5 at the time regulations are promulgated b MassDEP for those parameters . 

Monitor actual net electrical output, expressed in megawatt-hours . Actual net electrical 

output shall be provided for the Individual unit in the calculation for demonstrating 

compliance. 

In accordance with 310 CMR 7.29(5)(a)3.e . and f., any person who owns, leases, operates or 

controls an affected facility which combusts solid fossil fuel or ash shall monitor a facility's 

average total mercury removal efficiency or emissions rate for those units combusting solid 

fossil fuel or ash. This will be based on a mercury CEMS using the methodology approved by 

MassDEP In the monitoring plan required under 310 CMR 7.29(5)(a)3.g . and shall be calculated 

on a rolling consecutive 12 month basis. 

In accordance with 310 CMR 7.29(5)(a)3.g .l ., by January 1, 2008, any person who owns, 

leases, operates or controls an affected facility which combusts solid fossil fuel or ash shall 

Install, certify, and operate CEMS to measure mercury stack emissions from each soiid fossil 

fuel- or ash-Fired unit at a facility subj ect to 310 CMR 7.29. 

Actual emissions shall be monitored for Individual units and monitored as a facility total for all 

units Included in the calculation demonstrating compliance. Actual emissions shall be 

monitored In accordance with 310 CMR 7,29( 7)( b) i .b . c. and d. for H . 

In accordance with 310 CMR 7.29(5)(a)3 .g ., operate each CEMS at ail times that the emissions 

unit(s) Is operating except for periods of CEMS calibrations checks, zero span adjustment, and 

preventive maintenance as described In the monitoring plan approved by MassDEP and as 

determined during certification . Notwithstanding such exceptions, in all cases obtain valid data 

for at least 75% of the hours per day, 75% of the days per month, and 90% of the hours per 

quarter during which the emission unit Is combustln solid fossil fuel or ash 

* Legend to Abbreviated Terms within Table 3: 

EU# = Emission Unit Number 

NO = Nitrogen Oxides 

SOz = Sulfur Dioxide 

Hg = Mercury 

CO = Carbon Monoxide 

COz = Carbon Dioxide 

PM 2.5 = Fine Particulate Matter 

CEMS = Continuous Emissions Monitoring System 
Mt. Tom Generating Company, LLC. Amended ECP Final Approval 

Application 1-E-01-072, Transmittal W025214 

Page 8 of 13 

> . .,, . : ;~ .Table4*, : ; : 

, . :,RECORD KEEPING, REQUIREMENTS,, ;-; ;._ 

EU 1 Maintain a record of actual emissions for each regulated pollutant for each of the preceding 

12 months. Actual emissions shall be recorded for Individual units and as a facility total for 

all units included In the calculation demonstrating compliance. Actual emissions provide 

under this section shall be recorded In accordance with 40 CFR Part 75 for SO2, C02, and 

NO , and for CO and PM 2.5 at the time regulations are promulgated by MassDEP for those 

arameters . 

For the standards at 310 CMR 7.29(5)(a)3.c .l ., e.ii ., and f.li . based on mercury CEMS, from, 

mercury CEMS meeting quality assurance procedures detailed in 40 CFR Part 60 Appendix 

Procedure 1 and/or performance speclfications, test procedures and calculations approved b 

MassDEP in the monitoring plan required under 310 CMR 3 .29(5)(a)3.g . Any particulate 

bound mercury accounted for under the provisions of 310 CMR 7 .29(5)(a)3 .g .il . shall b 

calculated from : 

i . the most recent average measured pounds of particulate mercury emitted per million 

Btu consumed multiplied by 

ii . the heat Input determined under 40 CFR Part 75 for each calendar month . Affected 

facilities may choose to subtract the heat Input attributable to combustion of fuel 

other than solid-fossil fuel and ash If such heat input Is determined using the 

procedures of 40 CFR Part 75 Appendix D. 

In accordance with 310 CMR 7.29(5)(a)3 ., keep records of required mercury stack testing 

and ash testing . 

