1
The
EPA
has
defined
RACT
as
the
lowest
emission
limitation
that
a
particular
source
is
capable
of
meeting
by
the
application
of
control
technology
that
is
reasonably
available
considering
technological
and
economic
feasibility
(
44
FR
53762,
Sept.
17,
1979).

1
Technical
Support
Document
NOx
RACT
Source
Specific
SIP
Revision
­
State
of
New
Jersey
Schering
Corporation
­
HRSG/
Duct
Burner
CoGen
II
Cogeneration
Facility
April
28,
2005
I.
INTRODUCTION
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1
II.
DESCRIPTION
OF
NO
x
RACT
REQUIREMENTS
AND
NEW
JERSEY'S
NO
x
RACT
REGULATION
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2
A.
NO
x
RACT
and
Due
Dates
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2
B.
Applicability
of
NO
x
RACT
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2
C.
New
Jersey's
NO
x
RACT
Regulation
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3
D.
Subchapter
19.13
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3
E.
Enforceability
of
Subchapter
19
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4
III.
EPA's
ANALYSIS
OF
STATE
SUBMISSION
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5
A.
New
Jersey's
Source­
Specific
SIP
Revision
­
Schering
Corporation
.
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5
B.
EPA's
Evaluation
of
NJDEP's
SIP
Revision
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9
C.
Conclusion
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10
I.
INTRODUCTION
Title
I
of
the
Clean
Air
Act
Amendments
of
1990
(
the
Act)
contains
many
new
and
revised
requirements
for
areas
that
have
not
attained
the
national
ambient
air
quality
standard
for
ozone.
Section
182(
f)
of
the
Act
requires
States
to
apply
the
same
requirements
to
major
stationary
sources
of
nitrogen
oxides
(
NO
x),
as
defined
by
sections
302
and
182(
c),
(
d),
and
(
e),
as
are
applied
to
major
stationary
sources
of
volatile
organic
compounds
(
VOC).
The
new
NO
x
requirements
are
reasonably
available
control
technology
(
RACT)
1
and
new
source
review
for
major
stationary
sources
in
certain
ozone
nonattainment
areas
and
throughout
any
ozone
transport
region.
This
technical
support
document
deals
primarily
with
the
State
of
New
Jersey
Department
of
Environmental
Protection's
(
NJDEP's)
Source­
Specific
State
Implementation
Plan
(
SIP)
revision
to
the
ozone
SIP.
This
SIP
was
submitted
to
address
the
new
NOx
RACT
requirements,
specific
to
the
heat
recovery
steam
generator
(
HRSG)
with
duct
burner
for
the
CoGen
II
Cogeneration
Facility
operated
by
Schering
Corporation.
2
On
November
25,
1992,
the
Environmental
Protection
Agency
(
EPA)
published
a
NO
x
Supplement
to
the
General
Preamble
(
NO
x
Supplement)
to
provide
guidance
on
implementation
of
new
provisions
of
the
Act
concerning
emissions
of
NO
x.
[
57
Federal
Register
(
FR)
55620].
Because
EPA
is
describing
the
NJDEP
SIP
revision
here
only
in
how
it
addresses
the
new
NO
x
RACT
requirements
on
a
source­
specific
basis,
the
reader
should
refer
to
"
The
General
Preamble
for
Implementation
of
Title
I
of
the
Clean
Air
Act
Amendments,"
(
57
FR
13498,
April
16,
1992)
and
the
NO
x
Supplement
for
a
more
detailed
discussion
of
the
other
NO
x
requirements.

II.
DESCRIPTION
OF
NOx
RACT
REQUIREMENTS
AND
NEW
JERSEY'S
NOx
RACT
REGULATION
A.
NO
x
RACT
and
Due
Dates
Section
182(
f)
provides
that
SIP
provisions
required
for
major
stationary
sources
of
VOC
also
apply
to
major
stationary
sources
of
NO
x.
Section
182(
b)(
2)
requires
States
in
which
nonattainment
areas
have
a
"
moderate"
classification,
or
a
higher
classification,
to
submit
RACT
rules
for
major
stationary
sources
of
VOC
emissions
by
November
15,
1992,
and
to
implement
RACT
by
no
later
than
May
31,
1995.
Therefore,
States
must
submit
RACT
rules
for
major
stationary
sources
of
NO
x
emissions
in
moderate
nonattainment
areas
and
nonattainment
areas
with
a
higher
classification
by
November
15,
1992,
and
must
provide
for
the
implementation
of
the
required
measures
by
no
later
than
May
31,
1995.

