8/
10/
05
EXCERPT
FROM
RTC
DOC
 
RACT
&
CAIR
Comment:
Comments:
Several
State
and
industry
commenters
supported
EPA's
proposed
approach.
These
commenters
stated
that
the
level
of
emissions
reductions
required
by
the
NO
x
SIP
call
is
far
greater
than
the
level
of
reductions
achieved
by
controls
that
have
been
determined
to
be
NO
x
RACT.
Other
commenters
pointed
out
that
many
companies
have
employed
averaging
programs
for
NO
x
SIP
Call
compliance
and
want
this
option
preserved
under
the
8­
hour
ozone
standard
since
requiring
sources
to
individually
meet
NO
x
RACT
requirements
would
greatly
increase
the
costs
of
compliance
at
sources
already
subject
to
the
NO
x
cap­
and­
trade
program
without
achieving
greater
emission
reductions.
One
State
encourages
EPA
to
provide
this
exemption
to
other
areas
subject
to
approved
cap­
and­
trade
programs
in
addition
to
those
areas
affected
by
the
NO
x
SIP
call.
The
EPA
also
received
comments,
primarily
from
several
States
and
environmental
groups,
opposing
the
approach.
These
commenters
stated
that
there
are
no
exceptions
to
the
RACT
mandates
in
either
subpart
1
or
subpart
2
for
sources
subject
to
SIP
call
cap­
and­
trade
programs,
and
EPA
is
without
authority
to
invent
such
an
exception.
Because
the
NO
x
SIP
Call's
cap
and
trade
program
does
not
require
emission
control
technologies
to
be
installed
at
a
particular
source,
some
commenters
conclude
that
RACT
requirements
are
necessary
and
appropriate
to
ensure
that
all
sources
implement
at
least
a
minimum
level
of
control.
One
State
indicated
there
have
been
numerous
cases
where
sources
subject
to
the
NO
x
SIP
Call
have
not
had
to
install
controls
comparable
to
RACT.
Commenters
also
suggested
that
RACT
is
intended
to
be
a
benchmark
for
control
technology
at
individual
stationary
sources,
not
a
level
of
regional
reductions.
In
addition,
some
commenters
noted
that
the
NO
x
SIP
Call
requirements
are
specific
to
the
ozone
season,
where
RACT
requirements
are
year
round.
Consequently,
these
commenters
recommended
that
EPA
should
also
consider
non­
ozone
related
nitrogen
issues,
including
fine
particles,
visibility,
nitrification
and
acidification
of
watersheds
and
eutrophication
of
coastal
waters
all
of
which
would
be
reduced
with
year­
round
controls.
Response:
The
EPA
response
is
addressed
in
the
preamble
to
the
final
rulemaking
notice,
section
IV.
G.
1.
c.
"
What
requirements
should
apply
for
RACM
and
RACT
for
8­
hour
ozone
nonattainment
areas?"
Although
we
drafted
regulatory
language
for
this
aspect
of
the
RACT
program
(
and
for
other
RACT
provisions),
we
believe
it
is
sufficient
to
describe
EPA's
views
on
the
details
of
the
RACT
program
in
today's
preamble
and
in
other
guidance
(
e.
g.,
the
NO
x
Supplement
to
the
General
Preamble,
11­
25­
92);
thus,
some
detailed
portions
of
the
proposed
regulatory
text
regarding
RACT
were
not
retained
in
the
final
rule.
Further,
to
help
determine
if
sources
meeting
the
NO
x
SIP
Call
requirements
and
subject
to
NO
x
RACT
requirements
for
the
8­
hour
ozone
standard
will
be
operating
RACT­
level
combustion
controls
by
2010,
EPA
analyzed
data
from
IPM
runs
for
the
Clean
Air
Interstate
final
rule
(
CAIR).
The
data,
"
IPM
Base
Case
2010
Parsed,"
are
available
in
the
CAIR
docket
(
at
http://
www.
epa.
gov/
airmarkets/
epa­
ipm/
iaqr.
html)
and
show
which
electricity
generating
units
(
EGUs)
are
projected
to
have
NO
x
controls
in
2010.
As
described
below,
the
results
of
the
analysis
support
the
conclusion
that
the
vast
majority
of
sources
meeting
the
NO
x
SIP
Call
2
requirements
and
subject
to
NO
x
RACT
requirements
for
the
8­
hour
ozone
standard
would
be
operating
RACT­
level
combustion
controls
by
2010.
The
data
base
included
8,517
EGUs
in
the
CAIR
2010
emission
inventory.
Our
analysis
considered
the
681
EGUs
in
the
data
base
which
are
projected
to
emit
more
than
1
ton
per
day
of
NO
x
in
2010.
This
level
of
emissions
approximates
the
cutoff
level
for
"
large"
EGUs
in
the
NO
x
SIP
Call
Rule.