In accordance with 310 CMR 7 .29(5)(a)3.g ., maintain a record of all measurements, 

performance evaluations, calibration checks, and maintenance or adjustments for each 

mercury CEMS. 

Maintain a record of actual emissions for Hg for each of the preceding 12 months. Actual 

emissions shall be recorded for Individual units and as a facility total for all units Included in th 

calculation demonstrating compliance. Actual emissions shall be recorded In accordance wit 

310 CMR 7.29 7 b i.b . c. and d. for Hg. 

Maintain a record of actual net electrical output for each of the preceding 12 months, expresse 

In megawatt-hours. Records of actual net electrical output shall be maintained for the Individua 

unit In the calculation demonstrating com pliance, _ __ 

Maintain a record of the resulting output-based emission rates for each of the preceding 1 

months, and each of the 12 consecutive rolling month time periods, expressed In pounds per 

megawatt-hour. Output based emission rates shall be provided for the Individual emission unit 

in the calculatio n demonstrating compliance. 

Keep all measurements, data, reports and other Information required by 310 CMR 7.29 on-sit 

for a minimum of five years, or any other period consistent with the affected facility's Operatin 

~ Permit. I 

Legend to Abbreviated Terms within Table 4 : 

EU# = Emission Unit Number 

NO, = Nitrogen Oxides 

SOZ = Sulfur Dioxide 

Hg = Mercury 

CO = Carbon Monoxide 

COz = Carbon Dioxide 

PM 2.5 = Fine Particulate Matter 

CEMS = Continuous Emissions Monitoring System 
Mt. Tom Generating Company, LLC. Amended ECP Final Approval 

Application I -E-O1-072, Transmittal W025214 

Page 9 of 13 

., , ` Table 5 . 

EU# REPORTING REQUIREMENTS, . , : : :. . . 

EU 1 By January 30 of the year following the earliest applicable compliance date for the affected 

facility under 310 CMR 7 .29(6)(c), and January 30 of each calendar year thereafter, th 

company representative responsible for compliance shall submit a compliance report t 

MassDEP demonstrating the facility's compliance status with the emission standards containe 

in 310 CMR 7.29(5)(a) and in an approved Emission Control Plan . The report shall demonstrat 

he facility's compliance status with applicable monthly emission rates for each month of th 

previous calendar year, and each of the twelve previous consecutive 12-month periods . Th 

compliance report shall Include all statements listed in 310 CMR 7.29(7)(b)4.= 

For the mercury standards at 310 CMR 7.29(5)(a)3.c., the compliance reports due January 30, 

2007 and 2008 shall Include the quarterly emissions for each quarter beginning October 1 

2006. For the mercury standards at 310 CMR 7.29(5)(a)3.c .e . and f ., the compliance report 

due January 30, 2009 and each report thereafter shall demonstrate compliance with an 

applicable annual standard for the previous calendar year and with any applicable 12-month 

standard for each of the 12 previous consecutive 12-month periods. 

In accordance with 310 CMR 7.29(5)(a)3 .g ., certify each CEMS In accordance with the 

applicable quality assurance and quality control procedures contained In 40 CFR Part 6 

Appendix F and continue to compl y with the requirements of 40 CFR Part 60 Appendix F. 

In accordance with 310 CMR 7.29(5)(a)3.g., submit to the appropriate Department regional 

office by the 30th day of April, July, October, and January, a report detailing any of the 

following that have occurred within the previous calendar quarter; In the event none of the 

following Items have occurred, such Information shall be stated In the report : 

. the date and time that any mercury CEMS stopped collecting valid data; 

" when It started to collect valid data again, except for zero and span checks; and 

. the nature and date of system repairs. 

In accordance with 310 CMR 7 .29(7)(a), for the mercury standards at 310 CMR 7.29(5)(a)3.c ., 

the compliance reports due January 30, 2007 and 2008 shall Include the quarterly emissions for 

each quarter beginning October 1, 2006. For the mercury standards at 310 CM 

7 .29(5)(a)3.c ., e., and f ., the compliance report due January 30, 2009 and each repo 

hereafter shall demonstrate compliance with any applicable annual standard for the previous 

calendar year and with any applicable 12-month standard for each of the 12 previous 

consecutive 12-month periods . The compliance report shall contain Items listed In 310 CMR 

7.29( 7)( b) . 