B.
Applicability
of
NO
x
RACT
Major
sources
of
NO
x
are
subject
to
the
same
requirements
as
major
sources
of
VOC
compounds.
Thus,
the
NO
x
RACT
provisions
apply
to
major
sources
of
NO
x
in
ozone
nonattainment
areas
moderate
or
higher
and
throughout
an
ozone
transport
region.
The
Northeastern
portion
of
the
United
States
has
been
designated
an
ozone
transport
region.
Thus,
in
ozone
transport
regions,
the
Section
184(
b)(
2)
requirement
applied
to
the
Northeastern
States
provides
that
all
areas
designated
as
attainment/
unclassified
as
well
as
all
ozone
nonattainment
areas
must
meet
the
RACT
requirements
for
NO
x.

Section
184(
b)(
2)
requires
any
source
of
VOC
which
emits
or
has
a
potential
to
emit
50
tons
per
year
(
TPY)
in
ozone
transport
regions
to
be
subject
to
the
same
requirements
that
apply
to
major
sources
in
ozone
areas
classified
as
moderate,
unless
a
portion
of
the
State
has
been
excluded
from
the
ozone
transport
region
under
section
176(
a)(
2).
Thus,
where
a
State
is
designated
in
its
entirety
as
a
transport
region,
the
State
must
adopt
rules
to
apply
provisions
for
ozone
to
any
source
which
emits
or
has
a
potential
to
emit
50
TPY
of
VOC
compounds
Statewide.

Also,
section
182(
f)
specifically
provides
that
major
stationary
sources
of
NO
x
are
to
be
defined
by
section
302.
Section
302(
j)
provides
that
a
major
stationary
source
is
one
with
a
potential
to
emit
100
TPY.
Because
the
section
182(
f)
definition
refers
specifically
to
the
section
3
302
definition,
the
specific
50
TPY
requirement
for
VOC
major
stationary
sources
in
ozone
transport
region
is
limited
to
VOC
sources.
Therefore
in
ozone
transport
regions,
attainment/
unclassified
areas
as
well
as
marginal
and
moderate
ozone
nonattainment
areas,
a
major
stationary
source
for
NO
x
is
considered
to
be
one
which
emits
or
has
the
potential
to
emit
100
TPY
or
more
of
NO
x
and
is
subject
to
the
requirements
of
a
moderate
nonattainment
area.
(
See
NO
x
Supplement,
57
FR
55620).
NJDEP
has
defined
a
major
stationary
source
for
NO
x
as
a
source
which
has
the
potential
to
emit
25
TPY,
the
level
set
for
severe
ozone
nonattainment
areas.

C.
New
Jersey's
NO
x
RACT
Regulation
The
NO
x
RACT
regulation,
Subchapter
19,
was
developed
by
the
NJDEP.
The
NJDEP
held
public
hearings
on
March
18
and
19,
1993
to
obtain
public
comments
on
the
proposed
rule.
Following
the
public
hearings
and
comment
period,
NJDEP
adopted
and
on
November
15,
1993,
the
Acting
Commissioner
signed
Subchapter
19.
On
November
15,
1993,
NJDEP
submitted
Subchapter
19
to
EPA
as
a
revision
to
the
SIP.
EPA
reviewed
the
SIP
revision
and
on
or
around
December
29,
1993,
determined
it
to
be
administratively
and
technically
complete.
On
October
2,
1995,
EPA
proposed
full
approval
of
NJDEP's
Subchapter
19
in
the
Federal
Register,
60
FR
51379.
The
public
comment
period
ended
November
1,
1995.
EPA
did
not
receive
any
comments
on
the
October
2,
1995
Notice.
However,
during
this
public
comment
period,
discussions
developed
among
regional
EPA
offices
as
to
the
approvability
of
regulations,
such
as
NJDEP's
Subchapter
19,
containing
generic
or
"
process
oriented"
provisions
establishing
RACT
requirements
for
major
sources
of
NO
x
and/
or
volatile
organic
compound
(
VOC)
emissions.
The
approvability
issues
relating
to
Subchapter
19'
s
generic
provision
were
resolved
and
EPA's
approval
of
NJDEP's
Subchapter
19
was
published
in
the
Federal
Register
on
January
27,
1997
(
60
FR
51379)
and
became
effective
on
February
26,
1997.

