COMMONWEALTH OF MASSACHUSETTS

EXECUTIVE OFFICE OF ENERGY & ENVIRONMENTAL AFFAIRS

DEPARTMENT OF ENVIRONMENTAL PROTECTION

WESTERN REGIONAL OFFICE

436 Dwight Street  Springfield, Massachusetts 01103  (413) 784-1100

DEVAL L. PATRICK

Governor

TIMOTHY P. MURRAY

Lieutenant Governor

IAN A. BOWLES

Secretary

LAURIE BURT

Commissioner

Please note that some provisions of this approval are shown in strikeout for the sole 

purpose of showing what provisions are not incorporated into the Massachusetts Regional 

Haze State Implementation Plan (SIP). The provisions shown in strikeout are a part of the

approval and are state enforceable. 

This information is available in alternate format. Call Donald M. Gomes, ADA Coordinator at 617-556-1057. TDD# 866-539-7622 or 617-574-6868.

DEP on the World Wide Web: http://www.mass.gov/dep

 Printed on Recycled Paper

May 15, 2009

Mr. John S. Murray RE:Holyoke

Station Manager Western Region

Mt. Tom Generating Company, LLC 310 CMR 7.29

200 Northampton Street Power Plant Emission Standards

Holyoke, MA 01040 Application No. 1-E-01-072

Transmittal No. W025214

AMENDED EMISSION CONTROL PLAN 

Dear Mr. Murray:

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 (SO2) 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, LLC., Mt. Tom Station facility (ORISP 01606, hereinafter Mt. 

Tom) on Northampton Street in Holyoke, 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.
Mt. Tom Generating Company, LLC. Amended ECP Final Approval

Application 1-E-01-072, Transmittal W025214

Page 2 of 12

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 SO2 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 lb/MMBtu heat release potential on a 30-day rolling 

average.

 

Mt. Tom is in the process of installing a Babcock Power Environmental Turbosorp®

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

049) to control emissions of SO2 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 tetrasulfide 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 lb/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 lb/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 lb/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 lb/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 (SO2), carbon dioxide (CO2), 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 SO2 and 500 tons of NOx 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 CFR 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 12

The purpose of 310 CMR 7.29 is to control emissions of NOx, SO2, Hg, CO, CO2, 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 

NOx, SO2, and CO2, and establishing a cap on CO2 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 

limitation(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 SO2 and Hg emission rate specified under 310 CMR 7.29 (5) 2 and 3 respectively, without 

using Massachusetts SO2 Early Reduction Credits. The Consent Order also requires Mt. Tom to 

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

September 30, 2012. If Mt. Tom fails 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 1 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, SO2, 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 lb/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 1-E-01-072, Transmittal W025214

Page 4 of 12

1. EQUIPMENT DESCRIPTION

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

ECP Final Approval:

Table 1*

EU # DESCRIPTION OF 

EMISSION UNIT

EU DESIGN CAPACITY POLLUTION CONTROL MEASURES 

(PCM)1

(MMBTU/HR) MW (NET)

EU 1 Mt. Tom Unit 1 

Riley Stoker Boiler 1,480 147

Turbosorp® control device

Upgraded combustion controls and burner 

system

Selective Catalytic Reduction (SCR)

SO2 Early Reductions2

SO2 Allowances3

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

SO2 = Sulfur Dioxide
Mt. Tom Generating Company, LLC. Amended ECP Final Approval

Application 1-E-01-072, Transmittal W025214

Page 5 of 12

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 2 *

EU # RESTRICTION/

OPERATING 

PRACTICES

POLLUTANT EMISSION LIMIT/STANDARD APPLICABLE REGULATION

AND/OR

APPROVAL NUMBER

EU 1 NA NOx Shall not exceed 1.5 lbs/MWh calculated over 

any consecutive 12 month period, recalculated 

monthly.

310 CMR 7.29(5)(a)1.a.

Shall not exceed 3.0 lbs/MWh calculated over 

any individual month.

310 CMR 7.29(5)(a)1.b.

SO2 Shall not exceed 6.0 lbs/MWh calculated over 

any consecutive 12 month period, recalculated 

monthly. 