Of
the
681
EGUs,
as
few
as
3
­
11
are
projected
to
be
without
NO
x
controls
in
2010
CAIR
base
case
and
subject
to
an
8­
hour
ozone
NO
x
RACT
determination.
It
should
be
noted
that
8
of
these
11
EGUs
are
located
in
the
Chicago
area
which
was
granted
a
waiver
from
NO
x
RACT
under
the
1­
hour
ozone
standard
based
on
a
dispersion
modeling
analysis.
Since
the
area
may
request
a
waiver
from
NO
x
RACT
under
the
8­
hour
standard,
these
8
EGUs
might
not
be
subject
to
a
NO
x
RACT
determination
for
ozone.
The
remaining
3
EGUs
are
located
in
the
Cleveland
area;
because
there
are
7
additional
large
EGUs
in
the
same
area,
all
of
which
are
expected
to
have
NO
x
controls
(
low­
NO
x
burners,
selective
noncatalytic
reduction
(
SNCR)
and/
or
selective
catalytic
reduction
(
SCR)),
the
area
may
meet
RACT
by
averaging.
Additionally,
because
installation
of
combustion
controls
to
decrease
NO
x
emissions
is
almost
always
the
most
cost­
effective
strategy
and
since
the
2010
CAIR
base
case
did
not
take
into
consideration
that
both
areas
are
subject
to
attainment
demonstration
requirements
for
both
ozone
and
PM2.5
(
the
highest
particulate
nitrate
concentrations
in
the
East
tend
to
occur
in
cooler
regions,
70
FR
25129)
EPA
expects
sources
subject
to
the
CAIR
or
NO
x
SIP
Call
cap
and
trade
programs
in
these
areas
will
install
at
least
RACT
level
controls.
In
a
similar
manner,
the
same
2010
CAIR
base
case
data
was
used
to
determine
if
EGUs
emitting
more
than
one
ton/
day
of
NO
x
will
be
operating
RACT­
level
combustion
controls
by
2010
in
the
following
scenario:
(
1)
subject
to
CAIR
for
ozone,
(
2)
not
subject
to
the
NO
x
SIP
Call
requirements
and
(
3)
subject
to
NO
x
RACT
requirements
for
the
8­
hour
ozone
standard.
That
is,
how
many
EGUs
outside
the
NO
x
SIP
Call
area
may
meet
8­
hour
ozone
RACT
through
CAIR
and
what
controls
are
expected
to
be
in
place
at
those
EGUs
in
the
2010
base
case?
The
following
6
States
are
subject
to
CAIR
for
ozone
but
are
not
included
in
the
NO
x
SIP
Call:
Arkansas,
Florida,
Iowa,
Louisiana
,
Mississippi
and
Wisconsin.
The
following
States
do
not
contain
areas
subject
to
NO
x
RACT
for
the
8­
hour
ozone
standard:
Florida,
Iowa,
Louisiana
(
Baton
Rouge
is
marginal),
and
Mississippi.
Crittenden
County
in
Arkansas
is
subject
to
NO
x
RACT
for
the
8­
hour
ozone
standard;
however,
there
are
no
large
EGUs
in
the
data
base
for
this
area.
The
Milwaukee
and
Sheboygan
areas
in
Wisconsin
are
subject
to
NO
x
RACT
for
the
8­
hour
ozone
standard;
in
these
areas
11
of
13
large
EGUs
have
combustion
controls
for
NO
x
in
the
2010
base
case.
The
2
without
NO
x
controls
are
both
located
in
Milwaukee
County
(
South
Oak
Creek).
Thus,
there
may
be
only
2
EGUs
at
one
site
which
are
subject
to
CAIR
and
NO
x
RACT
for
ozone,
are
outside
the
NO
x
SIP
Call
area,
and
are
expected
to
be
uncontrolled
for
NO
x
in
the
2010
CAIR
base
case.
Because
there
are
6
additional
EGUs
in
Milwaukee
County,
all
of
which
are
expected
to
have
NO
x
controls
(
2
with
close
coupled
low­
NO
x
burners
with
overfire
air
using
subbituminous
coal)
,
in
the
2010
base
case,
the
area
may
be
able
to
demonstrate
RACT
by
averaging
emissions
over
all
the
affected
sources.
Further,
because
installation
of
combustion
controls
to
decrease
NOx
emissions
is
almost
always
the
most
cost­
effective
strategy
and
since
the
2010
CAIR
base
case
did
not
take
into
consideration
that
the
area
is
subject
to
attainment
demonstration
requirements
for
both
ozone
and
PM2.5
(
the
highest
particulate
nitrate
3
concentrations
in
the
East
tend
to
occur
in
cooler
regions),
EPA
expects
sources
subject
to
the
CAIR
cap
and
trade
program
in
Milwaukee
will
install
at
least
RACT
level
controls.