On
March
24,
1995,
NJDEP
adopted
amendments
to
Subchapter
19.
NJDEP
submitted
the
amended
Subchapter
19
to
EPA
as
a
SIP
revision
on
June
21,
1996.
EPA
reviewed
the
SIP
revision
and
on
or
around
September
26,
1996,
determined
it
to
be
administratively
and
technically
complete.
On
August
31,
1998,
EPA
proposed
a
full
approval
of
NJDEP's
Subchapter
19
in
the
Federal
Register,
63
FR
46209.
EPA's
approval
of
NJDEP's
March
24,
1995
amendments
to
Subchapter
19
was
published
in
the
Federal
Register
on
March
29,
1999
(
64
FR
14832)
and
became
effective
on
April
28,
1999.

NJDEP's
latest
version
of
Subchapter
19
was
adopted
on
April
5,
2004.
At
the
time
this
technical
support
document
was
written,
NJDEP
proposed
amendments
to
Subchapter
19
on
September
20,
2004.
The
public
comment
period
for
the
proposal
ended
on
November
19,
2004.

D.
Subchapter
19.13
The
Source­
Specific
SIP
revision
discussed
in
this
technical
support
document
was
submitted
to
EPA,
pursuant
to
Subchapter
19.
Subchapter
19.13
establishes
a
procedure
for
a
4
case­
by­
case
determination
of
what
represents
RACT
for
a
particular
facility,
item
of
equipment
or
source
operation.
This
procedure
is
applicable
in
two
types
of
situations:
(
1)
where
a
major
NO
x
facility
contains
any
source
operation
or
item
of
equipment
not
listed
in
19.2
with
the
potential
to
emit
more
than
10
tons
of
NO
x
per
year;
or
(
2)
where
the
owner
or
operator
of
a
source
operation
or
item
of
equipment
that
is
listed
in
19.2
seeks
approval
of
an
alternative
maximum
allowable
emission
rate.

In
the
first
instance,
for
any
source
operation
or
item
of
equipment
at
a
major
NO
x
facility,
with
the
potential
to
emit
10
TPY
or
more
of
NO
x,
not
specifically
regulated
under
section
19.2,
the
owner/
operator
must
submit
a
'
NO
x
Control
Plan'
to
the
NJDEP.
This
NO
x
Control
Plan
is
to
include
a
technical
and
economic
feasibility
evaluation
of
NO
x
control
technologies
as
well
as
a
proposed
NO
x
emission
limit.

In
the
second
instance,
those
specific
sources
subject
to
NO
x
limits
under
Subchapter
19
may
apply
for
an
alterative
emissions
limit.
In
this
case,
NO
x
RACT
control
measures
may
be
deemed
impractical
due
to
some
physical
constraints
or
the
control
measures
may
be
incapable
of
reducing
the
emissions
to
the
limits
required
under
Subchapter
19.
In
this
situation,
the
NJDEP
may
establish
an
alternative
maximum
allowable
emission
rate
for
the
affected
sources.

For
each
of
these
situations,
Subchapter
19.13
provides
that
NJDEP
establish
emission
limits
based
upon
a
RACT
determination
specific
to
the
facility
in
question.
The
procedures
for
requesting
that
determination,
and
the
standards
for
review
of
the
request,
are
the
same
in
each
situation.

The
owner
or
operator
of
a
facility
for
which
a
NO
x
control
plan
is
required
must
obtain
approval
of
the
plan,
implement
it
by
May
31,
1995,
and
continue
to
comply
with
it
thereafter.
The
Act
imposes
this
deadline.
Implementing
the
plan
includes
obtaining
the
required
permits
and
certificates,
installing
the
approved
NO
x
control
technology,
and
complying
with
the
emission
limits
approved
in
the
plan.
An
owner
or
operator
seeking
approval
of
an
alternative
maximum
allowable
emission
rate
must
obtain
approval
before
the
source
operation
or
item
of
equipment
in
question
becomes
subject
to
the
rate
normally
applicable
under
subchapter
19,
in
order
to
avoid
incurring
violations
for
exceeding
that
normally
applicable
rate.

Section
19.13(
h)
provides
that
"
any
alternate
emissions
limit
pursuant
to
section
19.3(
c)
or
NO
x
Control
Plan
pursuant
to
section
19.3(
b)
approved
by
the
NJDEP
will
be
submitted
as
an
amendment
to
the
SIP
for
ozone."
An
alternate
emissions
limit
or
NO
x
Control
Plan
would
be
first
proposed
and
adopted
in
New
Jersey
and
then,
as
required
by
law,
submitted
to
EPA
for
approval
as
a
SIP
revision.