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

Shall not exceed 3.0 lbs/MWh calculated over 

any consecutive 12 month period, recalculated 

monthly.

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

Shall not exceed 6.0 lbs/MWh calculated over 

any individual month.

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

Shall not exceed 2.0 lbs/MWh calculated over 

any consecutive 12 month period, recalculated 

monthly.

Approval 1-E-01-0724

Shall not exceed 3.0 lbs/MWh calculated over 

any individual month.

Approval 1-E-01-0724
Mt. Tom Generating Company, LLC. Amended ECP Final Approval

Application 1-E-01-072, Transmittal W025214

Page 6 of 12

Table 2 Notes:

4. SO2 emissions are actual measured emissions from the facility. Mt. Tom shall not use any SO2

early reductions or SO2 allowances to achieve this emission rate.

* Legend to Abbreviated Terms within Table 2:

EU# = Emission Unit Number

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

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

NOx = Nitrogen Oxides

SO2 = Sulfur Dioxide

Hg = Mercury

CO = Carbon Monoxide

CO2 = Carbon Dioxide

PM 2.5 = Fine Particulate Matter 

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

Application 1-E-01-072, Transmittal W025214

Page 7 of 12

B. COMPLIANCE DEMONSTRATION

The facility is subject to the monitoring/testing, 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# MONITORING/TESTING REQUIREMENTS

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 CFR 

Part 75 for SO2, and NOx. 

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.

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

units included in the calculation demonstrating compliance. 

* Legend to Abbreviated Terms within Table 3:

EU# = Emission Unit Number

NOx = Nitrogen Oxides

SO2 = Sulfur Dioxide

Hg = Mercury

CO = Carbon Monoxide

CO2 = 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 12

Table 4 *

EU# 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 provided 

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

i.

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

in megawatt-hours. Records of actual net electrical output shall be maintained for the individual 

unit in the calculation demonstrating compliance.

Maintain a record of the resulting output-based emission rates for each of the preceding 12 

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 calculation demonstrating compliance.

Keep all measurements, data, reports and other information required by 310 CMR 7.29 on-site 

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

Permit.

* Legend to Abbreviated Terms within Table 4:

EU# = Emission Unit Number

NOx = Nitrogen Oxides

SO2 = Sulfur Dioxide

Hg = Mercury

CO = Carbon Monoxide

CO2 = 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 9 of 12

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, the 

company representative responsible for compliance shall submit a compliance report to 

MassDEP demonstrating the facility’s compliance status with the emission standards contained 

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

the facility’s compliance status with applicable monthly emission rates for each month of the 

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

compliance report shall include all statements listed in 310 CMR 7.29(7)(b)4.1



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 any successor thereto.

FACILITY

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 12

3. COMPLIANCE SCHEDULE

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

accordance with the dates below:

TABLE 6 *

COMPLIANCE PATH

POLLUTANT STANDARD DATE

NOx

SO2

310 CMR 7.29(5)(a)1.a.

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

October 1, 2006

NOx

SO2

310 CMR 7.29(5)(a)1.b.

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

October 1, 2008

SO2 Shall not exceed 2.0 lbs/MWh 

calculated over any consecutive

12 month period, recalculated 

monthly.

October 1, 2009

Shall not exceed 3.0 lbs/MWh 

calculated over any individual 

month.

* Legend to Abbreviated Terms within Table 6:

NOx = Nitrogen Oxides

SO2 = Sulfur Dioxide

Hg = Mercury

CO2 = Carbon Dioxide
Mt. Tom Generating Company, LLC. Amended ECP Final Approval

Application 1-E-01-072, Transmittal W025214

Page 11 of 12

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 SO2 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 SO2 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 

SO2 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.

5. 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 

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

Application 1-E-01-072, Transmittal W025214

Page 12 of 12

Approval granted herein.

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 Simpson

Permit Section Chief

Western Regional Office

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

DEP/BWP-NERO: Edward J. Braczyk

DEP-Boston: Yi Tian