November 20,2015 

Shawn M. Garvin 

Regional Administrator 

U.S. Environmental Protection Agency 

Region Ill (3RAOO) 

1650 Arch Street 

Philadelphia, PA 19103-2029 

Dear Mr. Garvin: 

Thank you for your letter to Maryland Department of the Environment (MDE) Secretary Ben 

Grumbles on March 20, 2015. The U.S. Environmental Protection Agency (EPA) notified 

Maryland of the settlement agreement between the EPA, Sierra Club and the Natural Resources 

Defense Council over the new sulfur dioxide (S02) standard and the aggressive schedule 

included in that agreement. 

Maryland appreciates the opportunity to present the EPA with a recommendation for the 

designation of areas under the 2010 primary, 1-hour National Ambient Air Quality Standard 

(NAAQS) for SO:. Maryland recommends that EPA designate the Herbert A. Wagner 

Generating Plant ("Wagner") area as "attainment" with respect to the new standard. 

Between 2007 and 2010, Maryland power generators invested an estimated $2 billion in air 

pollution controls to reduce emissions. As shown in Attachments 1 and 2, these reductions 

in S02 emissions resulted in dramatic reductions in 1-hour SOz concentrations across the State. 

A summer 2013 air monitoring study regarding 1-hour S02 levels around the Wagner area shows 

that SOz levels are generally below the new standard. Attachment 3 summarizes the data from 

the 2013 air monitoring study. 

As shown in Attachment 4, preliminary air quality modeling also demonstrates that the Wagner 

area can attain the new SOz standard. In mid-April2015, the owners of the Wagner facility, 

Raven Power, began to use a lower sulfur coal at Wagner unit number 2 as a method of 

compliance with the federally enforceable Mercury and Air Toxics Standards. Modeling current 

emissions, adjusted for the reduced sulfur content of the new coal, results in S02 concentrations 

below the new standard. 
In early 2016, Raven Power will also be adding a dry sorbent injection (DSI) system to unit 

number 3 at the Wagner facility to comply with the Mercury and Air Toxics Standards. DSI 

control technology can also help reduce S02 emissions. The modeling described in Attachment 5 

will capture the benefits from both the 2015 and 2016 emission reduction efforts at the Wagner 

plant. 

Maryland is not making a designation area boundary recommendation at this time. Maryland 

recognizes, though. that this designation recommendation submittal is only the first step in the 

S02 designation process and looks forward to working with the EPA and Maryland stakeholders 

during the remaining steps of the process. Maryland is requesting routine coordination calls with 

EPA on issues related to the designation of the Wagner area. For more details, please see 

Attachment 6, which is a timeline. 

Please note that Maryland's submission of this designation recommendation letter is consistent 

with § 1 07( d)( 1) of the Clean Air Act. It is also consistent with Consent Decree, Case No. 3: 13-

cv-03953-SI, Sierra Club and Natural Resources Defense Council v. Gina McCarthy, 

Administrator, United States Environmental Protection Agency. 

If you have any questions about this submission, please do not hesitate to contact Ben Grumbles, 

Secretary, Maryland Department of the Environment at 410-537-3084. 

cc: Ben Grumbles, Secretary, Maryland Department of the Environment 

Enclosures