E.
Enforceability
of
Subchapter
19
For
sources
not
subject
to
specific
emission
limitations
or
work
practice
standards,
section
19.13
provides
a
procedure
and
schedule
which
must
be
followed
in
order
to
comply
with
5
Subchapter
19.
Should
a
source
not
comply
with
this
procedure
it
would
constitute
a
violation
of
Subchapter
19
which
would
subject
the
source
owner
or
operator
to
civil
and
applicable
criminal
penalties.
EPA
thinks
this
is
sufficient
to
deter
noncompliance.
Should
EPA
have
to
take
enforcement
action,
it
could
use
the
same
provisions
to
obtain
compliance.

EPA
will
process
all
source­
specific
SIP
revisions
submitted
by
NJDEP,
regardless
of
the
status
of
EPA­
approval
of
Subchapter
19,
provided
that
NJDEP
provides:

­
evidence
that
NJDEP
has
the
necessary
legal
authority
under
State
law
to
approve
and
implement
the
compliance
plan
with
reference
to
appropriate
State
laws
and
regulations;
­
a
description
of
the
enforcement
procedure
NJDEP
will
use
should
it
discover
a
violation;
­
a
description
of
the
compliance
strategy
NJDEP
will
use
to
ensure
compliance;
and
­
a
copy
of
any
relevant
permits
which
are
contained
in
the
compliance
plan.
For
"
grandfathered"
sources,
the
compliance
plan
must
identify
the
applicable
enforceable
requirements
or
restrictions.

III.
EPA's
ANALYSIS
OF
STATE
SUBMISSION
(
Note
this
Technical
Support
Document
summarizes
the
state
submission.
The
complete
RACT
analysis,
related
correspondence
and
SIP
revision
are
available
for
inspection
and
review
at
the
EPA
Regional
Office
and
NJDEP
State
Office.)

A.
New
Jersey's
Source­
Specific
SIP
Revision
­
Schering
Corporation
Pursuant
to
Subchapter
19.3(
h),
"
any
alternate
emissions
limit
pursuant
to
section
19.3(
c)
or
NO
x
Control
Plan
pursuant
to
section
19.3(
b)
approved
by
the
NJDEP
will
be
submitted
as
an
amendment
to
the
SIP
for
ozone."
An
alternate
emissions
limit
or
NO
x
Control
Plan
would
be
first
proposed
and
adopted
in
New
Jersey
then,
as
required
by
law,
submitted
to
EPA
for
approval
as
a
SIP
revision.
This
technical
support
document
discusses
EPA's
analysis
for
a
source­
specific
SIP
revision
for
facility­
specific
NO
x
emission
limits,
developed
pursuant
to
Subchapter
19.13(
c),
where
the
owner
or
operator
of
a
source
operation
or
item
of
equipment
that
is
listed
in
19.2
seeks
approval
of
an
alternative
maximum
allowable
emission
rate.

Before
discussing
New
Jersey's
Source­
Specific
SIP
Revision
in
detail,
it
is
important
to
note
how
Schering
complied
with
the
Act
requirements
for
NO
x
RACT
since
1995.
On
June
3,
1996,
New
Jersey
adopted
the
New
Jersey
Open
Market
Emission
Trading
(
OMET)
program,
Subchapter
30
of
Chapter
27,
Title
7
of
the
New
Jersey
Administrative
Code.
The
OMET
program
permitted
regulated
facilities
to
purchase
"
discrete
emission
reduction"
(
DER)
credits
for
volatile
organic
compounds
(
VOC)
and
NOx
to
meet
VOC
and
NOx
emission
limits
set
forth
in
Subchapters
16
and
19
of
Chapter
27,
Title
7
of
the
New
Jersey
Administrative
Code,
respectively.

On
January
9,
2001,
EPA
published,
in
the
Federal
Register,
a
proposed
conditional
approval
of
the
OMET
program.
(
66
FR
1796)
After
discussion
with
New
Jersey,
on
June
24,
6
2002,
EPA
sent
New
Jersey
a
letter
reiterating
a
number
of
concerns
about
the
OMET
program.
On
August
13,
2002,
New
Jersey
responded
to
this
letter
indicating
that
it
concluded
the
OMET
program
should
be
terminated.
On
October
18,
2002,
EPA
published,
in
the
Federal
Register
(
67
FR
64347),
its
determination
to
withdraw
a
prior
proposed
conditional
approval
of
the
OMET
program.