In accordance with 310 CMR 7.29(7)(g), any person subject to 310 CMR 7.29(5)(a)3 . shall 

submit the results of all mercury emissions, monitor, and optimization test reports, along wit 

supporting calculations to the Department within 45 days after completion of such testing. 

MassDEP may verify the facility's compliance status by whatever means necessary, including 

but not limited to requiring the affected facility to submit Information on actual electrical output 

of company generating units provided by the New England Independent System Operator 

ISO or an successor thereto. 

FACILITY Submit by January 15, April 15, July 15 and October 15 for the previous three month 

respectively, a 7.29 construction status report which Identifies the construction activities which 

have occurred during the past three months, and those activities anticipated for the following 

three months, and progress toward achieving compliance with the Implementation date 

Identified In Table 6 below. 

Table 5 Notes 

1 . If the ISO final settlement of actual electrical output is not available, the facility shall submit a 

compliance report based on provisional values of actual electrical output. Upon receiving 

certified ISO values of actual electrical output for all provisional months within the calendar 

year, the facility shall submit a revised compliance report within 30 days thereafter. 

* Legend to Abbreviated Terms within Table 5: EU# = Emission Unit Number 
Mt. Tom Generating Company, LLC. Amended ECP Final Approval 

Application 1-E-01-072, Transmittal W025214 

Page 10 of 13 

3. COMPLIANCE SCHEDULE 

The affected facility shall be In full compliance with the applicable requirements In 

accordance with the dates below : 

_ . . .. . ;: . , ._. . .,.. . :; . . . . .....: : .<.: : . ::.. .~ - :::: .. ._ .. . . ., . . .

.._ 

. ._

. . . . . . ., ... . . , . ..,. . _ - _ _ -- - - - - - . . .- .- . . .. .. 

: . .:u .- - 

. . . . . . . :. -_ . .,~ r~.., . . .. :.. . - - . .. .. . . ., . . : ~ . : : :. ..:_~ .: . . .- . : . . : - .. . ., . .. . .- - ..- :_ .... . A ~-:- - -- - - ., . - - - -- : :. . . ... . . ' . . . . .. . ... . . - . . . . . . .. .. .. . - : .:. - . -- - -- . . . : , .; .-.- 

..

;,, .. 

_

: . . ...... ...

.. ., . . 

. , . 

..

.- 

-

._

.

.-

._.:,...w.

. ._~ .. . .

. ....:,: ., .. ._ :~ .._ . . - , . .- _ .:... ::...: .. ....

-.._.:...:,. .. .......: .,:. . ...:.,. .. :.:~..... :. .,. ....- . . . .. .

~

.7 - .. ; .  ...

;, :-. ..............._;.:.. . :.... .. .:. ._..... ..7~~- ..,.._:.: . .... .. ...,, . ..._._: : ... :.~.,_ .. ..~ . .,.:..,.. .,-- .4 . . . . h~I : .: . P :=

._ 

:

_ 

.. . ;. AM- 

- . - - P. :~- _ - 

. - -- - - -- -- 

NO, 310 CMR 7.29(5)(a)i.a . October 1, 2006 

SOZ 310 CMR 7.29(5)(a)2.a . 

NO, 310 CMR 7.29(5)(a)i .b . October 1, 2008 

SOa 310 CMR 7.29(5)(a)2.b . 

SOZ Shall not exceed 2.0 Ibs/MWh October 1, 2009 

calculated over any consecutive 

12 month period, recalculated 

monthly. 

Shall not exceed 3 .0 Ibs/MWh 

calculated over any Individual 

month. 

