1. FUTURE NATURAL GAS POWER PRODUCTION RELIABILITY AND
DEP PERMITTING INFLUENCES
Massachusetts Electric
Restructuring Roundtable
16 February 2001
Edward P. Kunce
Deputy Commissioner
Department of Environmental Protection

2. FUEL AS BACT NESCAUM & EPA Guidance Pollution Prevention theme
Examples of Application
low sulfur fuels
consider NG as “Top” BACT
more NG use at dual fuel facilities
Typical Conditions
11/1 or 10/2 (NG/Oil months)
set by NG availability
set by “$/ton” impact

3. SINGLE FUEL (NG) FACILITIES
NOT driven by DEP permit process
More common at “greenfield” facilities
Secure NG contract available
Avoid fuel oil handling and storage costs
NIMBY’s influence??

4. RELATED PERMIT ISSUES Handling Emergency Situations
Use of Emergency Regulations
New Boston Station Model (ISO driven emergency condition)
Clean Coal & Bio Mass Can Be Permitted
subject to Top/Down BACT
NG not Top BACT
Can EFSB or ISO Require Dual Fuel Capability? Not a DEP Role
NG Pipeline Permitting Issues e.g. Hubline Project
Study Suggests Only One Problem Scenario in Ten Caused by Permit Limitations

5. BOTTOM LINE
DEP will work with Agencies to “Keep The Lights On”