On
December
16,
2002,
New
Jersey
held
a
public
meeting
discussing
options
for
repealing
the
OMET
program.
EPA's
withdrawal
of
its
proposed
approval
and
this
meeting
were
indications
that
sources
could
no
longer
rely
on
the
OMET
program
to
satisfy
the
Act
requirements
for
VOC
and
NOx
RACT.
On
February
25,
2004,
New
Jersey
adopted
rules,
repealing
the
OMET
program
and
adopted
rule
repeals,
and
amendments
to
rules
governing
other
programs
impacted
by
the
repeal
of
the
OMET
program,
including
Subchapter
19
(
the
state
NOx
RACT
rules).
36
New
Jersey
Register
1791(
a).
On
that
date,
New
Jersey
also
adopted
amendments
and
new
rules
to
replace
provisions
provided
by
the
OMET
program.
The
effective
date
of
the
repeals,
amendments
and
new
rules
is
April
5,
2004
and
the
operative
date
is
April
25,
2004.

On
April
26,
2004,
EPA
notified,
by
letter,
New
Jersey
that
"
sources
should
be
advised
that
if
they
rely
on
the
extended
compliance
deadlines
or
compliance
options
provided
in
the
revised
NJDEP
rule,
they
would
not
comply
with
the
federally­
approved
regulations,
which
do
not
provide
for
any
such
deadline
extensions."
By
copy
of
that
letter,
EPA
notified
sources
identified
as
OMET
credit
users
in
the
revised
rule
about
"
unresolved
issues
regarding
that
rule
and
the
probability
of
SIP
disapproval."
This
letter
also
refers
to
a
September
18,
2003
letter
in
which
EPA
provided
comments
to
New
Jersey,
which
identified
serious
deficiencies
in
the
originally
proposed
regulation.

While
the
State
of
New
Jersey
has
adopted
new
state
NOx
RACT
rules
that
allowed
Schering
and
other
sources
until
April
25,
2005
to
achieve
compliance
with
State
NOx
RACT
rules,
the
federally­
approved
NOx
RACT
rule
in
the
SIP
requires
compliance
with
the
federal
RACT
regulations
by
May
31,
1995.
Since
the
new
state
NOx
RACT
rules
have
not
been
and
are
not
likely
to
be
federally­
approved
and
included
in
the
SIP,
the
federally
enforceable
compliance
date
for
NOx
RACT
remains
May
31,
1995.

On
May
27,
2004,
EPA
held
a
meeting
with
Schering
and
several
other
owners/
operators
of
sources
copied
on
the
April
26,
2004
letter
to
New
Jersey
to
discuss
compliance
options.
Schering
attended
the
meeting
and
advised
EPA
that
it
would
submit
a
timely
proposal
for
compliance.
On
July
15,
2004,
Schering
submitted
for
EPA
and
New
Jersey
review,
a
proposal
for
an
alternative
emission
limit
(
AEL)
to
comply
with
both
federal
and
state
NOx
RACT.
On
January
19,
2005,
EPA
sent
Schering
a
Notice
of
Violation
describing
its
violations
of
Subchapter
19.
On
April
11,
2005,
EPA
issued
Schering
a
Compliance
Order
which
required
Schering
to
comply
with
the
proposed
NOx
RACT
emissions
limits
set
forth
in
its
AEL
application,
submitted
on
July
15,
2004,
until
the
limits
are
approved
by
the
State.
Following
state
approval,
Schering
shall
comply
with
the
state­
approved
AEL,
until
it
is
federally­
approved,
and
thereafter
comply
7
with
the
NOx
RACT
pursuant
to
the
federally­
approved
AEL.
Today's
proposed
action
is
the
next
step
in
the
federal
approval
process.

The
source­
specific
SIP
revision
for
the
HRSG
with
duct
burner
for
the
CoGen
II
Cogeneration
Facility
operated
by
Schering
Corporation
was
submitted
to
EPA
on
March
31,
2005.
Prior
to
the
SIP
submittal,
on
October
23,
2004
NJDEP
proposed
the
SIP
revision
through
a
Public
Notice
in
an
area
newspaper.
The
public
comment
period
ran
from
October
23,
2004
through
November
24,
2004.
No
public
comments
were
submitted
to
NJDEP
during
the
public
comment
period.
EPA
submitted
comments
to
NJDEP
prior
to
the
public
notice
on
October
14,
2004.
EPA
determined
the
March
31,
2005
SIP
revision
to
be
complete
on
April
25,
2005.
As
part
of
the
SIP
completeness
review,
EPA
ensured
that
NJDEP
complied
with
the
conditions
discussed
earlier
in
Section
II.
E.
for
source­
specific
SIP
revisions.
This
technical
support
document
is
the
next
step
in
EPA's
rulemaking
process.