COZ 310 CMR 7.29(5)(a)5.a . Calendar, Year 2006 

COZ 310 CMR 7.29(5)(a)5.b . Calendar Year 2008 

Hg 310 CMR 7.29(5)(a)3.e . January 1, 2008` 

310 CMR 7 .29(5)(a)3.f. October 1, 2012 

IACOP WE-07-7009 requires Mt. Tom to meet this average rate of the period from January 1, 

2008 through September 30, 2012. If Mt. Tom falls to meet this rate than an offset of the 

excess emission shall be provided from offsite Hg reductions at a 20 to 1 ratio pursuant to 

ACOP WE-07-7009 . 

* Legend to Abbreviated Terms within Table 6 ; 

NO, = Nitrogen Oxides 

SOZ = Sulfur Dioxide 

Hg = Mercury 

COZ = Carbon Dioxide 
Mt. Tom Generating Company, C.t,C. Amended ECP Final Approval 

Application 1-E-01-072, Transmittal W025214 

Page 11 of 13 

4. SPECIAL CONDITIONS FOR ECP 

1 . MassDEP may verify compliance of 310 CMR 7.29(5) by whatever means necessary, 

including but not limited to : inspection of a unit's operating records; requiring the 

facility to submit information on actual electrical output of company generating units 

provided to that person by the New England Independent System Operator, or any 

successor thereto; testing emission monitoring devices; and, requiring the facility to 

conduct emissions testing under the supervision of MassDEP. 

2. In accordance with 310 CMR 7 .29(5)(b)2., the amount of SOZ early reductions, with 

supporting Information, shall be provided to MassDEP prior to use for compliance 

with 310 CMR 7.29(5)(a)2 .a. Each ton of reduction may be used, once, to offset one 

ton of excess emissions from the facility . Excess emissions are any emissions above 

a level equal to the net electrical output of the facility times the applicable emission 

standard In 310 CMR 7.29(5)(a)2. 

3. In accordance with 310 CMR 7,29(5)(b)3 ., when using SOZ allowances created 

pursuant to 40 CFR Part 72 (the Federal Acid Rain Program), three allowances shall 

be used to offset each ton of excess emissions above the emission standard . Such 

SOZ allowances shall be in addition to those allowances used by the facility to comply 

with the requirements of 40 CFR Part 72, and shall be transferred to MassDEP and 

retired for the benefit of the environment. 

4. MassDEP Is not approving or denying any off-site or non-contemporaneous proposed 

COZ reduction measures at this time. 310 CMR 7 .29(5)(a)S.c. and d . provide that 

compliance with the COZ emission limitations may be demonstrated by using offslte 

reductions or sequestration In addition to onsite reductions, as long as certain 

established conditions are met. However, while there Is a provision for using early 

reductions of SOz to meet the SOz emissions limit in 310 CMR 7.29(5)(a)2.a., there 

is no similar regulatory provision for use of early reductions of COx for compliance 

with 310 CMR7.29(5)(a)5 . MassDEP Is In the process of developing provisions for the 

quantification and certification of Greenhouse Gas (GHG) reductions for use in 

demonstrating compliance with the COZ emission limitations contained In 310 CMR 

7.29. MassDEP will review and approve or deny proposals for off-site, sequestration, 

or non-contemporaneous reductions (i .e. early on-site reductions) of COZ or other 

GHG after adoption of amendments to 310 CMR 7.00: Appendix B, and other 

regulatory sections, If necessary. 

S. GENERAL CONDITIONS FOR ECP ' 

1. The facility shall maintain continuous compliance at all times with the terms of this 

Amended ECP Final Approval and the applicable emission rates In 310 CMR 7.29 . 

2. This Amended ECP Final Approval may be suspended, modified, or revoked by 

MassDEP, If at any time the facility Is violating any applicable Regulation(s) or 

condition(s) of this Final ECP Approval letter. . 

3. This Amended ECP Final Approval consists of Mt. Tom's application materials and this 

Amended ECP Final Approval letter . If conflicting information Is found between these 

two documents, then the requirements of this Amended ECP Final Approval letter 

shall take precedence over the documentation in the application materials . 

4 . Should a condition of air pollution occur as a result of the operation of this unit, then 
Mt. Tom Generating Company, LLC. Amended ECP Final Approval 

Application 1-E-01-072, Transmittal W025214 

Page 12 of 13 

the facility shall Immediately take appropriate steps to abate said condition even 

though the facility is otherwise in compliance with this Amended ECP Final Approval . 

