EPA seeks input on NOx plan for two Raven coal plants in Maryland

The U.S. Environmental Protection Agency is taking comment until Jan. 26 on a proposed revision to the Maryland state implementation plan (SIP) that would allow averaging of NOx emissions from Raven Power‘s Brandon Shores and H.A. Wagner coal plants to show compliance with emissions mandates.

Maryland has submitted to the federal agency for inclusion in the SIP a Consent Agreement between Maryland and Raven Power concerning an inter-facility averaging plan for emissions of NOx. The Consent Agreement allows Raven Power to use system-wide emissions averaging to comply with the applicable NOX emission limits for six units located at Brandon Shores and H.A. Wagner.

A Maryland NOx regulation, which is included in its SIP, established NOX emission limits for the 1-hour ozone national ambient air quality standard (NAAQS) for specific types of boilers and other fuel-burning equipment. Specifically, it established maximum NOx emission rates as pounds (lbs) of NOx per million British thermal units (MMBtu) per hour, ranging from 0.45 lbs/MMBtu to 0.80 lbs/MMBtu, depending on the type of combustion unit. The regulation also contains a provision that allows an owner or operator of more than one unit to demonstrate compliance with system-wide emissions standards through the use of an averaging plan.

In July 2016, the Maryland Department of the Environment (MDE) submitted to EPA a SIP revision based on the Consent Agreement. MDE requests that this new Consent Agreement and NOx averaging plan replace the Consent Order and NOx averaging plan previously approved into the Maryland SIP in February 2002. The Consent Agreement between MDE and Raven Power allows Raven Power to use system-wide emissions averaging to comply with the applicable NOx limits for six boiler units (Brandon Shores units 1 and 2 and H.A. Wagner units 1 through 4).

Pursuant to the new Consent Agreement, Raven Power is required to calculate mass emissions from the affected units on a daily basis, determine compliance with the averaging plan using continuous emissions monitors (CEMs), and to submit quarterly reports to both MDE and EPA. In the Consent Agreement, Raven Power agreed that if it fails to comply with the NOx averaging plan, all sources at Brandon Shores and Wagner remain subject to the unit-specific emission limits covered by the Maryland regulation. The aggregate mass emissions from all units at Brandon Shores and Wagner, under the NOx averaging plan, must be less than the mass emissions that would otherwise occur if each unit were subject to the applicable NOX emissions limit.

Brandon Shores is a two-unit, coal-fired, 1,273-MW facility. H.A. Wagner has five units, is 976 MW in size, and is fired by a combination of coal, natural gas and oil.

About Barry Cassell 20414 Articles
Barry Cassell is Chief Analyst for GenerationHub covering coal and emission controls issues, projects and policy. He has covered the coal and power generation industry for more than 24 years, beginning in November 2011 at GenerationHub and prior to that as editor of SNL Energy’s Coal Report. He was formerly with Coal Outlook for 15 years as the publication’s editor and contributing writer, and prior to that he was editor of Coal & Synfuels Technology and associate editor of The Energy Report. He has a bachelor’s degree from Central Michigan University.