Schering
Corporation
owns
and
operates
a
cogeneration
unit
(
CoGen
II)
at
their
facility
in
Union,
Union
County.
The
CoGen
II
unit
consists
of
a
gas
turbine
with
a
supplementary/
fresh
air
fired
(
FAF)
heat
recovery
steam
generator
(
HRSG).
The
HRSG
includes
a
duct
burner
that
fires
natural
gas
or
distillate
fuel
oil.
The
unit
is
associated
with
a
duel­
fuel
4.0
megawatt
combustion
turbine.
The
HRSG/
duct
burner
has
two
modes
of
operation:

(
1)
CoGen
mode
­
operation
of
the
cogeneration
plant
while
the
gas
turbine
is
base
loaded
and
the
duct
burner
fires
supplementary
natural
gas
or
distillate
oil
to
produce
additional
steam
in
the
HRSG
(
40.3
MMBtu/
hr
firing
natural
gas,
38.1
MMBtu/
hr
firing
distillate
oil);

(
2)
Fresh
Air
Fired
mode
(
FAF)
­
operation
of
the
cogeneration
plant
while
the
gas
turbine
is
not
operating
and
the
duct
burner
fires
natural
gas
or
distillate
oil
to
produce
the
required
steam
in
the
HRSG
(
77.2
MMBtu/
hr
firing
natural
gas,
73.9
MMBtu/
hr
firing
distillate
oil).

Schering
is
a
major
facility
and
the
HRSG/
duct
burner
has
a
gross
heat
input
greater
than
20
MMBtu/
hr.
Subchapter
19.2(
b)
2
requires
any
non­
utility
boiler
or
other
indirect
heat
exchanger
with
a
maximum
gross
heat
input
greater
than
20
MMBtu/
hr
to
be
subject
to
Subchapter
19.
HRSG/
duct
burners
are
regulated
under
Subchapter
19.7.
Subchapter
19.7(
b)
requires
any
non­
utility
boiler
between
50
to
100
MMBtu/
hr,
to
emit
NO
x
at
a
rate
no
greater
than
0.1
lbs/
MMBtu
firing
natural
gas
and
0.12
lbs/
MMBtu
firing
distillate
oil.

Schering's
HRSG/
duct
burner
complies
with
the
presumptive
NO
x
RACT
limits
at
Subchapter
19.7(
b)
when
operating
in
the
CoGen
mode.
However,
when
operating
in
the
FAF
mode,
the
HRSG/
duct
burner
cannot
meet
the
presumptive
limits.
The
HRSG/
duct
burner
is
currently
equipped
with
low
NO
x
burners
(
LNB)
and
burns
natural
gas
or
distillate
oil.
In
FAF
mode,
the
HRSG/
duct
burner
is
currently
permitted
to
emit
NO
x
at
no
greater
than
0.17
lbs/
MMBtu
while
firing
natural
gas,
and
no
greater
than
0.18
lbs/
MMBtu
while
firing
distillate
oil.
8
It
is
estimated
by
NJDEP
that
maximum
potential
NO
x
emissions
from
the
HRSG/
duct
burner
in
the
FAF
mode
are
4.0
TPY
based
on
a
maximum
heat
input
of
77.2
MMBtu/
hr
firing
natural
gas
and
73.9
MMBtu/
hr
firing
distillate
oil,
and
where
operation
of
the
unit
in
FAF
mode
is
limited
to
600
hours/
year.

Schering
evaluated
LNBs,
selective
catalytic
reduction
(
SCR),
selective
non­
catalytic
reduction
(
SNCR),
emissions
averaging,
repowering,
and
fuel
switching
for
controlling
NO
x
emissions
from
the
HRSG/
duct
burner.
Schering
determined
that
neither
SCR
nor
SNCR
are
technically
feasible
because
of
installation
constraints
of
the
control
equipment
with
the
HRSG/
duct
burner
unit
and
because
the
flue
gas
temperature
is
lower
than
required
by
the
control
technologies.
Also,
the
HRSG/
duct
burner
is
already
equipped
with
LNBs
and
natural
gas
and
distillate
oil
are
the
fuels
used
in
the
unit.
Although
the
duct
burner
is
equipped
with
LNBs,
it
is
still
unable
to
meet
the
presumptive
NO
x
RACT
limit
in
the
FAF
mode.
Therefore,
Schering
proposes
the
current
configuration
to
be
RACT
and
the
alternative
emission
limit
for
the
HRSG/
duct
burner
operating
in
the
FAF
mode
is
the
same
as
the
existing
permitted
limits
of
0.17
lbs/
MMBtu
while
firing
natural
gas
and
0.18
lbs/
MMBtu
while
firing
distillate
oil,
with
the
potential
for
a
lower
emission
limit
when
firing
natural
gas
after
performing
stack
tests.