5 . This Amended ECP Final Approval does not negate the responsibility of the facility to 

comply with this or any other applicable federal, state, or local regulations now or in 

the future . Nor does this Amended ECP Final Approval Imply compliance with any 

other applicable federal, state, or local regulations now or in the future . 

6 . If provisions or requirements from any other regulation or permit conflict with a 

provision of 310 CMR 7.29, the more stringent of the provisions will apply unless 

otherwise determined by MassDEP In the affected facility's Operating Permit. 

7 . Failure to comply with any of the above stated provisions will constitute a violation of 

the "Regulations", and can result In the revocation of the Amended ECP Final 

Approval granted herein . 

6. MODIFICATION TO THE ECP 

Amendments may be proposed to this approved Emission Control Plan. If MassDEP 

proposes to approve such amendments, or approve such amendments with conditions, then 

MassDEP will publish a notice of public comment on a FINAL ECP Amended Approval, in 

accordance with M .G .L. c. 30A. MassDEP will allow a 30-day public comment period 

following publication of the notice, and may hold a public hearing. Modifications to an 

affected facility's monitoring systems approved pursuant to the requirements of 40 CFR Part 

72 are not subject to such public comment prior to approval. All terms and conditions of the 

Final ECP Approval shall remain in effect until otherwise modified by MassDEP In a Final ECP 

Approva I . 

7. MASSACHUSETTS ENVIRONMENTAL POLICY ACT 

MassDEP has determined that the filing of an Environmental Notification Form (ENF) 

with the Secretary of Environmental Affairs, for air quality control purposes, was not required 

prior to this action by MassDEP. Notwithstanding this determination, the Massachusetts 

Environmental Policy Act (MEPA) and Regulation 301 CMR 11.00 Section 11 .04, provide 

certain "Fall Safe Provisions" which allow the Secretary to require the filing of an ENF and/or 

Environmental Impact Report at a later time. 

8. APPEAL OF APPROVAL 

This Final ECP Approval Is an action of MassDEP. If you are aggrieved by this action, 

you may request an adjudicatory hearing . A request for a hearing must be made In writing 

and postmarked within twenty-one (21) days of the date of Issuance of this Approval. 

Under 310 CMR 1 .01(6)(b), the request must state clearly and concisely the facts 

which are the grounds for the request, and the relief sought. Additionally, the request must 

state why the Final ECP Approval Is not consistent with applicable laws and regulations. 
Mt. Tom Generating Company, LLC. Amended ECP Final Approval 

Application I-E-O1-072, Transmittal W025214 

Page 13 of 13 

The hearing request along with a valid check payable to The Commonwealth of 

Massachusetts In the amount of one hundred dollars ($100.00) must be mailed to : 

The Commonwealth of Massachusetts 

Department of Environmental Protection 

P.O. Box 4062 

Boston, MA 02211 

The request will be dismissed If the filing fee Is not paid, unless the appellant Is exempt 

or granted a waiver as described below. 

The filing fee, Is not required If the appellant is a city or town (or municipal agency) 

county, or district of the Commonwealth of Massachusetts, or a municipal housing authority. 

MassDEP may waive the adjudicatory hearing filing fee for a person who shows that 

paying the fee will create an undue financial hardship . A person seeking a waiver must file, 

together with the hearing request as provided above, an affidavit setting forth the facts 

believed to support the claim of undue financial hardship . 

Should you have questions concerning this matter or regarding the terms or conditions 

of this Amended ECP Final Approval, please do not hesitate to contact Marc Simpson in 

writing at 436 Dwight Street, Springfield, MA 01103 or by telephone at 413-755-2115. 

Sincerely, 

/. 

Marc Simp 

Permit 546-tion Chief 

Western Regional Office 

ec : USEPA - Region 1, Air Permitting Program : Ida' McDonnell 

DEP/BWP-NERO: Edward 3. Braczyk 

DEP-Boston : YI Tian