NJDEP
will
require
Schering
to
maintain
the
LNBs
installed
on
the
unit,
to
annually
adjust
the
combustion
process
and
to
conduct
stack
tests
following
the
approval
of
the
alternative
emission
limit
application,
which
may
establish
a
lower
alternative
emission
limit
when
firing
natural
gas.
More
specifically,
the
alternative
emission
limit
for
the
HRSG/
duct
burner
when
operating
in
the
FAF
mode
and
when
firing
natural
gas
will
be
the
lower
of
0.17
lbs/
MMBtu,
or
115%
of
the
average
of
three
one­
hour
stack
tests,
each
performed
over
a
consecutive
60­
minute
period.

Alternative
means
of
compliance
such
as
emissions
averaging,
fuel
switching
and
repowering
were
also
evaluated.
The
HRSG/
duct
burner
already
burns
natural
gas
and
distillate
oil,
therefore
fuel
switching
cannot
be
applied.
The
remaining
useful
life
of
the
unit
is
approximately
25
years,
therefore
repowering
is
not
an
option.
Compliance
through
an
emission
averaging
plan
would
be
impossible
since
the
HRSG/
duct
burner
in
the
FAF
mode
and
the
combustion
turbine
do
not
operate
simultaneously
to
allow
averaging
of
the
emissions
to
meet
the
daily
compliance.

On
March
9,
2005
NJDEP
approved
a
Conditions
of
Approval
document
for
the
maximum
alternative
emission
limit
for
the
HRSG/
duct
burner
during
FAF
mode.
The
following
are
the
specific
emission
limitations
contained
in
the
Conditions
of
Approval
document:


the
alternative
emission
limit
for
the
HRSG/
duct
burner
when
operating
in
the
FAF
mode
and
when
firing
natural
gas
will
be
the
lower
of
0.17
lbs/
MMBtu,
or
115%
of
the
average
of
three
one­
hour
stack
tests,
each
performed
over
a
consecutive
60­
minute
period.


the
alternative
emission
limit
for
the
HRSG/
duct
burner
when
operating
in
the
FAF
mode
9
and
when
firing
distillate
oil
will
be
0.18
lbs/
MMBtu.


the
HRSG/
duct
burner
shall
not
operate
in
FAF
mode
for
more
than
600
hours
per
year.


maximum
annual
emissions
from
the
HRSG/
duct
burner
when
operating
in
FAF
mode
shall
not
exceed
4.0
TPY.


Schering
shall
annually
adjust
the
HRSG/
duct
burner
in
accordance
with
the
procedures
in
the
Conditions
of
Approval
document
and
Subchapter
16.


Schering
shall
demonstrate
compliance
by
conducting
stack
tests
by
May
15,
2005.

B.
EPA's
Evaluation
of
NJDEP's
SIP
Revision
EPA
has
reviewed
Schering's
application
and
NJDEP's
source­
specific
SIP
revision
for
completeness
and
approvability.
EPA
agrees
with
the
technical
feasibility
demonstration
and
the
alternative
NO
x
emission
limits
for
the
HRSG/
duct
burner
when
operating
in
FAF
mode.
EPA
has
reviewed
Schering's
RACT
evaluation
and
concurs
with
its
conclusion
that
the
existing
installation
of
LNBs
represents
RACT
for
the
HRSG/
duct
burner.
While
the
Agency's
Alternative
Control
Techniques
(
ACT)
Document
­­
NO
x
Emissions
from
Stationary
Gas
Turbines,
January
1993,
(
EPA­
453/
R­
93­
007),
page
5­
80
discusses
the
use
of
duct
burners
to
increase
the
capacity
of
the
HRSG
at
a
cogeneration
application,
the
ACT
does
not
suggest
any
control
technologies
which
may
be
available
specifically
for
the
duct
burner.
The
ACT
does
state
that
in
all
cases,
a
duct
burner
will
produce
a
relatively
small
level
of
NO
x
emissions
during
operation
(
0.1
lb/
MMBtu,
gas)
but
the
net
impact
on
total
exhaust
emissions
(
the
gas
turbine
and
the
duct
burner)
varies
with
operating
conditions.
In
Schering's
situation,
the
duct
burner
is
used
when
the
turbine
is
not
operating.

The
FAF
mode
of
the
duct
burner
was
designed
basically
as
an
emergency
mode
of
operation.
If
the
turbine
should
work
improperly
for
some
reason,
the
duct
burner
would
switch
to
FAF
mode
and
continue
to
supply
steam
for
plant
operations.
Schering
accepted
limits
on
the
operation
in
FAF
mode
to
no
more
than
600
hours
per
year
and
no
more
than
4
tons
per
year
of
NO
x
emissions.
Therefore,
if
the
use
of
SCR
or
SNCR
were
determined
to
be
technically
feasible,
it
is
likely
that
they
would
be
determined
not
to
be
economically
feasible
based
on
the
expected
hours
of
operation
of
the
equipment
and
the
diminimus
amount
of
emissions.

Since
the
existing
control
technologies
are
determined
to
be
RACT,
there
is
no
emission
reduction
associated
with
this
NO
x
RACT
determination.
The
annual
combustion
process
adjustment
of
the
unit
may
result
in
some
NO
x
emission
reduction,
although
it
is
difficult
to
quantify
at
this
point
in
time.
10
EPA
reviewed
a
draft
copy
of
NJDEP's
proposal
to
establish
an
alternative
emission
limit
for
Schering's
HRSG/
duct
burner
just
prior
to
the
October
23,
2004
public
notice.
On
October
14,
2004,
EPA
provided
comments
to
NJDEP
regarding
the
Schering
proposal.
In
the
March
31,
2005
SIP
submittal,
NJDEP
provided
responses
to
EPA's
comments.
NJDEP's
response
to
comments,
in
coordination
with
the
approved
Conditions
of
Approval
document
are
acceptable
to
EPA.

Finally,
Schering's
alternative
NO
x
emission
limit
is
comparable
with
other
alternative
emission
limits
seen
by
the
Region
for
similar
facilities
in
New
Jersey.
This
includes
EPA's
approval
of
another
NO
x
RACT
source­
specific
SIP
revision
for
the
Schering
Union
facility
on
October
20,
1998
(
63
FR
55949).
EPA's
approval
was
for
Schering's
U­
7
cogeneration
facility
and
the
operation
of
a
HRSG/
duct
burner
under
FAF
mode.
EPA's
approval
was
based
on
(
1)
annual
combustion
process
adjustments,
(
2)
continued
use
of
the
LNB
and
(
3)
an
alternative
NOx
emission
limit
of
0.183
lbs/
MMBtu
during
natural
gas
combustion,
with
the
potential
to
establish
a
lower
NOx
emission
limit
after
the
review
of
stack
test
results.

EPA
agrees
with
NJDEP's
determination
that
Schering's
alternate
emission
limit
can
be
considered
to
also
be
the
NO
x
RACT
limit
for
the
HRSG/
duct
burner.
With
respect
to
the
results
of
the
stack
tests
conducted
pursuant
to
NJDEP's
Conditions
of
Approval
which
may
result
in
a
lower
alternative
emission
limit,
as
a
policy,
EPA
agrees
that
the
15%
margin
of
safety
applied
to
the
stack
test
results
to
establish
the
new
lower
limit
is
appropriate
in
this
circumstance
since
there
is
no
environmental
degradation
due
to
the
diminimus
level
of
NO
x
emissions
resulting
from
the
SIP
revision.
In
similar
situations
for
other
RACT
plans,
EPA
could
accept
a
margin
of
safety
below,
but
not
greater
than,
15%.

The
RACT
analysis
and
Conditions
of
Approval
are
consistent
with
Subchapter
19
and
the
NJDEP
has
the
legal
authority
to
establish
this
alternative
emission
limit
and
are
fully
enforceable
by
the
State.
The
Conditions
of
Approval
issued
on
March
9,
2005
specify
the
alternative
NO
x
emission
limit,
the
stack
emission
testing,
the
annual
combustion
process
adjustment,
and
the
monitoring,
reporting
and
recordkeeping
requirements.
Compliance
shall
be
determined
based
on
stack
emission
tests.

C.
Conclusion
EPA
proposes
to
approve
NJDEP's
source­
specific
SIP
revision
for
Schering's
NOx
RACT
plan.

APPROVABILITY
RECOMMENDATION:
Full
Approval.
